Equality, Diversity & Inclusion Policy


We do not tolerate discrimination or harassment in any part of 2 Start Limited’s (2 Start) operations. We are fully committed to promoting equal opportunities and diversity in employment and education.

So, this policy covers any and all aspects of our company operations, how we treat those who work for and with us and how we recruit or engage others to join that community.

This means that our policy covers, but is not limited to, the following:

Pay and your employment conditions.

Our recruitment processes for both apprentices and employees

How we may appraise, reward, incentivise, promote, train, and commit to the continuing professional development of our workers, employees and apprentices

Our procedures for addressing grievances and disciplinary matters.

How we end employment contracts and exit employees, including related matters, such as how we give references

How visitors, clients and suppliers and other key business contacts and stakeholders are treated.

It also means that we will ensure, as far as possible:

full access to everyone applying for job vacancies and job opportunities with our business, and that all relevant decisions are made on the basis of objective criteria.

You should familiarise yourself with this policy and all 2 Start’s other policies, including, in particular our Grievance Policy and our Harassment and Bullying Policy.

Scope and Context

This policy relates to all activities of 2 Start.

All references to “learners” below should be recognised as pertaining to “apprentices” and vice versa.

This policy includes all training provision provided by 2 Start.

This Policy relates to all aspects of employment and academic life, including (but not limited to) advertisement, marketing, events, recruitment and selection, benefits, disciplinary and grievance, assessment and pedagogy practices.

This policy shall apply to all interactions with 2 Start, including, but not limited to:

  • Advertisement of vacancies for employment or apprenticeship
  • Assessment and selection of candidates for employment or selection
  • Agreement of contractual terms.
  • The employee life cycle including promotion and development.
  • The apprentice life cycle including opportunities for placement.

For the avoidance of doubt, “employee” shall include contractors, volunteers, those in paid employment with 2 Start and those applying to employment with 2 Start.

“Learner” or “Apprentice” shall denote any learner on a programme with 2 Start or applying to a programme.

Commitment Statement

2 Start Ltd committed to eliminating discrimination and encouraging diversity and inclusion amongst our own staff, learners, apprentices, visitors and associates. Our aim is that our staff are truly representative of all sections of society and that each employee, learner, apprentice and visitor feels respected and able to contribute to the best of their ability.

2 Start strongly opposes all forms of unlawful and unfair discrimination. All personnel, whether part-time, full-time or temporary, and learners and visitors to all premises, are treated fairly and with respect.

Policy Aim and Objectives

The aim of this policy is to create a culture of fairness, equality, diversity and inclusion, free from bullying, harassment, victimisation and unlawful discrimination, that promotes dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued.

This will be achieved by:

Creating an environment in which individual differences and the contribution of all staff, learners and visitors are recognized and valued

Ensuring every person is welcomed into an environment which promotes dignity, respect and tolerance; with no form of intimidation, bullying or harassment being acceptable

Ensuring that training, development and progression opportunities are available to all staff

Promoting the understanding that equality in the workplace is viewed as good management practice and makes sound business sense.

Training managers and all other employees about their rights and responsibilities under the equality, diversity and inclusion policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination.

Educating staff that they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public.

Taking seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities. This includes engaging apprentice employers to do the same.

Embedding principles of equality, diversity, inclusion and acceptance within all curricula.



Under UK employment law, there are a number of characteristics relevant to an individual who is covered by the policy that must not unfairly be considered (if accounted for at all) in decisions relating to any aspect of their working life.

These characteristics are called ‘protected characteristics’ and they are listed immediately below:

  • Age
  • Disability
  • Gender reassignment
  • Marital or civil partnership status
  • Pregnancy or maternity
  • Race (which includes colour and ethnic/national origin)
  • Sexual orientation
  • Religion or belief
  • Sex

If employment-related (or educational) decisions are made about an individual on the basis (whether wholly or partially), of any of these protected characteristics, it is almost inevitable that unlawful discrimination will have taken place.

The sorts of actions that would fall into this category of unlawful and prohibited initiatives, include (but aren’t limited to) those set out below. These actions need not be intended or directly committed by someone (indirect responsibility may be sufficient for someone to have unlawfully discriminated) and an omission or failure to do something may be just as culpable as a positive action.

