Equality & Diversity Policy
1. Purpose
1.1 Nowhere Group Limited ('nowhere' / 'the Company' / 'we') is an equal opportunity business taking into account the diversity within our workforce, customers and learners.
1.2 We believe that everyone should be treated equally, regardless of their religion, beliefs, age, gender, race, disability or sexual orientation.
1.3 The purpose of this policy is to ensure that we have a workplace where all employees ('Staff') feel valued, respected and included.
2. Scope
2.1 This policy applies to all Staff and requires a commitment from everyone within nowhere.
3. General Principles
3.1 No applicant, Staff or customer will receive less favourable treatment or be subjected to any form of discrimination on the grounds of their religion, beliefs, neurodiversity, age, gender, gender identity, race, disability or sexual orientation.
3.2 All Staff and customers will be given the help they need to attain their full potential wherever that is possible.
3.3 We secure the best Staff for our needs by accessing all sections of the community.
3.4 We achieve an ability-based workforce that is in line with the working population mix.
4. nowhere Responsibilities
4.1 Upon commencement of their employment, Staff will be informed of the existence of this Policy and the Company's expectations of them under its terms.
4.2 nowhere will not tolerate harassment, exclusion and bullying on any level and will not engage any form of modern slavery.
4.3 We will ensure that fair standards of employment practice and proper records of employment decisions are maintained.
4.4 We will deliver training on new and revised legislation to all our Staff.
4.5 We will treat all our business partners, customers and learners with respect, courtesy and consideration at all times.
4.6 We provide reasonable adjustments for disabled Staff in line with the Equality Act 2010, ensuring individuals are not disadvantaged and can carry out their roles effectively. Adjustments may include changes to working arrangements, duties or location.
5. Staff Responsibilities
5.1 All Staff must adhere to and comply with this Policy and the spirit in which it is written.
5.2 Staff must treat all colleagues and customers with courtesy, respect and consideration at all times.
5.3 If Staff believe that any form of discrimination is taking place within the workplace, we expect them to report this to their Line Manager immediately. It may be helpful to review the Grievance Policy for a procedural follow-through.
6. Recruitment
6.1 Wherever possible all vacancy advertisements will include an appropriate short statement on equal opportunity and diversity, and steps will be taken to ensure that knowledge of vacancies reaches all areas of the community.
6.2 We will also endeavour to ensure that all vacancies are advertised both internally and externally simultaneously.
6.3. Sexual Harassment and the Preventative Duty
6.3.1 In line with the Worker Protection (Amendment of Equality Act 2010) Act 2023, in force from 26 October 2024, nowhere is committed to taking reasonable steps to prevent sexual harassment of Staff in the course of their employment. This duty applies to harassment by other members of Staff and to harassment by third parties (such as clients, customers, suppliers, learners and visitors).
6.3.2 Sexual harassment means unwanted conduct of a sexual nature which has the purpose or effect of violating an individual's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.
6.3.3 Reasonable steps taken by nowhere include: (a) maintaining and communicating this policy and the Code of Conduct; (b) providing all Staff with anti-harassment training on induction and at least every 24 months thereafter; (c) carrying out a periodic risk assessment of sexual harassment risk (in conjunction with the Health and Safety Policy) covering work activities, working environments, third-party interactions, and work-related events; (d) making clear and accessible reporting routes available to Staff (set out below); and (e) ensuring that any report of sexual harassment is investigated promptly under the Disciplinary Policy and that Staff who report harassment in good faith are protected from victimisation under this policy and the Whistleblowing Policy.
6.3.4 Reporting routes: any Staff member who experiences or witnesses sexual harassment may raise the matter with their Line Manager, with any member of the HR Management Team, through the Grievance Policy, or, where appropriate, under the Whistleblowing Policy. Staff will not be penalised for raising a concern in good faith.
6.3.5 Third-party harassment: where a Staff member experiences harassment from a client, customer, supplier, learner or other third party, the matter should be reported as set out above. The Company will take appropriate action, which may include speaking with the third party, ending the working relationship, refusing to allow further interaction with the affected Staff member, or making other reasonable adjustments to the working arrangement.
7. Personnel Responsible for this Policy
7.1 The HR Management Team has overall responsibility for the effective operation of this policy and shall be responsible for reviewing this policy to ensure that it meets legal requirements and reflects best practice.
8. Breaches of Policy
8.1 nowhere will take appropriate measures to remedy any breach of the policy and its associated procedures and guidelines. In the case of Staff then the matter may be dealt with under the disciplinary procedures.