Purpose

FKM GROUP LTD is committed to promoting equality of opportunity for all current and potential employees, and to creating a workplace where diversity is valued and respected. We aim to ensure that no one is treated less favourably or subjected to unlawful discrimination on the grounds of:

  • Age
  • Disability
  • Gender reassignment
  • Marriage and civil partnership
  • Pregnancy and maternity
  • Race (including colour, nationality, and ethnic or national origin)
  • Religion or belief
  • Sex
  • Sexual orientation

This policy applies to all aspects of employment, including recruitment, training, promotion, pay, working conditions, and termination. It aligns with the requirements of the Equality Act 2010, and supports the guidance outlined in the ACAS Code of Practice.

We do not tolerate any form of discrimination, harassment, or victimisation.

Our Commitment

At FKM GROUP LTD, we value the unique contribution each employee brings and support an inclusive culture that promotes equality and diversity. We believe that a diverse workforce fosters innovation, creativity, and a broader range of perspectives, which strengthens our organisation and improves the services we deliver.

We are committed to maintaining an environment where all employees can thrive and develop their careers based on merit and ability.

Responsibilities

Managers’ Responsibilities

All managers are responsible for implementing and upholding this policy, ensuring that their teams are treated fairly and in line with our diversity objectives. Any questions regarding the application of this policy should be directed to the HR Department.

Employees’ Responsibilities

Employees are expected to support the principles of equality and diversity and behave in ways that uphold the dignity and respect of others. Any discriminatory or harassing behaviour will be treated as a disciplinary matter and may lead to dismissal.

Employees may be held personally liable for acts of unlawful discrimination.

Working Environment

We promote a positive, inclusive working environment in which all employees are empowered to reach their full potential. Employment-related decisions such as recruitment, training, pay, and promotion are based solely on objective, job-related criteria.

Recruitment and Promotion

We operate a fair and transparent recruitment process, ensuring that all job applicants are assessed solely on their skills, qualifications, and potential. We also encourage internal progression by giving current employees the opportunity to apply for vacancies.

Reasonable adjustments will be provided for applicants with disabilities.

Training and Development

All employees are required to complete our Induction Programme. Opportunities for further training are offered on an equal basis and aligned to individual and business needs.

Our performance management system is designed to identify development opportunities, address skills gaps, and support career progression. All appraisals are conducted fairly, with training provided to managers to ensure objective assessment.

Disciplinary and Grievance Procedures

We adopt a fair and consistent approach to handling disciplinary and grievance matters, in line with current legislation and the ACAS Code of Practice.

Employees who believe they have experienced discrimination, harassment or victimisation may raise a complaint under the Company’s grievance procedure. Complaints will be taken seriously and handled with appropriate confidentiality. Employees will not be penalised for raising legitimate concerns.

Disability and Reasonable Adjustments

We are committed to supporting employees with disabilities, including those who become disabled during employment. Under the Equality Act 2010, we will make reasonable adjustments to support disabled employees to perform their roles and remain in employment.

Harassment and Bullying

Harassment and bullying of any kind are strictly prohibited. All staff have the right to work in an environment free from intimidation and hostility. Harassment based on any protected characteristic is unlawful.

Examples of Harassment (not exhaustive)

  • Sexual Harassment: Unwanted touching, inappropriate comments, displaying offensive material, or making sexual advances.
  • Racial Harassment: Racist jokes, exclusion, abusive language, or offensive images.
  • Bullying: Intimidation, constant criticism, or misuse of power to undermine an individual.

Acts of harassment or bullying may be treated as gFKM Group misconduct and result in summary dismissal.

Employees experiencing harassment may report incidents to HR in confidence. We recognise the sensitive nature of such complaints and provide gender-appropriate points of contact where needed.

Religion or Belief

We respect the religious and philosophical beliefs of all employees. Where reasonably possible, we will accommodate religious practices, such as prayer time or leave for religious holidays, in line with operational needs.

Flexible Working

In accordance with the Flexible Working Regulations 2014 (as amended 2024), all employees have the right to request flexible working from day one of employment. FKM GROUP LTD supports flexible arrangements that help employees balance work and personal commitments, where compatible with business needs.

Monitoring and Data Protection

We monitor the diversity of our workforce to assess the effectiveness of our policy. Data collected is processed in line with the Data Protection Act 2018 and the UK GDPR. Personal data will be used for monitoring purposes only and held securely and confidentially.

