1. Introduction 

This policy outlines our commitment to adhering to all employment laws in the countries we operate, ensuring equality of opportunity for all who work for Illuminet and equal treatment of all our stakeholders our customers and suppliers in terms of employment and access to services; and to provide guidance on anti-discriminatory practice.  This policy is non-contractual. 

It is Illuminet’s policy to conduct all its business in an honest, transparent and ethical manner.  

This includes ensuring all employment is in compliance with all applicable laws and regulations of the countries in which Illuminet operates and effective systems and controls are in place to minimise the risk of slavery, human trafficking and use of child labour taking place in our business operations or supply chains.

2. General Principles 

The policy applies to employees directly employed by Illuminet, to workers employed via agencies, contractors in terms of employment, Trustees, and customers in terms of service provision.   

All employment must be in compliance with all applicable laws and regulations of the countries in which Illuminet operates. Where the applicable local laws and regulations require higher or additional levels of protection of human and employment rights than those set out in this Policy, the local laws and regulations will take precedence 

In relating to discrimination and equality of opportunity this policy reflects the ‘protected characteristics’ as defined in the UK Equality Act 2010: 

      (a) Age 

      (b) Disability 

      (c) Race 

      (d) Sex 

      (e) Religion or cultural beliefs 

      (f) Gender reassignment 

      (g) Marital status and civil partnership 

      (h) Sexual orientation 

      (i) Pregnancy and maternity 

The policy also reflects the principle that “All human beings are born free and equal in dignity and rights” as reflected in Article 1 of the United Nations Universal Declaration of Human Rights and the Human Rights Act 1998. 

The policy applies across the range of employment policies and practice, including those relating to Discipline, Grievance, Harassment and Complaints. 

3. Responsibilities 

We value our people and expect them to be treated in a respectful manner.  Accordingly, all have a responsibility to treat others with dignity and respect.  The Chief Executive Officer is responsible for providing advice and guidance on equality and diversity issues, and to ensure the Policy document is kept up to date.   

4. Aims 

As one of Illuminet core values is “Ethical Behaviour”, we aim to: 

• Promote equality of opportunity  
• Celebrate and value diversity 
• Eliminate unlawful direct and indirect discrimination 

We will provide equality of opportunity and equal treatment as an integral part of good practice.  The organisation is committed to a working environment in which the contribution and needs of everyone are fully valued and recognised.  We will support our people in not tolerating any inappropriate, violent or abusive behaviour from colleagues, other organisations or customers. 

5. General purpose 

Our practices will ensure that our people will not be discriminated against on any grounds including age, disability, race, sex, religion or cultural beliefs, gender reassignment, marital status and civil partnership, sexual orientation, pregnancy and maternity.   

Our commitment to anti-discriminatory practice relates to all kinds of discrimination, as set out in the Glossary. 

6. Employment Practices 

Our aim is to promote equality and diversity as an employer and to ensure that no job applicant or employee receives less favourable treatment or is disadvantaged by conditions or requirements that cannot be shown to be justifiable in the context of the policy.  Selection, recruitment, training, promotion and employment practices will be subject to regular review to ensure that they comply with the Diversity and Equalities Policy.  All training opportunities will be published widely to all appropriate employees and not in such a way so as to exclude particular groups. We regard discrimination, abuse, harassment, victimisation or bullying of staff, customers or others in the course of work as disciplinary offences that could be regarded as gross misconduct. 

We fully support the principle of equality and diversity. We aim to encourage, value and manage diversity and we recognise that talent and potential are distributed across the population. Not only are there moral and social reasons for promoting equality of opportunity, it is in the best interest of this organisation to recruit and develop the best people for our jobs from as wide and diverse a pool of talent as possible. 

We recognise that certain groups and individuals in society are oppressed and disadvantaged due to discrimination directed against them. We aim to remove any barriers, bias or discrimination that prevents individuals or groups from realising their potential and contributing fully to our organisation’s performance and to develop an organisational culture that positively values diversity. 

Discrimination operates through commonly held assumptions and prejudices, which are reinforced by laws, rules and customs.  This makes discrimination appear normal and inevitable. Discrimination works by stereotyping people into different roles, by treating some people worse than others, or simply by ignoring them. 

We are committed to opposing all forms of discrimination including that based on protected characteristics such as age, disability, gender reassignment, race (including colour, nationality, and ethnic or national origins), religion or belief, sex, sexual orientation, marriage or civil partnership, pregnancy and maternity.  This list is not exhaustive. 

