Policy

Equality, Diversity and Inclusion Policy

1. Introduction

WagePerks Ltd ("the Company") is committed to promoting equality, valuing diversity, and fostering an inclusive working environment in which all individuals are treated with dignity and respect. We believe that a diverse workforce, reflecting the communities we serve, strengthens our business and enhances the quality of our services.

This policy sets out the Company's approach to equality, diversity, and inclusion and the standards of behaviour expected of all Personnel.

2. Legal Framework

This policy is underpinned by the Equality Act 2010, which provides a comprehensive legal framework for protecting the rights of individuals and advancing equality of opportunity. The Act prohibits discrimination, harassment, and victimisation in employment and the provision of services.

The Company is also guided by:

  • The Human Rights Act 1998.
  • The Employment Rights Act 1996.
  • The Part-Time Workers (Prevention of Less Favourable Treatment) Regulations 2000.
  • The Fixed-Term Employees (Prevention of Less Favourable Treatment) Regulations 2002.
  • The Agency Workers Regulations 2010.
  • The Public Sector Equality Duty (Section 149, Equality Act 2010), applied as a matter of good practice.

3. Scope

This policy applies to all directors, employees, workers, contractors, agency staff, consultants, and any other person engaged by or acting on behalf of WagePerks Ltd ("Personnel").

It covers all aspects of employment, including:

  • Recruitment and selection.
  • Terms and conditions of employment.
  • Training and development.
  • Promotion and career progression.
  • Pay and benefits.
  • Working conditions and arrangements.
  • Disciplinary and grievance procedures.
  • Termination of employment.

The policy also applies to the Company's dealings with clients, users of the WagePerks platform, suppliers, and the general public.

4. Protected Characteristics

Under the Equality Act 2010, it is unlawful to discriminate against any person on the basis of the following protected characteristics:

  • Age -- a person's age or age group.
  • Disability -- a physical or mental impairment that has a substantial and long-term adverse effect on a person's ability to carry out normal day-to-day activities.
  • Gender reassignment -- where a person is proposing to undergo, is undergoing, or has undergone a process to reassign their sex.
  • Marriage and civil partnership -- being married or in a civil partnership.
  • Pregnancy and maternity -- being pregnant, having given birth, or being on maternity leave.
  • Race -- colour, nationality, ethnic origin, or national origin.
  • Religion or belief -- any religion, religious or philosophical belief, or lack of religion or belief.
  • Sex -- being male or female.
  • Sexual orientation -- a person's sexual orientation towards persons of the same sex, the opposite sex, or both.

WagePerks Ltd will not tolerate discrimination, whether direct or indirect, on any of these grounds.

5. Forms of Prohibited Conduct

5.1 Direct Discrimination

Treating a person less favourably than another person because of a protected characteristic. This includes discrimination by association (treating someone less favourably because of their association with a person who has a protected characteristic) and discrimination by perception (treating someone less favourably because they are perceived to have a protected characteristic).

5.2 Indirect Discrimination

Applying a provision, criterion, or practice that applies to everyone equally but puts persons sharing a protected characteristic at a particular disadvantage, unless it can be objectively justified as a proportionate means of achieving a legitimate aim.

5.3 Harassment

Unwanted conduct related to a protected characteristic that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment. This includes sexual harassment and less favourable treatment because of a person's rejection of or submission to harassment.

5.4 Victimisation

Subjecting a person to a detriment because they have, in good faith, made a complaint of discrimination, assisted another person in making such a complaint, given evidence in connection with a complaint, or taken any other action under or by reference to the Equality Act 2010.

6. Recruitment and Selection

WagePerks Ltd is committed to ensuring that recruitment and selection processes are fair, transparent, and free from discrimination.

  • All job vacancies are advertised in a manner that encourages applications from a diverse range of candidates.
  • Job descriptions and person specifications are based on genuine occupational requirements and do not include criteria that could directly or indirectly discriminate against persons with a protected characteristic.
  • Selection decisions are based solely on merit, assessed against objective, job-related criteria.
  • Interview panels receive training in equality and diversity and the avoidance of unconscious bias.
  • Reasonable adjustments are made to the recruitment process for candidates with disabilities, as required by the Equality Act 2010.
  • We do not ask health-related questions before offering employment, except where permitted by law (for example, to determine whether reasonable adjustments are needed for the recruitment process).

7. Promotion and Career Development

  • Decisions regarding promotion and career development are based on merit and objective criteria.
  • All Personnel have equal access to training, development, and progression opportunities.
  • We actively identify and seek to remove barriers to progression that may disproportionately affect persons with particular protected characteristics.
  • We support flexible working arrangements, including part-time working, job sharing, and remote working, to support the participation and progression of all Personnel.

