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diversity, equity and inclusion POLICY
purpose
BRAVE is committed to promoting equity, diversity and inclusion throughout the organisation and to creating a working environment in which everyone is treated fairly, respectfully and with dignity.
We recognise that a diverse and inclusive workplace benefits our people, our clients and the wider business. Different backgrounds, experiences, perspectives and ways of thinking strengthen our culture and the work we deliver.
We want everyone working with BRAVE to feel:
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valued;
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respected;
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included;
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able to contribute fully;
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supported to develop; and
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treated fairly.
The purpose of this policy is to:
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provide equality, fairness and respect for everyone working with BRAVE;
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promote a diverse and inclusive working environment;
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ensure employment decisions are made fairly and objectively;
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prevent unlawful discrimination, harassment, sexual harassment and victimisation;
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prevent inappropriate workplace behaviour;
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remove unnecessary barriers to recruitment, work and progression;
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support disabled employees and applicants through reasonable adjustments;
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establish clear standards of behaviour;
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protect employees from inappropriate behaviour by colleagues and third parties;
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promote fair access to training, development and career opportunities; and
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provide clear routes for raising and addressing concerns.
Who this policy applies to
This policy applies to:
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employees;
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directors;
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job applicants;
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freelancers;
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contractors;
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consultants;
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temporary workers;
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agency workers;
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interns;
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work-experience placements; and
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anyone else working with or on behalf of BRAVE.
The standards of behaviour in this policy also apply to interactions with:
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clients;
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suppliers;
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visitors;
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professional advisers;
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business partners;
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event attendees; and
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members of the public.
Where this policy applies
This policy applies throughout the employment relationship and wherever there is a connection with work.
This includes:
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recruitment and selection;
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onboarding;
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allocation of work;
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pay and benefits;
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terms and conditions;
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training and development;
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promotion;
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performance management;
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flexible working;
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family-related leave;
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disciplinary and grievance processes;
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redundancy;
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dismissal;
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termination of employment;
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access to workplace facilities and systems; and
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other employment or engagement decisions.
It applies whether behaviour occurs:
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in the BRAVE office;
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while working from home;
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at a client location;
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at another workplace;
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during business travel;
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at meetings or conferences;
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at industry events;
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at work-related social events;
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through Microsoft Teams;
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through email;
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through messaging applications;
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through video calls;
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through social media where there is a connection with work; or
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in any other work-related setting.
equality and the law
BRAVE will not unlawfully discriminate against anyone because of a protected characteristic under the Equality Act 2010.
The protected characteristics are:
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age;
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disability;
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gender reassignment;
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marriage and civil partnership;
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pregnancy and maternity;
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race, including colour, nationality and ethnic or national origin;
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religion or belief;
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sex; and
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sexual orientation.
BRAVE will oppose and seek to prevent unlawful discrimination in all aspects of employment and engagement.
our wider inclusion commitment
Our commitment to inclusion goes beyond the minimum requirements of discrimination law.
BRAVE expects people to be treated fairly and respectfully regardless of differences or personal circumstances including, where relevant:
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gender identity or expression;
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non-binary identity;
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neurodiversity;
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socioeconomic background;
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caring responsibilities;
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family circumstances;
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working pattern;
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educational background;
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personal appearance;
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accent;
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employment status; or
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other individual differences
Some of these matters may also fall within or be connected with a protected characteristic depending on the circumstances.
The fact that a particular characteristic is not separately listed as a protected characteristic under the Equality Act does not mean that disrespectful or inappropriate treatment relating to it is acceptable at BRAVE.
forms of discrimination
Unlawful discrimination can take different forms.
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DIRECT DISCRIMINATION
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Direct discrimination generally occurs where someone is treated less favourably because of a protected characteristic.
It may also arise in certain circumstances because:
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someone is wrongly perceived to have a protected characteristic; or
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someone is associated with a person who has a protected characteristic.
Employment decisions must not be based on assumptions, stereotypes or prejudices relating to protected characteristics.