We will not tolerate their practice by anyone within or associated within our business:

Direct discrimination

When someone with a protected characteristic is treated less favourably than somebody else has or would have been in identical circumstances.

An example of this would be where an applicant for a job is rejected on grounds of their racial background. Further examples would be where a pregnant employee, or one with young children, is not promoted

Indirect discrimination

When a group of people with one of the protected characteristics is disadvantaged by a provision, criterion or practice that is applied to all staff (unless the treatment may be justified for a good business reason).

Examples of this would be:

Insisting, without good reason, that all staff must work full time, (which indirectly discriminates anyone with child-care responsibilities, women in particular)

Refusing to provide a room for reflection and prayer, which would discriminate against individuals practising certain faiths

Dismissing or not employing a woman because she is pregnant or of child bearing age


Covers hostile, humiliating, degrading, intimidating or similarly offensive treatment or conditions to which an individual with one or more protected characteristics is subjected. Any such actions deprive an individual of their dignity and violate them. We draw no distinction between actions that may be labelled as ‘joking’ and not intended to cause offence, and those that may have been more direct and premeditated in their delivery.

So, for example, in line with legal definitions, reflecting general standards of decency, we will regard any of the following as falling within the definition of harassment:

  • excluding colleagues and/or making them feel that they have no option but to exclude themselves
  • making lewd comments and/or displaying pornographic material
  • calling someone unkind, derogatory or otherwise unwelcome names or nicknames
  • making insensitive jokes, whether about someone directly, or the content of which would be evidently offensive to anyone with a protected characteristic

You should refer to our Bullying and Harassment Policy for a full list of the matters that we consider to be covered by this definition.


This has a particular meaning under UK employment law and it is narrower than an ordinary dictionary definition, covering the situation only where:

  • a worker has complained of discrimination (or harassment)
  • or has supported a fellow worker in making a complaint about these concerns and has then suffered reprisals from others, including those responsible for that worker’s employment prospects and working conditions.

Other discriminatory actions that are also prohibited

The UK’s employment law also identifies other actions that can be unlawful under the equality and diversity legislation.

Examples of these include:

  • Failing to make reasonable adjustments to minimise certain disadvantages suffered by a disabled employee (or job applicant)
  • Instructing another person (or applying pressure on them) to discriminate
  • Knowingly assisting somebody else when they carry out a discriminatory act
  • Discriminating against somebody believed to have a protected characteristic, whether or not they actually do, or because they associate with a third party who does.

Our procedures and approach to this policy

Duties and responsibilities

Overall responsibility for the effective implementation and operation of the policy lies with 2 Start’s management, specifically with the board of directors and our HR team. All managers are expected to lead by example and attain and maintain appropriate standards of behaviour within the teams they manage.

However, everyone who works in and with 2 Start is responsible for ensuring that this policy works to prevent the activities that it prohibits from taking place within our business.

Because we are a values-led business, this goes beyond the legal obligations that each one of us has, (and regardless of our job titles or how long any of us has worked for or with 2 Start).

However, you need to be aware that the breach of these legal obligations alone will mean that any individual can be found personally liable for unlawful discrimination where they have breached this policy and they will face disciplinary action by us and potentially other legal actions. This is because if you breach this policy, you may also make the Company liable for your actions, and both of us may have to pay compensation to anyone who claims against us.

We therefore expect you to take personal responsibility for adhering to this policy’s aims and commitments and for promptly and appropriately drawing any breaches of them to our attention.

We always welcome feedback on how we can best promote and ensure equality and diversity throughout 2 Start. Please let your manager or specify alternative if you have any ideas or would like to be involved in any of our existing initiatives.

Management Responsibilities

The overall responsibility for ensuring the effective implementation and operation of the arrangements will rest with the Directors.  Directors shall ensure that they and their staff operate within the policy and arrangements and that all reasonable and practical steps are taken to avoid discrimination.

Each manager will ensure that:

  • all their reports are aware of the policy, the arrangements and the reasons for the policy.
  • grievances concerning discrimination are dealt with fairly and as quickly as possible.
  • proper records are maintained.

