DSSR is committed to the policy of equal treatment of all employees and applicants to promote a culture that actively values difference recognising that people from diverse backgrounds can bring valuable insights to the workplace and enhance the way we do business.

Policy: Equality & Diversity Policy (2021)

The Company’s aim is to be an inclusive organisation by recruiting, training, promoting and rewarding on the basis of merit and irrespective of the protected characteristics detailed in the Equality Act 2010 (gender, disability, sexual orientation, marriage or civil partnership, pregnancy & maternity, gender reassignment, age, religion or belief, race, which includes colour, nationality, ethnic or national origins) or in relation to part-time status, trade union membership and political belief or affiliations.

The Company is therefore committed to providing equality of opportunity for all employees by:

  • Preventing any form of direct or indirect discrimination or victimisation or bullying.
  • Promoting a good and harmonious working environment where all individuals are treated with respect and dignity and in which no form of intimidation or harassment from colleagues, customers or clients will be tolerated.
  • Fulfilling all legal obligations under relevant legislation and associated Codes of Practice where they apply.
  • Exceeding legal requirements to ensure that any person will be treated with fairness, respect and in a way that is non-discriminatory.

You must be aware of the importance which the Company attaches to this policy and must ensure that you do not, by your own actions, behaviour or attitude, directly or indirectly or unintentionally discriminate against any job applicants, employees, customers or clients.

Any act of discrimination will be treated as a disciplinary offence; these will include, for example, discrimination in selecting, promoting or training, refusing to work with or for a person because of any of the reasons stated in paragraph one of this policy and harassment of any employee, customer or client.

This policy applies to all individuals working at all levels, trainees, home-workers, casual workers, volunteers, agency staff, contractors and all job applicants.


Equality and Diversity are at the heart of how we do business. We recognise the importance of making full use of people’s talents and skills by creating an open and inclusive workplace culture where people from all backgrounds can work together with dignity and respect. We also recognise the importance of individuals to feel that they are being encouraged and developed to their full potential.

Steps we will take to ensure that we are fulfilling our responsibilities and promoting good practice include:

  • Complying with legal obligations in a transparent manner
  • Assessing the impact of policies and practices to identify remove or mitigate any disadvantage to underrepresented groups
  • Taking measures to eliminate discrimination
  • Take positive action to redress any imbalances identified by the monitoring carried out
  • Fostering good relations between people who share a protected characteristic and those who do not
  • Promoting awareness and understanding of equality and diversity matters among staff through policies, training and guidance
  • Ensuring that the Company’s property is, as far as possible, welcoming and accessible to all
  • Make sure that reasonable adjustments are made, as appropriate, to enable people with disabilities to overcome barriers in the work environment
  • Ensuring that employees are provided with appropriate tools so that they feel confident to discuss equality and diversity issues and raise any concerns they may have


Each employee has a responsibility to ensure that the ethos of this policy is put into practice in all areas of work and in any dealings with people external to the Company.

The Directors have responsibility for:

  • Providing leadership on the Equality, Diversity and Inclusivity strategy and policy, acting as overall champions to ensure that that policy is implemented effectively and communicating the strategy and policy both internally and externally.
  • Ensuring that training on this Policy is included as a core requirement at all levels within the Company
  • Closely monitoring all aspects of equality, diversity and inclusivity and taking action where any anomalies are identified to redress the imbalances found.
  • Establishing an Action Plan which can be cascaded to all sections of the Company work.

Managers at all levels are responsible for:

  • Demonstrating and role-modelling acceptable standards
  • Supporting their employees in meeting the aims of this policy
  • Ensuring that all employees participate in the training provided
  • Taking practical steps to implement and support this policy.
  • Ensuring that any complaints or grievances are dealt with fairly, in accordance with the Disciplinary Policy and Grievance Policy.
  • Implementing the policy as part of their day-to-day management of staff and in applying employment policies and practices in a fair and equitable way;
  • Ensuring equality and diversity issues are addressed in performance;
  • Effectively managing and dealing promptly when investigating issues relating to potential discrimination, including those matters concerning employees, members of the general public or other stakeholders;
  • Ensuring all policy or service decisions that will change provisions, practices or policies and affect the workforce are Equality Impact Assessed and
  • Being aware of any Action Plan set by the Board and ensuring that this is embedded into the work of their own department


All employees have a responsibility to guard against any form of discrimination and avoid any action which goes against the spirit of this policy. Employees at all levels must ensure that there is no discrimination in any of their decisions or behaviour. This includes the provision that all employees must:

  • Implement the policy in their day-to-day work and their dealings with colleagues, customers and visitors;
  • Being aware of any Action Plan for their own team and their part in its implementation;
  • Ensure their behaviour is appropriate to the policy and that they treat people with respect and dignity;
  • Not discriminate against other employees, volunteers or students; and
  • Notify their line Manager of any concerns with regard to the conduct of other employees, volunteers or students, the public or third parties.


