It is the organisations’ policy to promote equal opportunities and to work actively to remove barriers to access and progression, in the life and work of the company. This commitment is described in the following policy statement:
An Equal Opportunities and Diversity Policy is not only about ensuring that we meet our legal obligations but also about making clear our commitment to equality of opportunity and diversity and about reinforcing our ethos in respect of encouraging fairness and equality of treatment for all.
The Empire Group should be a place where staff, customers or volunteers hold common values about respect for others and about respecting the differences between people. These common values underpin and inform our policy.
Empire Group is committed to fairness in its practices and in meeting the needs of our diverse clients.
In addition, we recognise that some kinds of difference, discrimination or disadvantage are widely shared and experienced: where individuals have common needs, we also need equality and diversity strategies specific to particular groups of people.
We wish to achieve a mainstreaming of all equality and diversity issues, which will contribute to a change in organisational culture and performance.
We celebrate diversity so that different cultures can thrive, adding to the richness and experience of our community.
Empire Group welcomes and will actively comply with the statutory requirements laid down in Equality Act 2010 and related legislation
Commitment to Principles
- Life opportunities are a right for all and the company will use its resources to provide equal opportunities for all people to achieve their full potential.
- Empire Group will offer equality of opportunity to all actual and potential clients, staff, visitors and contractors. Discrimination on the grounds of age, disability, gender, marital status, civil partnerships, nationality, race, faith, transgender, gay, lesbian or bi sexual or any other sexual orientation will be opposed (the word discrimination in this clause is used in accordance with definitions laid out in the 1976 Race Relations Act, the Sex Discrimination Acts 1975 and 1986 and the Disability Act 1996).
- The company will address the issue of under-representation and the status of disadvantaged groups with the aim of enhancing their career, promotion and educational prospects, within all work that it undertakes.
- All staff and clients of the company will be made aware of their legal and moral responsibilities in respecting and promoting equal opportunities.
- Customers have access to all services and they are free of discrimination.
Commitment to Quality of Service
- Empire Group will stress its commitment to equal opportunities in its publications and official documentation as well as through marketing and promotional activities.
- To treat all customers with respect, dignity, and a quality service free from discrimination
- To provide accessible services according to individual need
- To support the effective implementation and realisation of the policy the company applies monitoring and evaluation procedures.
As an organisation striving to be an equal opportunities employer we are committed to working with all our employees with the aim of eliminating all aspects of discrimination within the organisation and the work force.
The importance of adhering to this policy is emphasised to all employees during their employment with the organisation and any breach of it will result in disciplinary action being taken against that employee.
The organisation shall ensure that employees are recruited, inducted, trained and are competent by the requirement of the job and are offered opportunities to further develop themselves.
All complaints by employees of unfair treatment will be investigated accordingly in a fair manner.
All employees of the organisation shall be treated fairly and equally in all aspects irrespective of their race, colour, ethnic or national origin, gender, marital status, disability, health status, sexuality, age, religion beliefs etc.
Applicants and employees with disabilities shall be treated fairly and equally and have access to training and personal development. Where a disable employee is unable to carry out existing duties, the organisation shall make reasonable alternative arrangement and adjustment to the job or find suitable alternative which best suit the employee.
To support the effective implementation and realisation of the policy the company applies monitoring and evaluation procedures, and as such the organisation shall take full responsibility for the monitoring of the operation of services and adherence to the policy by employees and job applicants and its periodic review.
RECRUITMENT POLICY PRACTICE AND PROCEDURES
- Recruitment and selection of employees This procedure covers recruitment and selection of employees (those with a contract of employment), whether full or part time, fixed term or open contract. See section
- For procedures relating to self-employed or subcontracted staff including consultants. Volunteers are dealt with elsewhere.