Types of Discrimination (as defined by law)

  • Direct Discrimination: Treating someone less favourably because of a protected characteristic.
  • Indirect Discrimination: Applying a policy or rule that disadvantages people with a protected characteristic.
  • Harassment: Unwanted conduct that violates someone’s dignity or creates an offensive environment.
  • Victimisation: Treating someone unfairly because they made or supported a complaint under this policy.
  • Failure to Make Reasonable Adjustments: Disadvantaging a disabled person by not adjusting working practices or conditions.

Policy Implementation

This policy is implemented under the authority of senior management and is monitored by HR. Managers and employees are expected to familiarise themselves with and uphold its provisions.

Manager's Responsibility

Every executive manager is responsible for the implementation and continuous delivery of our Equal Opportunities and Diversity Policy, procedures and management practices. Any instance of doubt about the purpose, application of the policy, or other questions, should and will be addressed to the HR Manager, as should any requests for special coaching or training relating to the deliverance of these practices.

Employee's Responsibility

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

Employees can be held personally liable as well as, or instead of, the Company for any act of unlawful discrimination. Employees who commit serious acts of harassment may be guilty of a criminal offence. Acts of discrimination, harassment, bullying or victimisation against employees or clients are disciplinary offences and will be dealt with under the Company’s disciplinary procedure. Discrimination, harassment, bullying or victimisation may constitute as gFKM Group misconduct and could lead to dismissal without notice.

Working Environment

FKM GROUP LTD encourages a working environment where you are encouraged to achieve your potential. We understand and respond to the full range of diversity and quality issues. All employment related decisions in terms of recruitment advertising, selection, training, and conditions of work, pay, and career development and selection for redundancy to every other aspect of employment are based on objective, non discriminatory job related criteria and are consistently applied. We also apply our policies to the treatment of our clients.

We continuously monitor and regularly review our resourcing, training development and people relations practices to ensure equality is a key factor and to ensure the diversity of our workforce. We feel that diversity is important in enacting our social responsibility as a company. By participating in external initiatives in local areas such as recruitment and training programmes we can provide a service to the local community by improving skill gaps and unemployment statistics.

Recruitment and Promotional Practices

Effective recruitment and selection of capable employees are fundamental to the success of the organization. The Company is committed to a policy of long-term employment. Before recruiting additional employees, every effort will be made to ensure that existing employees will have the opportunity to apply for these positions.

Recruitment procedures are in place to ensure that selection is based on the applicant’s skills, experience, and aptitude for the vacancy, irrespective of their sex, religion or belief, marital status, age, race, ethnic origin, color, disability, or sexual orientation.

The selection process is of crucial importance and will be carried out according to objective job-related criteria. This will apply to the job descriptions, person specifications, advertising, recruitment sources, and interview techniques. Ability assessments are used during the interview process to assess basic written, reading, spelling, punctuation, and numeracy skills. All tests are nondiscriminatory and reasonable adjustments will be made to individuals with learning disabilities such as dyslexia.

Training and Development Practices

All new employees will be expected to undergo the Company Induction Programme as part of the selection criteria. Selection for enhanced training opportunities will be based on job-related criteria. All training courses are certificated, all classroom activities, assessment, and examination processes are based on non-discriminatory criteria, and reasonable adjustments will be made for individuals with learning disabilities.

The Company Performance Management System will determine an individual’s developmental needs. The performance management system is designed to encourage a high-performance culture. Through the performance management system, the Company will be able to identify individual achievements whilst identifying any skills shortages that require further development. The system is fair and transparent and nondiscriminatory. All appraisers are fully trained in conducting objective performance appraisals.

Training and Development Practices

All new employees will be expected to undergo the Company Induction Programme as part of the selection criteria. Selection for enhanced training opportunities will be based on job-related criteria. All training courses are certificated, all classroom activities, assessment, and examination processes are based on nondiscriminatory criteria, and reasonable adjustments will be made for individuals with learning disabilities.

The Company Performance Management System will determine an individual’s developmental needs. The performance management system is designed to encourage a high-performance culture. Through the performance management system, the Company will be able to identify individual achievements whilst identifying any skills shortages that require further development. The system is fair and transparent and nondiscriminatory. All appraisers are fully trained in conducting objective performance appraisals.

Disciplinary and Grievance Handling

The Company ensures a fair, systematic and non-discriminatory approach to the enforcement of standards of conduct affecting all members of staff employed by the company. All disciplinary and grievance matters will be handled in a professional and non-bias manner, and all information obtained will be treated in the strictest of confidence and handled in accordance with the legislatives requirements and ACAS Codes of Practice.

If you consider that you have been unlawfully discriminated against, you may use the Company’s grievance procedure to make a complaint. The Company will take any complaint seriously and will seek to resolve any grievance which it upholds. You will not be penalised for raising a grievance, even if your grievance is not upheld, unless your complaint is both untrue and made in bad faith.