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INDIRECT DISCRIMINATION
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Indirect discrimination can arise where a provision, criterion or practice is applied generally but places people who share a protected characteristic at a particular disadvantage.
Such a requirement may be lawful where it can be objectively justified as a proportionate means of achieving a legitimate aim.
BRAVE will avoid imposing unnecessary requirements that disproportionately disadvantage particular groups.
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DISABILITY DISCRIMINATION
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Disability discrimination may include:
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direct discrimination;
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indirect discrimination;
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discrimination arising from disability;
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harassment;
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victimisation; and
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failure to make reasonable adjustments.
Employees must not be treated unfavourably because of something arising from a disability where doing so would be unlawful.
harassment
Harassment can include unwanted conduct related to a protected characteristic that has the purpose or effect of:
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violating someone's dignity; or
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creating an intimidating, hostile, degrading, humiliating or offensive environment.
When considering whether conduct has this effect, relevant circumstances include:
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the perception of the person affected;
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the circumstances of the case; and
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whether it was reasonable for the conduct to have that effect.
A person's intention is not necessarily decisive.
Something described as:
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a joke;
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banter;
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teasing;
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harmless fun; or
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part of someone's personality may still be inappropriate or amount to harassment depending on the circumstances.
sexual harassment
Sexual harassment is unwanted conduct of a sexual nature that has the purpose or effect of:
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violating someone's dignity; or
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creating an intimidating, hostile, degrading, humiliating or offensive environment.
Examples may include:
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unwanted sexual comments or jokes;
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unwanted sexual attention;
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sexual advances;
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intrusive questions about someone's sexual or personal life;
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comments about someone's body or appearance;
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sexualised messages;
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inappropriate images or videos;
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displaying or circulating sexual material;
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suggestive comments or gestures;
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unwanted touching;
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repeated unwanted invitations;
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inappropriate conduct at social events; or
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offering or withholding employment benefits in connection with sexual conduct.
Less favourable treatment because someone rejected or submitted to unwanted sexual conduct may also be unlawful.
preventing sexual harassment
BRAVE is committed to prevention rather than relying only on action after an incident has occurred.
BRAVE will take all reasonable steps to prevent sexual harassment in the course of employment.
Depending on the risks and circumstances, preventative measures may include:
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clear policies and standards;
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regular review of harassment risks;
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employee and manager training;
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induction training;
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communication and reminders;
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accessible reporting routes;
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appropriate investigation procedures;
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action following complaints or warning signs;
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consideration of risks at work-related events;
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consideration of alcohol-related risks;
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consideration of risks during business travel;
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consideration of client-facing situations;
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monitoring patterns or repeated concerns; and
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appropriate action against individuals who breach expected standards.
Managers must not wait for a formal complaint before responding to behaviour that gives genuine cause for concern.
third-party harassment
BRAVE employees regularly interact with people who do not work for BRAVE.
These may include:
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clients;
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suppliers;
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contractors;
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consultants;
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visitors;
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event attendees;
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service providers; and
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members of the public.
Harassment by a third party is not acceptable.
BRAVE will take all reasonable steps to prevent employees being subjected to unlawful harassment by third parties in the course of their employment.
Where inappropriate behaviour occurs, BRAVE may take action including:
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challenging the behaviour;
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speaking to the third party;
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escalating the issue within the third party's organisation;
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changing working arrangements;
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restricting contact;
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requiring another representative to be used;
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removing an individual from BRAVE premises or an event;
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refusing further interaction with an individual;
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reviewing contractual arrangements; or
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ending a business relationship where appropriate.
Commercial considerations will not justify knowingly tolerating unlawful harassment.
Employees should report inappropriate third-party behaviour so that BRAVE can assess the risks and respond.
bullying
Bullying is not itself a separate protected characteristic concept under the Equality Act, but it is contrary to BRAVE's standards and will not be tolerated.
Bullying may include:
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intimidating behaviour;
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insulting or humiliating someone;
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deliberately undermining someone;
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repeated unreasonable criticism;
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misuse of authority;
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threatening behaviour;
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deliberate exclusion;
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aggressive communications; or
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other behaviour intended or reasonably likely to undermine someone's dignity at work.