The procedure covers:
- Selection panels and job analysis
- Advertising posts
- Short listing candidates
- Interviewing candidates
- Coming to a decision and making an offer
1.1 Selection panels and job analysis
a. Decision to recruit. The decision to create a new post for an employee must be agreed by a full meeting of the Directors of the company
b. Job analysis. Following a decision to recruit, job analysis will be carried out on each post. A job analysis checklist will be used as a baseline for job analysis. The analysis will include suitability of the post for job sharing and/ or flexible working, as well as any genuine occupational qualification for appointment, and whether the post need to be bilingual (e.g. Welsh speaking). A job description and person specification will be produced based on the results of the analysis. The job description and person specification will be available before the post is advertised.
c. Job analysis and disability. The Empire Group aims to have an equal opportunities policy which reflects the requirements of the Disability Discrimination Act. Each job analysis should therefore routinely include consideration of the adjustments necessary to offer the job to:
- A blind or partially sighted person
- A deaf or hard of hearing person
- A person with permanent or intermittent mobility problems that may require use of a wheel chair.
- A person with a life threatening illness.
This job analysis can be used to help decide whether to encourage candidates with disabilities to apply for particular posts. Whatever the outcome however, any applications received from candidates with disabilities should be considered on merits and subject to exactly the same short listing process as all other candidates.
d. Person specification. The person specification is the key document in Empire Group recruitment. It outlines the experience, skills and knowledge required by the post holder against which all candidates will be assessed. Any skills, knowledge or experience required to perform the roles outlined in the job description must be included in the person specification. Desirable skills, knowledge or experience may be included but cannot be used unless candidates are in an equal position on essential criteria. If candidates may be considered on potential, i.e. that they could potentially meet criteria given necessary experience or training, then this should be mentioned on the person specification.
Where specific requirements such as ability to work occasional evenings/ weekends are required by the post, this must be included in the person specification. The person specification will include only requirements that relate specifically to the work of the post holder.
e. Selection panel. A selection panel will be appointed before the post is advertised. The panel will consist of a minimum of three people including a Director Empire Group or some representing the Director, one of whom must be the line manager for the post. The panel will be as diverse as possible (ethnicity and gender) within the range available amongst staff at the time. Where ability to speak/ write any language, including Welsh, is an essential criterion for the post, at least one panel member must be fluent in that language.
The selection panel will be chaired by one member of staff, normally the line manager for the post, who will be responsible for managing the recruitment process. The chair of the selection panel will take overall responsibility for the process but will not necessarily chair the interview. The selection panel will check the text of the advertisement and contents of the application pack for consistency with equal opportunities policies before these are issued.
f. Equal opportunities recruitment and selection training. Where possible all members of selection panels will have attended equal opportunities recruitment and selection training within the past three years. Courses will have been of at least one day’s duration and have been provided by a recognised training agency.
g. Fixed term contracts. Where a contract is a fixed term one of less than six months, job analysis should include an assessment of whether extension is a realistic possibility. If this is the case, jobs should be advertised ‘with possibility of extension’. Full equal opportunities recruitment and selection procedures should be used although a decision may be taken to limit advertising of the post. If extension is not a realistic possibility, the procedures in section two should be followed.
1.2 Advertisement of posts
a. Internal and external advertisement. All posts will be advertised internally and externally. Internal advertisements will be placed on the staff notice board and intranet. External advertisement will include national and local press, a variety of minority press, and other appropriate networks to encourage applications from all sectors of the community.
b. Anti discrimination statement. Every advertisement placed in the press will carry the statement:
Empire Group aims to challenge discrimination in all areas of its work and employment practices. And or any quality marks for Diversity it has been awarded
c. Under-representation statement. If black or other minority ethnic groups are under-represented on the staff team at the time, or if no one from a minority ethnic group has been appointed for the last two years, advertisements should also carry the statement:
“People from black, and minority ethnic communities are currently under-represented on the staff team and are encouraged to apply”
d. Additional equal opportunities information on advertisements. All advertisements will also carry details of any flexible working arrangements appropriate to the post, including job share. If job analysis has already indicated that it would be feasible to employ a blind or partially sighted person to the post, packs should be offered in different formats. If speaking Welsh (or any other language) is an essential requirement, advertisements must be bilingual. Where speaking any language, including Welsh, is a desirable criterion, bilingual advertising or a statement in that language must be considered.
e. Application pack. Every potential applicant for a vacant post will receive an application pack. This will contain:
- Covering letter outlining the process and clearly stating the importance of the person specification and application form
- Application form and guidance notes on completion
- Job description
- Person specification
- Terms and conditions of employment
- Information about Empire Group
- Outline of Empire Group equal opportunities and Diversity policy
- Equal opportunities monitoring form
- Descriptive outline of premises and access arrangements for consideration of candidates with disabilities
f. Application form. The application form will be revised to be consistent with this policy.
