Venturi values a diverse workforce and the contribution each individual makes. We are committed to promoting inclusivity, equality and diversity in our policies, practices and procedures.
This policy applies to our dealings with all its people as well as others engaged by or who work with the Venturi including, for example, clients, job applicants and other third parties.
Venturi believes in treating everyone equally and with the same attention, courtesy and respect regardless of their age, disability, gender reassignment, marriage/civil partnership, pregnancy/maternity, race, religion or belief, sex and sexual orientation. These will be referred to in this policy as the "protected characteristics"
For the purpose of this policy "Venturi" relates to both Venturi and Venturi Limited.
Regulation and Legislation
In developing and implementing our anti-discrimination policy, Venturi is committed to complying with principles and code of conduct in relation to equality and diversity and with all applicable anti-discrimination legislation and associated codes of practice, including the Equality Act 2010.
Forms of discrimination
Discrimination can take a variety of forms including direct discrimination, indirect discrimination, harassment, victimisation and, for those with a disability, discrimination arising from disability and a failure to make reasonable adjustments. A brief summary of each of these is set out in Appendix 1.
Employment and training
As an employer, it is Venturi's policy to treat all employees and job applicants equally and fairly and not to discriminate unlawfully against them. This will, for example, include arrangements for recruitment and selection, terms and conditions of employment, access to training opportunities, access to promotion and transfers, grievance and disciplinary processes, selection for redundancies, work allocation and any other employment-related activities.
Recruitment and selection
Venturirecognises the benefits of having a diverse workforce and will take steps to ensure that:
it endeavours to recruit from the widest pool of suitably qualified candidates possible
employment opportunities are open and accessible to all on the basis of their ability, skills, experience, appropriate qualifications and aptitude for the job
all recruitment agencies acting for Venturi align with our equality and diversity requirements and their own requirement not to unlawfully discriminate.
Terms and conditions of work
It is Venturi's policy to treat its people equally, to create a working environment which is free from unlawful discrimination and which respects, where possible, the diverse backgrounds and beliefs of partners and employees.
Working arrangements such as working hours, maternity and other leave arrangements, performance review systems and any other conditions of employment will not unlawfully discriminate against any employee in a way that cannot be justified on the basis of the protected characteristics.
Where appropriate, Venturi will endeavour to provide appropriate facilities and working arrangements which take into account the specific needs of employees which arise from their having any of, or being associated with, the protected characteristics.
Promotion and career development
Promotion within Venturi are made without reference to any of the protected characteristics and will be based solely on merit.
The selection criteria and processes for recruitment and promotion will be kept under review to ensure that there is no unlawful discriminatory impact on any particular group which cannot be justified.
While positive action measures may be taken in accordance with the relevant anti-discrimination legislation to encourage under-represented groups to apply for promotion opportunities, recruitment or promotion to all jobs will be based solely on merit.
All employees will have equal access to training and other career development opportunities appropriate to their experience and abilities. Venturi may take appropriate positive action (as permitted by the anti-discrimination legislation) to provide special training and support for groups which are under-represented in the workforce and encourage them to take up training and career development opportunities.
It is expected that everyone in Venturi will conduct themselves in an appropriate manner, which can be characterised by:
treating others with dignity, trust and respect
having an awareness of the effects our behaviour may have on others
working collaboratively to achieve objectives
communicating openly and honestly, clearly stating what we mean and what we expect of others
giving and receiving constructive feedback as part of normal day-to-day activities, that is evidence based and delivered appropriately
starting from the assumption that everyone is working to the best of their abilities, taking account of the current stage of their professional development.
Unacceptable behaviour (including bullying, harassment and victimisation) may involve actions, words or physical gestures that could reasonably be perceived to be the cause of another person's distress or discomfort. Unacceptable behaviour does not have to be face-to-face, any may take many forms such as written, telephone or email communications or through social media. Unacceptable behaviour will be dealt with under the processes set out in our Anti-harassment and bullying policy.
All partners and line managers are expected to set an appropriate standard of behaviour, lead by example and ensure that those they manage adhere to the policy and promote our aims and objectives in relation to equal opportunity, diversity and inclusion.
Promoting and communicating equality and diversity
This policy is published on the Venturi's intranet and is also available to job applicants on the Venturi website. In addition, diversity, inclusion and equality training is provided on a regular basis.