Discrimination can be direct, associative, perceptive, indirect, harassment (including by 3rd parties) or victimisation.  (See glossary at end for definitions). All forms of discrimination are unacceptable, regardless of whether there was any intention to discriminate or not. Employees have a duty to ensure that this policy is effective in ensuring equal opportunities and in preventing discrimination. Employees should draw the attention of the CEO to suspected discriminatory acts or practices or cases of bullying or harassment or follow the Whistleblowing policy. 

We recognise our employee’s rights to freely and voluntarily establish and join organisations of their own choice and permit employees to negotiate terms of employment either individually or in organised groups such as trade unions. 

We ensure as a minimum all employers are paid within the rates defined for the National Living Wage.  

We recognise that the promotion of equal opportunities requires more than passive opposition to discrimination; we are therefore committed to taking positive action towards equality of opportunity.  We further recognise that the limited resources and the operational needs of the organisation may impose justifiable restrictions upon our ability to take such action. However, we will undertake regular monitoring and review the effectiveness of this Policy in line with new developments in Equality and Diversity best practice. 

7. Labour Standards 

Illuminet ensures the company complies with applicable laws and industry standards on working hours and holiday entitlements. For those roles where Working Time Directives are applicable, normal working hours will not exceed 48 hours per week averaged over 17 weeks, including overtime. Illuminet ensures that all employees have the legal right to be employed in the country where they work. 

We recognise our employee’s rights to freely and voluntarily establish and join organisations of their own choice and permit employees to negotiate terms of employment either individually or in organised groups such as trade unions. 

Illuminet will not engage in or support any discriminatory practices in hiring, remuneration, access to training, promotion, termination or retirement based on race, national or social origin, caste, religion, gender, sexual orientation, political affiliations, age or other conditions that could give rise to discrimination. We actively promote good practice in terms of eliminating discrimination in all forms including through appropriate recruitment advertisements or other literature. 

The company will treat all employees with dignity and respect and will not tolerate the use of mental or physical coercion, physical or verbal abuse, or any form of bullying and harassment of personnel, whether by its own staff or management, customers or suppliers. 

Illuminet will comply with national laws and regulations with regard to wages and benefits. All work-related activities are carried out on the basis of a recognised employment relationship established according to national law and practice. We ensure as a minimum all employees are paid within the rates defined for the UK National Living Wage or equivalent in other countries where we operate. 

The company operates formal Disciplinary and Grievance procedures in line with UK ACAS processes and commit to managing these processes in a fair and objective way. 

For details on Equality, Diversity and Human Rights, please reference the separate company policy. Detailed Conditions of Employment can be found in the Employment Handbook.

8. Anti-slavery, Human Trafficking and Child Labour 

8.1 Definitions

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.  

Child labour refers to the employment of children in any work that deprives children of their childhood, interferes with their ability to attend regular school, and that is mentally, physically, socially or morally dangerous and harmful. 

8.2 Policy 
Illuminet strictly prohibits the use of modern slavery, child labour or human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring these practices do not take place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.   

• We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.  
  
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf.  
  
• We do not employ or utilise in any manner any individual below the minimum employment age set by national law or by International Labour Organisation Convention 138. 
  
• Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.  
  
• Consistent with our policy we may require third parties to our organisation to confirm their compliance with relevant laws. 
  
• Workers are advised to notify a member of the company Exco immediately they have any concern, whether internal to the company or within the supply chain, notifying either directly or via the Whistleblowing process so that the Company can take appropriate action 
  
  

If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action.  This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships 

9. Gender Transition 

Transitioning is a term used to describe the process and steps an individual takes in order to live in the gender they identify as. Transitioning is a unique process for each individual and may include any number of changes to a person’s life. Illuminet is fully committed to support transitioning staff in the workplace as well as existing LGBTQ staff. 

The Illuminet HR NED is responsible for helping a transitioning employee manage his/her/their workplace transition and will work with the individual to plan and manage in line with the route the individual wants to take through the transition process, including the release of information in accordance with an agreed communications plan and engaging other members of the management team and wider colleagues as agreed. 

