Equal Opportunities Policy

Equal opportunity can only be achieved through a shared commitment across the business to recognising and valuing the talents, skills and perspectives of every individual. At LUNA, we believe this is important not only for our people, but for the success of the Company as a whole.

We are fully committed to providing equal opportunities for all directors, employees, applicants, clients, suppliers and other individuals or organisations we work with. We aim to ensure that no one is treated unfairly and that unlawful discrimination, whether direct or indirect, is prevented in all areas of our business.

This policy sets out the Company’s approach to equality, diversity and inclusion and covers discrimination, harassment, bullying and victimisation. It is intended to provide a clear framework for fair treatment across all employment practices and business relationships.

We recognise our obligations under the Equality Act 2010 and other relevant legislation and guidance. We are committed to promoting a working environment in which everyone is treated with dignity, fairness and respect.

People are one of the Company’s most valuable assets and play a central role in achieving our objectives. To support individuals in this role, we will:

Take all reasonable and appropriate steps to ensure that employees are recruited, trained and promoted on the basis of ability, potential and the requirements of the role
Encourage staff to develop their full potential and provide appropriate training and support
Develop and improve communication so employees can see a clear link between their contribution and the achievement of the Company’s objectives
Regularly seek views and ideas from staff to improve the Company’s effectiveness and efficiency
Provide a healthier, safer and more inclusive working environment in which people can contribute and succeed

Dignity at Work

The Company values its employees, clients and wider business relationships and regards any form of discrimination, harassment or bullying as completely unacceptable.

Everyone, regardless of position or seniority, is expected to comply with this policy at all times during the course of employment and business activities, including at work related events and social occasions organised by or connected with the Company.

LUNA’s Responsibility

The Company has a responsibility to ensure that it does not discriminate unlawfully on any of the grounds protected by law. We are committed not only to avoiding discrimination, but to developing positive practices that promote equal opportunities throughout the business.

As an employer, the Company may be legally responsible for the actions of its employees where those actions are carried out in the course of employment. For that reason, the responsibility for providing equality of opportunity rests primarily with the Company, supported by effective monitoring and regular review of working practices.

Responsibilities of Individual Employees and Directors

While overall responsibility sits with the Company, all directors and employees also have an important role to play. Good working relationships and fair practices depend on everyone’s behaviour and attitudes.

All directors and employees are expected to:

Co operate with measures introduced to promote equal opportunity and prevent discrimination
Avoid any behaviour that could amount to unlawful discrimination, harassment, bullying or victimisation
Not instruct, encourage or pressure others to discriminate
Not victimise anyone who has raised a complaint or provided information in relation to discrimination
Not harass, intimidate or abuse colleagues, clients, suppliers or other business contacts
Raise concerns with management if they suspect discrimination or unfair treatment is taking place

Managers and Supervisors

Managers and supervisors have a particular responsibility to:

Make clear to employees the law and the Company’s policy on equal opportunities
Ensure this policy is implemented consistently and fairly
Address breaches of the policy promptly and take appropriate action where necessary
Report concerns involving individuals outside their direct line management responsibility to the appropriate manager
Support and encourage employees in a fair and non discriminatory way
Treat all employees with dignity and respect and give proper consideration to their views
Apply discipline fairly, consistently and in line with the Company’s disciplinary procedures
Remain alert to any signs of discrimination, harassment or victimisation and act appropriately

Promoting a Positive Environment

It is the Company’s policy that no employee, applicant, client, supplier or other person dealing with the Company should receive less favourable treatment because of:

Sex
Sexual orientation
Gender reassignment
Marriage or civil partnership
Race
Colour
Nationality
Ethnic or national origin
Religion or belief
Age
Disability
Pregnancy or maternity

The Company will also seek to ensure that no unjustified provision, criterion or practice places an individual or group at a disadvantage.

Wherever possible, and across all areas of the business, we will promote an environment of respect, fairness and encouragement, enabling our people to contribute fully and achieve their potential.

What Equal Opportunities Means

Equal opportunities means treating people fairly and consistently and not making decisions based on personal characteristics unrelated to the role or situation.

Where it is necessary to assess differences between individuals, for example during recruitment, promotion or performance review, this must be done only on the basis of objective, relevant and lawful criteria applied fairly and consistently.

What Discrimination Means

Discrimination occurs when someone is treated unfairly because of a protected characteristic, or when a rule, policy or way of working disadvantages a particular group without good reason.

Discrimination can take different forms.

Direct discrimination
This is where a person is treated less favourably because of a protected characteristic. For example, refusing to promote someone because they are pregnant or because of their race.