8. Pay and Benefits

  • We are committed to providing equal pay for equal work, in compliance with the Equality Act 2010.
  • We regularly review our pay practices to identify and address any unjustified pay gaps.
  • All Personnel have equal access to the Company's benefits and reward programmes.
  • The employee benefits delivered through the WagePerks platform are made available to eligible employees on an equal basis, regardless of protected characteristics.

9. Reasonable Adjustments

Under the Equality Act 2010, the Company has a duty to make reasonable adjustments for employees and applicants with disabilities. This may include:

  • Adjustments to the physical working environment, such as accessible facilities, ergonomic equipment, or modified workstations.
  • Adjustments to working arrangements, such as flexible hours, modified duties, or additional breaks.
  • Provision of auxiliary aids, such as assistive technology or communication support.
  • Adjustments to policies and procedures that may place a disabled person at a disadvantage.

Personnel who require reasonable adjustments are encouraged to discuss their needs with their line manager or the HR department. All requests will be considered sympathetically and in confidence.

10. Harassment and Bullying

10.1 Zero Tolerance

WagePerks Ltd has zero tolerance for harassment and bullying. All Personnel are entitled to a working environment free from intimidation, hostility, and offensive behaviour.

10.2 Examples of Unacceptable Behaviour

The following are examples of behaviour that may constitute harassment or bullying. This list is not exhaustive:

  • Unwelcome physical contact, ranging from unnecessary touching to assault.
  • Offensive or derogatory comments, jokes, or banter related to a protected characteristic.
  • Display or circulation of offensive material, whether in physical or electronic form.
  • Exclusion, isolation, or ostracism of a person or group.
  • Intrusive questions or comments about a person's private life, identity, or protected characteristics.
  • Persistent, unjustified criticism, undermining, or belittling of a person.
  • Threats, intimidation, or abuse of authority.

10.3 Reporting and Resolution

Any person who experiences or witnesses harassment or bullying is encouraged to report it through any of the following channels:

  • Their line manager or another manager they trust.
  • The HR department.
  • The Company's whistleblowing procedure.

All complaints will be taken seriously, investigated promptly and thoroughly, and dealt with in confidence so far as is practicable. Where a complaint is upheld, appropriate disciplinary action will be taken, which may include dismissal for serious cases.

No individual will be subjected to detriment for raising a genuine complaint of harassment or bullying or for assisting in an investigation.

11. Training

The Company provides equality, diversity, and inclusion training to all Personnel:

  • Induction training is provided to all new Personnel, covering the Company's policies, legal obligations, and expected standards of behaviour.
  • Annual refresher training ensures that awareness remains current.
  • Manager training includes guidance on handling discrimination complaints, conducting fair recruitment, and promoting inclusive team culture.
  • Unconscious bias training is provided to all Personnel involved in recruitment, selection, and management decisions.

12. Monitoring and Reporting

The Company monitors the effectiveness of this policy by:

  • Collecting and analysing anonymised workforce diversity data, with appropriate consent and in compliance with the UK GDPR.
  • Reviewing recruitment, promotion, and training data to identify potential barriers or disparities.
  • Monitoring the number and outcomes of discrimination, harassment, and bullying complaints.
  • Reporting on equality, diversity, and inclusion performance to the Board of Directors.

Data is collected on a voluntary basis and is used solely for the purpose of monitoring and improving equality outcomes. All data is processed in accordance with the UK GDPR and the Data Protection Act 2018.

13. Responsibilities

13.1 The Board of Directors

The Board has overall responsibility for this policy and for ensuring that the Company meets its legal obligations and commitments in relation to equality, diversity, and inclusion.

13.2 Managers

All managers are responsible for:

  • Promoting an inclusive culture within their teams.
  • Ensuring that this policy is applied in all employment decisions.
  • Addressing any discriminatory behaviour or practices promptly.
  • Supporting Personnel who raise concerns about equality and diversity.

13.3 All Personnel

All Personnel are responsible for:

  • Treating colleagues, clients, and third parties with dignity and respect.
  • Complying with this policy and the law.
  • Reporting any concerns about discriminatory behaviour.
  • Participating in equality, diversity, and inclusion training.

14. Breaches

Any breach of this policy will be treated as a disciplinary matter and may result in disciplinary action up to and including dismissal. Serious acts of discrimination, harassment, or victimisation may also constitute criminal offences and may be referred to the relevant authorities.

15. Review

This policy is reviewed annually by the Board of Directors to ensure it remains effective and aligned with legal requirements and best practice.

Policy Owner: Board of Directors, WagePerks Ltd

Last Reviewed: April 2026

Registered in Scotland