Equal Opportunities Policy

Equal opportunities statement

1.1 REO is committed to promoting equal opportunities in employment. You and any job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics).

About this policy

1.2 This policy sets out our approach to equal opportunities and the avoidance of discrimination at work. It applies to all aspects of employment with us, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.

1.3 This policy covers all employees, officers, consultants, contractors, casual workers and agency workers.


1.4 You must not unlawfully discriminate against or harass other people including current and former employees, job applicants, clients, suppliers and visitors. This applies in the workplace, outside the workplace (when dealing with clients, suppliers or other work-related contacts or when wearing a work uniform), and on work-related trips or events including social events.
1.5 The following forms of discrimination are prohibited under this policy and are unlawful:

“Harassment” is where there is unwanted conduct, related to one of the protected characteristics that has the purpose or effect of violating a person’s dignity; or creating an intimidating, hostile, degrading, humiliating or offensive environment. It does not matter whether or not this effect was intended by the person responsible for the conduct. This can include:

  • Bullying – encompasses unnecessarily disciplining or “dressing down” a subordinate in front of colleagues or your/his/her subordinates, pointing out a subordinate’s or colleague’s mistakes or shortcomings in a berating or abrasive or sarcastic manner, either in private or in public.
  • Disability – commenting unkindly or thoughtlessly (even unintentionally) on a disability – whether the person possesses this protected characteristic or not.
  • Sexual Discrimination – displaying printed or electronic material of a sexual nature. Displaying posters, nudity, pornographic photographs or drawings, cartoons etc., either in hard copy or computerised form of either sex. Physical, verbal or non-verbal sexual attention, including subtle or overt pressure for sexual favours, advances, propositions etc. Leering, touching, pinching, assault or coerced sexual acts. Sexual/sexist jokes. Comments or discussions on a person’s sexual orientation or appearance.
  • Racial Discrimination – commenting on race or ethnic custom or lifestyle in a derogatory way. Racist jokes.
  • On-going “banter” focused on gender, race, age or disability that the recipient deems to be offensive. This includes invasion of privacy, offensive language or obscene gestures.

This type of behaviour is unacceptable at the office and in all work related settings outside the workplace (e.g. social events, business travel or with customers). Where proven, it may constitute gross misconduct for which an employee may be summarily dismissed without notice.

“Discrimination” may arise in any of the following forms:

Direct discrimination is where a person is treated less favourably than another because of a protected characteristic. An example of direct discrimination would be refusing to employ a woman because she is pregnant.

Indirect discrimination is where a provision, criterion or practice is applied that is discriminatory in relation to individuals who have a relevant protected characteristic such that it would be to the detriment of people who share that protected characteristic compared with people who do not, and it cannot be shown to be a proportionate means of achieving a legitimate aim.

Victimisation occurs where an employee is subjected to a detriment, such as being denied a training opportunity or a promotion because he/she made or supported a complaint or raised a grievance under the Equality Act 2010, or because he/she is suspected of doing so. However, an employee is not protected from victimisation if he/she acted maliciously or made or supported an untrue complaint.

Associative discrimination is where an individual is directly discriminated against or harassed for association with another individual who has a protected characteristic.

Perceptive discrimination is where an individual is directly discriminated against or harassed based on a perception that he/she has a particular protected characteristic when he/she does not, in fact, have that protected characteristic e.g. treating someone less favourably because it is perceived they are have a particular religion.

Failure to make reasonable adjustments is where a physical feature or a provision, criterion or practice puts a disabled person at a substantial disadvantage compared with someone who does not have that protected characteristic and the employer has failed to make reasonable adjustments to enable the disabled person to overcome the disadvantage.

Recruitment and selection

1.6 Recruitment, promotion, and other selection exercises such as redundancy selection will be conducted on the basis of merit, against objective criteria that avoid discrimination. Shortlisting will normally be done by more than one person and with the involvement of HR, where possible. Our recruitment procedures should be reviewed regularly to ensure that individuals are treated on the basis of their relevant merits and abilities.

