Good equality practices benefit everyone. Wholegrain acknowledges that the quality of life for many people around the world has been eroded by disadvantage and discrimination, and that experience of this is both wide and varied.

It’s important to us that Wholegrain is a diverse, inclusive and open-minded place to work and we encourage people from a broad range of backgrounds to join our merry team.

Our ‘Equal Opportunities Policy’ reflects our commitment to equality, inclusivity and to promoting diversity in the workplace.  It also reflects the importance of creating a working environment that: provides freedom from unlawful discrimination; accepts and appreciates difference; and treats everybody with kindness and respect. 

This policy applies to all employees (including former), with various elements of it applying to self-employed contractors and applicants for vacancies within Wholegrain..  It is also the standard by which we expect all contractors, clients, suppliers, and office visitors to maintain in their working relationship with our team members. 

We aim to provide a service that does not discriminate against our clients and customers in both the means by which they can access the services we provide, as well as in our interactions with them.  It is therefore important that all employees and contractors, working with our clients and customers, are fully aware of our expectations in respect of their conduct and choice of behaviour. As such this policy should be read in conjunction with the company’s ‘Dignity at Work (Anti-Harassment, Discrimination and Bullying) Policy’ and the ‘Code of Ethics Policy.’

Any, and all, personal data used in conjunction with this policy shall be collected, held, and processed in accordance with our ‘Data Protection Policy.’ 

This policy does not form part of your contract of employment or contract for services and may be amended from time to time.

Policy Statement

We are strongly opposed to discrimination, whether intended or unintended, in all its forms. 

We are committed to:

  • promoting and understanding the principles and practices of equality and justice so that we may apply such to our policies, practices, and process, in addition to how we conduct ourselves in business;
  • identifying and removing practices and procedures within Wholegrain which may result in direct or indirect discrimination;
  • providing equal access to appropriate resources and opportunities throughout our services to our clients and customers;
  • encouraging active participation and the regular consultation of stakeholders regarding actions, and potential decisions, that may have an impact upon their community; 
  • ensuring that our recruitment, employment, promotion, and training systems provide equality of access throughout;
  • ensuring compliance with all relevant legislation relating to equality, diversity, and inclusion;
  • recognising that individuals’ needs vary and that a flexible approach is required to ensure full participation and access to all services;
  • monitoring and evaluating the implementation of company policies and making changes and corrections where necessary

Our topmost priority is to protect and promote the rights and interests of individuals and the communities within which we work. Where there are conflicts of interest, we will make judgments according to existing laws and policies.

We expect all of our team members to commit themselves to challenge and combat discrimination in all its forms.   Concerns or complaints relating to discrimination, or the execution of this policy, may be raised informally via your Line Manager or to the Managing Director.  Alternatively, the informal or formal stages of the company’s ‘Grievance Policy and Procedure’ may be used instead.

The Policy

As a business, we seek to play a part in creating, maintaining, and promoting a society in which each person has equal entitlement and access to high-quality opportunities and services, irrespective of their personal characteristics, whether prescribed in law or otherwise.

For clarity’s sake, the Equality Act 2010 references the following nine ‘protected characteristics’ that form the basis of equality laws in respect of discrimination and harassment:

  • Age;
  • Disability;
  • Gender reassignment;
  • Marriage or civil partnership;
  • Pregnancy and maternity;
  • Race;
  • Religion or belief;
  • Sex;
  • Sexual orientation

Wholegrain recognises that legal obligations in relation to discrimination may overlap between different groups and that some groups do not benefit from legislative protection. We therefore take the view that good practice towards all groups through this policy is an absolute necessity.

Policy Scope

This policy applies to all aspects of our relationship with former, current, and prospective employees to ensure that the following activities are determined on the basis of capability, experience, skills, and productivity:

  • recruitment;
  • employment terms and conditions;
  • promotion;
  • transfer;
  • training and development activities;
  • working conditions;
  • flexible working;
  • wages and salary administration;
  • employee benefits;
  • application of policies;
  • job appraisals and managing performance;
  • conduct at work;
  • the application of our Disciplinary and Grievance procedures;
  • redundancy and dismissal; 
  • termination of employment

Some elements of the above also apply to contractors as determined by law and updated from time to time.

Definition of Discrimination

Discrimination is unequal or differential treatment, which leads to one person being treated more or less favourably than others are, or would be treated in the same or similar circumstances, on the grounds of one or more of the nine ‘protected characteristics.’ Discrimination may be direct (when someone is put at a disadvantage or treated less favourably because of a ‘protected characteristic’) or indirect (when a working practice, policy or rule is the same for a group of individuals but has a worse effect on one or more individuals because of a ‘protected characteristic’), and includes discrimination by perception and association.

