Equity, Diversity & Inclusion Policy

1  Introduction

1.1 Scope

1.1.1  This policy applies to individuals employed by Mortgage Brain Limited, AE3 Media Limited and any other companies under the ownership of Mortgage Brain Holdings Limited (combined: the “Company” or “We”), including managers, officers, directors, part-time and fixed term employees (combined: “Colleagues” or “You”). It does not apply to workers, contractors, consultants or any self-employed individuals working for the organisation. The policy applies to the advertisement of jobs, recruitment and appointment to them, training, conditions of work, pay and to every other aspect of employment. It applies to the regular activities and projects organised and run by the Company. It applies equally to the treatment of the Company’s customers (clients) and business contacts.

1.1.2  The policy accompanies our Bullying, Harassment & Sexual Harassment Policy and Menopause Policy.

1.2 Purpose

1.2.1 The Company is committed to treating all job applicants and colleagues fairly and equally, regardless of:
• Disability;
• Age;
• Race;
• Sexual orientation;
• Religion or belief;
• Marital or civil partnership status;
• Gender, gender identity, or gender reassignment;
• Pregnancy, maternity, breastfeeding or paternity;
• Race, racial group, national or ethnic origins, or nationality; and
• Part-time or fixed-term status.

1.2.2 The Company promotes a work environment that is free from discrimination; where each individual has equal access to opportunities such as training, career development and promotion. The Company will not tolerate discrimination against any colleague, either directly or indirectly, for any protected characteristic as stated in the Equality Act 2010.

1.2.3 The objective of this policy and procedure is to promote good practice in this area in order to eliminate discrimination and harassment as far as is reasonably possible.

1.2.4 This policy applies to all colleagues and managers within all functions. Every manager and colleague has personal responsibility for the implementation of the policy, which must be adhered to in their day-to-day work.

1.3 Intended Audience

1.3.1 This document is intended to be read by all Company colleagues and must not be provided to Third Parties without approval from the document owners (currently, the Senior HR Manager and / or the Chief Financial Officer (CFO))Policy Statement

2  Overview

2.1.1 The Company seeks to secure genuine equity of opportunity in all aspects of its activities as an employer thus ensuring that no present colleague or potential applicant receives less favourable treatment than another.

2.1.2 The Company will, therefore, take all reasonable, practicable steps to ensure:
• When decisions are made about an individual the only personal characteristics taken into account will be those which, as well as being consistent with relevant legislation, are necessary for the proper performance of the work involved.
• When such decisions are made about an individual they will be based solely on an assessment of the capability, qualifications and fitness for the job of that individual regardless of their gender; sexual orientation; marital or civil partnership status; gender, gender identity or reassignment; race, racial group, religion or belief; nationality, ethnic or national origin; disability or age; pregnancy, maternity or paternity; trade union membership; or the fact that they are a part-time worker or a fixed term colleague or any other personal circumstances or characteristics which are not directly relevant.
• Employment policies, practices and procedures which are fair, equitable and consistent with the skills and abilities of the Company’s present or potential Colleagues are applied so that no individual is disadvantaged by conditions or requirements which cannot be shown to be justifiable.
• The Company will not discriminate against a job applicant or Colleague due to their disability and will make reasonable adjustments to accommodate these colleagues. If a colleague becomes disabled during their employment, the Company will make every effort to enable them to remain in employment;
• Terms and conditions of employment are awarded fairly and equitably amongst the Company’s Colleagues;
• Opportunities for promotion, relocation or training and development are available to all Colleagues and are available on a fair and equitable basis in line with their needs;
• Part-time Colleagues will not be treated less favourably than comparable full-time colleagues. Part-time Colleagues will receive the same pro-rata terms and conditions and access to training and development;
• Grievances and disciplinary situations are dealt with fairly and consistently;
• A Colleague will not be treated less favourably during her pregnancy and Colleagues will be able to return to work after a period of maternity, shared parental or parental leave;
• The performance management process, mid-year and annual reviews and evaluation criteria have been designed to assess actual job performance focussing on performance goals, personal development goals and competencies and is not affected by any protected characteristic;
• Dismissals and redundancies will not adversely affect Colleagues predominately included in one of the above protected characteristics categories;
• Any form of sexual, racial or other harassment or victimisation will not be tolerated and will be dealt with in accordance with the Company’s Bullying, Harassment & Sexual Harassment Policy.

2.2  What we expect from you

2.2.1 We expect you, and every one of our Colleagues, to take personal responsibility for observing, upholding, promoting and applying this policy. Our culture is made in the day-to-day working interactions between us so creating the right environment is a responsibility that we all share.

2.2.2 We expect you to treat your Colleagues and third parties (including customers, suppliers, contractors, agency staff and consultants) fairly and with dignity, trust and respect. This means allowing for different views and viewpoints and making space for others to contribute.

2.2.3 By embedding such values and constructively challenging inappropriate comments or ways of working, you can help us achieve and maintain a truly inclusive workplace culture.

2.2.4 Any dealings that you have with Colleagues, or third parties must be free from any form of discrimination, harassment, victimisation or bulling.

2.2.5 If any of our Colleagues are found to have committed, authorised or condoned an act of discrimination, harassment, victimisation or bullying, the Company will take appropriate action in accordance with our Disciplinary & Grievance & Capability Procedures procedure up to and including dismissal (for those to whom it applies).

