Matsons Ltd. is committed to encouraging equality, diversity and inclusion among our workforce, and eliminating unlawful discrimination.

The aim is for our workforce to be truly representative of all sections of society and our customers, and for each employee to feel respected and able to give their best.

The organisation - in providing goods and/or services and/or facilities - is also committed against unlawful discrimination of customers or the public.

The policy’s purpose is to:

• Provide equality, fairness and respect for all in our employment, whether temporary, part- time or full-time
• Not unlawfully discriminate because of the Equality Act 2010 protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex and sexual orientation
• Oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents, requests for flexible working, and selection for employment, promotion, training or other developmental opportunities

Matsons Ltd. commits to:

• Encourage equality, diversity and inclusion in the workplace as they are good practice and make business sense.
• Create a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued.
• This commitment includes training managers and all other employees about their rights and responsibilities under the equality, diversity and inclusion policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination.
• All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public.
• Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities.
• Such acts will be dealt with as misconduct under the organisation’s grievance and/or disciplinary procedures, and appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice.
• Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence.
• Make opportunities for training, development and progress available to all staff, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the efficiency of the organisation.
• Decisions concerning staff being based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act).
• Review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law.
• Monitor the make-up of the workforce regarding information such as age, sex, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality, diversity and inclusion, and in meeting the aims and commitments set out in the equality, diversity and inclusion policy.
• Monitoring will also include assessing how the equality, diversity and inclusion policy, and any supporting action plan, are working in practice, reviewing them annually, and considering and taking action to address any issues.

The equality, diversity and inclusion policy is fully supported by senior management and has been agreed with employee representatives.

Details of the organisation’s grievance and disciplinary policies and procedures can be found in the employee handbook or by contacting the HR administrator. This includes with whom an employee should raise a grievance – usually their line manager.

Use of the organisation’s grievance and/or disciplinary procedures does not affect an employee’s right to make a claim to an employment tribunal within three months of the alleged discrimination.

Sexual Harassment Policy

Policy Statement

Matsons Ltd. is committed to providing a safe environment for all its employees free from discrimination on any ground and from harassment at work including sexual harassment. Matsons Ltd will operate a zero-tolerance policy for any form of sexual harassment in the workplace, treat all incidents seriously and promptly investigate all allegations of sexual harassment. Any person found to have sexually harassed another will face disciplinary action, up to and including dismissal from employment.

All complaints of sexual harassment will be taken seriously and treated with respect and in confidence. No one will be victimised for making such a complaint.

Definition of sexual harassment

Sexual harassment is unwelcome conduct of a sexual nature which makes a person feel offended, humiliated and/or intimidated. It includes situations where a person is asked to engage in sexual activity as a condition of that person’s employment, as well as situations which create an environment which is hostile, intimidating or humiliating for the recipient.

Sexual harassment can involve one or more incidents and actions constituting harassment may be physical, verbal and non-verbal. Examples of conduct or behaviour which constitute sexual harassment include, but are not limited to:

Physical conduct

• Unwelcome physical contact including patting, pinching, stroking, kissing, hugging, fondling, or inappropriate touching
• Physical violence, including sexual assault
• Physical contact, e.g. touching, pinching
• The use of job-related threats or rewards to solicit sexual favours

Verbal conduct

• Comments on a worker’s appearance, age, private life, etc.
• Sexual comments, stories and jokes
• Sexual advances
• Repeated and unwanted social invitations for dates or physical intimacy
• Insults based on the sex of the worker
• Condescending or paternalistic remarks
• Sending sexually explicit messages (by phone or by email)

Non-verbal conduct

• Display of sexually explicit or suggestive material
• Sexually-suggestive gestures
• Whistling
• Leering

Anyone can be a victim of sexual harassment, regardless of their sex and of the sex of the harasser. Matsons Ltd. recognises that sexual harassment may also occur between people of the same sex. What matters is that the sexual conduct is unwanted and unwelcome by the person against whom the conduct is directed.

Matsons Ltd. recognises that sexual harassment is a manifestation of power relationships and often occurs within unequal relationships in the workplace, for example between manager or supervisor and employee or an employee and a supplier, or an employee and a client.

Anyone, including employees of Matsons Ltd. clients, customers, casual workers, contractors or visitors who sexually harasses another will be reprimanded in accordance with this internal policy. All sexual harassment is prohibited whether it takes place within Matsons Ltd. premises or outside, including at social events, business trips, training sessions or conferences sponsored by Matsons Ltd.

