1. Statement of Policy
- DPI is committed to promoting equality and diversity as well as a culture that actively values difference and recognises that people from different backgrounds and experiences can bring valuable insights to the workplace and enhance the way we work.
- We recognise that discrimination is unacceptable, and equality of opportunity has been a long-standing feature of our employment practices and procedures, as we strive to recruit, develop and retain the most talented people.
- The aim of the policy is to ensure no job applicant, employee or worker is discriminated against either directly or indirectly on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation.
- This policy is not contractual however DPI intends to follow and implement its terms so far as possible at all times.
- We will ensure that the policy is circulated to any agencies responsible for our recruitment and a copy of the policy will be provided by the agencies to all candidates introduced to DPI.
- The policy will be communicated to all members of staff working for the Company in any manner (including employees, partners, workers, interns, placement students, agency workers, consultants, individual contractors and directors) reminding them of their responsibilities to follow the Company’s policy. The policy is also available on https://www.dpi-llp.com/equality-and-diversity-policy.
- This policy applies to every aspect of employment with DPI, including the advertising of jobs and recruitment and selection, to training and development, opportunities for promotion and career development, to conditions of service, terms and conditions of employment, benefits and pay, to health and safety and to conduct at work, to grievance and disciplinary procedures and to termination of employment.
- Breaches of the policy will lead to disciplinary proceedings and, if appropriate, disciplinary action.
- The policy will be implemented in accordance with the appropriate statutory requirements and full account will be taken of all available guidance and in particular any relevant Codes of Practice.
- DPI maintains a neutral working environment in which no member of staff, job applicant or visitor should feel under threat or intimidated. This policy applies to all conduct in the workplace and also to conduct outside of the workplace that is related to our work (e.g. at meetings, business events, social events and social interactions with colleagues or clients) or which may impact on DPI’s reputation (e.g. the expression of views on social media, contrary to the commitments expressed in this policy, that could be linked to DPI).
2. Equality and Diversity
- To DPI, equality means breaking down barriers, eliminating discrimination and ensuring equal opportunities and access for all groups in employment and to goods and services.
- To DPI, diversity means celebrating difference and valuing everyone. Each person is an individual with visible and non-visible differences. By respecting this everyone can feel valued for their contributions which is beneficial not only for the individual but for DPI too.
- We acknowledge that equality and diversity are not inter-changeable but inter-dependent. There can be no equality of opportunity if difference is not valued and harnessed.
- Every member of staff is entitled to a working environment that promotes dignity, equality and respect for all. DPI will not tolerate any acts of unlawful or unfair discrimination (including harassment or victimisation) committed against a member of staff, job applicant or visitor because of a protected characteristic namely:
- gender reassignment,
- marriage and civil partnership,
- pregnancy or maternity,
- race (including racial group, ethnic origin, colour, nationality and national origin),
- religion or belief,
- sex, or
- sexual orientation.
Discrimination on the basis of work pattern (part-time working, fixed term contract, flexible working) which is unjustifiable will also not be tolerated. See Appendix I for an explanation of the different forms of discrimination.
- No form of intimidation, bullying or harassment will be tolerated regardless of whether it is intentional or unintentional. If you believe that you may have suffered discrimination because of any of the above protected characteristics, you may wish to informally raise the matter with the person who has caused the concern, with a DPI Partner or your line manager, or though DPI’s formal procedures. Please refer to the Employee Handbook for DPI’s Personal Harassment Policy and Procedure and Grievance Policy.
- DPI works with organisations that promote the attraction and retention of women and minorities within private equity, such as SEO, PEWIN, Level20.
- Any colleague who is, after investigation, found to have provided false information or to have acted in bad faith in relation to a complaint under this policy, whether as complainant, witness or otherwise, will be subject to action under DPI’s disciplinary procedure.
3. Recruitment and Selection
- The recruitment and selection process is crucially important to any equal opportunities policy. Our goal is to ensure that different experiences, perspectives, skills, genders, ages, ethnicities and cultural and social backgrounds are represented across the Company, reflecting the investors we serve, the portfolio companies we partner with and the communities in which we conduct business.
- We will endeavour through appropriate training to ensure that employees making selection and recruitment decisions will not discriminate, whether consciously or unconsciously, in making these decisions.
- Job descriptions, where used, will be in line with our equality and diversity policy. Job requirements will be reflected accurately in any personnel specifications.
- Agencies will be encouraged to introduce a balanced mix of candidates reflecting the diverse nature of our business.
