Equal Opportunities Policy

1. Introduction

1.1. SA Safety Ltd is committed to encouraging and achieving a working environment
which is underpinned by fairness to all individuals, where equality and diversity is
recognised, encouraged and valued, and the concept of individual
responsibility is accepted by all.

1.2. SA Safety Ltd expects all its employees to recognise their obligations to Equal
Opportunities at all times and in accordance with SA Safety Ltd’s ethos.

2. Purpose

2.1. This policy commits SA Safety Ltd to being an equal opportunity employer and
aims to set out the framework for a clear and consistent application of the equal
opportunities legislation across SA Safety Ltd.

3. Scope

3.1. This policy applies to all employees directly employed by SA Safety Ltd.

3.2. This policy also applies to workers and volunteers, i.e. agency workers, casual
workers, consultants, contractors and also to job applicants.

4. Responsibilities

4.1. The role of the Board of Directors is to ensure that agreed staffing policies and
systems of infrastructure are in place and operating effectively to ensure that the
legal requirements of the Company are met.

5. Policy overview

5.1. This policy should be read in conjunction with SA Safety Limited’s policy on
harassment and bullying, and grievance policy.

5.2. This policy covers all aspects of how you are treated by the company and
everybody who works for us. It also sets out the standards of conduct we need
from you. It covers but isn’t limited to:
● Recruitment
● pay and conditions of employment.
● training and continuing professional development.
● promotion
● appraisals
● grievances and disciplinary matters
● ending employment
● giving references
● how visitors are treated
● how clients and suppliers are treated
● how any other business contacts and associates are treated.

6. Our Equal Opportunities Commitment and Aims

6.1. We will not tolerate discrimination or harassment and are committed to
promoting equal opportunities in employment. Those staff who work for us, and
anyone applying for a job with us will receive fair and equal treatment.

6.2. We ensure, where possible, full access for everyone applying for a vacancy.
Decisions about transfers and internal promotions are made, so far as possible,
using only objective criteria.

6.3. We will never victimise anyone who makes a legitimate complaint to us about
harassment and or discrimination, or who supports a colleague’s complaint.

6.4. This policy is underpinned by the following further commitments and aims:

● a working environment free from all forms of unlawful discrimination, including
victimisation and harassment.
● a workforce capable of allowing everyone to achieve their greatest potential,
and where individuals are willing to give their best.
● a Company-wide understanding of the message promoted by this policy.
● a commitment to ensuring all staff understand their rights and responsibilities
under this policy — if you are not sure what we consider acceptable and
unacceptable, you should check with your manager.
● a policy of ensuring employment opportunities are open to all qualified
candidates so that we recruit from the largest possible pool of available talent
and recruit the best-qualified staff.
● a commitment to recruiting based on ability to do the job.
● a commitment to regularly review this policy and our workplace practices to
identify issues and eliminate any unlawful discrimination or other unacceptable
behaviour we may find.
● a commitment to protecting staff from being victimised or treated less fairly if
they make or support a complaint in good faith under this policy.

7. What is Equality and Diversity?

7.1. ‘Equality’ requires us, and you, to treat everyone equally and fairly, with equal
opportunities and rights.

7.2. ‘Diversity’ recognises that this world is full of differences, and that we value and positively embrace these differences. It is important for differences to be
recognised. It is important that, whilst recognising them, we all do so positively,
with equality at the forefront of their minds.

8. How do we Define Discrimination?

8.1. The following list gives you a general description of the types of acts that may
both breach this policy and be unlawful. Sometimes actions can be intentional,
and sometimes unintentional and we include examples of both types in this list:
● when somebody is treated less favourably because of a protected
characteristic than somebody else has been — or would have been — in
identical circumstances, then this is direct discrimination. Rejecting a job
applicant because of their beliefs would, for example, amount to direct
discrimination.
● when a group of people with one of the protected characteristics (subject to a
couple of exceptions) is put at a disadvantage by a provision, practice or
criteria applied to all staff unless the treatment is justified for a good business
reason, this is indirect discrimination. For example, refusing a request to work
part time without good business reason (which indirectly discriminates against
women, who are more likely to have childcare responsibilities).
● directly discriminating against someone because they associate with another
person who possesses a protected characteristic is known as associative
discrimination. For example, an employee may be overlooked for job
promotion if the employer believes that they will not be able to dedicate time
to their job if they are caring for a disabled dependant. This would amount to
discrimination because of the employee’s association with a disabled person.
● when somebody is treated less favourably because of the personal
characteristics of somebody else, this is known as associative discrimination. For
example, treating an employee less favourably because their parents are
Jehovah’s witnesses.
● where someone is treated less favourably because someone wrongly believes
they have a particular protected characteristic, this is known as perceived
discrimination. For example, treating an employee less favourably because
someone thinks he is gay, when in fact he isn’t gay.
● when a hostile, humiliating, degrading or similarly offensive environment is
created in relation to a protected characteristic, this is harassment. We also consider it harassment for a worker to be subjected to uninvited conduct
related to a protected characteristic that — as an intended or unintended
consequence — violates their dignity. Name calling, lewd comments, excluding
colleagues, making insensitive jokes, and displaying pornographic material are
all examples of harassment. We deal in detail with this under our separate
policy on harassment and bullying.
● when a worker has complained about harassment or discrimination, or
supported a colleague in their complaint, it is victimisation if they are then
treated less favourably. For example, an employee who is sent ‘sent to
Coventry’ because they spoke up on behalf of one of their colleagues in a
harassment investigation, or an employee who is dismissed under a pretext
because they have complained about discrimination.