1.7 Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying. Job applicants should not be asked questions which might suggest an intention to discriminate on grounds of a Protected Characteristic. For example, applicants should not be asked whether they are pregnant or planning to have children.

1.8 Job applicants should not be asked about health or disability before a job offer is made. There are limited exceptions which should only be used with the approval of HR. For example:

  • Questions necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments).
  • Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at interview or assessment.
  • Positive action to recruit disabled persons.
  • Equal opportunities monitoring (which will not form part of the selection or decision-making process).

Where necessary, job offers can be made conditional on a satisfactory medical check.

1.9 We are required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made based on appearance or apparent nationality. All prospective employees, regardless of nationality, must be able to produce original documents (such as a passport) before employment starts, to satisfy current immigration legislation. The list of acceptable documents is available from HR or UK Visas and Immigration.

1.10 To ensure that this policy is operating effectively, and to identify groups that may be underrepresented or disadvantaged in our organisation, we monitor applicants’ ethnic group, gender, disability, sexual orientation, religion and age as part of the recruitment procedure. Provision of this information is voluntary and it will not adversely affect an individual’s chances of recruitment or any other decision related to their employment. The information is removed from applications before shortlisting, and kept in an anonymised format solely for the purposes stated in this policy. Analysing this data helps us take appropriate steps to avoid discrimination and improve equality and diversity.

Management responsibilities

1.11 All managers have a direct responsibility towards all of their staff to uphold our policy and maintain the required standard of professional conduct between colleagues working in their area. Managers are responsible for ensuring that their employees are aware of REO’s policy.

1.12 Complaints to a manager will be dealt with quickly and sensitively and it is the Manager’s responsibility to ensure that as far as reasonably practicable, employees are protected against victimisation for making or being involved in a complaint.

Employees’ responsibilities

1.13 Every employee in REO is responsible for his/her own behaviour and is expected and required to behave in an acceptable manner and in accordance with this policy.

1.14 Every employee is required to assist REO to meet its commitment to provide equal opportunities in employment and avoid unlawful discrimination.

1.15 Employees who believe that they are subject to unacceptable treatment must make it plain at an early stage that the behaviour is unacceptable to them and that if it is not stopped, they will invoke the complaint procedure. In the event that an employee believes him or herself to be subjected to continued unacceptable treatment, it is their personal responsibility to utilise the complaints procedure at the time the problem occurs. Without this, REO cannot take the specific steps necessary to redress the particular problem.

1.16 Employees can be held personally liable as well as, or instead of, REO for any act of unlawful discrimination. It should be noted that employees who commit serious acts of unacceptable treatment may be found guilty of a criminal offence.

1.17 Acts of discrimination, harassment, bullying or victimisation against employees or customers are disciplinary offences and will be dealt with under our disciplinary procedure. Discrimination, harassment, bullying or victimisation may constitute gross misconduct and could lead to dismissal without notice.
Customers, suppliers and other people not employed by REO

1.18 REO will not discriminate unlawfully against customers using or seeking to use goods, facilities or services provided by REO.

1.19 Employees should report any bullying or harassment by customers, suppliers, visitors or others to their manager who will take appropriate action.

Complaints procedure

1.20 Wherever possible, an employee who is a recipient of unacceptable treatment is encouraged to seek to resolve the problem informally, by communicating clearly to the person engaging in the unacceptable treatment that the behaviour in question is not welcome. The individual may wish to ask a colleague or manager or HR to act as a representative in making this request.

1.21 In the event that an employee feels that he/she has suffered unacceptable treatment in any way, and where he/she regards attempts at informal resolution as inappropriate, or where informal attempts at resolution have been refused, or where the outcome has been unsatisfactory, REO’s formal grievance procedure should be used.

1.22 If appropriate, the complaint should be made to the employee’s own immediate or another manager, notifying HR. If this is not appropriate, the complaint should be made directly to HR or a more senior manager.