Indirect discrimination
This is where a provision, criterion or practice applies to everyone but disadvantages people who share a protected characteristic, and cannot be objectively justified. For example, requiring something unnecessary for a role that may unfairly exclude certain groups.

Disability discrimination
Disability discrimination may occur where a disabled person is treated unfavourably because of something arising from their disability, or where reasonable adjustments are not made to remove barriers that place them at a substantial disadvantage.

The Company will consider and make reasonable adjustments where appropriate to support disabled employees, job applicants and visitors.

Policy Statement on Disability

The Company is committed to ensuring that no customer, supplier, visitor, job applicant or employee is disadvantaged because of a disability.

We will take reasonable steps to ensure that disabled people are able to access our services, facilities and offices and are treated with dignity, equality and respect.

Positive Action

Positive action is permitted by law in certain circumstances and is different from positive discrimination, which is unlawful.

Where appropriate, the Company may take lawful steps to encourage underrepresented groups to apply for roles or access training and development opportunities, with the aim of improving equality of opportunity.

All appointments and promotions within the Company will continue to be made on merit.

Vacancies will be advertised appropriately to attract a diverse range of candidates, and we will seek to ensure that equal opportunities are available at every stage of recruitment and selection.

The Company will take steps to ensure that there are no signs that:

Prejudices or assumptions are influencing decisions
Indirect discrimination is having an unfair impact on any group
Recruitment, progression or working practices are creating unnecessary barriers

Harassment and Bullying

Harassment is unwanted conduct that is offensive, intimidating, hostile, degrading, humiliating or upsetting, and which violates a person’s dignity or creates an adverse environment.

It is the effect of the behaviour, not the intention behind it, that matters.

Harassment may be related to a protected characteristic and can be a single serious incident or a pattern of behaviour.

Bullying is persistent or serious behaviour directed at an individual that is intimidating, malicious, insulting or undermining, and which makes that person feel threatened, humiliated or vulnerable.

Examples of harassment or bullying may include:

Verbal abuse or insulting behaviour
Offensive jokes or comments about race, sex, disability, sexual orientation, age or religion
The circulation of offensive or inappropriate material
Threatening, intimidating or coercive behaviour
Unjustified and persistent criticism
Humiliating someone in front of others
Excluding someone because of a protected characteristic
Unwanted physical contact, staring or sexual comments
Online abuse, including hostile or inappropriate emails or messages

Legitimate, fair and constructive management of performance or conduct does not amount to bullying.

Harassment and bullying in any form are unacceptable and may lead to disciplinary action.

Victimisation

Victimisation occurs when someone is treated less favourably because they have:

Raised a complaint under this policy
Supported someone else in making a complaint
Given evidence or information in relation to a complaint

Individuals are protected from victimisation even if the complaint is not upheld, provided it was made in good faith. Malicious or knowingly false allegations will not be protected and may themselves result in disciplinary action.

Breach of this Policy

Failure to follow this policy may expose the Company to legal risk and reputational damage. The Company will not tolerate breaches of its equal opportunities policy and may take disciplinary action where appropriate.

Unlawful discrimination, harassment or victimisation can also result in personal legal liability for the individual involved.

Grievance and Disciplinary Procedures

Any alleged breach of this policy may be dealt with under the Company’s grievance or disciplinary procedures, as appropriate.

Concerns or complaints will be taken seriously and investigated fairly. Where there are reasonable grounds to believe that this policy has been breached, appropriate steps will be taken to stop the behaviour and prevent it from recurring.

Serious breaches may result in dismissal and, where appropriate, referral to the police or other external authorities.

Any employee who believes they have been subjected to conduct in breach of this policy should report it in line with the Company’s grievance procedure.

Where a client, supplier or other business contact believes they have been treated in a way that is inconsistent with this policy, they should raise the matter with their usual Company contact or another appropriate senior manager.

Success of this Policy

While the Company is fully committed to removing barriers to equal opportunities, the success of this policy depends on the commitment of everyone across the business.

Line managers and supervisors have an important day to day role in ensuring that the policy is followed, but all employees and directors share responsibility for making it effective.

Action, Monitoring and Review

The Company will review and, where necessary, update policies and procedures to ensure they continue to support equal opportunities and reflect current legal requirements and good practice.

Training will be provided, where reasonably practicable, to help directors and employees understand the principles and practical application of this policy. Particular attention will be given to recruitment and selection, management responsibilities and appropriate workplace behaviour.

The Company may monitor relevant workforce data, where appropriate and lawful, to help identify patterns, barriers or areas for improvement. Any information collected for monitoring purposes will be handled confidentially and used only for legitimate equality, safety and compliance purposes.

This policy will be reviewed regularly and updated where needed.