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Document Number: HCAUK.HR.HR.POL.1024
Publication Date: 11/04/2022
Review Date: 11/10/2024
Document Owner: Head of Employee
Expiry Date: 11/04/2025
Replaces Document: HCAUK.HR.HR.POL.035
Corporate Diversity and Inclusion Policy
Approved by: Vice President of Human Resources

Target Audience: All employees, potential
employees, service users, secondees, agency
workers, contractors, volunteers, work
experience and student placements.
Date approved: 11/04/2022
Document Summary:
This policy provides a framework to ensure
that equality, diversity and inclusion are
integral and fully reflected in HCA’s
Key words:
Diversity and Inclusion, Equality and
Diversity, Religion and Belief,
Discrimination, protected characteristics
Key linked polices/ guidelines
HCAUK.HR.HR.POL.1021 – Gender
Reassignment Policy
HCAUK.HR.HR.POL.1047 – Annual Leave
Policy HCAUK.HR.HR.POL.1003 – Dress code
and Appearance Policy
Version Tracking
Date Version Number Changes made to document
18/11/2016 1.0 This document was reviewed and approved under
HCAUK.HR.HR.POL.035 Corporate Diversity and
Inclusion Policy.
21/10/2019 1.1 Policy under review, 6-month extension of review
agreed by VP of HR
April 2020 N/A Policy extended due to Covid19 pandemic April 2020
24/03/2021 1.2 Policy extended due to migration project 2021
04/02/2022 1.3 Policy reviewed – minor amends only
11/04/2022 1.4 Grammatical amends made to policy




HCA Healthcare UK (HCA) is committed to providing a working environment that is
welcoming, inclusive, respectful, and free from discrimination.
HCA is fully committed to the elimination of unlawful and unfair discrimination and values
the differences that a diverse workforce brings to the organisation.
HCA will not discriminate because of age, disability, gender reassignment, marriage and civil
partnership, pregnancy and maternity, race (which includes colour, nationality and ethnic or
national origins), religion or belief, sex or sexual orientation. HCA will not discriminate
because of any other irrelevant factor and will build a culture that values meritocracy,
openness, fairness and transparency.
All employees are responsible for the promotion and advancement of this policy. Behaviour,
actions or words that transgress the policy will not be tolerated and will be dealt with in line
with HCA’s Disciplinary Policy.
HCA aspire to have a diverse workforce because diversity enables better business outcomes.
HCA also believe that a more inclusive workplace, where people of different backgrounds
work together, ensures better outcomes for all employees. From application to interview,
HCA place inclusion as an integral part of all we do.

This policy and procedure applies to all employees, as well as potential employees, service
users, secondees, bank workers, agency workers, contractors, volunteers, work experience
and student placements.
This policy and procedure applies equally to all aspects of the employment cycle including
recruitment and selection, promotion, education, learning and development, grievances,
sickness and absence, conduct, terms and conditions of service, and reasons for
This policy covers HCA procedures and practice on:
1. Equal Opportunities;
2. Religion and Belief.

HCA believes that all employees should expect to be treated with dignity and respect, and
that equality, diversity, and inclusion are embedded into the organisation’s communication,
both internally and externally. The overall aim of this policy and procedure is to provide a
framework that supports the below:
to ensure that equality, diversity, and inclusion are integral and fully reflected in
HCA’s employment practices, policies and procedures;
to ensure that HCA is compliant with the statutory employment duties under
equality legislation (The Equality Act 2010);
to increase awareness and understanding of equality, diversity, and inclusion across

to ensure that HCA attracts and retains a diverse workforce through appropriate
means of recruitment and promotion methods;
to ensure that no employee or potential employee experiences less favourable
treatment as a result of personal attributes or circumstances;
to reinforce the view that any form of unlawful direct and / or indirect, or other form
of discrimination in employment practice is unacceptable.