Reasonable management action, including appropriate feedback, performance management or legitimate instruction, will not normally amount to bullying simply because an employee disagrees with it or finds it difficult.
victimisation
Victimisation occurs where someone is subjected to a detriment because they have done, or are believed to have done, a protected act under equality legislation.
This may include:
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making a discrimination or harassment complaint;
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raising a concern about unlawful treatment;
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supporting another person's complaint;
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giving evidence;
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participating in an investigation; or
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exercising rights under equality legislation.
BRAVE will not tolerate retaliation against anyone who raises or supports a genuine concern.
standards of behaviour
Everyone working for BRAVE is expected to:
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treat others with dignity and respect;
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behave professionally;
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consider how their words and actions affect others;
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avoid discriminatory behaviour;
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avoid bullying and harassment;
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avoid inappropriate sexual conduct;
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respect individual differences;
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challenge inappropriate behaviour where safe and appropriate;
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raise serious concerns;
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cooperate with measures designed to promote inclusion;
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complete required training; and
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cooperate appropriately with investigations.
Individuals, as well as BRAVE, may in certain circumstances incur personal legal liability for unlawful discrimination or harassment.
recruitment and selection
BRAVE is committed to fair and inclusive recruitment.
Recruitment decisions must be based on:
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skills;
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experience;
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ability;
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qualifications where relevant;
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potential;
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legitimate role requirements; and
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suitability for the position.
BRAVE will seek to:
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use objective selection criteria;
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advertise vacancies appropriately;
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avoid stereotypical or exclusionary wording;
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encourage applications from a broad range of candidates;
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avoid unnecessary job requirements;
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consider reasonable adjustments;
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assess applicants consistently; and
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regularly review recruitment practices.
Job applicants must not be rejected because of assumptions relating to a protected characteristic.
client instructions
BRAVE will not accept or act upon an instruction from a client or other third party that requires unlawful discrimination.
For example, BRAVE will not accept a request to:
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exclude candidates because of a protected characteristic;
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recruit only a particular age group without lawful justification;
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exclude disabled candidates;
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select candidates because of race, sex or another protected characteristic without a lawful occupational requirement; or
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apply another unlawfully discriminatory selection criterion.
Where a client raises a requirement connected with a protected characteristic, BRAVE will establish whether a genuine lawful occupational requirement, statutory exception or other lawful justification applies.
If there is no lawful basis, BRAVE will not act on the instruction.
recruitment questions
Applicants must not be asked inappropriate questions that could indicate an intention to discriminate.
In particular, applicants should not generally be asked:
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whether they are pregnant;
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whether they plan to have children;
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about childcare arrangements;
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about marital or civil partnership status;
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about protected characteristics unless there is a legitimate reason; or
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inappropriate questions about health or disability.
Questions about health or disability before an offer of employment may only be asked in limited circumstances permitted by law.
These may include questions needed to:
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establish whether a candidate can carry out an intrinsic function of the role;
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establish whether reasonable adjustments are required for interview or assessment;
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support lawful positive action;
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monitor diversity separately from selection; or
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satisfy another lawful exception.
Where there is uncertainty, advice should be sought from Operations before asking such questions.
right-to-work checks
BRAVE is required to ensure that employees have the right to work in the UK.
Right-to-work checks must be conducted consistently and must not be based on assumptions about a person's:
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appearance;
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name;
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race;
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accent;
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nationality; or
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perceived immigration status.
Appropriate checks will be conducted in accordance with current government requirements.
reasonable adjustments
BRAVE recognises its legal obligations towards disabled employees, workers and job applicants.
Where a disabled person is placed at a substantial disadvantage, BRAVE will consider reasonable adjustments.
Adjustments may include changes to:
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working arrangements;
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working hours;
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duties;
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equipment;
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software;
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communication methods;
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workplace facilities;
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recruitment processes;
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interview arrangements;
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training;
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policies or procedures; or
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another aspect of work.
