Equality and Diversity Policy

1. Purpose

Coaley Peak Limited is committed to promoting equality, valuing diversity, and creating an inclusive environment in which everyone is treated with dignity and respect. This policy sets out our approach to equality and diversity and explains the standards of behaviour we expect from all those who work for us or on our behalf.

This policy applies to all employees, directors, contractors, consultants, temporary workers, volunteers, and anyone else acting in the name of Coaley Peak Limited, regardless of the nature or duration of their engagement. It also reflects the standards we uphold in the delivery of our services to clients and the public.

2. Scope

This policy covers all aspects of our business, including:

• Recruitment, selection, and onboarding
• Terms and conditions of employment
• Pay, benefits, and reward
• Performance management, promotion, and career development
• Training and learning opportunities
• Disciplinary and grievance procedures
• Termination of employment or engagement
• Service delivery to clients and end users
• Relationships with suppliers and business partners

3. Legal Framework

Coaley Peak Limited complies fully with the Equality Act 2010 and all other applicable equality legislation in the United Kingdom. The Equality Act 2010 makes it unlawful to discriminate against a person because of a protected characteristic.

The nine protected characteristics under the Equality Act 2010 are:

• Age — This includes people of all ages. It is unlawful to treat someone less favourably because of how old they are.
• Disability — A person has a disability if they have a physical or mental impairment that has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities.
• Gender reassignment — This covers people who are proposing to undergo, are undergoing, or have undergone a process of reassigning their sex.
• Marriage and civil partnership — Employees are protected from discrimination because they are married or in a civil partnership.
• Pregnancy and maternity — This covers unfavourable treatment connected with pregnancy, maternity leave, or breastfeeding.
• Race — This includes colour, nationality, and ethnic or national origins.
• Religion or belief — This includes any religion, religious or philosophical belief, or lack of religion or belief.
• Sex — This covers direct and indirect discrimination against men or women.
• Sexual orientation — This covers heterosexual, homosexual, and bisexual people, as well as those who are asexual.

4. Types of Unlawful Discrimination

The Equality Act 2010 identifies several forms of unlawful conduct. All of the following are prohibited at Coaley Peak Limited:

• Direct discrimination — Treating a person less favourably than another person because of a protected characteristic. For example, refusing to consider a candidate for a role because of their age or ethnicity.
• Indirect discrimination — Applying a provision, criterion, or practice that applies equally to everyone but puts people who share a protected characteristic at a particular disadvantage, and which cannot be objectively justified. For example, requiring all employees to work on a particular day that disproportionately disadvantages those with certain religious observances.
• Harassment — Unwanted conduct related to a protected characteristic that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment. This includes conduct by colleagues, managers, clients, and third parties.
• Victimisation — Treating a person less favourably because they have made, supported, or are believed to have made or supported a complaint or grievance under equality legislation, or because they have given evidence in connection with such a complaint.

Discrimination by association (treating someone less favourably because of another person’s protected characteristic) and discrimination by perception (treating someone less favourably because you mistakenly believe they have a protected characteristic) are also unlawful and equally prohibited.

5. Our Commitments

5.1 Recruitment and Selection

We are committed to fair, objective, and consistent recruitment and selection processes. All vacancies are advertised in a manner that does not unlawfully restrict the pool of applicants. Selection criteria are based solely on the requirements of the role. Interview panels are trained to avoid bias, and decisions are documented and capable of objective justification. We welcome applications from all sections of the community.

5.2 Pay and Benefits

Coaley Peak Limited is committed to equal pay for equal work. Pay and benefit structures are designed to ensure that no individual receives less favourable treatment on the grounds of a protected characteristic. We review our pay practices periodically to identify and address any disparities that cannot be objectively justified.

5.3 Promotion and Career Development

Decisions relating to promotion, progression, and career development are based on merit, demonstrated capability, and the requirements of the role. We actively seek to remove barriers that may prevent individuals with protected characteristics from advancing and to ensure that all employees have equal access to career opportunities.

5.4 Training and Learning

Access to training, development opportunities, and professional qualifications is open to all employees on an equal basis. We will make reasonable adjustments to training delivery where necessary to ensure that employees with disabilities or other protected characteristics are not disadvantaged.

5.5 Service Delivery

We are committed to delivering our services in a manner that is free from unlawful discrimination. We take reasonable steps to ensure that our services are accessible to all and that clients, users, and members of the public are treated with equal respect and dignity regardless of any protected characteristic.

6. Reasonable Adjustments

We recognise our duty under the Equality Act 2010 to make reasonable adjustments for disabled employees, job applicants, and, where applicable, the users of our services. A reasonable adjustment is a step taken to remove or reduce a disadvantage caused by a disability.