10. Legislation 

We will take all reasonable steps to ensure that we and our staff do not unlawfully discriminate under: 

• Employment Rights Act 1996  
  
• Human Rights Act 1998 
• Part-Time Workers (Prevention of Less Favourable Treatment) Regulations 2000  
• Fixed-Term Employees (Prevention of Less Favourable Treatment) Regulations 2002 
• Civil Partnership Act 2004  
• Work and Families Act 2006  
• Equality Act 2010 
• Race Relations Act 1976 
• Modern Slavery Act 2015 
• Employment of Children Act 1973 
• Disability Equality Duty 
• Gender Equality Duty 
• Racial equality code of practice for employment 
• Sex discrimination act 1975 
• Equal Pay act 1970 
• the Rehabilitation of Offenders Act 1974 
• Disability Discrimination Act (DDA) 1995 and; 
• any other relevant legislation in force from time to time or subsequently introduced and the equivalent legislation in countries within which we operate relating to discrimination. 

11. Training 

The Chief Executive Officer will ensure that all new employees will receive copies of this policy and are fully aware of their role to comply.  

12. Review 

The Board shall regularly monitor and evaluate the effectiveness of this policy in achieving the stated aims.  This process shall be undertaken at least annually, shall include the review of each component of the policy, and shall aim to seek the views of organisations representing the interests of those groups referred to in this policy.

13. Complaints and Sanctions 

We will treat seriously any complaints of unlawful discrimination on any of the stated grounds made by employees, clients or other third parties and will take action where appropriate. 

14. Glossary 

Definition of types of discrimination: 

Freedom of Association 

The right of employees to establish and join organisations which are designed to engage in collective bargaining and other initiatives to further and defend the interests of the workforce. 

Protected Characteristics  

The protected characteristics as listed in the Equality Act 2010 are sex, sexual orientation, marriage or civil partnership, gender reassignment, race, religion or belief, age, disability, pregnancy and maternity. 

Disability 

Under the Equality Act 2010, a person is disabled if they have a physical or mental impairment which has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities. 

Gender reassignment 

A transsexual person is someone who proposes to, starts or has completed a process to change his or her gender.  The person does not have to be under medical supervision. 

Human Rights  

The universal rights that every human being is entitled to enjoy and to have protected, most appropriately defined as those rights that require us to treat others as we ourselves would want to be treated, and which protect us – as individuals and groups – from abuses of power. 

Race 

Race includes colour, nationality and ethnic or national origins.  A racial group can be made up of two or more different racial groups. 

Religion or belief 

Under the Equality Act 2010, religion includes any religion. It also includes lack of religion, in other words employees or jobseekers are protected if they do not follow a certain religion or have no religion at all. Additionally, a religion must have a clear structure and belief system. Belief means any religious or philosophical belief or a lack of such belief. To be protected, a belief must satisfy various criteria, including that it is a weighty and substantial aspect of human life and behaviour.  

Sexual orientation 

Includes bisexual, gay, heterosexual, and lesbian people. 

Direct discrimination 

Direct discrimination occurs when someone is treated less favourably than another person because of a protected characteristic they have or are thought to have (see perceptive discrimination below), or because they associate with someone who has a protected characteristic (see associative discrimination below). 

Associative discrimination 

This is direct discrimination against someone because they are linked or associated with another person who possesses a protected characteristic.  

Perceptive discrimination 

This is direct discrimination against an individual because others think they possess a particular protected characteristic. It applies even if the person does not actually possess that characteristic. 

Indirect discrimination 

Indirect discrimination can occur when you have a condition, rule, policy or even a practice in your company that applies to everyone but particularly disadvantages people who share a protected characteristic and which cannot be justified in relation to the job. 

Harassment 

Harassment is “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, degrading, humiliating or offensive environment for that individual”. 

Third party harassment 

Harassment of employees by people (third parties) who are not employees of your company, such as clients.  We have a duty to prevent harassment and may be liable if aware that harassment has occurred on at least two previous occasions and does not take reasonable steps to prevent it from happening again. 

Victimisation 

Victimisation occurs when an employee is treated badly because they have made or supported a complaint about discrimination or harassment or raised a grievance under the Equality Act; or because they are suspected of doing so.  An employee is not protected from victimisation if they have maliciously made or supported an untrue complaint. 

Positive action 

Some people with protected characteristics are disadvantaged or under-represented in some areas of life, or have particular needs linked to their characteristic. They may need extra help or encouragement if they are to have the same chances as everyone else.  The new positive action provisions held within the Equalities Act 2010 enable service providers to take proportionate steps to help people overcome their disadvantages or to meet their needs.