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Equality & Diversity Policy

1. What is our Policy?

We are totally committed to the principle of equal opportunities and to creating a working environment in which you are treated with dignity and respect that is free from unlawful discrimination, victimisation or harassment as per the Equality Act 2010 on the grounds of:

  • colour, race, nationality or ethnic origin;

  • sex, marital status/civil partnership or gender reassignment;

  • disability of any kind;

  • religion or belief;

  • sexual orientation;

  • pregnancy & maternity

  • age; and

  • Trade Union or Staff Consultative Committee membership.


Our commitment applies to all aspects of employment including:

  • grievance and disciplinary procedures; recruitment

  • employment terms and conditions

  • pay and benefits

  • training

  • promotion and transfer opportunities

  • redundancy

  • dismissal


SUMO Services currently employ no non English speaking staff, however it recognises the need to ensure that those who do not have a good understanding of English are not discriminated against, it should be noted that this policy dose not only apply to foreign nationals, as British nationals may also experience difficulties with literacy and their communication skills may also be poor.

Information will be provided by the company to take account of any language difficulties, either spoken or written English.  This will be provided in whatever form is most suitable to the circumstances to ensure that it is understood by everyone. SUMO Services has access to a translation/printing service for this end.

SUMO Services is committed to continued training of staff and to this end would consider communication course(s) through one of the following advisors/training organisations:


SUMO Services would also, through its training partner “PETA”  put key supervisory/managerial staff through either communications training or a “Working with Different Nationalities” course.

We take this policy very seriously. A breach of this policy is considered to be gross misconduct and disciplinary action, including dismissal for serious offences, will be taken against people who do not comply with it.

What is Discrimination?

Broadly, a person has been discriminated against if:

they have been treated less favourably than another person on any of the grounds set out above; or

a procedure or practice places a group of employees at a disadvantage on any of the above grounds; or

they have a disability or religious belief and reasonable steps have not been taken to meet their needs.


What is Harassment?

Harassment is unwanted conduct which violates a person's dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment for that person.

Harassment is unlawful where it is motivated by one of the grounds set out above but we include more general harassment within our definition. Although not exhaustive, the following are examples of types of behaviour that may amount to harassment:

  • physical assault;

  • physical or verbal abuse;

  • threats;

  • suggestive comments or gestures;

  • offensive gestures, language, gossip or jokes;

  • insulting or abusive behaviour or comments;

  • isolation or exclusion;

  • bullying;

  • unreasonable persistent criticism or humiliation;

  • unfair allocation of work or responsibilities.


What is Sexual Harassment?

Sexual harassment is one form of harassment. Generally it involves behaviour towards another, where the perpetrator knows or should know that the behaviour is unwelcome because it is offensive and is perceived to be of a sexual nature.


Although not exhaustive, the following are examples of types of behaviour that may amount to sexual harassment:

  • Physical conduct of a sexual nature - unwanted physical conduct, including unnecessary touching, brushing against another employee's body.

  • Verbal conduct of a sexual nature - unwelcome sexual advances, continued suggestions of social activity outside work after it has been made clear that this is unwelcome.

  • Non-verbal conduct of a sexual nature - the display of sexually suggestive or pornographic pictures or the sending of sexually harassing messages or images through electronic mail.

  • Sex-biased conduct - Conduct that denigrates, ridicules, is intimidating or physically abusive towards an employee because of their sex, marital status or sexual orientation.


Sexual harassment by someone of the same sex as the victim also amounts to harassment. 


What is Victimisation?

Someone is victimised where they suffer unfavourable treatment because they have, in good faith, made a complaint under this policy, acted as a witness or accompanied a complainant to a hearing.

2. Responsibilities

What are my responsibilities as an employee?

It is your obligation to be sensitive about the impact that you have on others and behave in a way that supports our policy when dealing with everyone that you come into contact with as part of your employment with the Company. Our policy is not designed to discourage normal social relations among colleagues or with the public but aims to prevent discrimination, harassment and victimisation.

Our policy applies not only at the Company premises but anywhere you are working as part of your employment with the Company. This includes any social occasions organised by the Company.


You must not instruct or aid someone to carry out an act of discrimination, harassment or victimisation or condone discrimination, harassment or victimisation by others. You must report any incidents to your Line Manager.


What is my Responsibility as a Line Manager

In addition to the general responsibilities above, it is also your responsibility to make sure that your team are aware of and are complying with this policy.

3. The Complaints Procedure

We aim to resolve any complaints as quickly as possible. All complaints will be treated seriously and confidentially. Only complaints that relate to a breach of this policy should be made using this procedure. Complaints about other matters should be made using our grievance procedures.


What do I do if I am experiencing discrimination, harassment or victimisation?

