Section 1   Introduction

1.1               Scope of the policy

DNA Skills is committed to equality of opportunity in all aspects of its activities. 

This policy applies to all apprentices, employees, and partners with whom we interact.

1.2           Purpose of the policy

To enable DNA Skills to comply with The Equality Act 2010. This policy has been developed to ensure that no stakeholder receives less favourable treatment on the grounds of:

  • Age
  • Gender, gender reassignment
  • Sexual orientation
  • Marital or family status, including pregnancy
  • Disability or learning difficulty
  • Mental or physical health status
  • Physical appearance
  • Socio-economic status
  • Ethnic origin, perceived ‘race’, skin colour, nationality or national origin
  • Religion or belief, philosophical belief or no belief
  • Working hours
  • Membership/non-membership of trade unions
  • Or any other cause leading to unfair discrimination, including any Reasonable Assessment Adjustment requirements (see Reasonable Assessment Adjustments & Special Considerations Policy for further information)

1.3           Reviewing the policy

This policy will be reviewed annually or:

  • Interim when there has been changes to policy or legislation
  • Where DNA Skills are approved for additional apprenticeship standards

Section 2    Key Principles

To fulfil this policy DNA Skills is committed to the following key principles:

  • Promoting an organisation where people are treated with respect and dignity and where no form of intimidation or harassment is or will be tolerated
  • Creating a positive, inclusive ethos with a shared commitment to respecting diversity and difference and to encourage good relations between people of different groups
  • Taking reasonable steps to prevent any form of harassment, direct or indirect discrimination or victimisation
  • Taking reasonable steps to make sure that no apprentice, staff member or job applicant is placed at a disadvantage by stipulated requirements or conditions that are unreasonable or irrelevant
  • Consulting with staff, apprentices and partners on issues relating to equality and diversity
  • Actively working to raise the awareness of apprentices to the importance of equality and diversity issues and DNA Skills expectations of them to contribute to a safe and inclusive environment
  • Developing a product offer that meets the needs of our wider community and supports underrepresented groups
  • The collection, analysis and reporting on a range of data that will identify areas of inequality and the development of appropriate strategies and actions that will address those inequalities
  • Assessment of all potential apprentices or job applicants on their individual merits and their ability to undertake employment, training, and education successfully
  • Making reasonable adjustments to ensure apprentices and staff are supported to participate and achieve. This includes those with physical or mental impairments as defined by the Disability Discrimination Act and the application of any Reasonable Assessment Adjustments requested in line with that policy
  • Carrying out impact assessments on the range of our policies, practices, and procedures to assess potential or actual negative impact on specific groups
  • Providing suitable training and support for staff so that they have the skills, knowledge, and confidence to implement equality and diversity throughout their work
  • Equality principles specific to employment

Section 3    Equality Principles in Employment

DNA Skills aims to employ a workforce which reflects at every level the community, which it serves. In seeking to achieve a balanced workforce at all levels, DNA Skills will ensure that no employee, job applicant or candidate for promotion will be disadvantaged, or treated less favourably because of conditions or requirements that are not related to the job. 

Reasonable adjustments will be made to arrangements and premises to ensure equal access for employees or potential employees who fall under the provisions of the Equality Act 2010 in relation to disability.

To ensure equality and fairness at all stages of employment, DNA Skills will ensure that equality issues are embedded into all its recruitment and employment policies and procedures.

Section 4    Equality Principles in End-point assessment

DNA Skills will treat all apprentices as individuals and with dignity and respect in the provision of access to facilities, opportunities, and support. DNA Skills offer will be devised to positively promote all required of equality and diversity.

Section 5    Discrimination and Victimisation

DNA Skills will ensure that support and assistance is provided to apprentices and staff who consider themselves to have been a victim of discrimination or victimisation. All acts of unlawful discrimination or victimisation by staff shall be treated as disciplinary offences under the Disciplinary Procedure, which in serious cases may lead to dismissal. Individuals can potentially be held personally liable for acts of discrimination and/or victimisation, which they commit, authorise, contribute to, or condone.