- We adopt a consistent, non-discriminatory approach to the advertising of vacancies.
- We will not confine our recruitment to areas or media sources which provide only, or mainly, applicants of a particular group.
- All applicants who apply for jobs with us will receive fair treatment and will be considered solely on their ability to do the job.
- All employees involved in the recruitment process will periodically review their selection criteria to ensure that they are related to the job requirements and do not unlawfully discriminate.
- Short listing and interviewing is carried out by more than one person where possible.
- Interview questions will be related to the requirements of the job and will not be of a discriminatory nature.
- We will not disqualify any applicant because he/she is unable to complete an application form unassisted unless personal completion of the form is a valid test of the standard of English required for the safe and effective performance of the job.
- Selection decisions will not be influenced by any perceived prejudices of other staff.
4. Training and Promotion
- Promotion and advancement will be made on merit and all decisions relating to this will be made within the overall framework and principles of this policy.
- Senior staff will receive training in the application of this policy to ensure that they are aware of its contents and provisions.
- All promotion will be in line with this policy.
- We will maintain and review the employment records of all employees in order to monitor the progress of this policy.
- Monitoring may involve:
- the collection and classification of information regarding the race in terms of ethnic/national origin and sex of all applicants and current employees;
- the examination by ethnic/national origin and sex of the distribution of employees and the success rate of the applicants; and
- recording recruitment, training and promotional records of all employees, the decisions reached and the reason for those decisions.
- The results of any monitoring procedure will be reviewed at regular intervals to assess the effectiveness of the implementation of this policy and our Data Protection policies. Consideration will be given, if necessary, to adjusting this policy to afford greater equality of opportunities to all applicants and staff.
- All members of staff have a responsibility to guard against any form of discrimination and avoid any action which goes against the spirit of this policy. Thus, all members of staff at all levels must ensure that there is no discrimination in any of their decisions or behaviour. This includes the provision that all staff must:
- report any suspected discriminatory acts or practices;
- not induce or attempt to induce others to practice unlawful discrimination;
- co-operate with any measures introduced to ensure equality of opportunity;
- not victimise anyone as a result of them having complained about, reported or provided evidence of discrimination;
- not harass, abuse or intimidate others.
- Those working at management level have a specific responsibility to set an appropriate standard of behaviour, to lead by example and to ensure that those they manage adhere to the policy and promote the aims and objectives of the Company with regard to equal opportunities.
Appendix I – Forms of Discrimination
The main forms of discrimination are listed below:
- Direct discrimination occurs where one person is treated less favourably than another because of a protected characteristic e.g. not promoting a pregnant employee on the basis that she is shortly due to go on maternity leave would be direct discrimination on the protected characteristic of the employee’s sex. Other types of direct discrimination are:
- Associative discrimination – this is direct discrimination against someone because they associate with another person who possesses a protected characteristic e.g. an employee is discriminated against because his child is disabled.
- Discrimination by perception – this is direct discrimination against someone because you think they possess a particular protected characteristic e.g. discrimination against someone because you think they are gay even if they do not actually possess that characteristic.
Both associative discrimination and discrimination by perception apply except in the case of marriage and civil partnership, or pregnancy and maternity. Unlike other forms of direct discrimination, direct discrimination because of age may be permitted if it can be shown to be for a good reason.
- Indirect discrimination occurs when a provision, criterion or practice is applied, which appears to be the same for all, but which has a disproportionate, adverse effect on one group of people even though there was no intention to discriminate e.g. a requirement for UK-based qualifications could disadvantage applicants who have obtained their qualifications outside of the UK and could result in indirect discrimination on the grounds of race. Such a rule will be indirectly discriminatory unless it can be objectively justified as a proportionate means of achieving a legitimate aim.
- Victimisation occurs when a member of staff is treated less favourably, disadvantaged or subjected to a detriment because they have made or supported a complaint of discrimination or raised a grievance under the Equality Act or DPI’s policies or because they are suspected of doing so. A member of staff is not protected from victimisation if they have maliciously made or supported an untrue complaint.
- Harassment is any form of unwanted conduct which occurs with the purpose or effect of violating the dignity of a person or creating an intimidating, hostile, degrading, humiliating, or offensive environment for the recipient. The intention behind the conduct is irrelevant. If conduct should reasonably be considered to have the effect described, it will be harassment. An alleged harasser might not always realise that his or her behaviour is found offensive, and it is important for everyone to recognise that what is acceptable to one colleague may not be acceptable to another, or may not be acceptable behaviour on other occasions or from a different colleague. Harassment also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past.