Examples may include:
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specialist equipment;
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alternative software;
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adjusted hours;
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additional breaks;
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accessible information;
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changes to a workstation;
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adjusted interview arrangements;
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alternative communication methods; or
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changes to particular duties where reasonable.
What is reasonable will depend on the circumstances.
Employees and applicants are encouraged to tell BRAVE where an adjustment may assist them.
Requests can be raised with:
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the employee's line manager; or
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Operations.
Where BRAVE considers a particular adjustment not to be reasonable, we will explain the position and consider reasonable alternatives where possible.
neurodiversity
BRAVE recognises that people may think, process information, communicate, concentrate or work in different ways.
Neurodivergence may include conditions or differences such as:
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autism;
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ADHD;
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dyslexia;
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dyspraxia;
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dyscalculia; or
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other neurological differences.
Some neurodivergent individuals may meet the legal definition of disability and be entitled to reasonable adjustments.
Regardless of whether a legal disability threshold is met, BRAVE aims to foster an environment in which different working and communication styles are treated respectfully.
gender reassignment, gender identity and expression
The Equality Act protects people proposing to undergo, undergoing or having undergone gender reassignment.
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BRAVE will support employees appropriately and will not tolerate discrimination or harassment connected with gender reassignment.
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BRAVE also expects employees to treat colleagues respectfully in relation to:
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gender identity;
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gender expression;
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names; and
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personal identity.
Relevant personal information will be treated sensitively and confidentially.
Where workplace changes are required, these should be discussed appropriately with the individual concerned.
pregnancy and maternity
BRAVE will not treat an applicant or employee unfavourably because of:
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pregnancy;
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pregnancy-related illness;
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maternity leave; or
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exercising maternity-related rights.
Pregnancy and maternity must not unlawfully influence decisions relating to:
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recruitment;
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training;
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promotion;
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performance;
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pay;
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redundancy;
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allocation of work; or
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continued employment.
Relevant BRAVE family and leave policies provide further information.
religion or belief
BRAVE respects religious and philosophical beliefs.
Where reasonably practicable, requests relating to religion or belief will be considered fairly.
These may include matters concerning:
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religious observance;
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working arrangements;
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dress;
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dietary requirements; or
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workplace practices.
Requests will be considered alongside legitimate:
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business;
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client;
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operational;
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health and safety; and
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legal requirements.
age
Employment decisions must not be based on assumptions relating to age.
Age should not be used as a substitute for assessing:
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skill;
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experience;
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competence;
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performance;
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potential; or
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suitability.
Age requirements should only be imposed where there is a legitimate and lawful reason.
part-time employees
BRAVE will not treat part-time employees less favourably than comparable full-time employees simply because they work part time unless different treatment can lawfully be justified.
Part-time employees should have appropriate access to:
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pay and benefits, subject to legitimate pro-rating;
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holiday entitlement;
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pension arrangements;
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training;
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development;
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promotion;
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family-related leave;
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career opportunities; and
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redundancy processes.
fixed-term employees
Fixed-term employees should not be treated less favourably than comparable permanent employees simply because of their fixed-term status unless different treatment can lawfully be justified.
They should have fair access to:
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employment benefits;
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training;
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career opportunities; and
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information about permanent vacancies
where applicable.
flexible and different working patterns
Employees may work different agreed patterns, including:
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full time;
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part time;
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compressed hours;
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flexible hours;
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hybrid working; or
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other approved arrangements.
Employees should not be disadvantaged simply because they work an agreed alternative pattern.
Employment decisions should focus on legitimate role and business requirements.
pay, benefits and conditions
BRAVE is committed to fair pay and reward practices.
Decisions should be based on legitimate factors such as:
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role;
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responsibilities;
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skills;
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experience;
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performance;
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market considerations; and
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objective business requirements.
BRAVE will not unlawfully discriminate in relation to:
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salary;
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bonuses;
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benefits;
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pension arrangements;
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facilities; or
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other terms and conditions.
training, development and promotion
Employees should have fair access to:
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training;
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development;
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performance support;
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career opportunities; and
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promotion.