Key Issues for Different Groups

Discrimination can be direct or indirect, intentional, or unintentional. Discrimination can be perpetrated by individuals, groups, or institutions. At an individual level, discrimination is based on personal attitudes of superiority; at a group level, shared behaviour serves to reinforce discrimination; at an institutional level, prejudice becomes embedded in policy and procedure with the effect of excluding some people in favour of others.

At all levels, discrimination caused by unfair treatment and unequal distribution of opportunities and resources deprives people of a good quality of life and serves to reinforce a cycle of multi-faceted disadvantage.

  • Age Discrimination
    Definition – negative assumptions based on a person’s age, which can affect both young and older people, particularly when they apply for jobs. It is not permissible to treat a person less favourably because of their age.
  • Disability Discrimination
    Definition – this occurs when disabled people are faced with barriers to their full participation in society e.g. lack of access, negative attitudes, lack of support systems.  A disability relates to either a physical or mental impairment, or an impairment that has a substantial and long-term adverse effect on the individual’s ability to carry out normal day-to-day activities.  It is not permissible to treat a disabled person less favourably than a non-disabled person.  Furthermore, reasonable adjustments (see below) must be made to give the disabled individual as much access to any services and ability to be employed, trained, or promoted as a non-disabled person. Wholegrain undertakes to be proactive in countering this form of discrimination and promoting a positive attitude towards providing opportunities for people with disabilities.
  • Racial Discrimination
    Definition – the belief that one culture and set of values is superior to another, leading to prejudice on nationality, ethnic, origin, colour, and culture.  It is not permissible to treat a person less favourably because of their race, the colour of their skin, their nationality, or their ethnic origin.
  • Discrimination on the grounds of Sexual Orientation
    Definition – negative attitudes and prejudices based on the belief that heterosexuality is the norm. It is not permissible to treat a person less favourably because of their sexual orientation.
  • Discrimination on the grounds of Religion and Faith
    Definition – negative perceptions based on the view that one set of beliefs is superior to another.  It is not permissible to treat a person less favourably because of their religious beliefs or their religion or their lack of any religion or belief.
  • Sex Discrimination
    Definition – discrimination in employment and opportunity against a person (typically a woman) on grounds of sex.  It is not permissible to treat a person less favourably on the grounds of sex, marital status, civil partnership, pregnancy or maternity, gender reassignment or transgender status. This applies to men, women, those undergoing or intending to undergo gender reassignment.  Sexual harassment of men and women can also be found to constitute sex discrimination.

Recruitment and Positive Action statement

‘Positive action’ means the steps that a company can take to encourage people from groups with different needs or with a past record of disadvantage or low participation, to apply for positions within the company.   If Wholegrain chooses to utilise positive action in recruitment, this will not be used to treat people with a protected characteristic more favourably. It will be used only in tie-break situations, when there are two candidates of equal merit applying for the same position.

Reasonable Adjustments

Wholegrain will make reasonable adjustments to facilitate the employment of a disabled employee, job applicant, self-employed contractor, or worker. These may include:

  • making adjustments to premises;
  • re-allocating some of a disabled employee’s duties;
  • transferring a disabled employee to a role better suited to their disability;
  • relocating a disabled employee to a more suitable office;
  • giving a disabled employee time off work for medical treatment or rehabilitation;
  • providing training or mentoring for a disabled employee;
  • supplying or modifying equipment, instruction, and training manuals for disabled employees;
  • any other adjustments that Wholegrain considers reasonable and necessary provided such adjustments are within the financial means of the company

If an employee has a disability and feels that any such adjustments could be made by the company, they should speak to their Line Manager.   During the recruitment process, candidates will be reminded to make Wholegrain aware of any reasonable adjustments that may be necessary to support them during the process.


The Managing Director is responsible for determining the ‘Equal Opportunities Policy’ and along with Line Managers, for overseeing its implementation across our business activities.  This includes the responsibility for ensuring that this policy is distributed to all employees and contractors. In addition to Wholegrain clients, suppliers and office visitors so as to support our working relationship with them and their teams, and in the event it is necessary to deal with any breaches of it.  Line Managers are also responsible for ensuring that they promote equal opportunities in their planning and operations activities.

The HR Consultant is responsible for assessing our company policies, ensuring that they’re free from bias and that all team members have awareness of them to ensure their compliance and support of them.  Should we discover any bias in our policies, we will immediately refine our processes and provide any necessary training.

Every employee is responsible for adhering to this policy,  for mainstreaming its provisions, and for highlighting any practices or behaviour within Wholegrain that contravenes it. 

All employees and contractors have a responsibility to ensure that they follow our policies and procedures and to conduct themselves towards others in accordance with this policy.  The co-operation of all team members is essential for the success of it. 

Breaches of the policy will be dealt with under the company’s disciplinary procedures as appropriate. In addition, individuals may also be held independently and individually liable for their discriminatory acts by Wholegrain and in some circumstances, by a judicial court.