Complaints procedures

Anyone who is subject to sexual harassment should, if possible, inform the alleged harasser that the conduct is unwanted and unwelcome. Matsons Ltd. recognises that sexual harassment may be occurring in unequal relationships (i.e. between a supervisor and his/her employee) and that it may not be possible for the victim to inform the alleged harasser.

If a victim cannot directly approach an alleged harasser, he/she can approach one of the designated staff members responsible for receiving complaints of sexual harassment. This person could be another supervisor, a member of the human resources department, etc.

When a designated person receives a complaint of sexual harassment, he/she will:

• Immediately record the dates, times and facts of the incident(s)
• Ascertain the views of the victim as to what outcome he/she wants
• Ensure that the victim understands the company’s procedures for dealing with the complaint
• Discuss and agree the next steps: either informal or formal complaint.
  on the understanding that choosing to resolve the matter informally does not preclude the victim from pursuing a formal complaint if he/she is not satisfied with the outcome
• Keep a confidential record of all discussions
• Respect the choice of the victim
• Ensure that the victim knows that they can lodge the complaint outside of the company
• Through the relevant country/legal framework

Throughout the complaints procedure, a victim is entitled to be helped by a counsellor within the Company. Matsons Ltd. will nominate a number of counsellors and provide them with special training to enable them to assist victims of sexual harassment. Matsons Ltd. recognises that because sexual harassment often occurs in unequal relationships within the workplace, victims often feel that they cannot come forward. Matsons Ltd. understands the need to support victims in making complaints.

Informal complaints mechanism

If the victim wishes to deal with the matter informally, the designated person will:

• Give an opportunity to the alleged harasser to respond to the complaint
• Ensure that the alleged harasser understands the complaints mechanism
• Facilitate discussion between both parties to achieve an informal resolution which is acceptable to the complainant, or refer the matter to a designated mediator within the company to resolve the matter
• Ensure that a confidential record is kept of what happens
• Follow up after the outcome of the complaints mechanism to ensure that the behaviour has stopped
• Ensure that the above is done speedily and within 14 days of the complaint being made

Formal complaints mechanism

If the victim wants to make a formal complaint or if the informal complaint mechanism has not led to a satisfactory outcome for the victim, the formal complaint mechanism should be used to resolve the matter.

The designated person who initially received the complaint will refer the matter to a senior human resources manager to instigate a formal investigation. The senior human resources manager may deal with the matter him/herself or refer the matter to an internal or external investigator or refer it to management.

The person carrying out the investigation will:

• Interview the victim and the alleged harasser separately
• Interview other relevant third parties separately
• Decide whether or not the incident(s) of sexual harassment took place
• Produce a report detailing the investigations, findings and any recommendations
• If the harassment took place, decide what the appropriate remedy for the victim is, in consultation with the victim (i.e.- an apology, a change to working arrangements, a promotion
• If the victim was demoted as a result of the harassment, training for the harasser, discipline, suspension, dismissal)
• Follow up to ensure that the recommendations are implemented, that the behaviour has stopped and that the victim is satisfied with the outcome
• If it cannot determine that the harassment took place, he/she may still make recommendations to ensure proper functioning of the workplace
• Keep a record of all actions taken
• Ensure that the all records concerning the matter are kept confidential
• Ensure that the process is done as quickly as possible and in any event within 90 days of the complaint being made.

Outside complaints mechanisms

A person who has been subject to sexual harassment can also make a complaint outside of the company. They can do so through an employment tribunal.

Sanctions and disciplinary measures

Anyone who has been found to have sexually harassed another person under the terms of this policy is liable to any of the following sanctions:

• Verbal or written warning
• Adverse performance evaluation
• Reduction in wages
• Transfer
• Demotion
• Suspension
• Dismissal

The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable deterrent sanctions will be applied to ensure that incidents of sexual harassment are not treated as trivial. Certain serious cases, will result in the immediate dismissal of the harasser.

Implementation of this policy

Matsons Ltd. will ensure that this policy is widely disseminated to all relevant persons. It will be included in the staff handbook. All new employees must be trained on the content of this policy as part of their induction into the company.

Every year,cMatsons Ltd. will require all employees to attend a refresher training course on the content of this policy.

It is the responsibility of every manager to ensure that all his/her employees are aware of the policy.

Monitoring and evaluation

Matsons Ltd. recognises the importance of monitoring this sexual harassment policy and will ensure that it anonymously collects statistics and data as to how it is used and whether or not it is effective.

Supervisors, managers and those responsible for dealing with sexual harassment cases will report on compliance with this policy, including the number of incidents, how they were dealt with, and any recommendations made. This will be done on a yearly basis. As a result of this report, the company will evaluate the effectiveness of this policy and make any changes needed.