Equality, Diversity & Inclusion policy

  1. Dignity at work


The Company believes that the working environment should at all times be supportive of the dignity and respect of individuals. If a complaint of harassment is brought to the attention of the Executive Team, it will be investigated promptly, and appropriate action will be taken.


Harassment can be defined as conduct which is unwanted and offensive and affects the dignity of an individual or group of individuals.

Sexual harassment is defined as behaviour characterised by the making of unwanted, unwelcome and inappropriate sexual remarks or physical advances in a workplace or other professional or social situation.

People can be subject to harassment on a wide variety of grounds including but not limited to:

  • race, ethnic origin, nationality or skin colour
  • sex or sexual orientation
  • religious or political convictions
  • willingness to challenge harassment, leading to victimisation
  • disabilities, sensory impairments or learning difficulties
  • status as ex-offenders
  • age
  • real or suspected infection with a blood borne virus (e.g., AIDS/HIV)
  • membership of a trade union or activities associated with membership

Forms may include:

  • physical contact ranging from touching to serious assault
  • verbal and written harassment through jokes, offensive language, gossip and slander, sectarian songs, letters and so on
  • visual display of posters, graffiti, obscene gestures, flags and emblems
  • isolation or non-cooperation at work, exclusion from social activities
  • coercion ranging from pressure for sexual favours to pressure to participate in political/religious groups
  • intrusion by pestering, spying, following someone
  • bullying


If you feel you are being harassed, you are strongly encouraged to seek early advice/support from your line manager. If you feel your line manager is harassing you, then you should contact a member of the Executive Team.

You should also keep a written record detailing the incidents of harassment and any requests made to the harasser to stop. This written record should be made as soon as possible after the events giving rise to concern and should include dates, times, places and the circumstances of what happened.

  1. Equal opportunities


The Company recognises that discrimination is unacceptable and that it is in the interests of the Company and its employees to utilise the skills of the total workforce.

It is the aim of the Company to ensure that no employee or job applicant receives less favourable facilities or treatment on grounds of age, disability, sex, gender reassignment, pregnancy, maternity, race (which includes colour, nationality and ethnic or national origins), sexual orientation, religion or belief, or because someone is married or in a civil partnership. These are known as "protected characteristics". 

Present numbers of employees and applicants for appointments or promotion shall be assessed on the basis of their suitability, capability and qualifications.

This policy and the associated arrangements shall operate in accordance with statutory requirements.

In addition, full account will be taken of any Codes of Practice issued by the Commission for Racial Equality, the Equal Opportunities Commission and the Department of Employment, and guidance from the Department of Health, and other statutory bodies.


Where discrimination against any person or group is referred to it shall be deemed to be potential discrimination within any of the categories listed in the policy statement. Two types of discrimination are covered by statute - direct and indirect.

Direct Discrimination

Direct discrimination occurs when a person or group is treated less favourably than others. Segregating a person or group on the basis of their race, sex or disability is unlawful. It also is unlawful for an employer to discriminate against a job applicant whose conviction is spent.

Indirect Discrimination

Indirect discrimination occurs when a condition or requirement is imposed which, although applied equally to all individuals or groups, is such that:

  • the proportion of persons of a group who can comply with it is significantly smaller than the proportion of persons not of that group who can comply with it.
  • the employer cannot show it as being justifiable based upon the needs of the job.
  • it is to the detriment of the individuals concerned because they cannot reasonably comply with it.

For example, a dress policy which prevents women wearing trousers discriminates against women of a particular race or religion; a higher language standard than is actually needed to do the job discriminates on the grounds of nationality/race; a training policy which excludes part-time employees may discriminate against women, who fill the majority of part-time jobs.


The Company attaches particular importance to the needs of people with disabilities.