Disabled Workers

Any worker that is disabled or becomes disabled, either physically or mentally during their employment with FKM GROUP LTD will not be treated less favorably than a non-disabled employee. Under the Disability Discrimination Act 1995, FKM GROUP LTD will take reasonable steps to accommodate the disability. Wherever possible, the Company will make adjustments to their existing employment or offer redeployment opportunities. Appropriate training will also be available to enable them to remain in employment with the Company

Harassment and Bullying

The Company deplores all forms of harassment whether is it non verbal, verbal or physical and seeks to ensure that the working environment is sympathetic to all its employees. Sexual and racial harassment at work is unlawful, and both the Company and the harasser may be held liable for such unlawful actions. Harassment creates a threatening environment, and will be dealt accordingly. All staff has the right to work in an atmosphere free from sexual or racial harassment. Bullying is not dissimilar to harassment. However, it usually involves the misuse of power or intimidation, leaving the individual feeling hurt, vulnerable, threatened, disengaged, angry or helpless. All forms of bullying will be treated seriously and dealt with in accordance with Company procedures.

1. Examples of Sexual Harassment include:

a. Insensitive jokes and pranks
b. Lewd comments about appearance
c. Unnecessary body contact
d. Displays or sexually offensive material, e.g , pin-ups
e. Requests for sexual favours
f) Speculation about a person’s private life and sexual activities
g. Threatened or actual sexual violence
h. Threat of dismissal, loss of promotion, etc for refusal of sexual favours.

2. Examples of Racial Harassment include:

a. Insensitive jokes related to race
b. Pranks
c. Deliberate, exclusion from conversations
d. Abusive, threatening or insulting words and behaviour
e. Displaying abusive writing and pictures

All of the examples above are not exhaustive. The Company treat harassment very seriously and will use the disciplinary procedure as appropriate, which could result in dismissal. Items 1(g), 1(h) and 2(d) are examples of gFKM Group misconduct, punishable by summary dismissal, but other items may constitute gFKM Group misconduct depending on the circumstances of the case in question.

The Company recognises the sensitive nature of complaints of sexual harassment. Female employees that wish to discuss such complaints, in confidence, should contact the HR Manager at Head Office or another female member of the HR Department. Male employees should contact a Male Operations Manager

Religious or Belief Employment Practices

At FKM GROUP LTD we recognize individuals’ religious beliefs and their association with that beliefs. In accordance with the Employment Equality (Religion or Belief) Regulations 2003 we ensure that no individual will suffer less favorable treatment based on their religion or belief during their application or employment within the Company.

We will support their commitment to their belief by trying to accommodate their preferred working arrangements. If a person is a member of the Seventh-Day Adventist Church and needs to leave early on a Friday to worship, we will try to accommodate this request. The Company keeps abreast of all key dates of religious festivities to ensure that the members of staff whose beliefs require them to be away from the working environment on these specific days are accommodated.

Flexible Working Arrangements

FKM GROUP LTD will genuinely give consideration to flexible working arrangements in accordance with the Flexible Working (Procedural Requirement) Regulations 2002.

We recognize the spirit and practical implications of having a flexible working environment. By offering flexible working arrangements we can widen the pool of talented applicants and not suffer from self-de-selection or be in breach of indirect discrimination. We also understand the benefits of promoting flexible working practices through increased productivity levels, motivation, staff retention, and reduced absence levels.

Monitoring

All employees and job applicants will be asked to provide data concerning their sex, age, nationality, ethnic origin, and any disability that they have. This information is held on the Company HR Information System and used solely as the basis for monitoring the diversity of the workforce. All such data obtained by the Company will be maintained in accordance with the Data Protection Act 2002.

Types of Unlawful Discrimination:

Direct – is when an individual is blatantly treated less favorably on the grounds of gender, race, disability, or sexual orientation.

Indirect – is when a condition or rule is applied which disqualifies an individual or group of individuals from an activity.

Victimization – when an individual is treated less favorably because he/she has alleged unlawful discrimination or has committed a “protected act” such as making a complaint or agreeing to give evidence at an internal hearing.

Harassment – is where there is unwanted conduct related to one of the prohibited grounds which has the purpose of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment for that person. Failure to make reasonable adjustments – where arrangements disadvantage an individual because of a disability, and reasonable adjustments are not made to overcome the disadvantage. The implementation of the Equal Opportunities and Diversity Policy is the duty of all managers and supervisors and all employees are expected to comply.