8.2. Although it is important to create a workplace which promotes fairness for all, the
law focuses its protection on nine characteristics. These ‘protected
characteristics’ are:
● age
● disability
● gender reassignment
● marriage and civil partnership.
● pregnancy and maternity
● race (which includes colour and ethnic origin, national origin and nationality)
● religion or belief
● sex
● sexual orientation

8.3. There are other actions which can be unlawful under the equal opportunity’s
legislation, and these are collectively labelled other acts. Examples include:
● Failure to make reasonable adjustments to minimise certain disadvantages
suffered by a disabled employee (or job applicant).
● instructing another person — or applying pressure on them — to discriminate.
● knowingly assisting somebody else when they carry out a discriminatory act.
● discriminating against somebody believed to have a protected characteristic,
whether or not they actually do, or because they associate with a third party
who does.

8.4. There are practices which, although they appear to breach the aims of this
policy, are in fact justifiable on objective and operational grounds. These are
called lawful practices. If you are not sure whether some aspect of workplace behaviour you have experienced or witnessed is discriminatory or a lawful
practice, please ask your manager for clarification.

9. How will we carry out our responsibilities and duties?

9.1. Management and the wider workforce are essential to ensuring the success of
this policy. We all have a legal responsibility to comply with it, and any of us —
however senior or junior we are — may be personally liable for unlawful
discrimination if we breach its terms.

9.2. Overall responsibility for the effective implementation and operation of the policy
lies with management, specifically with the Board of Directors. Everyone working
at managerial level is expected to act in full accordance with this policy, lead by
example, and attain and maintain appropriate standards of behaviour within the
teams they manage.

9.3. The ethos and standard covered by this policy can only be achieved and
maintained if everyone in our workforce cooperates fully. It is important to
understand that you have a legal responsibility to comply. If you breach this
policy, you may also make SA Safety Ltd liable for your actions and we may both
have to pay compensation to anyone who claims against us. We expect you to
take personal responsibility for adhering to the policy’s aims and commitments
and for drawing any actual or potential breaches to our attention.

9.4. We also encourage everyone who works for us to help promote equal
opportunities across SA Safety Ltd. Please contact your manager if you have any
ideas about how we could do this better.

10. How will we recruit, promote, and make other selections?

10.1. We carry out all recruitment, promotion and other types of selection procedures
— such as redundancy selection processes — on the basis of merit using nondiscriminatory
and as far as possible, objective criteria.

10.2. Advertisements for vacancies must not include wording that may discourage
some groups of people from applying, or stereotype in any way, and they must
be placed where they can reach as wide and diverse a pool of potential
candidates as possible.

10.3. Nobody applying for a job with SA Safety Ltd, may be asked about their health or
whether they have a disability before a job offer is made, except in very limited
situations. It may, for example, be justifiable to ask whether the applicant needs
any disability-related measures put in place for the interview, or to check that
they are capable of carrying out a key part of the job. It is acceptable to make
some job offers dependent on a medical examination.

10.4. It is unlawful to ask job applicants anything that might suggest an intention to
discriminate on the grounds of a protected characteristic. Asking an applicant
about their religion when they are applying for a job that involves weekend
working would not, for example, be allowed. Nor would asking an applicant
whether they have childcare responsibilities be allowed, as that suggests you
might be intending to indirectly discriminate on the grounds of sex or marital
status.

10.5. It is fine to include certain health or disability questions in equal opportunities
monitoring exercises, but the data gathered must not be used for selecting or in
making other employment-related decisions.

11. How will we enforce this Policy and handle breaches?

11.1. We will investigate any complaint or allegation you raise regarding a potential
breach of this policy. If you believe you have been harassed or discriminated
against you should contact your manager as soon as possible. If you want to take
formal action, you will need to follow our grievance procedure (see our
Grievance Policy) and read our policy on harassment and bullying.

11.2. You will face disciplinary action if we find you have harassed or discriminated
against anyone else in breach of this policy. Sometimes this type of behaviour
may amount to gross misconduct, in which case you may be dismissed without
notice.

11.3. Most concerns are raised in good faith, but occasionally someone makes a false
allegation out of malice or because they believe they have something to gain.
This is classed as a vexatious claim. Anyone found doing this will face action
under our Disciplinary Policy and may be dismissed for misconduct, or even gross
misconduct.

12. How will we monitor whether this Policy is working?

12.1. We may record and analyse information about equal opportunities within the
workplace.

12.2. All personal data obtained to monitor our commitment to equal opportunities will
be handled with the utmost integrity and confidentiality in line with our data
protection policy. Employees may be reminded of the types of data the
Company holds, and our practices in relation to that data by reviewing the
Company’s data protection policy and employee privacy notice, which is
available on our HR Portal.

12.3. We use the information to make sure this policy is operating properly and refine it,
to review the composition of the workforce, and to promote workplace equality.

13. Review

13.1. This policy does not form part of an employee’s contract of employment and the
Company may amend it at any time.

13.2. This policy reflects current statutory legislation at the time of writing. Any changes
to statutory legislation will take precedence in the event of a dispute.

13.3. Should you have any feedback on this policy, please contact Andy Appleton,
Commercial Director.

13.4. History of Policy Changes

Apr 2024  Version 2.0 New Policy – Replaces Existing Equality and Diversity Policy
22.05.2024 Version 2.0  Document reviewed and formatted Exco