Equality can be described as breaking down barriers, eliminating discrimination and ensuring equal opportunity and access for all groups both in employment and to goods and services; the basis of which is supported and protected by legislation.

It should be noted that this does not mean treating everyone ‘the same’. What it does mean is recognising that everyone is different with different strengths and needs which need to be addressed.

Diversity can be described as celebrating differences and valuing everyone. Each person is an individual with visible and non-visible differences and by respecting this everyone can feel valued for their contributions which is beneficial not only for the individual but for the Company.

Equality and Diversity are not inter-changeable but inter-dependent. There can be no equality of opportunity if the difference is not valued and harnessed and taken into account.

The key benefits of adopting an Equality and Diversity Policy are:

  • To promote fairness in access to employment opportunities
  • To attract employees and to retain existing employees
  • To gain a diversity of talent and experience
  • To ensure that every employee has the opportunity to develop their potential
  • To provide fair and equitable services to customers/clients
  • To ensure legal compliance, particularly with regard to the Company’s responsibilities under health and safety and to the common law duty of care.



Unlawful direct discrimination occurs when a person is treated less favourably than another because of one or more of the protected characteristics. These protected characteristics include gender, disability, sexual orientation, marriage or civil partnership, pregnancy & maternity, gender reassignment, age, religion or belief, race, which includes colour, nationality, ethnic or national origins) or in relation to part-time status, trade union membership and political belief or affiliations. Direct discrimination, for example, can occur where a woman is refused a job, training or promotion because she is pregnant.


Unlawful indirect discrimination is when a provision, criterion or practice is applied to all people but which, in practice, is such that fewer people in certain groups are able to comply and it cannot be shown to be a proportionate means of achieving a legitimate aim. Some practices may look fair but have an unintended discriminatory effect.

For example, if the Company made a GCSE English qualification a requirement as selection criteria. This would have a disproportionate adverse impact on people educated overseas and may not be justified if all that is required for the job is to demonstrate a level of literacy or the ability to communicate with others.

The necessary level of literacy can be tested or checked in other ways that are more relevant to the job.


If any employee is victimised (treated unfairly) because they have supported another person who has a protected characteristic, that employee will have the same protection as if he or she had that protected characteristic.

For example, one person gives a statement confirming that they witnessed the other employee being harassed due to his or her race. The witness is then victimised, and pressure is brought in an attempt to get him or her to withdraw the statement. The witness will then be protected in the same way as the original employee who was being harassed.


This is where a person is discriminated against because they have an association with someone who has a particular protected characteristic. For example, a non-disabled person is discriminated against because of the action they need to take care of a disabled dependent.


Discrimination against a person because the discriminator thinks the person possesses that characteristic. For example, a person has not been shortlisted for a job on the basis that the recruiter assumes the applicant does not have the correct VISA to work in the UK as they have a foreign-looking name on their application form


Harassment is defined as unwanted conduct which can be physical, verbal or non-verbal that either violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment for that person. The Company will not tolerate harassment on the grounds detailed in the Equality Act 2010 (gender, gender reassignment, race, which includes colour, nationality, ethnic or national origins, disability, sexual orientation, age, religion or belief. It may be a persistent or an isolated incident. It can take many forms, from relatively mild banter to actual physical violence.

You may not always realise that your behaviour constitutes bullying or harassment but you must recognise that what is acceptable to one person may not be acceptable to another.

The Company has a separate Anti-Bullying, Harassment & Stalking Policy.


The Company will consider any request made for time off to observe particular religious commitments with sensitivity and sympathetically. For example, if you need to be home by a certain time on Friday or Saturday to observe the requirements of your faith, the Company will review your duties to see if it is feasible to accommodate this request. Where possible, such requests will be agreed and time may be taken as unpaid time off or made up at a different time that suits the Company.

If the work simply cannot be done at another time, then the Company will be unable to agree to the request as it would mean that the business operation would suffer. The same type of consideration will be given to practising Christians who may not wish to work on Sunday or to refrain from working at Christmas or Easter.

Consideration will also be given to the locations and the timings of meetings and functions. The Company will treat employees’ beliefs and religion with sensitivity. For example, locations for business meetings will be checked regarding alcohol if one of the people required to attend the meeting follows a doctrine that prevents him or her from attending meetings at such a place. The timing of routine meetings will, as far as possible, not be arranged when employees who follow a particular religion would be unable to attend due to that religion.

Some religions require their followers to pray at specific times during the day. The Company will allow time off for quiet prayer which can be taken at times convenient to the business and in a convenient place. This time will be unpaid unless it can be made up at a time that is convenient to the Company.

If you request time off for religious practices, such requests will be treated with sensitivity, and your duties and the impact on the business considered carefully.

If you wish to make a request under this section of the policy, you should talk to your Line Manager who will discuss your requirements to see if these can be accommodated.


Sensitive consideration will be given to requests to take holiday (or unpaid leave) to observe religious holidays. Wherever possible, the Company will agree to these requests. However, if the Company has a legitimate business reason for refusing any request then this will be the outcome as the Company is permitted to make these decisions based on the need to operate the business effectively. If requests are made with as much notice as possible being given it may be more likely that these can be accommodated and planned for in the business work schedule.


