Diversity & Equality policy

Owner: HoQ

Reviewed: 01/04/2018


1 Policy Statement


CPR Global Tech is committed in all its activities as an employer and user of other businesses and individuals to:

• the elimination of discrimination, and

• the promotion of equality of opportunity, diversity and inclusivity.


Diversity and equality of opportunity are important to us. Our core business focuses on protecting individuals so we have a deep appreciation that each individual is by definition, unique. We aim to treat people fairly and to recognise and respond to their individual needs, experiences and aspirations. Human diversity strengthens and enriches our organisation.


Building a truly diverse and socially inclusive business is a long-term and ongoing process and we are committed to achieving this. We recognise that it is a key area for the business and one which we have to continuously monitor and strive to improve. Our aim is to build a culture that values meritocracy, openness, fairness and transparency.


Specifically, Brook Innovation will consider all people on merit and will not discriminate, without lawful cause, nor victimise or harass on the grounds of:

• Age,

• Disability,

• Gender re-assignment,

• Marital or civil partnership status,

• Pregnancy or maternity,

• Race, colour, nationality, ethnic or national origin,

• Religion or belief,

• Sex, or

• Sexual orientation


The principles of non-discrimination and equality of opportunity apply to the way in which our people treat each other as well as how they treat job applicants, visitors, clients, and former members of staff.


2 Who is covered by the policy?

The policy covers all individuals working at or for Brook Innovation, including all employees, partners, consultants, contractors, trainees, casual workers and agency staff.


3 Responsibilities under the policy

Andrew Sandbrook, the CEO, has overall responsibility for ensuring the policy is adhered to. All our people have a responsibility for their personal behaviour in relation to equal opportunities, diversity and following all aspects of this policy.

All our people are made aware of the contents of this policy and receive appropriate training and support to promote its application.


4 Scope of the policy

This policy applies to every aspect of employment including advertising, recruitment and selection, training, opportunities for promotion, conditions of work, pay and benefits, conduct at work, disciplinary and grievance procedures and termination of employment. The application of the policy to specific aspects of employment is dealt with in more detail below.

This policy also applies to all aspects of Brook Innovation’s delivery of services and acquisition of services from suppliers.

Brook Innovation will also seek to promote equality, diversity and social exclusivity beyond its core business activities by involvement in or sponsorship of suitable community activities under the umbrella of our Corporate Responsibility and Sustainability Policy Statement.


5 Recruitment and selection

5.1 Brook Innovation’s recruitment and selection process aim to select the most suitable person for the job in respect of experience and qualifications without making assumptions or pre-judgements about the suitability of a candidate based on one of the protected characteristics.


5.2 Recruitment publicity will positively encourage applications from suitably qualified, experienced people and will avoid any stereotyping of roles. All vacancies will be advertised in a wide variety of ways to ensure that a fair cross-section of potential applicants has access to the advertisement.


5.3 Questions on the application form will be relevant and non-discriminatory. At an interview, no questions will be asked or assumptions made about a candidate’s personal, health and domestic circumstances or plans. Where the requirements of the job affect the candidate’s personal life (e.g. unsocial hours or travel) this will be discussed objectively. There are limited exceptions when questions about an applicant’s health may be asked at interview.


5.4 If selection tests are used to ensure that applicants have the skills and aptitude required for the job, all such tests will be valid and reliable and free from any discrimination based on the protected characteristics.


5.5 Person and job specifications shall be limited to those requirements which are necessary for the effective performance of the job.


5.6 Our selection procedures will be reviewed from time to time to ensure that they are appropriate for achieving our objectives and for avoiding unlawful discrimination.


5.7 In accordance with recommended practice the composition of our people and applicants for jobs will be monitored for its diversity on an anonymous basis at all levels. This will include all protected characteristics, where known.


5.8 As far as practicable, action will be taken to ensure that the workforce forms a balanced reflection of the various groups within the local community

6 Staff training and promotion and conditions of service.


6.1 We will aim to ensure that our people achieve their full potential and that all employment decisions are taken without reference to irrelevant or discriminatory criteria.


6.2 Access to training and career development will be made available to all our people having regard to an individual's ability and commitment to attain the required level of performance and taking into account Brook Innovation’s requirements.


6.3 As far as practicable, positive action will be taken, to assist disadvantaged individuals to reach their full potential by providing appropriate training, education or practical assistance.


6.4 The conditions of service, benefits and facilities will be reviewed regularly to ensure that they are available to all our people who should have access to them and that there are no unlawful obstacles to accessing them.


