Equality, Diversity & Inclusion Policy

Version 1.6 – June 2025

DEFINITIONS

This policy outlines the organisation’s approach to equality and diversity at work. It is important to understand the difference between the concepts of equality and diversity.

Equality (or equal opportunities) is about protecting certain groups of staff and learners against unfair treatment based on a particular personal characteristic. We are committed to preventing unfair treatment on any grounds.

Diversity is about recognising, valuing and using the differences which people have.

PURPOSE

The purpose of this policy is to encourage an atmosphere in which all staff and learners embrace the benefits of working in a diverse environment and to promote fair and equal treatment for all employees, learners, job applicants, customers, suppliers and visitors, irrespective of their individual differences or any personal characteristics.

SCOPE

This policy applies to all employees, workers, contractors, volunteers, job applicants and learners, wherever the work is carried out (including online and off-site events).

The principles apply equally to all dealings with customers, learners, suppliers and visitors.

STATEMENT OF POLICY

The company is committed to the principles of valuing diversity. We recognise the benefits that can be secured through employing a diverse workforce and harnessing the individual talents of staff from different backgrounds and with different skills. These include:

  • Tangible business benefits such as improved staff morale, reduced absence levels, customer satisfaction and profits.
  • An improved company image leads to a wider customer base and a wider pool of people to recruit from.
  • The avoidance of costly legal proceedings caused by breaches of equality legislation.

We are committed to providing fair and equal treatment for all staff, customers, suppliers and visitors and all staff are expected to treat everyone with whom they come into contact with dignity and respect. Staff should be aware of the importance the company attaches to this policy and that breaches will be classed as disciplinary offences and dealt with accordingly.

LEGAL OBLIGATIONS

The Equality Act 2010 protects individuals against direct discrimination, indirect discrimination, harassment (including bullying) and victimisation because of their sex, race, gender reassignment, marital status, civil partnership, disability, sexual orientation, religion or belief, or age. We will not tolerate any form of prejudice, discrimination, victimisation or harassment against any employee or service user/customer. In pursuing this policy we believe that the principles which underpin the above legislation should be extended to all staff regardless of any personal characteristic.

Worker Protection (Amendment of Equality Act 2010) Act 2024 – From 26 October 2024 every employer has a proactive duty to take reasonable steps to prevent sexual harassment of workers. Tribunals may uplift compensation by up to 25 % where this duty is breached.

Equality Act 2010 (Amendment) Regulations 2023 – In force 1 January 2024. These regulations preserve key EU-derived case law, including protection where a claimant does not share the protected characteristic in an indirect-discrimination claim.

Supreme Court judgment (Apr 2025) – Confirmed that the term “sex” in the Act refers to biological sex; a Gender Recognition Certificate does not alter this definition. The Equality & Human Rights Commission (EHRC) issued interim guidance in May 2025.

Authoritative guidance is available from ACAS and the EHRC; managers must consult these sources when handling equality matters.

RESPONSIBILITIES

All staff are expected to have read and understood this policy, and ensure they behave in accordance with its principles, encourage the same level of behaviour in colleagues and immediately report any breaches witnessed.

All Leads are responsible for ensuring this policy is understood and complied with by staff and learners in their area, dealing with breaches and complaints (whether reported or not) seriously, speedily, sensitively and confidentially and contributing ideas for the advancement of diversity principles within the organisation.

The Human Resource Officer is responsible for implementing, reviewing, monitoring the effectiveness of and providing advice on this policy, encouraging the adoption of its principles throughout the organisation and ensuring complaints are adequately investigated.

The Chief Executive Officer has overall responsibility for this policy.

Board of Directors – overall accountability for EDI compliance.

All managers – embed EDI in day-to-day decisions and complete annual refresher training.

All staff, learners & contractors – uphold this policy and speak up about breaches.

Breaches of this policy may be treated as a disciplinary issue. Additionally, if legal requirements are contravened, both the company and the employee concerned may be liable to legal proceedings and risk having unlimited damages awarded against them.

Alternatively, some form of training or education may be more appropriate where minor breaches have occurred due to a lack of understanding of equality and diversity principles.

PREVENTING DISCRIMINATION & HARASSMENT

We will:

  1. Provide mandatory induction plus annual refresher training on equality, diversity, inclusion and safeguarding.
  2. Carry out equal-pay reviews every two years and publish actions.
  3. Take reasonable steps to prevent sexual harassment, including (a) risk-assessing customer-facing roles, (b) ensuring a visible reporting route, and (c) monitoring incidents so that lessons are learned.
  4. Investigate complaints from staff and learners promptly, fairly and confidentially in line with our Grievance Procedure (staff) or Learner Complaints appeals Procedure (learners).