Protected Characteristics Grounds upon which discrimination is unlawful. The
characteristics are: age, disability, gender reassignment,
marriage and civil partnership, pregnancy and maternity, race,
religion or belief, sex, sexual orientation.
Age Refers to a person belonging to a particular age (for example
32 years old) or range of ages (for example 18-30 years old).
Disability A person has a disability if they have a physical or mental
impairment which has a substantial and long-term adverse
effect on that person’s ability to carry out normal day-to-day
Gender reassignment Another way of describing a person’s transition. To undergo
gender reassignment usually means to undergo some sort of
medical intervention, but it can also mean changing names,
pronouns, dressing differently and living in their selfidentified gender.
Marriage & Civil Partnership Marriage and civil partnership means someone who is legally
married or in a civil partnership. Marriage and civil partnership
can either be between a man and a woman, or between
partners of the same sex.
Pregnancy & Maternity Pregnancy is the condition of being pregnant or expecting a
baby. Maternity refers to the period after the birth and is
linked to maternity leave in the employment context. In the
non-work context, protection against maternity discrimination
is for 26 weeks after giving birth and this includes treating a
woman unfavourably because she is breastfeeding.
Race Refers to the protected characteristic of Race. It refers to a
group of people defined by their race, colour and nationality,
including citizenship, ethnic or national origins.
Religion & belief Religion has the meaning usually given to it but belief includes
religious and philosophical beliefs including lack of belief, such
as Atheism. Generally, a belief should affect your life choices
or the way you live for it to be included in the definition.
Sex and Intersex Assigned to a person on the basis of primary sex
characteristics (genitalia) and reproductive functions.
Sometimes the terms ‘sex’ and ‘gender’ are interchanged to
mean ‘male’ or ‘female’. Intersex is a term used to describe a
person who may have the biological attributes of both sexes
or whose biological attributes do not fit with societal
assumptions about what constitutes male or female. Intersex
people may identify as male, female or non-binary.
Sexual orientation A person’s sexual attraction to other people, or lack thereof.
Along with romantic orientation, this forms a person’s
orientation identity.
Equality Equality is about ensuring that every individual has an equal
opportunity to make the most of their lives and talents, and
believing that no one should have poorer life chances because
of where, what or whom, they were born, what they believe
or whether they have a disability.
Diversity The mosaic of people who bring a variety of cultural, social and
historical backgrounds, styles, perspectives, values and beliefs
as assets to the groups and organisations with which they
Inclusion Inclusion is about positively striving to meet the needs of
different people and taking deliberate action to create
environments where everyone feels respected and able to
achieve their full potential.

5.1 Employees
All employees will:
• treat people with dignity and respect;
• be aware of their responsibilities and, report inappropriate behaviour(s) and raise
any incident(s) that breach this policy and procedure;
• familiarise themselves with this policy and procedure, ensuring that their practices
are consistent with its contents and legislation;
• champion equality, diversity and inclusion in the workplace;
• provide personal diversity information when required notwithstanding the fact that
there is a right not to disclose this information;
• be aware of their personal liability in breaching the requirements of the Section 110
of the Equality Act 2010.
5.2 Line Managers
Line Managers will:
• be responsible for promoting and championing equality, diversity, and inclusion;
• be responsible for creating a climate where the differences that individuals bring to
the workplace are valued;
• foster good relations between all employees;
• ensure that their direct reports complete equality and diversity and ethics and code
of conduct training as part of mandatory training each year, in addition to Company
5.3 Human Resources Department
The Human Resources Department will:
ensure that the Diversity and Inclusion policy and procedure is updated following
legislative changes;
request equality information on the protected characteristics from job applicants, on
application to a new post, and employees on a two-yearly basis, giving assurances
that this information will be kept confidential;
carry out regular reviews to identify any potential barriers in relation to recruitment,
selection, education and learning and career development;
ensure that at least one member of the Recruitment and Selection process has
undertaken the Recruitment and Selection training and, that all members of the
Recruitment and Selection process, has completed equality and diversity and ethics
and code of conduct;
implement Recruitment and Selection training for all managers raising awareness of
unconscious bias and stereotype threat;
ensure that all HR policy and procedures are Equality Impact Assessed;
advise on and manage employee complaints and grievances in relation to equality,
diversity, and inclusion issues;
advise the Senior Management Team and Line Managers on best practice on
employee issues taking into account the principles of equality, diversity, and
inclusion in all advice that is provided;
advise Line Managers on handling all disability related employee issues, especially
when taking into account Occupational Health (or other medical practitioner) advice
on reasonable adjustments;
require equality monitoring data to be analysed to identify gaps and dis-
sponsor and encourage ‘smart’ flexible working policy and practice to attract and
retain diverse talent.
5.4 Local Senior Management and Executive Teams
The local senior management and Executive Teams will:
ensure that all employees within their area of responsibility comply with this policy;
communicate personal commitment in creating a culture which supports diversity
and inclusion within their teams;
promote and communicate strategic value of diversity and inclusion;
ensure that the implications for diversity of all major changes and initiatives are
considered early in any change, or decision-making process;
ensure systematic consideration of potential service users who are under

