BETWEEN THE LINES LIMITED (the “Employer”)

EQUAL OPPORTUNITIES POLICY

Introduction

We are an equal opportunities employer. A commitment to equal opportunities in the workplace is not only good management practice, it also makes sound business sense. We wish to encourage a working environment which is free of discrimination, harassment and victimisation. We aim to ensure that our staff achieve their full potential and that all employment decisions are taken without reference to irrelevant or discriminatory criteria. We have adopted this Equal Opportunities policy as a means of helping to achieve these aims.

Every member of staff should have a copy of this policy. Further copies may be obtained from the Employer who is responsible for the implementation of this policy.

It may be necessary for the Employer to amend this policy from time to time to take account of developments in legislation but any changes will be notified to you in writing.

If there are any parts of this policy you do not understand or if there are any incidents or practices occurring in the workplace which you feel breach this policy, you should bring this to our attention as soon as possible.

If you are a manager and you require clarification and further information about any of the issues raised in this policy, then you should contact Florian or Lindsey Kleinlercher.

For avoidance of doubt, any examples which are detailed in this policy are for illustrative purposes only and the list of examples is non-exhaustive.

Policy Statement

We are committed to ensuring within the framework of the law that our workplaces are free from unlawful discrimination on the grounds of colour, race, nationality, ethnic or national origin, sex, gender (including gender reassignment), religion, religious belief or philosophical belief, sexual orientation, marital status, disability or age.

WHAT IS DISCRIMINATION?

Discrimination law defines different types of discrimination:

· Direct discrimination

· Indirect discrimination

· Harassment

· Victimisation

In addition, the law on disability discrimination differs slightly because there is no indirect discrimination, but there is a rule requiring reasonable adjustments to be made.

TYPES OF DISCRIMINATION

Direct discrimination occurs where someone is put at a disadvantage on discriminatory grounds in relation to his or her employment. Direct discrimination may occur even when unintentional and no act of direct discrimination can be justified, regardless of whether it was intentional.

When can direct discrimination arise?

· A woman with young children fails to obtain a job because it is feared that she might be an unreliable member of staff.

· A Sikh applicant for a senior post is not appointed because he might not “fit in” with the existing (all white) team.

· A person is subjected to sexual innuendo or other offensive conduct because he or she is homosexual or bisexual.

Indirect discrimination occurs where the individual’s employment is subject to an unjustified condition which a particular group finds more difficult to meet although on the face of it the condition or requirement is “neutral”. A particular group could be those of a particular colour, race, nationality, ethnic or national origin, sex, gender (including gender reassignment), marital status, religion, religious belief or philosophical belief, sexual orientation, disability or age. Indirect discrimination can be justified, but only where the employer can demonstrate objective grounds for its actions or requirements.

Examples of when can indirect discrimination can arise?

· A requirement for GCSE English as a selection criterion. This would have a disproportionately adverse impact on people educated overseas and may not be justified if all that is needed is to demonstrate a reasonable level of literacy.

· A requirement for employees to undertake full-time work – this would have a disproportionately adverse impact on more women with small children as they are generally accepted as taking the primary childcare role. It may not be justified if our business needs can still be met by more flexible working arrangements.

· A rule that male employees must be clean shaven. This would have an adverse impact on some religious groups where men are required to have a beard. It may not be justified if there is no legitimate health and safety reason for the rule.

Harassment is unwanted conduct (whether intentional or otherwise) on the grounds of a discriminatory reason such as the individual’s race, gender, religion, sexual orientation or age which has the purpose or effect of violating that individual’s dignity, or of creating an intimidating, hostile, degrading, humiliating or offensive environment.

Victimisation occurs where an individual is treated less favourably than colleagues because he or she has taken action to assert their rights under discrimination law or under this policy, or because he or she has assisted a colleague with information in that regard.

Disability discrimination occurs where an individual is unjustifiably disadvantaged in employment or recruitment for a reason connected with his or her disability unless the discrimination cannot be avoided by making reasonable adjustments.

When can disability discrimination arise?

· A requirement for staff to hold a valid driving licence for a job which involves little travelling.

· Failure to recruit a wheelchair user without first considering whether the working arrangements or premises can reasonably be adapted to his or her needs.

We are committed to ensuring that all our staff and applicants for employment are protected from unlawful discrimination in employment. This commitment also applies to access to promotion and training opportunities.

We are also committed to non-discrimination in providing employment references.

IMPLEMENTING EQUALITY OF OPPORTUNITY

· All staff have a right to equality of opportunity and a duty to implement this policy.

· All staff are entitled to a working environment which promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated.

· Recruitment and employment decisions will be made on the basis of fair and objective criteria. Our selection procedures are reviewed from time to time to ensure that they are appropriate for achieving our objectives and for avoiding unlawful discrimination.

· All employees, whether part-time, full-time or temporary will be treated fairly and equally unless the difference in treatment is objectively justified.

· We will not base our recruitment and employment decisions on generalised assumptions, stereotypes or prejudices.

· The requirements of job applicants and existing members of staff who have or have had a disability will be reviewed to ensure that whatever possible reasonable adjustments are made to enable them to enter into or remain in employment with us. Promotion opportunities, benefits and facilities of employment will not be unreasonably limited and every reasonable effort will be made to ensure that disabled staff participate fully in the workplace.

· Person and job specifications will be limited to those requirements which are necessary for the effective performance of the job. Interviews will be conducted on an objective basis and personal or home commitments will not form the basis of employment decisions except where necessary.

· Any adjustments/requests will be taken into account with careful consideration of your colleagues and the needs of the business.

· No references shall be given on behalf of the Employer without the authority of Florian or Lindsay Kleinlercher. Any references given will be fair, factual, not misleading and non-discriminatory.

· Breach of this equal opportunities policy is potentially a serious disciplinary matter and could lead to dismissal.

· Anyone who believes that he or she may have been disadvantaged on discriminatory grounds or who feels that this policy has been breached is entitled to raise the matter through the grievance procedure. Matters will be dealt with sensitively and confidentially.

· Training will be offered to the relevant staff and managers where deemed appropriate by the organisation.

June 2009 © Between The Lines Limited