Decisions should be based on relevant factors including:
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skills;
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performance;
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potential;
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experience;
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development needs; and
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business requirements.
performance, disciplinary and grievance decisions
Performance management, disciplinary action and grievance procedures must be applied fairly and without unlawful discrimination.
Managers must avoid allowing assumptions relating to protected characteristics or personal circumstances to influence decision-making.
Reasonable adjustments should be considered where disability affects participation in a process.
redundancy
Redundancy selection criteria and processes must be:
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legitimate;
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fair;
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objective; and
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non-discriminatory.
Criteria that could disproportionately disadvantage a protected group must be considered carefully.
Relevant adjustments should be considered where required.
positive action
The Equality Act permits proportionate positive action in certain circumstances to address:
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disadvantage experienced by people sharing a protected characteristic;
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different needs; or
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disproportionately low participation.
BRAVE may consider lawful positive action where appropriate.
Positive action is not the same as unlawful positive discrimination.
Any initiative involving positive action should be carefully assessed before implementation.
equality and diversity monitoring
BRAVE may collect and review workforce information to help assess whether our employment practices are fair and inclusive.
Depending on what is appropriate and lawful, this may include information relating to:
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age;
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sex;
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race or ethnicity;
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disability;
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sexual orientation;
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religion or belief;
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recruitment;
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promotion;
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pay;
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training;
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employee turnover; and
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other relevant workforce trends
Participation in diversity monitoring will normally be voluntary unless the information is required for another legitimate purpose.
Monitoring information should:
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not improperly influence recruitment or employment decisions;
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be separated from selection processes where appropriate;
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be anonymised or aggregated where practicable;
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only be accessible where there is a legitimate need; and
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be handled in accordance with BRAVE's Data Protection Policy.
BRAVE may use monitoring information to identify:
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trends;
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potential barriers;
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under-representation;
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areas of disadvantage; or
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opportunities to improve inclusion.
responsibilities of managers
Managers have an additional responsibility to lead by example.
Managers must:
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make employment decisions fairly and objectively;
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promote an inclusive working environment;
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consider reasonable adjustments;
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challenge inappropriate behaviour;
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take concerns seriously;
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avoid dismissing behaviour as harmless banter;
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not wait for a formal complaint where serious concerns are apparent;
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maintain confidentiality as far as reasonably practicable;
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prevent retaliation against people raising genuine concerns;
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seek advice from Operations where required; and
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cooperate with preventative measures and investigations.
responsibilities of operations
Operations is responsible for:
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maintaining this policy;
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supporting fair employment practices;
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providing advice to employees and managers;
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supporting recruitment and selection;
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coordinating reasonable adjustments where appropriate;
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supporting or coordinating investigations;
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monitoring relevant legal developments;
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supporting equality, diversity and inclusion training;
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supporting harassment-prevention measures;
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reviewing workforce information where appropriate; and
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periodically reviewing this policy.
responsibilities of ceo and exec team
The CEO and Exec team have overall responsibility for supporting a culture consistent with BRAVE's equality, diversity and inclusion commitments.
They are expected to:
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support the implementation of this policy;
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promote appropriate standards;
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take serious concerns appropriately;
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support preventative measures; and
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ensure appropriate action is taken where significant issues arise.
training and awareness
BRAVE will take appropriate steps to ensure employees and managers understand their responsibilities.
This may include:
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equality, diversity and inclusion training;
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harassment and sexual-harassment training;
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manager training;
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recruitment training;
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new-starter induction;
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company presentations;
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policy reminders;
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targeted guidance;
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risk-based training; and
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refresher training.
Employees are expected to participate appropriately in required training.
raising a concern
Anyone who believes they have experienced or witnessed:
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discrimination;
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bullying;
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harassment;
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sexual harassment;
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victimisation; or
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another breach of this policy
should raise the matter as soon as reasonably practicable.