represented in the current customer profile; as well as the appropriateness of
services and facilities to the diversity of the existing customer profile;
take a no tolerance approach to behaviour which does not support diversity and

6.1 Protected Characteristics
The Diversity and Inclusion Policy of HCA provides that all current employees and applicants
for employment shall receive equal treatment, regardless of any protected characteristics
they may possess, defined by the Equality Act 2010 as:
gender reassignment
marriage or civil partnership
pregnancy or maternity
religion or belief
sexual orientation
Further, they will not be disadvantaged by conditions or requirements, which cannot be
shown to be relevant to the job or justified as necessary on operational grounds.
Employees are reminded of the importance of the HCA Code of Conduct and expectations in
terms of how they conduct themselves at work.
HCA and its Directors place great emphasis on maintaining policies and procedures which
are free from all forms of discrimination. Policies, procedures, and practices will be regularly
monitored and any necessary amendments made to ensure its aims are achieved.
6.2 Discrimination
Discrimination is defined as less favourable treatment because of a protected characteristic,
this also covers less favourable treatment because of an association with someone with a
protected characteristic or an incorrect belief that someone has a protected characteristic.
Discrimination can take many forms:
 Direct discrimination:
Occurs when someone is treated less favourably from others in the same
circumstances due to a particular characteristic that is protected by law. An example
of direct discrimination would be to refuse to appoint someone to a particular job
simply because of their nationality.
 Indirect Discrimination:
Occurs when applying a provision, criterion, or practice which, although applied
equally to everyone, is such that a person with a particular characteristic that is
protected by law cannot comply with it, and the provision, criterion or practice
cannot be justified. An example of indirect discrimination would be making a rule
about uniform which would disadvantage those from a certain racial or ethnic group,
and for which there was no justification.
 Associative Discrimination:
Where a person treats another person differently on the basis that they have an
association with a person who has a particular characteristic protected by law. An
example of this includes a male being subjected to harassment on the basis that his
partner is undergoing gender reassignment surgery.
 Perceptive Discrimination:
Where a person treats another person differently because they perceive them as
having a protected characteristic that is protected by law. An example of this is
where an individual in his 50s is not given a promotion because the recruitment
panel presumes he is in his late 20s, and therefore inexperienced. This could amount
to age discrimination based on perception.
 Disability Discrimination:
A person discriminates against a disabled person if that person treats the other
unfavourably because of something arising in consequence of their disability and
they cannot show that the treatment is a proportionate means of achieving a
legitimate aim.
It is possible to discriminate against a person on more than one ground based on
characteristics that are protected by law. For example, discrimination can take place in
relation to the same person on the basis of their race, sex, and religion.
6.3 Harassment and Bullying
HCA has a separate Bullying and Harassment Policy with a view to preventing bullying and
harassment in the workplace, and to ensure appropriate steps are taken to investigate and
take any necessary action where an allegation of bullying and / or harassment is made.
6.4 Victimisation
Victimisation occurs when an individual is treated less favourably because they have taken
action to assert their legal rights under discrimination legislation or has assisted a colleague
to do so.
6.5 Customers / Clients
This policy applies equally to the treatment of HCA customers/clients. In promoting equality
of opportunity, HCA fulfils its social responsibilities towards its employees, customers and
clients, and communities in which it operates, and also recognises its legal obligations under
the relevant equality legislation.