g. Equal opportunities monitoring form. The application form will include a detachable section for equal opportunities monitoring, which all candidates will be asked to fill in. The form will monitor age, gender, and ethnicity
h. Statement of special needs. The application form will include a section where candidates will be asked to state whether they have any disabilities or special needs, including any which need to be taken into account by an employer.
i. Statement of convictions. All candidates will be asked to declare unspent convictions. All candidates will also be informed that a police check will be necessary before a formal offer of employment is made. For any post involving unsupervised contact with children, checks will be made at the Enhanced Criminal Records Certificate level.
j. Use of recruitment agencies. Recruitment agencies may be used at any stage of the recruitment process provided that any candidates put forward by agencies are selected via an identical procedure using the same application form, selection panel, questions etc.
1.3 Short-listing candidates
a. Short-listing assessment forms. Selection panel chairs will be responsible for the production of short-listing assessment forms for each candidate. Each of the criteria on the person specification will be listed on the form and numerical scores will be assigned as follows: 2 = wholly met, 1 = partly met, 0 = not met. Selection panels will agree which if any criteria must be fully met and for each of those specific criteria agree an unambiguous definition of what ‘fully met’ means. Panels may agree to weight some scores for particular posts.
b. Assessment process A minimum of two members of the selection panel will complete an assessment form for each candidate based solely on the application form. Late applications will not be considered, and neither will applications which are not based on the form, for example CVs. Application forms will not be available to selection panel members prior to the short-listing process and selection panel members will not discuss the forms until they have completed their own assessments.
c. Short-listing meeting. When the assessments are complete, selection panel members will meet and agree a short-list based on the highest scores. Panels should aim to short-list no more than six candidates although in exceptional circumstances it may be necessary to interview more.
d. Number of interviews. More than one interview may be required especially for more senior posts. The selection panel should decide this at short-listing stage.
e. Tests. The selection panel should agree any parts of the person specification that will be assessed through a practical test, e.g. a presentation, in-tray sort or typing test. Where ability to speak or write any language, including Welsh, is an essential requirement, a practical oral or written test should form part of the interview.
e. Special needs. Where candidates for interview indicate that they have special needs, where possible these should be accommodated within the limits imposed by our size. If a candidate with special needs fulfils the requirements of the person specification, an interview should be offered even if job analysis suggests that it would be difficult to make the necessary adjustments.
f. Invitation to interview. Candidates will be contacted by letter and invited to attend an interview. If there will be more than one interview involved in the selection process they should be told at this stage. Candidates should also be informed about any tests they are asked to prepare for in advance. Invitation letters should include a map and a request to candidates to highlight any special needs they have for access to interview. Invitation letters should also offer an opportunity for an informal visit to Empire Group’ offices to learn more about the job, which will not be part of the selection process.
1.4 Interviewing candidates
a. Informal visits. Where offers for informal visits are taken up, individuals who are not part of the selection panel should carry this out. Information gathered via informal interviews must not be passed to the selection panel in their decision making process.
b. Preparation for interviews. Interviews should be carried out by selection panels, to ensure consistency throughout the interview process. Selection panel chairs are responsible for ensuring that question and assessment forms are available in advance, that all necessary equipment is available for tests and practical exercises, and that all members of the selection panel are clear about the process and their role. The questions should be available to the panel on a form, which provides space for comments and scoring. There will be space to record a total score. A chair for the interview should be agreed in advance.
There should also be space on the form to indicate whether or not each candidate was appointable, and panels should agree clear criteria in advance to decide this (for example certain essential criteria unmet, less than half the essential criteria fully met)
c. Content of interviews. All candidates for interview should be asked to complete the same task and asked the same questions initially, with follow up and probing questions as appropriate. Questions should be designed to explore key points on the person specification and the same scoring process should be used: 2 = wholly met, 1 = partly met, 0 = not met. Candidates should also be marked 0-5 for their task, using criteria agreed in advance. For example where the task is a presentation, it might be agreed that candidates will be awarded a maximum of 3 marks for content and 2 for presentation skills.