A concern may be raised with:
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the employee's line manager;
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another manager;
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Operations;
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a member of the Exec team; or
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the CEO where appropriate.
Employees do not need to raise a concern with their line manager where that would be inappropriate or uncomfortable.
Employees do not need to confront the person concerned before raising an issue with BRAVE.
informal resolution
In some circumstances, an employee may wish to seek informal resolution.
This might involve:
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speaking directly to the person concerned;
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asking a manager to assist;
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asking Operations to facilitate a discussion; or
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another proportionate intervention.
Informal resolution is not mandatory.
An employee may raise a formal complaint immediately where:
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they prefer to do so;
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the matter is serious;
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behaviour has been repeated;
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there is an abuse of authority;
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harassment or sexual harassment is alleged; or
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informal action would otherwise be inappropriate.
formal complaints
Formal concerns may be dealt with under BRAVE's Grievance Procedure or another appropriate investigation process.
Employees should provide as much relevant information as reasonably possible, including where available:
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what happened;
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dates and times;
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locations;
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individuals involved;
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witnesses;
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relevant emails or messages;
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other supporting information; and
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any action already taken.
BRAVE will seek to investigate concerns:
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fairly;
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sensitively;
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objectively; and
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as promptly as reasonably practicable.
confidentiality
Concerns will be handled sensitively.
Absolute confidentiality cannot always be guaranteed because information may need to be shared in order to:
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investigate;
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respond fairly to allegations;
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obtain evidence;
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take disciplinary action;
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comply with law; or
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protect individuals.
Information will be shared only where there is a legitimate reason.
Employees involved in an investigation may also be required to maintain appropriate confidentiality.
protection from retaliation
No person should suffer retaliation or detrimental treatment because they have:
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raised a genuine concern;
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made a complaint;
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supported someone else's complaint;
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provided evidence;
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acted as a witness;
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participated in an investigation; or
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exercised an equality-related legal right.
Victimisation or retaliation may itself result in disciplinary action.
false or malicious allegations
A complaint will not be treated as malicious simply because it is not ultimately upheld.
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However, deliberately making an allegation known to be false and doing so in bad faith may itself be treated as misconduct.
breaches of this policy
BRAVE takes breaches of this policy seriously.
Discrimination, harassment, sexual harassment, bullying or victimisation may constitute misconduct.
Serious cases may amount to gross misconduct and may result in dismissal without notice.
Where unacceptable conduct involves a:
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freelancer;
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contractor;
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supplier;
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client;
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visitor; or
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other third party,
BRAVE may take appropriate action, including:
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restricting access;
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terminating an assignment;
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ending an engagement;
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escalating the matter to another organisation; or
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ending a commercial relationship.
Certain conduct may also result in personal civil or criminal liability independently of BRAVE's internal procedures.
monitoring and review
BRAVE will periodically review:
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this policy;
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recruitment practices;
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employment procedures;
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harassment risks;
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training;
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workforce trends;
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complaints and concerns; and
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relevant legal developments.
The policy should normally be reviewed at least annually and sooner where:
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legislation changes;
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official guidance changes;
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significant concerns arise;
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working practices materially change; or
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BRAVE identifies an area requiring improvement.
status of this policy
This policy does not form part of any employee's contract of employment.
BRAVE may amend it from time to time to reflect:
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changes in law;
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official guidance;
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good practice;
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organisational requirements; or
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changes to the way BRAVE operates.
related brave policies
This policy should be read alongside relevant BRAVE policies and procedures, including:
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Anti-Harassment Policy;
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Third-Party Harassment Policy;
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Recruitment & Selection Policy;
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Flexible Working Policy;
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Homeworking Policy;
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Grievance Procedure;
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Disciplinary Rules and Procedure;
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Maternity & Paternity Leave Policy;
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Adoption, Adoption Appointments & Shared Parental Leave Policy;
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Parental Leave Policy;
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Time Off for Antenatal Appointments Policy;
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Performance Review Policy;
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Redundancy Process Policy; and
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Data Protection Policy.