7.1 Religious Observance
Many religions or beliefs have special festival or spiritual observance days. An employee
may request annual leave in order to celebrate festivals or attend ceremonies. Managers
should sympathetically consider such a request where it is reasonable and practical for the
employee to be away from work and they have sufficient annual leave to be taken from
their entitlement. In dealing with such matters, Line Managers must seek to balance the
operational needs of their service with the religious or belief needs of employees. Any
request should also be considered in accordance with the HCA Annual Leave Policy.
Some religions or beliefs have specific dietary requirements. If employees bring food into
the workplace they may need to store and heat food separately from other food. This
should be accommodated if reasonably practicable to do so.
Some religions require their followers to pray at specific times during the day. Employees
may request access to an appropriate quiet place to undertake their religious observance,
this should be accommodated whenever possible. HCA is not required to provide time and
facilities (e.g. a Prayer room). However, if a quiet place can be found, and allowing its use
for prayer does not interfere with the business, Line Managers should positively consider
allowing the request.
7.2 Dress Code
HCA operates a Dress Code and Appearance Policy which recognises cultural / religious
considerations. This policy is available in the Policy Library.
s policy document is uncontrolled. Please access the Policy Library for the most current version.

All reasonable endeavours will be made to ensure that individuals are treated equally and
fairly, and that decisions on recruitment, selection, training, promotion, and career
development are based solely on reasonable and objective criteria, including but not limited
to merits, ability to do work of a particular kind, and job criteria.
This policy applies to all aspects of employment, including the advertisement of jobs,
recruitment and appointment of employees, appraisals, promotion, conduct at work,
training, and conditions of work, pay, benefits, disciplinary and grievance procedures, and
termination of employment.
Line Managers must ensure that any employee involved in recruitment, in particular, has
had the necessary training with regards to the application of this policy.
Line Managers should note that the imposition of a condition or requirement of
employment, which whether intended or not, adversely affects, or favours one particular
group will also be unlawful, unless it can be reasonably and objectively justified on grounds
of business need. By way of example, a height requirement of 5’10” will eliminate some
men, but proportionately more women, and so may therefore be unlawful. In all such
situations, Line Managers should contact the local HR team for guidance.
In the event that an employee becomes disabled during their employment and / or unable
to perform their role, the Line Manager must ensure that “reasonable adjustments” to their
employment or working conditions are considered and where practicable implemented.
These will be adjustments which are considered necessary to assist the employee in the
performance of their duties. Contact the local HR team for advice.
Any employee who wishes to complain about discriminatory conduct (including conduct on
the basis of sex, race, religion or belief, sexual orientation, change of gender, age, marriage
or civil partnership status or disability) should in the first instance contact the local HR team,
who will discuss this informally and advise on the options available to them. HCA wishes to
ensure that employees feel able to raise such concerns / complaints, and no individual will
be penalised or face disciplinary action for raising such concerns in good faith.
In the event that an employee wishes to formalise their concerns / complaint, an employee
may instigate HCA’s Grievance Policy / Procedure or HCA’s Bullying and Harassment Policy /
Procedure (if appropriate). Details of these can be found in the Policy Library.

 Line Managers are responsible for familiarising themselves with this policy and for
following it with regard to matters such as requests for leave.
 Employees are responsible for familiarising themselves with this policy, for informing
their Line Manager of their particular requirements, and for making up any time lost
as a result of religious/beliefs observance.
 Employees who experience discrimination from service users or contractors working
within HCA should inform their Line Manager as soon as possible, in order that the
situation can be resolved. Employees may wish to refer to the Bullying and
Harassment Policy or the Grievance Policy.
 Line Managers must notify their local HR team of complaints that are brought to
their attention and be guided by their advice.
The policy will be distributed to the following groups:
Group Responsibility
Vice President of Human Resources Accountable for delivery
Head of Employee Relations Review and implementation oversight
Facility Human Resources Team Implementation
Facility Senior Management Team Information and support of process
Line Managers Information and support of process
Employees Information

Review and monitoring of the Diversity and Inclusion Policy will take place through the HR
system and the employee relations case monitoring process.

Training on this policy is available from your local HR Team.

Equality Act 2010

– End Document