d. Conduct of interviews. Questions should be asked in the same order, and by the same panel members. Assessment sheets should be completed immediately following each interview. Panel members should not discuss their assessments until all the interviews are complete. When interviews are complete, panel members should compare scores.
e. Areas to avoid. Candidates must not be asked questions about their personal circumstances or present or intended family commitments. Where the job involves irregular hours or travel, the full facts must be presented in the person specification to all candidates before the interview. The selection panel must establish by a simple question whether or not candidates have understood the requirements of the job.
f. Disabilities. Disabilities should be discussed in the context of the person specification. For example if the person specification requires presentation skills and the candidate is deaf, their prior experience in this area and special needs to fulfil this requirement should be explored.
g. Transferable experience. Where a candidate’s formal work experience does not meet the requirements of the person specification, any informal but relevant experience (for example voluntary work) may also be taken into account when this has been stated on the person specification.
h. Records. All paperwork on interview candidates, including the application form, short-listing assessment form and interview assessment form, should be kept for six months as a record of the interview. Records on internal applicants should be kept for the duration of their employment and not discarded until six months after their departure.
1.5 Decisions
a. Coming to a decision. Panels should come to a decision within 48hrs of interview. All panel members should be in agreement before an offer can be made. Candidates’ scores should initially be aggregated and an overall decision made about each candidate’s appointability. Where a single candidate’s score exceeds others by a substantial margin, or more points, an offer should be made to that candidate, provided all panel members consider that candidate appointable. Where several appointable candidates are close, the panel should debate the merits of each candidate against the person specification. Considerations relating to family commitments, cultural or ethnic background, health or disability status should not influence this discussion unless the post has a Genuine Occupational Qualification.
b. Candidates with disabilities. If a candidate with a disability emerges as the strongest candidate, and job analysis has already indicated it would be possible to make necessary adjustments, the offer should be made immediately. If job analysis has indicated difficulty with necessary adjustments however, the analysis should be re-appraised in the light of the candidate’s specific needs, as discussed at interview.
c. Offers of appointment. These should be made to the strongest candidates on the telephone and in writing on a formal and clear basis, being specific about the need for police checks and references. As soon as a telephone offer has been accepted, other appointable candidates should be informed by a letter which acknowledges that they made a strong application. Candidates who were not appointable should also be informed by tactful letter at this stage. If the strongest candidate turns down the offer, or if references are unsatisfactory, the job should be offered to the next strongest, and so on. This process should continue until the list of appointable candidates is exhausted. No offers should be made to candidates who were considered unappointable at interview.
d. Complaints. Any candidate wishing to complain about the procedure should be asked to write to the Chair of the Panel. On receipt of a written complaint, the Chair will consult the person responsible for HR with the intention of resolving the complaint informally, and arrange a meeting if necessary.
e. References and police checks Requests for formal references should be made via a standard letter which asks former employers to supply details of length of employment, post held, and days off sick in the past year, and to comment on the candidate’s suitability, including any points of the person specification which they feel the candidate does not meet. Police checks at the level appropriate to the post should also be requested at this point.
References which produce information inconsistent with the application should be followed up by telephone. If references prove unsatisfactory the job should be offered to other appointable candidates.
f. Failure to recruit. If the procedure has been followed and the result has been a failure to recruit the post should be re-advertised. However the advertisement process should be agreed in the light of response to the first advertisement. Current staff and trustees may be invited to send the job description and person specification to personal contacts with relevant experience. Press advertisement may be more limited. Recruitment agencies may be used, in accordance with the policy. However, all candidates should complete an application form and go through the standard recruitment and selection procedure.
2. RECRUITMENT AND SELECTION OF SHORT TERM CONTRACT EMPLOYEES, SELF EMPLOYED CONTRACTORS AND CONSULTANTS
a. Short term contracts. Where posts last less than six months and there is no realistic possibility of extension, line managers may choose to use less rigorous selection procedures including recruitment agencies. As a basic minimum however there should still be internal and some external advertisement of the post (if only by word of mouth), a closing date, an application form, a person specification, job description and interview(s). Should the post be extended for any reason however, re-advertisement and full recruitment and selection procedures would become necessary.
b. Self employed contractors and consultants. All self-employed contractors and consultants should be covered by a contract to supply goods and services which makes it clear that they are not employees and are liable for their own tax and National Insurance. Self-employed contractors should do the majority of work from their own premises, using their own equipment. Contractors who do work worth more than £10,000 per year, or single contracts worth £10,000 or more spread over more than one year, should be selected on the basis of open tender.