Section 6    Responsibilities and monitoring

The Governing Board has oversight for ensuring that DNA Skills adheres to the law and for promoting the policy on equality and diversity. The Governing Board is therefore responsible for giving a high-profile lead on equality and diversity issues and integrating equality objectives into strategic plans. Their responsibilities include:

  • Provide leadership and ensure the accountability of equality and diversity
  • Ensure that DNA Skills adheres to equalities legislation
  • Ensure that equality and diversity aspects are built into DNA Skills strategic plans
  • Provide leadership to ensure and promote equality of opportunity, no unlawful discrimination, harassment or bullying
  • Provide appropriate role models for all managers, staff, and apprentices
  • Congratulate examples of good practice among individual managers, staff, and apprentices
  • Ensure a consistent response to incidents, e.g., bullying cases and racist incidents
  • Initiate, oversee the development and regular review of equality policies and procedures
  • Ensure that apprentices, staff, and partners are consulted in the development and review of the policies
  • Ensure equality and diversity aspects are built into DNA Skills strategic plans
  • Ensure the communication of the policies to all apprentices, staff, and partners
  • Ensure that managers and staff undertake the necessary training to enable them to carry out the policies
  • Oversee the effective implementation of the Equality and Diversity Policy, as with all DNA Skills policies
  • Hold line managers accountable for effective policy implementation
  • Ensure DNA Skills publishes and celebrates successful outcomes
  • Ensure positive action is taken to tackle unlawful and unfair discrimination, inequality, and unfairness
  • Encourage opportunities and mechanisms for the sharing of good practice and working collaboratively
  • Ensure information informing apprentices and staff of the action that they need to take if they are being bullied or harassed is readily accessible
  • Ensure that DNA Skills carries out its statutory duties effectively

The responsibilities of employees (e.g., assessors) include:

  • Raise issues with line managers which could contribute to policy review and development
  • Ensure discriminatory behaviour is routinely and effectively challenged
  • Provide a consistent response to incidents, e.g., bullying cases
  • Maintain awareness of DNA Skills current Equality and Diversity Policy 
  • Implement the policy as it applies to staff and apprentices
  • Behave with respect and fairness to all colleagues and apprentices
  • Undertake appropriate equality and diversity training and other opportunities for CPD
  • Ensure that there are opportunities for all apprentices to share their comments, 
    suggestions and feedback


Section 7    Who does the act protect

The grounds on which someone can be discriminated against are referred to as ‘protected characteristics’. The Equality Act 2010 recognises 9 protected characteristics, which are:

Age - People of all ages are protected by the Equality Act.

Disability - People who have a physical or mental impairment which has a substantial and long-term effect on their ability to carry out normal day to day activity are protected by the Equality Act.

Gender Reassignment - This is the process of transitioning from one gender to  another.

Marriage and Civil Partnership - Marriage is defined as a ‘union between a man and a woman’. Same-sex couples can have their relationships legally recognised as ‘civil partnerships’.

Pregnancy and Maternity - Pregnancy refers to being pregnant or expecting a baby. Maternity refers to the period after the birth and is linked to maternity leave in an employment context.

Race - Refers to a group of people defined by their race, colour, nationality, ethnicity, or national origins.

Religion and Belief - Religion has the meaning usually given to it but belief includes religious and philosophical beliefs. Protection also extends to a lack of religion or belief.

Sex - This refers to the biological characteristics that make us male or female.

Sexual Orientation - Whether a person is attracted to their own sex, the opposite sex or both sexes. A person’s sexuality can change over time.

Discrimination takes place when an individual or group of people is treated less favourably than others because of factors unrelated to their merit, ability or potential. It is unlawful to discriminate against someone on grounds of their sex (including gender reassignment), sexual orientation, marital status, race, nationality, ethnic origin, religion, beliefs, disability, pregnancy, or childbirth or because they are a member, or not, of a trade union. It is also unlawful to discriminate against part-time workers.

Section 8    Types of discrimination

The British law (Equality Act 2010) recognises 8 types of discrimination:

8.1           Direct Discrimination:

Occurs when factors unrelated to the merit, ability or potential of a person or group are used as an explicit reason for discriminating against them. An example would be recruiting to a male applicant to a position rather than a more appropriately qualified woman because of irrational, prejudicial or stereotypical views, or nor promoting someone because they have a disability.