COMMUNICATING THIS POLICY

To ensure the principles of this policy are embedded in everything we do:

  1. All existing staff will receive a copy of this policy and training on its practical application.
  2. This policy will be covered in all future staff and learner inductions.
  3. Contractors, sub-contractors, learners and visitors will comply with this policy and customers/service users will be made aware of it. Available on the website.

Reporting discrimination – learners

Learners who experience or witness discrimination, harassment or victimisation can use any of the routes below:

Tell your tutor or assessor – they will log the concern immediately with the HR and the Safeguarding Lead.

E-mail: info@fittraining.co.uk (monitored weekdays 08:00–18:00). All messages generate a confidential case file.

Concerns will be acknowledged within two working days and handled under the Learner Complaints Procedure, with an investigation outcome normally issued within 15 working days.

Learners will not suffer any detriment for raising issues in good faith. If you are dissatisfied with the outcome, you may escalate to the awarding organisation.

PROTECTED CHARACTERISTICS

  • Age – A particular age (e.g. 32-year-olds) or a range of ages (e.g. 18–30-year-olds).
  • Disability – A physical or mental impairment which has a substantial and long-term adverse effect on normal day-to-day activities.
  • Sex (male/female) – Biological sex as designated at birth.
  • Gender reassignment – The process of transitioning from one sex to another; the law protects individuals whether or not they are under medical supervision.
  • Marriage and civil partnership – Marriage is a legal union; civil partners must be treated the same as married couples on a wide range of legal matters.
  • Pregnancy and maternity – Pregnancy is the condition of being pregnant or expecting a baby. Maternity refers to the period after birth and is linked to maternity leave in the employment context. Explicit protection extends to breastfeeding mothers for 26 weeks after giving birth.
  • Race – A group of people defined by race, colour, nationality (including citizenship) and ethnic or national origins.
  • Religion or belief – Religious and philosophical beliefs, including lack of belief (e.g. atheism), that significantly influence life choices.
  • Sexual orientation – A person’s attraction towards their own sex, the opposite sex or both.

TYPES OF DISCRIMINATION

The different types of discrimination recognised by law include (but are not limited to):

  • Associative discrimination
  • Disability discrimination (including discrimination arising from disability)
  • Direct discrimination
  • Harassment
  • Indirect discrimination
  • Institutional discrimination
  • Perceptive discrimination
  • Victimisation

The 2023 Amendment Regulations clarify that indirect discrimination applies even where the claimant does not share the protected characteristic.

RECRUITMENT, TRAINING & PROMOTION

Our recruitment and selection processes shall:

  • Produce carefully worded and objective job descriptions/person specifications for all vacancies.
  • Circulate job advertisements widely to encourage applications from all sections of the community and avoid age limits.
  • Apply the ‘Confident About Disability’ standard for applicants with a disability.
  • Base short-listing and selection solely on merit against objective criteria; reasons for all decisions will be recorded.
  • We also follow the CIMSPA / Aspire EmployAbility Leisure – Guide C checklist and the Government’s Disability Confident framework to attract, recruit and retain more disabled people.

All employees will be encouraged to achieve their full potential through:

  • Mandatory equality and diversity training for all staff.
  • Additional CPD for those with EDI responsibilities.
  • Objective, timely appraisals and transparent promotion criteria.
  • Positive-action initiatives, where lawful, to address under-representation.

MEETING INDIVIDUAL NEEDS

Wherever possible, the company will accommodate individual needs in areas such as caring responsibilities, flexible working patterns, disability adjustments and religious practices.

All programmes are reviewed against CIMSPA / Aspire EmployAbility Leisure – Guide B to make sure course materials, venues and assessments are fully accessible for disabled learners.

COMPLAINTS PROCEDURE

Staff who believe this policy has been breached should raise the matter with their leader in the first instance. Formal complaints may be made via the Grievance Procedure. Advice and support are available from Heads of Area or the HR Officer.

POSITIVE ACTION INITIATIVES

We may undertake positive-action initiatives for certain groups of staff to enable them to compete more equally. Positive discrimination (i.e. preferential treatment) remains illegal.

MONITORING, REVIEW & CONSULTATION

We will monitor equality data across the employee and learner lifecycle (recruitment, induction, training, promotion, discipline, grievance, dismissal and exit). Statistics will be broken down by sex, race, disability and any other relevant factors and circulated.

We will also track and publish each year the percentage of disabled staff and learners, using this KPI to help close disability employment and participation gaps.

This policy will be reviewed annually (next review: May 2026). Staff and their representatives will be consulted during each review cycle.

We also commit to revisiting the policy once the Government proposals on pay band transparency and enhanced equal-pay fines are finalised.

RELATED DOCUMENTS

  • Bullying & Harassment Policy/Procedure
  • Grievance Procedure
  • Staff Handbook
  • Recruitment & Selection Policy/Procedure
  • Complaints procedure

© Fit Training International – All rights reserved.

Approved by Board of Directors 15th June 2025 signed:

Next review May 2026