You may wear appropriate religious and cultural dress (for example, clerical collars, head scarves, skullcaps, turbans, burqa, hijab) unless it creates a health and safety risk to them or any other person, or otherwise breaches this policy.

For operational and health and safety reasons, employees of the Company may have to be flexible in some circumstances. However, the Company’s policy is to ensure that any such restrictions regarding clothing to be worn in an operational environment are genuine requirements on grounds of operational effectiveness or health and safety.

Where necessary management can give further information and guidance on cultural and religious dress in the workplace.


Complaints about, or reports of, discriminatory behaviour or harassment should be made through the Company Grievance Procedure.

Complaints should be raised as soon as possible so that the matter can be dealt with quickly. The matter should be raised first with the complainant’s line Manager.

If this would cause embarrassment or if the complainant feels it inappropriate, for example, if the line Manager is the subject of the complaint, then the matter should be raised with another, possibly more senior Manager.

If you experience any discriminatory behaviour from a third party such as customers or clients, you should raise the matter immediately with your line manager or any other Manager present at the place of work. The matter will be treated seriously and the Manager will carry out a full investigation.


Any accusations of unlawful discrimination will be investigated fully by the Company. As part of the investigation, you will be given every opportunity to answer the allegation and provide an explanation of your actions.

Once the investigation is complete, if the Company finds that no unlawful discrimination occurred, no further action will be taken. However, if the Company decides that your actions amount to unlawful discrimination, you may be subject to disciplinary action up to and including summary dismissal for gross misconduct.

If, after the investigation is complete, it is found that the claim is false or malicious, disciplinary action may be taken against the employee who raised the complaint.

Equal opportunities practice is constantly developing as social attitudes and legislation change. The Company will keep its policies under review and will implement changes where these could improve equality of opportunity.


This is a key area where anti-discriminatory practice can make a difference. It is important that the Company recruits the best person for each vacancy that arises.

All advertisements, job descriptions and the shortlisting and interview procedures should take cognisance of the Company’s Equality and Diversity Policy.

Please note that special consideration should be applied when drawing up the section relating to knowledge, skills and experience. The key points are to be objective, be clear about the role and avoid unfair assumptions (E.g. that women will have childcare issues).

The Company will undertake a periodic review of the Equal Opportunities Monitoring forms and any feedback or complaints arising during the recruitment and selection process will help to amend any practices and make any necessary adjustments.


The Company believe that all employees should be given the opportunity to undertake learning and development as part of the Company’s commitment to continuous professional development.
Specific ways to encourage diversity through training and development include:

  • Providing appropriate training for all staff involved in the recruitment and selection process and to those who may provide feedback to candidates
  • Offering Diversity training as part of the induction process and updating all staff on any changes to practices or legal framework affecting this policy
  • Having regular refresher training on diversity so that it is maintained as a crucial part of how the Company operates
  • Encouraging awareness of all sections within the Company through initiatives including secondments, mentoring, attending presentations, occasional hot-desking, and development days
  • Allowing all employees, the opportunity to fulfil their potential through ongoing development in accordance with the Performance Management Policy.


The Disability Discrimination Act was passed in 1995 and is included in the Equality Act 2010. As well as dealing with issues that may occur in employment it also places an obligation on service providers to ensure that disabled people are able to use their services. This also means that reasonable adjustments have to be made to buildings so those physical barriers do not prevent disabled people from accessing services.

The installation and use of induction loops, text phones, appropriate use of colour contrast, low-level reception desks, and having information available in large print, tape or Braille can help to meet these requirements.

The Equality Act compels the Company to think about how it offers its services in ways that allow disabled people to have access as well as considering what needs to be done to facilitate the employment of disabled people.

The Company is committed to making every effort that should any employee become disabled they will stay in employment. Should a candidate with a disability apply for any vacancy within the Company, they will be considered on their abilities, not their disability.

Where any employee has a condition that is regarded as a disability, the Company will be as flexible as possible discussing any reasonable adjustments with the employee so that the workplace is comfortable and accommodates their requirements.

This will also include any adjustments to the dress code followed by the Company.

If any employee would like to discuss any adjustments, they should talk to their Line Manager in the first instance.


If you have a condition that is regarded as a disability, the Company will be as flexible as possible by discussing any reasonable adjustments with you so that the workplace is comfortable and accommodates your requirements.

This will also include any adjustments to the dress code followed by the Company.

If you would like to discuss any adjustments, you should talk to your Line Manager in the first instance.


While it is important to have a policy on Equality, Diversity and Inclusivity, it is equally important to have a robust monitoring system with checks and balances in place so that any issues can be highlighted. This also allows management to identify where there may be areas of institutional discrimination happening which may not be as obvious as individual occurrences. A result of any monitoring will be published along with any action plan devised to address the imbalances shown.