8.2       Indirect Discrimination:

Occurs when there are rules, regulations or procedures operating, which have the effect of discriminating against certain groups of people. This may happen in subtle ways. For example, staff at a shop in London had to wear a uniform skirt, but an Asian woman worker refused for religious reasons. A tribunal found the shop guilty of indirect discrimination, because a large number of Asian women would not be able to comply with the rule. 

8.3       Discrimination:

Arising from disability occurs when somebody is treated unfavourably because of something arising in consequence of his or her disability (there may be instances where such treatment may be justifiable).

8.4       Discrimination by Association:

This is direct discrimination against someone because they associate with another person who possesses a protected characteristic.

8.5       Discrimination by Perception:

This is direct discrimination against an individual because others think that they possess a particular protected characteristic. It applies even if the person does not actually possess the characteristic.

8.6       Harassment:

Occurs when an individual is subjected to unwanted conduct, which has the purpose (intentional) or effect (unintentional) of Violating a person’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual.

Moreover, harassment is unlawful when it is on the grounds of sex, gender reassignment, race, ethnic or national origin, sexual orientation, age, religion/belief, or for a reason relating to a person’s disability. It is also unlawful to subject an individual to sexual harassment, or to harassment on the grounds of that individual’s membership or non-membership of a trade union.

8.7       Third Party Harassment:

Such harassment is deemed to occur where a third party (e.g., a partner organisation) harasses an employee three or more time in the course of them carrying out their job and the employer is aware but fails to take reasonable steps to prevent it. It doesn’t matter whether the third party is the same or a different person on each occasion.

8.8       Victimisation:

A person is victimised if they are punished or treated unfairly because they have made a complaint, or are believed to have made a complaint, or to have supported someone who has made a complaint. A person or group of people can also be victimised or singled out for discriminatory or even criminal treatment because of, for example, their race, gender, disability age etc. This could be workplace discrimination with regard to such things as recruitment and selection or promotion. Apprentices could be similarly victimised e.g. refusal of application or unfair marking.


Section 9    Equality and Diversity Terms

The below provides definitions of some of the terms most commonly used when talking about equality and diversity:

9.1 Diversity:

Diversity describes the range of visible and non-visible differences that exist between people. Managing diversity harnesses these differences to create a productive environment in which everybody feels valued, where talents are fully utilised and in which organisational goals are met.

9.2 Equal Opportunities:

Equal opportunities, or equality of opportunity, may be defined as ensuring that everyone is entitled to freedom from discrimination. There are two main types of equality encompassed in equal opportunities:

1.     quality of treatment is concerned with treating everyone the same. Thus, in an organisational context itrecognises that institutional discrimination may exist in the form of unfair practices or procedures that favour those with some personal attributes over others without them. Equal opportunities is therefore concerned with the elimination of these barriers.

2.      Equality of outcome focuses on policies that either have an equal impact on different groups or intend the same outcomes for different groups.

9.3 Bullying:

Although not defined legally, can be described as offensive, intimidating, malicious or insulting behaviour, an abuse or misuse of power through means intended to undermine, humiliate, denigrate, or injure the recipient.

9.4 Hate Crime or Incident:

A hate crime is any crime committed against a person, a group or the property of a person or group where the motivation for the crime is hatred of, or prejudice against, their sex, sexual orientation, race, religion, or disability. The most common forms of hate crime are racial, homophobic, or sectarian.


Section 10   Contacts

Your contact for this policy

If you have any queries about the contents of the policy, please contact our DNA Skills EPA Team:

Email: enquiries@dnaskills.co.uk

Telephone: 01344 944675

DNA Skills EPA Team
7 Lakeside Business Park
GU47 9DN

Title & Key Responsibilities

General Manager - Accountable for the strategic objectives of DNA Skills and its regulatory compliance. Ensures all policies are effectively implemented

Head of Quality & Compliance - Responsible Office and point of contact for regulatory bodies. Oversees the version control of policies

Head of Product & Assessment Development - Acting Deputy for Responsible Officer. Manages the development and life cycle of our products

Quality & Performance Manager - Responsible for the delivery of assessments and quality assurance processes