Equal Opportunities Policy

1. General

The purpose of this policy statement is to emphasise the commitment of Moongroup to securing fair and equal consideration of applications by persons seeking to be employed by the Group and fair and equal treatment of persons who are so employed. The statement affirms that Management will rigorously pursue the objectives and principles set out in the statement and be committed to promoting equality of opportunity and fair participation within the Group.

It is the policy of the Group that all eligible persons will have equal opportunity for employment and advancement in the Group, irrespective of perceived religious belief, political opinion, gender, disability or race. Selection for employment and advancement will be on the basis of ability, qualifications and aptitude to carry out the duties of the post. There will be no unlawful discrimination, direct or indirect, against any person in recruitment, training, promotion or in any other way.

Management should be aware of the forms which unlawful discrimination can take, guard against them and avoid any action which might influence others to discriminate unlawfully.

2. Legal Framework

There is a legal framework to protect individuals from unlawful discrimination. This statement is designed to build on the statutory position and to reflect the spirit as well as the letter of the legislation. The existence of law and agreed procedures cannot of themselves ensure that any policy of non-discrimination will work effectively. This will be achieved only when officers at all levels critically examine their attitudes to people and ensure that no trace of unlawful discrimination is allowed to affect their judgement.

The Group recognises its obligations under the Fair Employment Acts (NI) 1976 and 1989, the Sex Discrimination (NI) Orders 1976 and 1988, the Equal Pay Act (NI) 1970 as amended and the Disabled Persons (Employment) Acts (NI) 1945 and 1960.

2.1 Unlawful Discrimination

Unlawful discrimination means acting in such a way as to place at a disadvantage or treat unlawfully any individual because of factors which are irrelevant in any respect of the employment relationship. Direct discrimination means treating a person less favourably on the grounds of religion, political opinion, sex, marital status, disability, race, or any other criterion which is not relevant or justified in law. Indirect discrimination occurs where a requirement or condition which is not relevant or justified in law is applied equally, but is of such a nature as to be unfavourable for particular groups in that a considerably smaller proportion of the group can comply with it.

Victimisation means treating a person less favourably because they have made or intend to make a complaint or may have assisted an individual in asserting their rights under the Fair Employment, Sex Discrimination or Equal Pay legislation. Individuals have a legal right to make a complaint without prejudice to their existing, potential or future employment opportunities.

Harassment means any behaviour, deliberate or otherwise which is offensive to an individual or group and which may threaten an officer’s job security or create an intimidating work environment. There are more subtle and unconscious forms of unlawful discrimination which may not easily be identified. These may result from general assumptions about the capabilities, characteristics and interests of particular groups or individuals which influence the way in which they are treated; they may also take the form of applying conditions or requirements, without considering whether they operate disproportionately to the disadvantage of particular groups.

3. Recruitment And Promotion

As an Equal Opportunity Employer the Group will endeavour to reach the widest possible labour market. Public advertisements and internal trawls will not indicate, or appear to indicate, an intention to discriminate in selection for recruitment, promotion or transfer. Nothing will be stated which might be interpreted as reflecting any form of discrimination. Public advertisements will not be confined unjustifiably to geographical areas or media publications which would exclude or disproportionately reduce the number of applicants from a particular group.

A statement promoting the group Equal Opportunities policy will be included in all advertisements.

Opportunities to obtain information on careers within the Group will be readily available to all existing and potential officers. Eligibility criteria and tests used for recruitment or promotion must be related to job requirements and will be non-discriminatory. Eligibility criteria will be stated in public advertisements and internal trawls. Criteria and tests will be reviewed to ensure that they do not have a disproportionate impact on particular groups or individuals. Selection panels will, where possible, consist of male and female members and be representative of both communities.

Selection panel decisions and reasons for such decisions will be recorded at each stage of the selection process. All documentation will be retained for a period of at least three years. All persons partaking or likely to partake in the selection process will receive training in equal opportunities with regard to recruitment and selection interviewing.

4. Career Development

Employees will be given equal opportunity in training and development to enable them to acquire necessary skills and give them the opportunity to achieve their full potential.

Staff Appraisal

When carrying out staff appraisal, appraisers will objectively assess the individual’s capabilities, performance and potential. Appraisal reports will not reflect any assumptions or prejudices of the appraisal officer about the appraisee.

5. Complaints Of Unlawful Discrimination

The Group’s grievance procedure is available to all employees. Where complaints arise relating to unacceptable conduct of a sexual nature the procedures laid down in the Code of Practice on measures to combat sexual harassment in the work place should be utilised. Persons who believe they have been unlawfully discriminated against in appointment, promotion and training etc, should in the first instance raise the matter with the Office Manager or Equal Opportunities Unit of the Group.

If they are not satisfied with the outcome they may seek advice and assistance as follows:

• In matters of unlawful discrimination on grounds of sex or marital status
• Equal Opportunities Commission
• In matters of unlawful discrimination grounds of religious belief or political opinion
• Fair Employment Commission
• Injustice as a result of maladministration
• The Commissioner for Complaints

Individuals should check with the statutory agencies regarding time limits within which complaints should be lodged. It is the policy of the Group that an employee who makes a complaint in respect of alleged unlawful discrimination or maladministration will not be subject to any form of victimisation. Acts of discrimination, victimisation or harassment perpetrated by an officer of the Group against any other officers will result in disciplinary action. It should be noted that complaints can also be brought against individuals as well as the group.

6. Implementation

The Managing Director of the Group is responsible for ensuring that the policy statement is implemented and reviewed on a regular basis. The Office Manager is responsible for monitoring, co-ordinating and developing the policy through the group’s equal opportunities unit. Line managers are responsible for ensuring that all officers for whom they have responsibility are aware of the group’s policy on equal opportunity and that there is no unlawful discrimination of any kind. All employees of the group have a responsibility to accept personal involvement in the Application of the Equal Opportunities Policy. A copy of this statement will be issued to all employees and a summary to all potential applicants for employment. Its aims and objectives will be reflected as appropriate in training courses, circulars and guidance to recruitment and promotion panels and will be included in careers literature and job advertisements.

Monitoring

The composition of officers, applicants for employment and the appointees will be monitored on the basis of sex, marital status, perceived religious affiliation and disability to measure the effectiveness of this policy. Monitoring provides an objective view on the existence and progress of equality of opportunity.

7. Regular Review

The group is committed to a process of consultation with staff representatives on the policy and practices outlined in this statement. These will be regularly reviewed to ensure that the group’s objectives on equality of opportunity are assessed and such affirmative action as is deemed lawful, appropriate and necessary will be taken.

8. Agreement

This policy statement has been agreed by the Group.