Version 4 – October 2025
Policy Aims
Stonegate is made up of brilliant people. Each of us is unique, and we value the differences our colleagues bring. We are committed to providing equal opportunities to all colleagues regardless of personal status and to prohibiting all forms of discrimination, harassment and bullying.
What’s Covered
- Roles and Responsibilities
- Definitions
- Our Commitment to You
- What We Expect from You
- Discrimination
- Bullying and Harassment
- Recruitment and Selection
- Complaints
Definitions
- Direct Discrimination: Treating someone less favourably because of a protected characteristic.
- Indirect Discrimination: Applying a rule or practice that puts those with a protected characteristic at a disadvantage.
- Associative Discrimination: Discriminating against someone because they associate with a person with a protected characteristic.
- Perceptive Discrimination: Discriminating against someone because you believe they have a protected characteristic.
- Discrimination Arising from Disability: Treating someone unfavourably because of something linked to their disability.
- Reasonable Adjustment: A change made to reduce or remove disadvantage caused by disability.
- Harassment: Unwanted conduct related to a protected characteristic that violates dignity or creates an offensive environment.
- Bullying: Behaviour that intimidates, humiliates or causes harm, without needing a link to a protected characteristic.
- Third Party: Anyone not employed directly by Stonegate, such as contractors, guests, suppliers, DJs or auditors.
Roles and Responsibilities
Stonegate
We are committed to a culture free from bullying, harassment and discrimination.
Colleagues
Colleagues must comply with this policy and foster a culture of inclusivity, showing dignity and respect to all colleagues, guests and third parties.
Line Managers
Line managers must uphold this policy, prevent discrimination, and handle complaints sensitively in accordance with Grievance and Disciplinary procedures.
HRBP (PST)
Available to provide advice to colleagues who witness or experience discrimination, harassment or bullying.
ER Support / HRBP (Ops)
Available to provide guidance to colleagues and line managers regarding discrimination, bullying or harassment.
Our Commitment to You
We are committed to promoting an environment based on dignity, respect and trust, free from discrimination, harassment and bullying. We do not tolerate any form of discrimination on the grounds of the following protected characteristics:
- Gender
- Marital status
- Sexual orientation
- Gender reassignment
- Pregnancy or maternity
- Ethnic origin
- Religion or belief
- Disability
- Age
What We Expect from You
Colleagues are expected to take responsibility for upholding this policy and treating everyone with dignity and respect. This includes acknowledging different viewpoints, valuing contributions and ensuring behaviours are always free from discrimination, harassment or bullying.
Any colleague found to have committed, authorised or condoned such behaviour will face disciplinary action.
Discrimination
Discrimination is prohibited based on the protected characteristics listed above. Types include:
Direct Discrimination
Treating someone less favourably because of a protected characteristic.
Associative Discrimination
Treating someone less favourably because they are associated with someone who has a protected characteristic.
Indirect Discrimination
Applying a rule or policy that disadvantages people with a protected characteristic without justification.
Perceptive Discrimination
Treating someone less favourably because you believe they have a protected characteristic, even if they do not.
Discrimination Arising from Disability
Treating someone unfavourably because of something connected to their disability and where such treatment is unjustified.
Harassment, Sexual Harassment and Bullying
Harassment
Unwanted conduct which has the purpose or effect of violating dignity or creating an offensive environment. This can be related to protected characteristics and can be a one-off event or a series of incidents.
Sexual Harassment
Conduct of a sexual nature that violates dignity or creates an intimidating, hostile or offensive environment. It also includes treating someone unfavourably because they rejected sexual advances.
Failure to Make Reasonable Adjustments
Failing to remove or minimise disadvantage for disabled colleagues, such as refusing equipment or adjustments.
Victimisation
Treating someone detrimentally because they made or supported a discrimination or harassment complaint.
Bullying
Offensive, malicious, intimidating or insulting behaviour. It may be face-to-face or through digital channels.
Recruitment and Selection
Discrimination is not permitted during recruitment and selection. Decisions will be based on objective, non-discriminatory criteria.
Equality and diversity information collected during applications is anonymised and not accessible to hiring managers.
Managers involved in recruitment will receive appropriate training to ensure fair and consistent decision-making.
Reasonable Adjustments
We will make reasonable adjustments for applicants with disabilities, assessed on an individual basis. Examples include:
- Accessible interview locations or virtual interviews
- Providing interview questions in advance
- Extra time for assessments or interviews
- Adjusting lighting, noise or temperature
Consequences of Non-Compliance
Any colleague who breaches this policy may face disciplinary action up to and including dismissal, in accordance with the Disciplinary Policy. Serious acts of harassment may also constitute a criminal offence.
Complaints
Treatment of Discrimination
Colleagues with concerns should speak to a line manager, their manager’s manager or the relevant HRBP or ER Support. Formal complaints should be raised through the Grievance Procedure.
How to Deal with Complaints
Many colleagues do not initially complain due to embarrassment or fear of not being believed. Any concerns will be taken seriously. Speaking informally to a trusted colleague or manager may help provide perspective.
If you wish to make a formal complaint, use the Grievance Procedure. Managers consulted informally must seek advice from HRBP or ER Support.
The Law
This policy complies with the following legislation:
- The Equality Act 2010
- The Employment Rights Act 1996
- Worker Protection (Amendment of Equality Act 2010) 2023
External Support
- Licensed Trade Charity: 0808 801 0550
- National Bullying Helpline
- Victim Support
Supporting Policies
This policy should be read in conjunction with:
- Grievance Policy
- Disciplinary Policy
- Bullying and Harassment Policy
- Whistle-blowing Policy
- Code of Conduct
- Social Media Policy
- Socialising at Stonegate Policy
- Menopause Policy
- Absence Policy
Monitoring and Review
This policy is reviewed annually and amended where necessary. We analyse data relating to bullying or harassment allegations (in line with data protection obligations) to monitor policy effectiveness and support our inclusion strategy.
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Discrimination Disability Neurodiversity Pregnancy Race Pregnant Religion Age Gender Gay Lesbian Bisexual Gender neutral Gender fluid Transexual Transition Marriage Dyslexic ADHD Asperger's Autistic LGBTQIA Sex Belief Inclusive
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