Under the terms of this policy, managers are required to:

  1. make reasonable adjustment to maintain the services of an employee who becomes disabled, for example, training, provision of special equipment, reduced working hours etc.
  2. include people with disabilities in training/development programmes.
  3. give full and proper consideration to people with disabilities who apply for jobs, having regard to making reasonable adjustments for their particular aptitudes and abilities to allow them to be able to do the job.


Discrimination by victimisation occurs when a person is treated less favourably than another because he/she had asserted his/her rights under the Acts relating to discrimination or had helped another person to assert those rights.


The responsibility for ensuring the effective implementation and operation of the arrangements will rest with the Chief Executive. The Executive Team shall ensure that they and their employees operate within the policy and arrangements, and that all reasonable and practical steps are taken to avoid discrimination. The Executive Team will ensure that:

1. all employees are aware of the policy and the arrangements, and the reasons for the policy; 2. grievances concerning discrimination are dealt with properly, fairly and as quickly as possible.

3. proper records are maintained.

The Executive Team are also responsible for monitoring the operation of the policy in respect of employees and job applicants.


Whilst the responsibility for ensuring that there are no unlawful discrimination rests with the Executive Team, the attitudes of employees are crucial to the successful operation of fair employment practices. In particular, all employees should:

  1. comply with the policy and arrangements.
  2. not discriminate in their day-to-day activities or induce others to do so.
  3. not victimise, harass or intimidate other employees or groups on the grounds specified in the policy statement.
  4. inform a member of the Executive Team if they become aware of any discriminatory practice.


All employment arrangements have a bearing on equality of opportunity. The Company policies will be reviewed regularly, and any discriminatory elements removed.


Employees have a right to pursue a complaint concerning discrimination or victimisation.

Discrimination and victimisation will be treated as disciplinary offences, and they will be dealt with under the Grievance/ Disciplinary Procedure.

  1. Valuing diversity


The OCM is committed to valuing diversity and seeks to provide all employees with the opportunity for employment, career and personal development on the basis of ability, qualifications and suitability for the work as well as their potential to be developed into the job.

We believe that people from different backgrounds can bring fresh ideas, thinking and approaches which make the way work is undertaken more effective and efficient.

The Company will not tolerate direct or indirect discrimination against any person on grounds of race, religion, age, sex, marital status, disability, sexual orientation and the like whether in the field of recruitment, terms and conditions of employment, career progression, training, transfer or dismissal.

It is also the responsibility of all employees in their daily actions, decisions and behaviour to endeavour to promote these concepts, to comply with all relevant legislation and to ensure that they do not discriminate against colleagues, customers, suppliers or any other person associated with the Company.


In adopting these principles, The OCM:

  1. Will not tolerate acts that breach this policy, and all such breaches or alleged breaches will be taken seriously, be fully investigated and may be subject to disciplinary action where appropriate.
  2. Fully recognises its legal obligations under all relevant legislation and codes of practice.
  3. Will allow employees to pursue any matter through the internal procedures which they believe has exposed them to inequitable treatment within the scope of this policy. 
  4. Will ensure that all managers understand and maintain their responsibilities and those of their team under this policy.
  5. Will offer opportunities for flexible working patterns, wherever operationally feasible, to help employees to combine a career with their domestic responsibilities.
  6. Will provide equal opportunity to all who apply for vacancies through open competition.
  7. Will select candidates only on the basis of their ability to carry out the job, using a clear and open process.
  8. Will provide all employees with the training and development that they need to carry out their job effectively.
  9. Will provide all reasonable assistance to employees who are or who become disabled, making reasonable adjustments wherever possible to provide continued employment. We will ensure an appropriate risk assessment is carried out and that appropriate specialist advice is obtained when necessary.
  10. Will publish this statement in the Employee handbook which is made available to all employees of the Company.


This policy will be reviewed annually by the Chief Executive, Ed Parsloe and MD OCM Apprenticeships, Charlotte Bruce-Foulds.

Last review 01 September 2023.

Next review: 01 September 2024.