Equality, Diversity and Inclusion Policy

1 - Introduction

    1. Hawthorn & Kent Ltd (‘the Company’) is committed to being inclusive, aqnd we see inclusivity as one of the Company’s greatest strengths. it is essential that inclusion and equality of opportunity be at the core of all the Company’s activities.

  • This policy applies equally to current and prospective members of the Company, including contractors.

  • This policy is made available on the Company website and can be made available upon request. All Company policies can be made available in large print or other accessible format if required.

  • The Company is committed to a zero tolerance policy in relation to less favourable treatment on the grounds of any protected characteristic under the protected characteristics – Equality Act 2010 (www.legislation.gov.uk/ukpga/2010/15/section/4).

  • The Company is committed to promoting and developing inclusion & equality of opportunity in all its functions and will seek to do this by:

  1. Communicating its commitment to equality and diversity to all members of its community

  2. Ensuring all staff and contractors are aware of the aims of this policy

  3. Developing monitoring, evaluation and review mechanisms of Company policies and procedures and decision-making

  4. Demonstrating our zero tolerance attitude towards discrimination by taking allegations seriously

2 - Responsibility

  • The Directors have responsibility for ensuring that the Company operates within the legal framework for equality and for implementing the policy throughout the Company.

  • Each member of the Company community is responsible for being alert to and challenging discrimination; embracing diversity; respecting different faiths and beliefs; and upholding equality of opportunity for all.

3 - The Legal Framework

  • Discrimination can take the following forms. Including:

  1. Direct Discrimination – This occurs where a person is treated less favourably than others because of their (or a family member’s) actual or perceived protected characteristic.

  2. Indirect Discrimination – This occurs by applying a provision, criterion or practice, which disadvantages people on the grounds of a protected characteristic and which cannot be justified as a proportionate means of achieving a legitimate aim.

  3. Victimisation – This occurs where an individual has exercised their rights under equality legislation (or has indicated that they intend to do so) and is treated less favourably as a direct result. It applies equally to a person who is supporting (or indicates that they intend to support) another person who is exercising their rights under the legislation.

  4. Harassment – This is defined as unwanted conduct related to a relevant protected characteristic which has the purpose OR effect of violating an individual’s dignity or creating a hostile, humiliating or offensive environment for that individual.

  5. Disability Discrimination – This includes direct and indirect discrimination, any unjustified less favourable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability.


4 - Aims and Values

  • The aims of this policy and the Company’s ethos as a whole are to:

  1. Eliminate unlawful discrimination on the grounds of any of the protected characteristics

  2. Eliminate all bullying and unlawful discrimination on the basis that an individual has a learning difficulty or special educational need, or because English is an additional language

  3. Comply with the Company’s equality obligations contained in the Equality Act 2010

  4. Provide an environment where all individuals feel valued and feel they have a sense of belonging

  5. Provide and promote positive information about the diversity of UK society

  6. Actively challenge discrimination and ensure that all members of the Company learn from these experiences

  7. Embed inclusion through all our activities

  • To achieve these aims we will:

  1. Involve, where reasonably practicable, all members of the Company in the development, review, evaluation, and impact assessment of all relevant improvement plans, policies and procedures

  2. Publish and share Company policies to the whole Company community

  3. Collect and analyse data to monitor any potential disadvantage amongst our client base

  4. Operate a clear zero tolerance policy towards abusive or discriminatory behaviour

  5. Work in partnership with the wider community to establish, promote and disseminate inclusive practice and help tackle discrimination

  • The Company aims to promote inclusion and tackle any form of discrimination and actively, and to promote harmonious relations in all areas of Company life and with our key partners. 

  • The Company recognises that discrimination may be, for example, direct, indirect or arising from disability whether or not it was intentional. 

  • The Company will:

  1. Treat all members of the Company community with respect and dignity and seek to provide a positive working environment free from discrimination

  2. Endeavour to meet the needs of all members of the Company and ensure that there is no unlawful discrimination on the grounds of any of the protected characteristics listed above

  3. Challenge inappropriate discriminatory behaviour by all members of the Company

  4. Foster a culture which promotes openness and encourages individuals to come forward if they have experienced discrimination.

  5. Ensure that all individuals undertaking activities on behalf of the Company are aware of their responsibilities promote equality of opportunity and are given appropriate training and support

  6. Ensure that it reviews, monitors and evaluates the effectiveness of inclusive practices.

5 - Responsibilities

    • It is the Company’s responsibility to:

  1. Ensure that all Company representatives act as role models of inclusive behaviour and practice

  2. Ensure that the Company complies with its equality obligations

  3. Ensure that the Company’s policies & procedures are monitored in light of this policy and the Company’s wider equality obligations


6 - The Directors

  • It is the Directors’ responsibility to:

  1. Ensure effective implementation of this policy and its and procedures

  2. Ensure that all Company representatives are sufficiently aware and trained within equality & diversity

  3. Actively challenge and take appropriate action in any cases of discriminatory practice within the Company, be it by staff, contractors or visitors

  4. Have procedures in place to deal effectively with any reported incidents of discrimination, victimization or harassment

  5. Ensure that all visitors and contractors are aware of, and comply with, this policy.

7 - EDI co-ordinator

  • It is the policy co-ordinator’s responsibility to:

    1. Ensure the policy is amended and updated as required

    2. To lead Inset as required on EDI

    3. To ensure all staff are aware of the policy and follow it

    4. Actively challenge and take appropriate action in any cases of discriminatory practice within the Company

    5. To ensure it is embedded across the Company

8- All Staff

  • It is the responsibility of all staff to:

  1. Positively role model inclusive behaviour

  2. Actively challenge any forms of discrimination, victimization, harassment or bullying

  3. Identify and challenge bias and stereotyping within the curriculum and in the Company’s culture

  4. Commit to broadening their knowledge, confidence and inclusive behaviour by attending relevant training and accessing information from appropriate sources.

7 - Concerns and Complaints

  • The Company will seek to provide a supportive environment for those who make claims of discrimination and/or harassment. Any individual who believes that they have been discriminated against or have been subject to discriminatory conduct should talk to the Company Directors.

8 - Monitoring and Review

    • This policy is monitored on an ongoing basis to evaluate its effectiveness and ensure appropriate steps can be taken to eliminate unlawful discrimination.

    • This policy is usually reviewed on an annual basis to ensure the aims of the policy are carried out in accordance with the Company’s equality obligations.

9- Breaches of the Policy

    1. All breaches of the policy will be rigorously followed up using the appropriate procedures and reported promptly to the Company Directors.

Last Updated: 5th January 2025

EDI Co-ordinator: Sophie Adams