All those who act on the Venturi's behalf will be informed of this policy and will be expected to comply with it .
In all its dealings, with clients and other third parties, Venturi will seek to promote the principles of diversity, inclusion and equality.
Venturi will make every effort to reflect its commitment to diversity, inclusion and equality in its marketing and communication activities where appropriate.
Implementing the policy
Responsibility and implementation
The Managing Director supported by the Director Of Operations has overall responsibly for the effective implementation and operation of this policy. The directors are expected to support them in this. This policy is also supported by the Venturi's Diversity and Inclusion group and the Customer Success team.
All Directors and employees of Venturi are expected to pay due regard to the provisions of this policy and should ensure compliance with it when undertaking their jobs or representing the company.
Acts of unlawful discrimination by partners, employees or others may result in disciplinary action, which in serious cases could result in summary dismissal. Please see our Disciplinary Procedure for more information. Failure to comply with this policy will be treated in a similar fashion.
Acts of unlawful discrimination by those acting on behalf of the Venturi will lead to appropriate action, which may include termination of services where appropriate.
Complaints of discrimination
Venturi will investigate all complaints of unlawful discrimination made by partners, employees, clients or other third parties in relation to Venturi and take action where appropriate. All complaints will be investigated in accordance with the Venturi's grievance or complaints procedure and the complainant will be informed of the outcome.
There will be no victimisation or retaliation against employees who complain about discrimination. However, making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under the Venturi's disciplinary procedure.
Monitoring and evaluation
Venturi's Diversity and Inclusion group report into the Board of Directors.
Venturi collects, reports and monitors diversity data. This allows us to see the effectiveness of equality and diversity initiatives that have been implemented, as well as helping us to take appropriate steps to avoid unlawful discrimination. Having up-to-date and comprehensive data enables us to target and support initiatives within Venturi and illustrates our commitment to diversity and inclusion.
In particular, Venturi will (in accordance with SRA requirements), as appropriate and where possible, monitor and record:
The protected characteristics, whether someone has caring responsibilities and their educational background (to measure social mobility), at different levels of Venturi. This data is collected on a voluntary basis through Venturi's annual diversity survey. The HR system securely holds age, gender, disability, ethnic and national origins, sexual origination, religion or belief and disability data for employees and partners.
On a voluntary and anonymous basis the gender, ethnic group, disability, sexual orientation and age on of all applicants as part of the recruitment process for all jobs and training contracts. This data is kept separate from the candidates actual job application.
The number and outcome of any complaints of unlawful discrimination made by partners, employees, clients and other third parties in relation to Venturi and its business.
To support Venturi's business strategy, the Diversity and Inclusion group sets diversity and inclusion objectives. With specific priorities in mind the Diversity and Inclusion group will:
set specific areas of focus every 18-24 months
collect, monitor and report diversity and inclusion data
plan initiatives around agreed actions
execute those initiatives
evaluate initiatives to establish if they were successful.
Last updated January 2019
Appendix: forms of discrimination
Protected characteristics under the Equality Act 2010 (the "Act") are:
marriage and civil partnership
pregnancy and maternity
race (including colour, nationality and ethnic or national origins)
religion or belief
Direct discrimination – occurs where a person is treated less favourably than another person because:
they have a protected characteristic
they are thought to have a protected characteristic
they associate with someone who has a protected characteristic.
Indirect discrimination – occurs when a provision, criterion or practice that applies to everyone but adversely affects people with the protected characteristic more than others and is not justified.
Discrimination arising from disability – occurs where a person is treated unfavourably because of something arising in consequence of their disability and that treatment is not justified.
Failure to make reasonable adjustments – occurs where Venturi fails to take such steps (adjustments) as are reasonable to alleviate disadvantages caused by a disability.
Harassment occurs when unwanted conduct related to a relevant protected characteristic takes place with the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. Harassment may involve physical acts or verbal and non-verbal communications and gestures. Harassment is dealt with in our anti-harassment and bullying policy.
Victimisation occurs when an employer subjects a person to a detriment because the person has carried out (or the employer believes they have or may have carried out) what is referred to as a 'protected act'. A protected act includes:
bringing proceedings under the Act
giving evidence or information in proceedings brought under the Act
doing anything which is related to the provisions of the Act
making an allegation that another person has done something in breach of the Act.