1. Policy Statement

SDPC (NW) Ltd (The Company) is committed to supporting, developing and promoting diversity and equality in all of its employment practices and activities and aims to establish an inclusive culture free from discrimination and based on the values of fairness, dignity and respect. The Company will support and develop staff through providing everyone with access to facilities, personal and career development opportunities and employment on an equal basis regardless of race, national or ethic origin, disability, age, gender, sexual orientation, transgender identity or religion/belief.

This policy builds on the foundation of equality and anti-discrimination legislation and strives, not only to comply with legal requirements, but to use these to ensure that The Company endeavours to exemplify best practice.

The Company values diversity and recognises that the organisation is greatly enhanced by the different range of backgrounds, experiences, views, beliefs and cultures represented within its staff. The Company aims to embrace diversity in all of its activities and acknowledges that variety and difference are intrinsic to the success and future development of its business.

The Company values, People, Pride and Professionalism, underpin the Diversity and Equality policy and are integral to The Company becoming an employer of choice. We expect all employees, contractors and agency staff to act in accordance with this Policy.

2. Aim
The aim of this Policy is to build a fully inclusive organisation. This will be achieved by:
• Making the best use of the range of talent and experience available within the workforce and potential workforce
• Building a culture that encourages dialogue
• The Company and employees fulfilling their legal obligations

3. Principles
The principles of the diversity and equal opportunities policy are:
• To develop and promote a culture of diversity and equality throughout the organisation;
• To develop and promote a culture of fairness, integrity and dignity;
• to support all staff, regardless of race, national or ethnic origin, age, disability, gender, sexual orientation, gender reassignment, religion or belief;
• to prevent all forms of unlawful discrimination;
• to deal with all forms of discrimination consistently, promptly and effectively;
• to ensure that the Diversity and Equality policy influences and informs the culture of The Company.

4. Scope

The policy applies to all applicants for posts with The Company, to all staff employed on a full time or part-time basis, on permanent or temporary contracts, to agency staff and contractors. This forms a part of the company employee handbook and will form part of the induction process as the new employees join the company.

5. Legislative Framework
This Policy is underpinned by legislation, which places individual responsibilities on staff/service users/visitors as well as The Company, this includes:
• Human Rights Act 1998
• The Civil Partnership Act 2004
• The Gender Recognition Act 2004
• The Equality Act 2006
• Equality Act 2010
The above list is not exhaustive and will be reviewed regularly.

Under the above Equality legislation, it is unlawful to:
• discriminate directly against anyone and treat him/her less favourably than others because of a protected characteristic they have or are thought to have (perception discrimination), or because they associate with someone who has a protected characteristic (discrimination by association).;
• discriminate indirectly against anyone by applying a criterion, provision or practice which particularly disadvantages people who share a protected characteristic;
• subject someone to harassment related to a relevant protected characteristic (pregnancy and maternity and marriage and civil partnership are excluded);
• victimise someone because s/he has made, or intends to make, a complaint or allegation or has given or intends to give evidence in relation to a complaint of discrimination;
• discriminate against someone in certain circumstances because of a protected characteristic after the working relationship has ended.

The protected characteristics are:
• age
• disability
• gender
• gender reassignment
• marriage and civil partnership
• pregnancy and maternity
• race
• religion or belief
• sexual orientation

6. Definitions
Equal Opportunities
Equal opportunities is a principle that emphasises that opportunities in employment, education and other areas are available to all. Equal Opportunities in particular relates to a Legal Framework, which makes it illegal to discriminate against people because of a protected characteristic they have.


Diversity is a broader concept that builds upon the progress made through equal opportunities. Everyone is different, and diversity is about recognising, respecting and valuing the differences we each bring to work. Equal opportunities and diversity work together by identifying and addressing any inequalities and barriers faced by people and by valuing, learning and benefiting from the diverse cultures in society and our staff.

Direct Discrimination

Direct discrimination occurs when an individual is treated less favourably than another because of a protected characteristic they have.   

Discrimination by Association

This is direct discrimination against someone because they associate with another person who possesses a protected characteristic.

Perception Discrimination 

This is direct discrimination against an individual because others think they possesses a protected characteristic. It applies even if the person does not actually possess the protected characteristic.

Indirect Discrimination

Indirect discrimination occurs when a provision, criterion or practice is applied universally, but its effect disadvantages people who share a protected characteristic.  


Harassment is uninvited and unwanted behaviour related to a protected characteristic  and makes a person feel intimidated or humiliated.  


Victimisation is where someone is treated less favourably because they have made a complaint about discrimination or harassment or have given evidence relating to a complaint.


It is essential that all members of The Company behave with dignity, courtesy and respect and to act in a non-discriminatory manner at all times

The Company 

The Company has a legal responsibility for demonstrating that it treats all groups of staff fairly in its employment practices. This includes promoting good relationships between different groups of staff and ensuring equality of opportunity.  

