1. POLICY STATEMENT

The DPDgroup UK Ltd Dignity at Work Policy has been revised in order to reflect the changes to UK
employment legislation that have been introduced following implementation of the Equality Act 2010.
All Company employees have the right to be treated with dignity and respect and to work in a climate free
from harassment and intimidation. DPDgroup Limited prohibits any form of discrimination, harassment,
bullying, or victimisation by fellow employees and wishes to ensure equity throughout the employment
relationship.

No employee or person seeking employment within any business unit of DPDgroup will be treated less
favourably than another on the grounds of the “Protected Characteristics” as specified within the Equality
Act and set out below. The Company is unreservedly opposed to any form of discrimination whether direct,
indirect, by perception or via association and equality of opportunity will apply to all areas of employment,
including:

● Advertising, recruitment and selection
● Terms and conditions contained within employment offers
● Progression, promotion and transfer
● Training, development and career progression opportunities
● Work allocation, including additional earnings potential
● Selection for redundancy, short time, lay off, shift work or overtime
● Provision of benefits, facilities and services such as holiday entitlement, hours of work and
sick pay
● Treatment of or by colleagues

Employees will not be placed at a disadvantage by requirements or conditions that are unnecessary for the
performance of the job.

Company policy will be subject to continuous improvement with recruitment practices, training and
development opportunities and career progression actively monitored to ensure individuals are treated
objectively and on the basis of their merit and ability.

​

2. Discrimination

The Equality Act introduced new definitions for discrimination, whilst broadening existing protection.
Discrimination can now be considered under four defined categories.

Direct Discrimination – occurs when someone is treated less favourably than another individual
(comparator) because of a protected characteristic

Indirect Discrimination – occurs when a rule, policy or practice exists which applies to everyone but
which particularly disadvantages people who share a particular protected characteristic

Discrimination by Association – occurs where someone is treated less favourably than another
person (comparator) because they associate with an individual who possesses a protected
characteristic, e.g. they are required to take time off to care for a relative with a disability

Discrimination by Perception – occurs when an individual is discriminated against because it is
thought that they possess a protected characteristic. It applies even if the individual does not actually possess that characteristic, e.g. discrimination because an individual is believed to be gay (whether the individual is gay or not).

​

3. What are the "Protected Characteristics"?

The Equality Act 2010 repealed existing legislation regarding discrimination and introduced the
following “protected characteristics” which includes previous areas covered by discrimination
legislation and introduces new areas.

Discrimination can affect anyone. However, some people may be more likely to be affected, particularly
when they are seen as different, are in a minority, or are perceived to have less power. People can
be subject to discrimination or harassment on a variety of grounds, including:

● Age;
● Disability;
● Gender reassignment;
● Race;
● Religion or Belief;
● Sex / Gender;
● Sexual Orientation;
● Marriage and Civil Partnership; and
● Pregnancy and Maternity.

This list is not exhaustive. Discrimination and/or Harassment can occur between people of the same
sex, race, etc. Discrimination, harassment or bullying on the basis of any of the protected
characteristics above, or for any other reason is both negative and unacceptable. Where such
conduct or behaviour is seen to take place within the workplace, it will be deemed as a
gross-misconduct offence and will be subject to disciplinary action with sanction up to and including
summary dismissal where appropriate.

​

4. What is Harrassment?

Harassment 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 an intimidating, hostile,
humiliating or offensive environment for that individual”. It is for each individual to determine what
behaviour is acceptable to them and what they regard as offensive or humiliating. It is the unwanted
nature of the conduct that distinguishes harassment from friendly behaviour which is welcome and
mutual.

The following are examples of behaviour that may constitute harassment:

● Physical Conduct - Ranging from brushing up against or touching a person, through to
physical intimidation or assault.
● Verbal Conduct - This includes threats, bullying, unwelcome advances, innuendo,
suggestive or insulting remarks and lewd, racist or belittling comments.
● Non-Verbal Conduct - This covers gestures, noises or the display of pictures or symbols,
interference with personal property and harassment via E-Mail or text messages. In general
terms it includes unreasonable behaviour which creates an unpleasant working environment.

​

5. Procedure for dealing with Allegations of Harrassment

It may be possible and preferable to provide an informal resolution as many complainants will require
only for the behaviour to stop. However, it is the Company's responsibility to follow up ANY
accusations of harassment and ensure that this policy is both implemented and upheld.

Handling Informal Action
Harassment can often be stopped by informal, early and local intervention by a Manager. An informal
approach is a useful starting point for potential or actual harassment of a potentially less serious
nature.

Registering a Formal Complaint
When an employee feels that he/she is being harassed or discriminated against and wishes to raise a
formal complaint, they should do so with their Line Manager or Supervisor in the first instance. Where the
complaint is against the persons’ immediate manager the next level of management should be contacted.
The complaint will be formally recorded and signed by the complainant. The complaint must be dealt with
as quickly as possible and should be concluded within ten working days, unless exceptional circumstances
prevail.

Once a written complaint has been received the alleged harasser will be informed of the complaint and that
an investigation will take place. The alleged harasser may be suspended in line with the Company
Disciplinary Procedure.

A Manager receiving a formal complaint or allegation should seek guidance from their designated People
Business Partner before suspending an individual from duty or commencing an investigation.

Carrying Out The Investigation
The normal investigation process will be followed by an independent person who has no connection with
the complaint, and is credible to both parties and the Company. Full records will be kept and witness
statements will be taken.

Interviewing the Complainant
The complainant will be interviewed first and asked to make a signed written statement, He/she may also
wish to produce additional evidence such as a diary of events or names of witnesses.
The complainant is entitled to be accompanied by a Union Representative or colleague.

​

Interviewing the Alleged Harasser
The alleged harasser will then be interviewed and asked to make a signed written statement in response to
the allegations made against them, before any other witnesses are contacted. The alleged harasser is
entitled to be accompanied by a Union Representative or colleague.

Interviewing Witnesses
Any witnesses cited by either party will then be interviewed and asked to provide signed written statements.
Any witnesses are entitled to be accompanied by a Union Representative or a colleague. In exceptional
circumstances, e.g. where fear of intimidation exists, managers may at their discretion accept anonymous
statements. This should only be done where the Manager knows the identity of the witness and has sought
guidance from their People Business Partner

​

Insufficient/Inconclusive Evidence
Where the investigation is considered to be inconclusive or there is insufficient evidence to sustain the
allegations no further action will be taken against the alleged harasser.
If the alleged harasser was suspended/relocated pending the investigation he/she will be returned to his/her
normal duties and reintegration of the parties may be necessary, counselling therefore could be advisable.
Both parties should be assured of their rights and responsibilities including protection against victimisation.

​

Victimisation
It is unacceptable for a complainant or alleged harasser to be victimised due to their actions at any point
following a complaint being made under the DPDgroup Dignity, Diversity & Inclusion at Work policy. Any
allegation of victimisation will be thoroughly investigated and if found to have substance will warrant
disciplinary action.

Redress
Redress available under this procedure is as follows:

● Change to Company policies or practices;
● Communication issued to all employees to cease discriminatory behaviour, language etc. and
any appropriate action to ensure this occurs e.g. training;
● A formal apology;
● Consideration of action through the disciplinary procedure against the perpetrator;
● Other action thought appropriate in the circumstances.

Allegations that are proven to be malicious will be considered as Gross Misconduct and subject to
the appropriate disciplinary action;

​

Appeal
Appeals regarding the decision should be made in writing in line with the Company Discipline and
Grievance Procedures.