Examples of reasonable adjustments may include, but are not limited to:

• Modifying working hours or patterns
• Providing specialist equipment or assistive technology
• Adjusting the physical working environment
• Reallocating certain duties
• Providing additional support or mentoring
• Allowing additional breaks or rest periods
• Modifying assessment or selection processes

Employees or applicants who consider that an adjustment may be appropriate should raise this with their line manager or with the HR function at the earliest opportunity. All requests will be considered promptly and in good faith. Where an adjustment is not considered reasonable, the reasons will be explained clearly. The fact that an adjustment has been made will be treated as confidential information.

7. Responsibilities

7.1 All Staff and Contractors

Every person working for or on behalf of Coaley Peak Limited has a personal responsibility to:

• Treat colleagues, clients, and all other people with dignity and respect
• Comply with this policy and any associated procedures
• Avoid behaviour that constitutes unlawful discrimination, harassment, or victimisation
• Report promptly any behaviour they witness or experience that may amount to a breach of this policy
• Co-operate with any investigation into an alleged breach

7.2 Managers and Supervisors

In addition to the responsibilities above, managers and supervisors are expected to:

• Model inclusive behaviour and set a positive example
• Ensure that decisions relating to their team are made on objective grounds and documented appropriately
• Address concerns, complaints, and informal disclosures promptly and sensitively
• Facilitate reasonable adjustments discussions in a timely and constructive manner
• Ensure team members are aware of this policy and understand their obligations under it
• Participate in equality and diversity training as required

7.3 Leadership and Senior Management

The leadership team is responsible for setting the tone and culture of the organisation. Senior management will:

• Champion equality and diversity at every level of the business
• Ensure that sufficient resource is allocated to equality and diversity initiatives
• Review this policy at least annually and update it to reflect changes in law or best practice
• Ensure that equality considerations are embedded in business strategy, procurement decisions, and client relationships
• Take appropriate action where patterns of concern are identified through monitoring data or grievance reporting

8. Public Sector Equality Duty

Coaley Peak Limited provides services to, and works in partnership with, public bodies subject to the Public Sector Equality Duty (PSED) under section 149 of the Equality Act 2010. As a supplier to such bodies, we recognise our role in supporting their compliance with the PSED, which requires public authorities to have due regard to the need to:

• Eliminate unlawful discrimination, harassment, and victimisation
• Advance equality of opportunity between people who share a protected characteristic and those who do not
• Foster good relations between people who share a protected characteristic and those who do not

We will co-operate with client organisations in meeting their equality obligations and, where contractually required, provide relevant data, undertake equality impact assessments, and implement any additional measures agreed with the commissioning body.

9. Complaints and Reporting

Coaley Peak Limited takes all complaints relating to equality and diversity seriously. Any person who believes they have been subjected to discrimination, harassment, or victimisation — or who has witnessed such conduct — is encouraged to report it promptly.

Complaints may be raised through the following routes:

• Informal resolution — Where appropriate, concerns may be resolved informally through discussion with the relevant individual or their line manager. This is not always suitable and there is no obligation to attempt informal resolution before making a formal complaint.
• Formal grievance — A formal written complaint may be submitted in accordance with our grievance procedure. All formal complaints will be investigated promptly, impartially, and confidentially.
• Confidential reporting — Concerns may be raised confidentially by contacting compliance@coaleypeak.co.uk.

Victimisation of any person who raises a concern in good faith is a serious disciplinary matter and will not be tolerated. Where a complaint is upheld, appropriate remedial and disciplinary action will be taken. Where a complaint is not upheld, no adverse consequences will follow for the complainant provided the complaint was made in good faith.

Where an individual remains dissatisfied after the conclusion of our internal process, they may have the right to refer their complaint to the Equality and Human Rights Commission (EHRC) or to bring a claim before an employment tribunal or civil court, subject to applicable time limits.

10. Monitoring and Review

Coaley Peak Limited monitors the effectiveness of this policy through a combination of quantitative data and qualitative feedback. Monitoring activity may include analysis of recruitment and selection outcomes, pay data, promotion rates, training participation, grievance and disciplinary records, and staff survey results, where data can be collected and analysed lawfully and without compromising individual privacy.

Monitoring data is reviewed by senior management at least annually. Where the data reveals disparities or areas for improvement, an action plan will be developed and implemented. The outcomes of monitoring will be used to inform updates to this policy and associated procedures.

This policy is reviewed at least annually and whenever there is a material change in applicable legislation or guidance. The most recent version of this policy supersedes all previous versions.

For questions about this policy, please contact compliance@coaleypeak.co.uk.