Responsibilities: Staff and Apprentices

Whilst the overall responsibility for ensuring that there is no unlawful discrimination rests with management, the attitudes of staff and apprentices are crucial to the successful operation of fair practices. In particular, all members of staff and apprentices should:

  • comply with the policy and arrangements.
  • not discriminate in their day-to-day activities or induce others to do so.
  • not victimise, harass, or intimidate other staff or apprentices on the grounds specified in the policy.
  • inform their manager or tutor if they become aware of any discriminatory practice.
  • understand they act as ambassadors for the organisation and as such should positively promote this policy in their dealings with other employees, apprentices, employers of Apprentices and the public

All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation, and unlawful discrimination, in the course of their employment, against fellow employees, apprentices, suppliers and the public.

Staff and apprentices not complying with this policy should understand that their actions will be subject to investigation and may result in enforcement of the Staff or Apprentice Disciplinary Procedure.

Recruitment, Promotions and Identifying Candidates for Other Opportunities

In any selection process that we use within our business, whether we’re selecting interviewees for job opportunities, offering jobs, identifying individuals for promotion or considering other opportunities or necessities (like redundancy situations or apprentice assessment and enrolment), we will apply a rigorous, objective selection process using non-discriminatory criteria, as far as possible.

Some forms of discrimination may be justified, for example both direct and indirect age discrimination may be justified and lawful, if the less favourable treatment, criterion or practice amounts to a proportionate means of achieving a legitimate aim.

A legitimate aim must relate to a genuine business need on our part that is not related to age discrimination itself. For example, a legitimate aim potentially justifying age discrimination might include:

  • Economic factors such as business needs and efficiency;
  • The health, welfare and safety of the individual concerned (including the protection of young people or older workers);
  • The particular training requirements of the job.

All job adverts and opportunity announcements must be:

  • Discussed with and signed off by the HR Manager, one of whose responsibilities is to ensure that any advert is compliant with this policy
  • Located and/or circulated so as to reach as wide and diverse a pool of interested candidates as possible, and
  • Worded so as to encourage, as far as possible and reasonable, applications from individuals of all characteristics to apply – or, at the very least, so as not to discourage any individuals with protected characteristics from applying.

There may be circumstances where some indication of required skills (that do discriminate) is justified and where self-deselection is inevitable, for example, where the job vacancy is for a window cleaner who works at height, wearing abseiling harnesses. The job advert might specify that interested candidates must be willing and capable of abseiling to be considered for the job.

If you are involved in interviewing and or any other part of our recruitment process, you must never ask a job applicant about their health, attendance record, or whether they have a disability before making a job offer to them (except in very limited circumstances).

You can ask someone if they have any particular needs or requirements with which you can assist if they are coming to meet you for an interview. In certain limited cases, it may also be permitted to make a job offer conditional on a successful medical examination.

During interviews or other interactions with candidates for a role, you must not ask anything that might infer a bias against any candidate with one or more protected characteristics. So, for example, asking a candidate if they are married, intend to have children (or any more children), or whether their religion permits them to work at weekends, are strictly no-go zones.

If you are ever in doubt about what you can or must not say, or if you believe that a particular job vacancy needs a medical examination as part of the recruitment or onboarding process, you must check the position with the HR Manager.

Data Gathering

During any recruitment and onboarding process, we may ask questions that include some protected characteristics to help us monitor our diversity and how we are succeeding in our commitment to promote equal opportunities. Including health or disability questions in equal opportunities monitoring exercises is acceptable, but the data gathered must not be used for any employment-related decisions, such as whether to offer a role or opportunity to a particular candidate.

We may also record and analyse information about equal opportunities more generally within the workplace. We do this so that we can make sure this policy operates successfully. The data helps us to refine it, review the composition of our workforce, and to promote workplace equality.

When you join the Company, you give us consent to gather and process this data about you.

Promotion and Engagement of this Policy

A thorough induction is completed with all new employees, volunteers and contractors, that includes a review and acceptance of this policy. This induction also includes the completion of a mandatory training programme covering the practical implementation of this policy.