To achieve this The Company will:  

  • Gather information on the profile of our staff and our employment practices, such as recruitment; Consult employees and trade unions about how our services and employment practices could be improved
  • Assess the impact of current and proposed employment policies, practices and services
  • Identify priorities and set equality objectives
  • The Directing Board will monitor progress through the Equality Impact Assessment process and support the implementation of action plans.

This will enable The Company to achieve its aim of a healthy work-life balance for all staff, improve retention and prevent under-utilisation of some staff. Employees and job applicants will  receive no less favourable treatment on the grounds of race, national or ethnic origin, religion or belief, gender, sexual orientation, gender reassignment, disability or age.  

All of this is in line with The Company Diversity and Equality Strategy which has the overall aim of: 

  • Improving Delivery through Diversity – to ensure diversity and equality is our reality and habit with a view to improving our business.
  • The Company Delivery Plan sets out how we will deliver its diversity and equality strategy through the achievement of these outcomes. The actions are intended to comply with the legal requirements to meet or exceed good practice under the seven equality strands of race, gender, transgender, sexual orientation, disability, age and religion or faith. Since the Company is committed to ensuring diversity and equality is our reality and habit, this delivery plan goes beyond the separate equality strands to also specifically include flexible working patterns of staff (part-time and home-working), which facilitate the recruitment and progression of staff with domestic responsibilities. 

The Chief Executive 

The Chief Executive is ultimately accountable for ensuring that all SD Painting business and employment practices are compliant with Diversity and Equality legislation and promote equality of opportunity. 

Will ensure that all members of staff within The Company receive the appropriate diversity and equality training. Will investigate all matters of alleged discrimination, harassment and inappropriate behaviour promptly and thoroughly. Will ensure that selection and appointment procedures, performance management processes, staff development opportunities and disciplinary and grievance processes are fairly and consistently applied to all staff. Will treat all applications for flexible working patterns on a fair and equitable basis and will provide reasonable and objective reasons when such requests must be refused. Will ensure that diversity and equality issues are considered as part of The Company planning processes. 


Legal responsibilities also extend to employees, and The Company therefore expects all staff, contractors and agency staff to act in accordance with this Policy when delivering The Company’s business. Staff are expected to treat colleagues and every service user fairly and with respect. All staff should deliver their work to the highest standard and that means adapting as much as possible to the specific needs of each individual service user and working in a supportive way with colleagues. Every member of staff is an essential member of a team and should feel able to develop their skills and play their part fully in the organisation. Staff should actively encourage non-discriminatory practices and challenge any incidences of behaviour that fail to comply with this policy. All staff should undertake appropriate diversity and equality training. 

Human Resources
Will ensure the incorporation of this policy’s principles into all other Insolvency Service policies and procedures. Will provide appropriate diversity and equality awareness training for all staff. Will support managers in implementing the policy. Will ensure that recruitment advertising, selection and appointment procedures, performance management processes and disciplinary grievance processes are fair and transparent and are consistently applied.Will produce and monitor diversity and equality data and will publish the findings of monitoring activity. 

8. Application of the Policy

Recruitment and Selection

Recruitment advertising will encourage applications from all sectors of the community reflecting The Company’s commitment to diversity and equality:

  • recruitment advertising will appear in publications appropriate to the audience capable of producing the best candidates; 
  • job descriptions, person specifications and recruitment advertisements will be written on the basis of the essential and justifiable requirements of the position;
  • shortlisting, appointment and rejection decisions will be transparent and justifiable and will be supported by written comments.

Grading and Promotion

  • All grading and promotions criteria and procedures will be free from prejudice and must be applied equitably and consistently.

Staff Development

  • All staff will have equal access to induction, personal and career development

opportunities and facilities.

Performance Management

  • Probation and performance management procedures will be clear and transparent and will be applied fairly across all staff.

Discipline and Grievance

  • Disciplinary and grievance procedures will be applied fairly and transparently for all staff; 
  • allegations of discrimination, harassment or inappropriate behaviour will be dealt with under the appropriate disciplinary procedures for staff. 

9. Advice and Complaints

All staff who believe they have been subjected to discrimination or harassment have the right to seek redress. Staff may seek advice from their line manager, Human Resources or Trade Union representative. Complaints should be submitted in accordance with The Company’s Grievance Procedure. Verbal or physical abuse by anybody will not be tolerated. The Company may discipline staff who are found to be abusive. 

10. Policy Framework and Support

The Company has also developed a number of other policies and practices in support of the achievement of an organisational culture free from unfair bias, discrimination and harassment. In particular The Company’s Race, Disability and Equality Schemes and action plans to address inequality. Also, The Company‘s Dignity at Work Policy


Diversity and Equality awareness raising training will be available for all staff. 


This policy will normally be available on The Company’s intranet.  It will also be available, if requested, in different formats (e.g. large print, audio cassette, in braille). This policy will be included in staff induction. 


Statistics will be gathered to monitor equality across all aspects of Insolvency Service processes and will be used to inform future practice. 


Any information disclosed to The Company in relation to diversity and equality issues will be kept strictly confidential in accordance with legislative requirements. 

11. Policy Review

This policy will be reviewed at regular intervals to ensure it remains in line with legislation and The Company‘s organisational principles.