You should consider whether it is appropriate to raise the matter directly with the person concerned in order to resolve the problem. If it is not, you should speak to your Manager. If you feel unable to discuss the matter with your Manager then you should discuss it with the General Manager.

For further information:

Following your discussion, you will be asked to choose one of the following options:

  •  agree that no further action is necessary;

  • agree to discuss the complaint with the individual who is alleged to have caused offence;

  • ask your line manager and/or your Departmental Manager to help to resolve the matter through informal and/or discreet approaches; or

  • make a formal written complaint to your line manager or your Departmental Manager.


If you are not satisfied with an informal approach, a formal complaint can be made at any stage.


How do I make a formal complaint?


You should make your complaint in writing and sign and date your letter. You should write a new letter to trigger each stage of the process.

  •  Stage 1 - will be heard by your Line Manager or Head of Department. You will find out the result of your complaint within 15 working days of the receipt of your letter. If you do not feel that it is appropriate for your complaint to be heard within your division, or you feel that your complaint has not been appropriately dealt with you may go to stage 2 of the process.

  • Stage 2 - will be heard by the General Manager. You will find out the result of your complaint within 15 working days of the receipt of your letter. If you do not feel that your complaint has been appropriately dealt with you may go to stage 3 of the process.

  • Stage 3 - will be heard by the Managing Director. You will find out the result of your complaint within 20 working days of the receipt of your letter. This decision will be final.


You may ask that someone of the same sex hears your complaint. If your request is reasonable in your particular circumstances then a different person may need to be selected to hear your complaint. For stages 1 to 3 this will be Senior Staff Members or an External Consultant if appropriate.

If you are interviewed as part of your complaint you will have the same right to be accompanied as in our grievance procedure.

If the complaint, at any stage of the process, has resulted in a disciplinary investigation against another person, the case will not normally be reopened if you escalate the complaint to the next stage. 

What will happen after I have made my Complaint?

Where a formal complaint is made, a full investigation will be conducted.

The first step is to investigate the allegations carefully and as discreetly as possible. This will involve hearing detailed accounts from all parties. Other members of staff may also be asked to provide information. Documents, e-mail, text messages and other evidence may be considered. A full record of the progress and outcome of the investigation and any steps taken will be reported to the complainant. Those conducting the investigation will not be parties directly involved in the allegation.

What will happen if a formal complaint about a person is upheld?

Where a formal investigation has been conducted and where it has been reasonably concluded that some form of discrimination, harassment or victimisation may have taken place, those responsible will be subject to our normal disciplinary procedures. Action will not normally be initiated without the agreement of the complainant but there are some circumstances where the Company may need to pursue the matter formally. For example, if other people could be at risk if no action is taken.


The outcome of the disciplinary procedures will depend upon the circumstances. Serious acts of discrimination, harassment or victimisation will be regarded as gross misconduct and may lead to instant dismissal. Consideration may be given to redeploying either the discriminator/harasser or the complainant. If redeployment is considered, the wishes of the complainant will normally come first and the complainant will not usually be redeployed if they do not want to be.


Am I protected if I make a complaint, act as a witness or accompany a complainant to a hearing?


Yes. Any acts of retaliation or intimidation against an employee will be treated as a disciplinary offence. Having said this, an employee who maliciously makes an unfounded complaint will be subject to disciplinary action.


What if the complaint is about someone who is not employed by the Company?


Appropriate action to deal with the problem will be discussed with you.


4. Special Requirement


What is meant by special requirements?


We understand that people's needs at work are different and that some employees may have special requirements. For example, employees of a particular religion may need somewhere quiet to pray during their lunch break, need to take holiday on a particular day for a religious event, or need to have somewhere to store specially prepared foods. Alternatively you may have a disability and may feel that you need to have changes made to your workplace to help you do your job.


We will accommodate your requirements where it is possible and practical for us to do so but we cannot do so unless you let us know. Where you need particular time off, or are requesting a temporary change to your working hours, your line manager is more likely to be able accommodate this if you let them know well in advance.


What should I do if I have any special requirements?


You should discuss your requirements with your line manager. They will seek advice, if they need it, from their Manager or the General Manager. If you feel unable to discuss your request with your line manager, you can raise it directly with the General Manager or Managing Director.


5. Legislation


A number of Acts and Regulations contain various prohibitions on discrimination on the grounds of race, sex, disability, age etc, and as such SUMO complies with all relevant legislation including the following:

Equality Act 2006
Gender Recognition Act 2004
Race Relations (Amendment) Act 2000
Disability Discrimination Act 1995
Sex Discrimination Act 1975 & 1986
The Employment Equality (Age) Regulations 2006
The Employment Equality (Religion or Belief) Regulations 2003
The Employment Equality (Sexual Orientation) Regulations 2003

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