1. Purpose

To support this inclusive culture, this policy:

• outlines our commitment to equality, diversity and inclusion and sets out how we put this commitment into practice;
• explains the behaviours we expect of our people in support of this commitment; and
• sets out the key steps we take to make our culture as inclusive as possible, including how we ensure equality of opportunities for all employees, trustees and the families we support.

We reserve the right to amend or withdraw the policy at any time.

The policy accompanies our Anti-harassment and anti-bullying policy and any other equality, diversity and inclusion (EDI) policies adopted by the organisation.

2. Our Commitment

We believe that a culture of equality, diversity and inclusion not only benefits our organisation but supports wellbeing, enabling our colleagues, our trustees and our families to be themselves and feel that they belong.

We are committed to promoting an environment based on dignity, trust and respect, and one that is free from discrimination, harassment, bullying or victimisation.

We ensure that our internal processes for colleagues and the services we provide to our families do not treat people less favourably because of their:

• disability;
• gender, gender identity or gender reassignment status;
• marital status;
• race, racial group, ethnic or national origin, or nationality;
• religion or belief;
• sexual orientation;
• age;
• civil partnership status;
• pregnancy or maternity;
• paternity;
• employment status

3. Our Expectations

We expect every one of our people, to take personal responsibility for observing, upholding, promoting and applying this policy. Our culture is made in the day-to-day interactions between us, and creating the right environment for our colleagues and our families is a responsibility that we all share.

We expect everyone to be treated fairly and with dignity, trust and respect. Sometimes, this may mean allowing for different views and viewpoints and making space for others to contribute. We actively seek out the views of others and will regularly ask for feedback from our families and our colleagues to help us to ensure that our Equality, Diversity and Inclusion commitments are met.

By embedding such values and having the courage to challenge if required, you can help us achieve and maintain a truly inclusive culture.

Any concerns raised to us regarding Equality, Diversity & Inclusion will be investigated. For our colleagues, anyone who is found to have committed, authorised or condoned an act of discrimination, harassment, victimisation or bullying, may have take action against them including under our Disciplinary procedure.

Anyone can be personally liable for discrimination and harassment.

4. Discrimination

The Equality Act 2010 prohibits discrimination because of certain protected characteristics. These are:

• disability;
• sex;
• gender reassignment;
• marital or civil partnership status;
• race;
• religion or belief;
• sexual orientation;
• age; and
• pregnancy or maternity.

Discrimination can be intentional or unintentional and may occur directly, indirectly, by association, or by perception (see Different types of discrimination under the Equality Act 2010).

There are also two specific types of discrimination that apply only to disability: “discrimination arising from disability” and “failing to make reasonable adjustments” (see Different types of discrimination under the Equality Act 2010).

Discrimination is not always obvious and can be subtle and unconscious. This stems from a person’s general assumptions about the abilities, interests and characteristics of a particular group that influences how they treat those people (known as “unconscious bias”). Such assumptions or prejudices may cause them to apply requirements or conditions that put those in particular groups at a disadvantage.

Examples can include:

• steering colleagues into particular types of work on the basis of stereotypical assumptions without considering the particular attributes and abilities of individuals;
• recruiting or promoting individuals into particular roles because of assumptions about the reactions or preferences of other colleagues or clients; and
• using different standards for different groups of colleagues to judge performance.

5. Different types of Discrimination under the Equality Act 2010

Direct discrimination

Treating someone less favourably because of a protected characteristic compared with someone who does not have that characteristic. This could include not providing the required level of support or opportunity to someone due to a protected characteristic.

Indirect discrimination

Where a policy, procedure or way of working that applies to everyone puts people with a particular protected characteristic at a disadvantage, compared with people who do not have that characteristic, unless there is a good reason to justify it. This could include limiting opportunity and support in a way that prevents.

Associative discrimination

Treating someone less favourably because they are associated with someone who has a protected characteristic, for example because their partner is transgender.

Discrimination by perception

Treating someone less favourably because you perceive them to have a protected characteristic even if they do not.

Discrimination arising from disability

Treating someone unfavourably because of something connected with that person’s disability and where such treatment is not justified.

Failing to make reasonable adjustments

Employers are legally obliged to make reasonable adjustments to ensure that aspects of employment, or the employer’s premises, do not put a disabled person at a substantial disadvantage. Failing to comply with this duty is unlawful.

Harassment and sexual harassment

Harassment is unwanted conduct related to a protected characteristic that has the purpose or effect of:

• violating someone else’s dignity; or
• creating an intimidating, hostile, degrading, humiliating or offensive environment for someone else.