2.1 Conditions of service
In keeping with the Company’s commitment to equality of opportunity, staff conditions of service include sections, which, are based on continued funding being available.
Staff conditions of service also include sections:
- Providing job related training,
- Providing paid or unpaid compassionate leave;
- Providing a childcare allowance, for staff attending meetings outside of normal working hours, (subject to available finance);
- Stating the needs of both prospective members of staff and staff who become disabled whilst working for Empire Group will be considered carefully and every effort will be made to provide facilities which enable them to carry out their duties;
- Sexual or racial harassment is recognised as constituting gross misconduct, which may result in dismissal without notice.
2.2 Terms and Conditions of Employment
Language Empire complies with the Equal Pay Acts and is committed to ensuring that they do not unreasonably discriminate against any individual in the terms and conditions, both contractual and implied, within which they offer and provide employment.
Staff facilities and services shall be equally available to all employees and where, for reasons of space and cost, this is not being achieved, reasonable alterations will be made.
Contracts and Terms and Conditions of employment shall be made available in a variety of media and positive consideration will always be given to requests for them in other formats
3. VOLUNTEERS
3.1 Empire Group supports the National Association of Volunteer Bureau Code of Practice, which includes the belief, that:
- Everyone has the right to volunteer without experiencing unfair discrimination, and Empire Group has a responsibility to treat volunteers appropriately and sensitively
- Volunteering is a matter of free choice and there can be no compulsion to become a volunteer;
- Volunteering is a valuable integral part of society and as such volunteers deserve support and recognition;
- Volunteers assist in effecting social change and improving the quality of life and play an essential role in alleviating the effects of poverty, ignorance, inequality and injustice.
All volunteers working directly for Empire Group will be monitored by: gender, disability, race and age. This monitoring information will be reported annually. Volunteers working for Empire Group shall be entitled to claim expenses for their activities where appropriate.
4. SERVICES
4.1 Individual Service Users
Empire Group undertakes different/various kinds of services & activities; therefore it is necessary for the use of these services /activities to be monitored individually.
Training course run by Empire Group
Monitoring of participants by gender, disability, race, whether attending as a manager or casual worker. The information will be recorded and will be reviewed on an annual basis.
4.2 Voluntary organisations/ statutory departments as service users
Meetings/seminars/conferences organised: All such events should be held in wheelchair accessible venues. In the event of hosting a meeting/ event to the general public, consideration will be given to the provision of an induction loop, signer and interpreter.
5. TRAINING
5.1 Language Empire’s policy of equality extends to training; this covers its general training programme and training in disability awareness and equality and diversity training.
Each employee has the right to expect not to be unreasonably discriminated against, either directly or indirectly, in the opportunities to be trained, in how it is provided, where it is provided and through what medium
5.2 All new employees shall receive induction training within one month of starting work to give them a good understanding of the organisation and its policies and practices
Regular and appropriate training will be provided to all staff to enable them to perform their jobs effectively and to ensure that they have the best opportunities for advancement.
6. OVERALL MONITORING
6.1 It is the responsibility of both Management and staff members to handle any discriminatory, oppressive language or behaviour in the work setting in a constructive manner.
6.2 Our Diversity & Equality Specialist Advisor is responsible for monitoring the effective implementation of the Equality & Diversity Policy with overall responsibility for its implementation and supervision remaining with Language Empire.
6.3 All aspects of Personnel policies and procedures shall be kept under review and as part of this, and in order to identify the effectiveness of Policy implementation, an anonymous and confidential record maintained giving a profile of the company’s staff make up. The information will then be logged for monitoring purposes.
The employee audit will be carried out annually, to establish the composition of the work force.
6.4 Similarly from time to time we will monitor customer profile to determine any unknowing barriers to our services by identified groups.
6.5 Any issues highlighted form monitoring and evaluation will be subject to a report to the Management Board and a plan of action agreed to address the issues.
Overall responsibility for ensuring that Empire Group fulfils its equal opportunities policy lies with the Management Board.