7 Termination of employment

7.1 Selection for redundancy or the termination of employment will be based on objective criteria and best practice and will not be based on discriminatory criteria.


7.2 Disciplinary procedures and penalties will be applied without discrimination.



8 Breaches of the policy

8.1 If any of our people believe they may have been discriminated against, they are encouraged to raise the matter through our Head of Quality.


8.2 Allegations regarding potential breaches of this policy will be treated in confidence and investigated in accordance with the Grievance Procedure. People who raise potential breaches in good faith will not be victimised or treated less favourably as a result. False allegations which are found to have been made in bad faith will be dealt with under the Disciplinary Procedure.


8.3 Any of our people who are found to have committed an act of discrimination or harassment will be subject to action. Such behaviour may constitute gross misconduct and, as such, may result in summary dismissal in the case of an employee.


9 Review of the policy

The policy will be reviewed by the Head of Quality on an ongoing basis to reflect changes in the law, demographics and internal business requirements. People are invited to comment on this policy and suggest ways in which it might be improved by contacting the Head of Quality.

This policy does not form part of any employee’s contract of employment and may be amended at any time.

Any queries about this policy should be directed to the Head of Quality.



Further Information about the Protected Characteristics: Key Points under the Equality Act 2010

The Act protects people of all ages. However, there may be grounds to justify that different treatment because of age was not unlawful direct or indirect discrimination if you can demonstrate that it was a proportionate means of meeting a legitimate aim. Age is the only protected characteristic that currently allows employers to justify direct discrimination. The Act continues to allow employers to have a default retirement age of 65 until April 2011.

The Act has made it easier for a person to show that they are disabled and protected from disability discrimination. Under the Act, a person is disabled if they have a physical or mental impairment which has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities, which would include things like using a telephone, reading a book or using public transport.

An employer is required to make reasonable adjustments when recruiting, selecting, inducting and promoting disabled employees. The Act puts a duty on the employer to make reasonable adjustments for staff to help them overcome disadvantage resulting from an impairment (e.g. by providing assistive technologies to help visually impaired staff use computers effectively). The Act includes a new protection from discrimination arising from disability. This states that it is discrimination to treat a disabled person unfavourably because of something connected with their disability (eg a tendency to make spelling mistakes arising from dyslexia). This type of discrimination is unlawful where the employer or other person acting for the employer knows, or could reasonably be expected to know, that the person has a disability. This type of discrimination is only justifiable if an employer can show that it was a proportionate means of achieving a legitimate aim. Additionally, indirect discrimination now covers disabled people. This means that a job applicant or employee could claim that a particular rule or requirement you have in place disadvantages people with the same disability. Unless you could justify this, it would be unlawful. The Act also includes a new provision which makes it unlawful, except in certain circumstances, for employers to ask about a candidate´s health before offering them work.

Gender reassignment
The Act provides protection for transsexual people. A transsexual person is someone who proposes to, starts or has completed a process to change his or her gender. The Act no longer requires a person to be under medical supervision to be protected – e.g. a woman who decides to live as a man, but does not undergo any medical procedures, would be covered.

It is discrimination to treat transsexual people less favourably for being absent from work because they propose to undergo, are undergoing or have undergone gender reassignment than they would be treated if they were absent because they were ill or injured.

Marriage and civil partnership
The Act protects employees who are married or in a civil partnership against discrimination. Single people are not protected.

Pregnancy and maternity
A woman is protected against discrimination on the grounds of pregnancy and maternity during the period of her pregnancy and any statutory maternity leave to which she is entitled. During this period, pregnancy and maternity discrimination cannot be treated as sex discrimination. You must not take into account an employee´s period of absence due to pregnancy-related illness when making a decision about her employment.

For the purposes of the Act `race´ includes colour, nationality and ethnic or national origins.

Religion or belief
In the Equality Act, religion includes any religion. It also includes a lack of religion, in other words employees or jobseekers are protected if they do not follow a certain religion or have no religion at all. Additionally, a religion must have a clear structure and belief system. Belief means any religious or philosophical belief or a lack of such belief. To be protected, a belief must satisfy various criteria, including that it is a weighty and substantial aspect of human life and behaviour. Denominations or sects within a religion can be considered a protected religion or religious belief. Discrimination because of religion or belief can occur even where both the discriminator and recipient are of the same religion or belief.

Both men and women are protected under the Act.

Sexual orientation
The Act protects bisexual, gay, heterosexual and lesbian people.

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