Sexual harassment is: conduct of a sexual nature that has the purpose or effect of violating someone’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment; and less favourable treatment related to sex or gender reassignment that occurs because of a rejection of, or submission to, sexual conduct.

You should refer to our Anti-harassment and anti-bullying policy for further information on our procedure for reporting harassment.

Victimisation

Victimisation is treating another person detrimentally either because that person has made a complaint of discrimination or harassment, or because they have supported someone else who has made such a complaint, for example by giving a witness statement that supports the allegations.

Bullying

There is no legal definition of bullying. However, we regard it as conduct that is offensive, intimidating, malicious, insulting, or an abuse or misuse of power, and usually persistent, that has the effect of undermining, humiliating or injuring the recipient.

Bullying can be physical, verbal or non-verbal conduct. It is not necessarily face to face and can be done by email, phone calls, online or on social media. Bullying may occur at work or outside work.

If the bullying relates to a person’s protected characteristic, it may also constitute harassment and, therefore, will be unlawful (see Harassment).

You should refer to our Anti-harassment and anti-bullying policy for further information on our procedure for reporting bullying.

6. Equality of Opportunity

Recruitment

We take reasonable and appropriate steps to encourage job applications from as diverse a range of people as possible.

Anyone making a decision about recruitment must not discriminate in any way and must have attended appropriate diversity and inclusion training.

Every decision-maker should challenge themselves, and other members of the recruitment selection panel, to make sure that any stereotypes, unconscious bias or prejudice do not play any part in recruitment decisions.

Career development

Any decision you make relating to a person’s promotion or career development must be free from discrimination.

We ensure that selection criteria and processes for recruitment and promotion are reviewed on a regular basis so that there is no discriminatory impact on a certain group.

7. Disability Inclusion

Recruiting people with a disability

The NFF ask applicants at the outset if they require any reasonable adjustments to be made to the recruitment process.

If you are involved in the interview process, you must not ask job applicants about their health or disability except with prior approval from the CEO. Such approval is given only in exceptional circumstances and where there are specific legal grounds for doing so.

Talking about disability

We understand that some people find it hard to discuss their disabilities and that disability can be invisible.

Psychological safety, where people feel able to speak up about their experiences without fear of negative consequences, is paramount to ensuring disability inclusion.

However, this is only possible if we treat people with dignity, trust and respect and we expect everyone to uphold these values.

We do not tolerate ableist language in our organisation. Ableist language is language that is negative, inappropriate or offensive towards people with a disability and may take the form of jokes or “banter”. If you adopt such language, we will take action against you including (for those to whom it applies) under our Disciplinary procedure.

Reasonable adjustments

If you have a disability, you do not have to tell us. However, we would encourage you to let us know so that we can support you, for example by making reasonable adjustments to our premises or to aspects of your role, or to our working practices.

If you are experiencing difficulties at work because of your disability, please contact your Line Manager to discuss potential reasonable adjustments that may alleviate or minimise such difficulties. We may need to discuss your needs with you and your medical adviser to help us get the right support in place.

For colleagues who are returning from long-term disability-related absence, we will work with you to develop a supportive return to work programme that accommodates you own personal circumstances.

Training

All new starters must attend equality, diversity and inclusion training as part of their onboarding programme. Current colleagues should complete this annually.

We expect all our people to proactively support our equality, diversity and inclusion initiatives and to educate themselves on the challenges faced by others and how to help alleviate these in the workplace.

8. Review & Monitoring

We will regularly review this policy to ensure its continuing compliance with relevant employment legislation.

Where issues are identified that impact on the working of this policy, these will be reviewed with a view to identifying measures to improve its effectiveness.

It is the responsibility of every colleague to assist us to meet our commitment to provide equal opportunities in employment and to avoid unlawful discrimination.

Colleagues have a responsibility to ensure the continuing success of the implementation of this policy by:

• Refraining from harassment and discrimination.
• Bringing to our attention any suspected practices in breach of this policy.
• Ensuring that selection for promotion, training, work allocation etc. is carried out in a non-discriminatory manner.
• Working together to promote a harmonious working environment and eliminating discrimination and harassment.

Colleagues can be held personally liable as well as, or instead of us for any act of unlawful discrimination. Colleagues committing serious acts of harassment may be guilty of committing a criminal offence.

Acts of discrimination, harassment, bullying or victimisation against colleagues, clients or customers are disciplinary offences and will be dealt with under the Disciplinary Procedures. Discrimination, harassment, bullying or victimisation may constitute gross misconduct and may lead to dismissal without notice. Reference is made to these offences in the Disciplinary Procedures.