1.23 To make a complaint of unacceptable treatment, it will be necessary, as far as possible, for the complainant (the person making the complaint and alleging unacceptable treatment) to provide the following:

  • the name of the person alleged to be responsible for the unacceptable treatment;
  • details of the circumstances of the alleged incidents or series of incidents, including times, dates and locations;
  • any witnesses or names of those who may be able to assist with gathering information;
  • details of any previous complaints made by the complainant against the particular individual for alleged unacceptable treatment; and
  • a preference for the solution to the issues raised.

1.24 Information is revealed strictly on a need to know basis. Information contained in a formal complaint is kept confidential. However, the identity of a complainant and witnesses may need to be revealed to the individual alleged to be subjecting the complainant to unacceptable treatment to progress the complaints procedure. It should also be noted that although requests for details to be redacted may be made (e.g. a person’s name) and enacted by REO, this does not always guarantee anonymity.

1.25 As far as possible, employees will be protected from victimisation for being involved in or making a complaint of discrimination or harassment and any individual accused of victimising another will be subject to our disciplinary policy.

1.26 We are committed to carrying out an objective investigation of alleged unacceptable treatment as soon as possible in accordance with our Grievance procedure.

1.27 An employee who has found to have violated our Equal Opportunities policy will normally be given a disciplinary warning under REO’s disciplinary procedure. In serious cases of the offending employee may be dismissed without notice or pay in lieu of notice on the grounds of gross misconduct.

1.28 We recognise that complaints of unacceptable treatment also have a serious effect on the alleged perpetrator and malicious or vexatious allegations of unacceptable treatment against any employee may lead to disciplinary action against the complainant by REO. Notes of records of a complaint will be kept in employee files.

1.29 Where an investigation results in an outcome that is unsatisfactory to the complainant, the affected individual may request REO hear their grounds for appeal under our Grievance Procedure.

Training and promotion and conditions of service

1.30 Training needs will be identified through regular appraisals. You will be given appropriate access to training to enable you to progress within REO.

1.31 Workforce composition and promotions may be monitored to ensure equality of opportunity at all levels of REO. Where appropriate, steps will be taken to identify and remove unjustified barriers and to meet the special needs of disadvantaged or underrepresented groups.

1.32 Our conditions of service, benefits and facilities are reviewed regularly to ensure that they are available to all of you who should have access to them and that there are no unlawful obstacles to accessing them.

Termination of employment

1.33 We will ensure that redundancy criteria and procedures are fair and objective and are not directly or indirectly discriminatory.

1.34 We will also ensure that disciplinary procedures and penalties are applied without discrimination, whether they result in disciplinary warnings, dismissal or other disciplinary action.


1.35 If you are disabled or become disabled, we encourage you to tell us about your condition so that we can support you as appropriate.

1.36 If you experience difficulties at work because of your disability, you may wish to contact a member of HR to discuss any reasonable adjustments that would help overcome or minimise the difficulty. A member of HR may wish to consult with you and your medical adviser about possible adjustments. We will consider the matter carefully and try to accommodate your needs within reason. If we consider a particular adjustment would not be reasonable we will explain our reasons and try to find an alternative solution where possible.

1.37 We will monitor the physical features of our premises to consider whether they might place anyone with a disability at a substantial disadvantage. Where necessary, we will take reasonable steps to improve access.

Part-time and fixed-term work

1.38 Part-time and fixed-term employees should be treated the same as comparable full-time or permanent employees and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified.

Breaches of this policy

1.39 We take a strict approach to breaches of this policy, which will be dealt with in accordance with our Disciplinary Procedure. Serious cases of deliberate discrimination may amount to gross misconduct resulting in dismissal.

1.40 If you believe that you have suffered discrimination you can raise the matter through our Grievance Procedure. Complaints will be treated in confidence and investigated as appropriate.

1.41 There must be no victimisation or retaliation against employees who complain about discrimination. However, making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under our Disciplinary Procedure.

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