Learners and apprentices also complete a thorough induction which includes the review and acceptance of this policy.

Equality, diversity and inclusion activities and assessments are embedded into programmes to support learners to build skills, knowledge and behaviours that promote inclusivity and diversity.

Annual refresher training is completed by employees, in accordance with the 2 Start CPD Policy.

Employers are engaged around the concepts of this policy during initial meetings and required to accept the policy in full prior to signing Service Agreements.

Assessors discuss the policy at regular intervals with both employers and apprentices to determine the cultural penetration of the policy at the employer.

Equality and Diversity information of apprentices and employees is regularly provided to the Board of Directors and analysis conducted.

2 Start will utilise its social media platforms and newsletters to target and highlight areas of this policy to stakeholders.

The policy is available to all stakeholders via the 2 Start website and to employees internally via the intranet.

Information, advice and guidance to signpost staff and learners to appropriate additional support agencies is provided, if required

Handling Breaches and Enforcement

We take all allegations of breach and any breaches that we discover very seriously.

All allegations and/or suspicions of breach will therefore be thoroughly investigated.

Employees and apprentices have a right to pursue a complaint concerning discrimination or victimisation via the Grievance, Harassment or Appeals and Complaints Procedures as appropriate.  If the complaint is against the individual’s manager or tutor, the complaint should be raised with the next level of management.

Discrimination and victimisation are serious matters.  They will be treated as disciplinary offences and dealt with under the Disciplinary Procedure.

Anyone raising a concern about matters covered by this policy, who does so in good faith, will have our full support and co-operation in getting to the bottom of what has happened and any appropriate action that needs to follow on from that examination. This will be the case regardless of our conclusions and including where we determine that the allegation was mistakenly made. There will never be any reprisals against those who genuinely have, or consider that they have, valid grounds to bring concerns about discrimination to our attention.

However, complaints made in bad faith, for whatever reason (including where this is an attempt to avoid or to deflect disciplinary action), will be treated as misconduct and may lead to a dismissal for gross misconduct.

We will also take prompt disciplinary action against you if we discover that you have harassed or discriminated against anyone else in breach of this policy. If we conclude that your behaviour amounts to gross misconduct, we will be within our rights to dismiss you without notice and with no payment in lieu of that notice.

Engaging and Training Employees and Apprentices in Implementation of this Policy

Where staff are involved in the training and assessment of apprentices, the Quality Processes for observation of teaching, learning and assessment incorporate scrutiny of the promotion of Equality and Diversity to ensure this is being delivered in line with 2 Start’s expectations as set out in this policy.

Appropriate training and coaching will be provided to assist with implementation of the Equality and Diversity policy.

Staff and Apprentices are made aware of the organisation’s contacts for expressing any concerns relating to Equality and Diversity, as well as the organisation’s Complaints Policy. Both staff and apprentices are encouraged to call out discriminatory practices, both in the learning environment and in Apprentices’ workplaces.

2 Start will continue to review and update its curriculum to ensure its’ programmes meet the needs of a diverse range of apprentices.

All apprentices receive workbooks specifically designed to further their learning on Equality and Diversity as part of their personal development during their programmes of learning. Where directly related to the apprenticeship standards being delivered, Equality and Diversity is taught as part of the apprenticeship curriculum.

Monitoring and Review

The Senior Leadership Team will be responsible for monitoring and reviewing the Policy. As a minimum the policy will be reviewed annually.

Monitoring will include assessing how the Equality Policy, and any supporting action plan, are working in practice, reviewing them annually, and considering and taking action to address any issues.

The organisation’s MI and data system will be used in this monitoring to provide data on admissions, progression of apprentices and destination data to ensure that equal opportunities are promoted and upheld.

Where there are any legislative changes to UK Government Policy on Equality and Diversity, the review date of this policy will be brought forward accordingly to ensure any changes are reflected within this policy.

This policy was last reviewed on 5th January 2023 when contact details were updated, letterhead changed and minor rewording to Policy Statement.

This policy is scheduled to be reviewed by 4th January 2024.

Policy Approval

Date: 12/01/2023

Name: Daisy Udy

Position: Sales Director

Date of next review: By 04/01/2024

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