Equality & Diversity

1. EQUAL OPPORTUNITIES STATEMENT

1.1 We are committed to promoting equal treatment of all individuals with whom we interact, engage, employ or otherwise have relationships with. Whilst interacting with H2O, in any way, you can expect equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation or political preference (together known as “Protected Characteristics”).

1.2 The provisions of this policy apply to employees, contractors and suppliers to H2O Logistics Ltd.

2. ABOUT THIS POLICY

2.1 This policy sets out our approach to equal opportunities and the avoidance of discrimination at work. It applies to all aspects of employment and engagement with us, including, where relevant and appropriate, recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and complaints procedures, and termination of employment.
2.2 The Managing Director is responsible for this policy and any necessary training on equal opportunities.
2.3 This policy does not form part of any employee’s or worker’s contract of employment or engagement and we may amend it at any time.

3. DISCRIMINATION

3.1 You must not unlawfully discriminate against or harass other people. This includes current and former employees, job applicants, clients, customers, suppliers and visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts or when wearing a work uniform), and on work-related trips or events including social events.
3.2 The following forms of discrimination are prohibited under this policy and are unlawful:
a) Direct discrimination: treating someone less favourably because of a Protected Characteristic. For example, rejecting a job applicant because of their religious views or because they might be gay.
b) Indirect discrimination: a provision, criterion or practice that applies to everyone but adversely affects people with a particular Protected Characteristic more than others, and is not justified. For example, requiring a job to be done full-time rather than part-time would adversely affect women because they generally have greater childcare commitments than men. Such a requirement would be discriminatory unless it can be justified.
c) Harassment: this includes sexual harassment and other unwanted conduct related to a Protected Characteristic, which has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Harassment is dealt with further in our Anti-harassment and Bullying Policy.
d) Victimisation: retaliation against someone who has complained or has supported someone else’s complaint about discrimination or harassment.
e) 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. INDEPENDENT SERVICE PROVIDERS AND SUPPLIERS

4.1 Any decisions regarding the suitability of suppliers and contractors, agents or other third parties to provide goods or services to H2O, or to our clients, will be made in accordance with this policy and never on the basis of any of the Protected Characteristics.
4.2 All suppliers, independent contractors, agents, or other third parties instructed by H2O, whether for itself or on behalf of clients, will be made aware of this policy and the need to adhere to it. Failure of any supplier, contractor, agent or other third party or of any of its staff to adhere to the principles set out in this policy or to carry out any discrimination on unlawful grounds will be investigated and appropriate action taken which may include immediate termination of our relationship with them.

5. RECRUITMENT AND SELECTION

5.1 Recruitment, promotion, and other selection exercises, such as redundancy selection, will be conducted on the basis of merit, against objective criteria, that avoids discrimination. Shortlisting should be done by more than one person if possible.
5.2 Vacancies should generally be advertised to a diverse section of the labour market. Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying. They should include a short policy statement on equal opportunities and a copy of this policy will be made available on request.
5.3 Job applicants should not be asked questions which might suggest an intention to discriminate on grounds of a Protected Characteristic. For example, applicants should not be asked whether they are pregnant or planning to have children.
5.4 Job applicants should not be asked about health or disability before a job offer is made, except in the very limited circumstances allowed by law: for example, to check that the applicant could perform an intrinsic part of the job (taking account of any reasonable adjustments), or to see if any adjustments might be needed at interview because of a disability. Where necessary, job offers can be made conditional on a satisfactory medical check. Health or disability questions may be included in equal opportunities monitoring forms, which must not be used for selection or decision-making purposes.

6. DISABILITIES

6.1 If you are disabled or become disabled, we encourage you to tell us about your condition. Whilst we are under no obligation to make reasonable adjustments, we can consider how we may support you providing services to us.

7. PART-TIME AND FIXED-TERM WORK

7.1 Part-time and fixed-term employees will be treated the same as comparable full-time or permanent employees and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate) unless different treatment is justified.

8. BREACHES OF THIS POLICY

8.1 We take a strict approach to breaches of this policy, which will be dealt with either:

a) in accordance with our Disciplinary Procedure for employees; or

b) by terminating any contract in place with service providers or suppliers.

Serious cases of employees deliberately discriminating against any other person may amount to gross misconduct resulting in dismissal.
8.2 If you suspect or believe that you, or another have suffered discrimination:
8.2.1 Employees can raise the matter through their line manager subject to our Grievance Procedure; or
8.2.2 Any other Service Provider, Consultant, visitor or other affected third party can raise their concerns in writing to compliance@h2ologistics.co.uk.
All complaints will be treated in confidence and investigated as appropriate.
8.3 You must not be victimised or retaliated against for complaining about discrimination. However, making a false allegation deliberately and in bad faith will be treated as wrongdoing and dealt with as appropriate.

Anti Bribery & Corruption

1. ABOUT THIS POLICY

1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
1.2 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any Service Provider or supplier who breaches this policy may have their contract terminated with immediate effect.
1.3 This policy does not form part of any employee’s or worker’s contract of employment or engagement and we may amend it at any time.

2. WHO MUST COMPLY WITH THIS POLICY?

2.1 This policy applies to all persons working for, or providing services to us, or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

3. WHAT IS BRIBERY?

3.1 ‘Bribe’ means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
3.2 ‘Bribery’ includes offering, promising, giving, accepting, or seeking a bribe.
3.3 All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with a representative of the Management Team either in person or by email to compliance@h2ologistics.co.uk.
3.4 Specifically, you must not:
a)   give or offer any payment, gift, hospitality, or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
b)   accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
c)   give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;
3.5 You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

4. GIFTS AND HOSPITALITY

4.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
4.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
4.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.
4.4 Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers, and business partners.

5. RECORD-KEEPING

5.1 You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
5.2 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

6. HOW TO RAISE A CONCERN

6.1 If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify a representative of the Management Team either in person or by email to compliance@h2ologistics.co.uk.