2.2.6 You should be aware that you can be personally liable for discrimination and harassment.

3  Definitions and Descriptions

3.1 Discrimination

3.1.1 The Equality Act 2010 prohibits discrimination because of certain protected characteristics. These are:
• disability;
• sex;
• gender reassignment;
• marital or civil partnership status;
• race;
• religion or belief;
• sexual orientation;
• age; and
• pregnancy or maternity.

3.1.2  Discrimination can be intentional or unintentional and may occur directly, indirectly, by association, or by perception (see
https://www.acas.org.uk/discrimination-and-the-law).

3.1.3  There are also two specific types of discrimination that apply only to disability: “discrimination arising from disability” and “failing to make reasonable adjustments” (see https://www.acas.org.uk/disability-discrimination).

3.1.4  Discrimination is not always obvious and can be subtle and unconscious. This stems from a person’s general assumptions about the abilities, interests and characteristics of a particular group that influences how they treat those people (known as “unconscious bias”). Such assumptions or prejudices may cause them to apply requirements or conditions that put those in particular groups at a disadvantage. Examples include:
• steering Colleagues into particular types of work on the basis of
stereotypical assumptions without considering the particular attributes and abilities of individuals;
• recruiting or promoting individuals into particular roles because of
assumptions about the reactions or preferences of other colleagues or clients; and
• using different standards for different groups of Colleagues to judge performance.

3.2 Different types of discrimination under the Equality Act 2010

3.2.1  Direct discrimination: Treating someone less favourably because of a protected characteristic compared with someone who does not have that characteristic (for example choosing not to recruit someone because they are disabled and you think they “wouldn’t fit in” to the team).

3.2.2  Indirect discrimination: Where a policy, procedure or way of working that applies to everyone puts people with a particular protected characteristic at a disadvantage, compared with people who do not have that characteristic, unless there is a good reason to justify it. An example is introducing a requirement for all Colleagues to finish work at 6pm. It is arguable that female Colleagues, who statistically bear the larger share of childcare responsibilities could be at a disadvantage if the new working hours prevent them from collecting their children from school or nursery.

3.2.3  Associative discrimination: Treating someone less favourably because they are associated with someone who has a protected characteristic, for example because their partner is transgender.

3.2.4  Discrimination by perception: Treating someone less favourably because you perceive them to have a protected characteristic even if they do not, for example choosing not to promote someone because you mistakenly perceive them to be gay.

3.2.5  Discrimination arising from disability: Treating someone unfavourably because of something connected with that person’s disability and where such treatment is not justified. Examples include:
• dismissing or failing to pay a bonus to someone because of their disability-related absence; or
• disciplining someone for losing their temper where such loss of temper was out of character and was due to severe pain caused by them having cancer.

3.2.6  Failing to make reasonable adjustments: Employers are legally obliged to make reasonable adjustments to ensure that aspects of employment, or the employer’s premises, do not put a disabled person at a substantial disadvantage. Failing to comply with this duty is unlawful.

Examples of reasonable adjustments might include:
• allocating some of the disabled person’s duties to a colleague;
• changing their working hours or place of work;
• adjusting procedures for assessing job candidates; and
• modifying disciplinary and grievance procedures.

3.3  Harassment and Sexual Harassment

3.3.1  Harassment is unwanted conduct related to a protected characteristic that has the purpose or effect of:
• violating someone else’s dignity; or
• creating an intimidating, hostile, degrading, humiliating or offensive environment for someone else.

3.3.2  Sexual harassment is:
• conduct of a sexual nature that has the purpose or effect of violating someone’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment; and
• less favourable treatment related to gender or gender reassignment that occurs because of a rejection of, or submission to, sexual conduct.

3.3.3  You should refer to our Bullying, Harassment & Sexual Harassment Policy for further information on our procedure for reporting harassment.

3.3.4  The Company recognises its strengthened legal duty to take all reasonable steps to prevent harassment, in line with developments under the Employment Rights Act 2025. This includes proactively identifying and addressing risks of harassment (including by third parties), ensuring appropriate training, and taking swift, effective action where concerns are raised.

3.4  Victimisation

3.4.1  Victimisation is treating another person detrimentally either because that person has made a complaint of discrimination, harassment or sexual harassment, or because they have supported someone else who has made such a complaint, for example by giving a witness statement that supports the allegations.

3.4.2  You should refer to our Disciplinary, Grievance and Capability Procedures for further information if you believe you have experienced victimisation.

3.5  Bullying

3.5.1  There is no legal definition of bullying. However, we regard it as conduct that is offensive, intimidating, malicious, insulting, or an abuse or misuse of power, and usually persistent, that has the effect of undermining, humiliating or injuring the recipient.

3.5.2  Bullying can be physical, verbal or non-verbal conduct. It is not necessarily face to face and can be done by email, phone calls, online or on social media.

Bullying may occur at work or outside work.

3.5.3  If the bullying relates to a person’s protected characteristic, it may also constitute harassment and, therefore, will be unlawful.

3.5.4  You should refer to our Bullying, Harassment & Sexual Harassment policy for further information on our procedure for reporting bullying.

4 Equity of Opportunity

4.1 Recruitment

4.1.1  We take reasonable and appropriate steps to encourage job applications from as diverse a range of people as possible.

4.1.2  Anyone making a decision about recruitment must not discriminate in any way and must have completed the Equity, Diversity and Inclusion eLearning and any other appropriate training if required.

4.1.3  Every decision-maker should challenge themselves, and other members of the recruitment selection panel, to make sure that any stereotypes, unconscious bias or prejudice do not play any part in recruitment decisions.

4.2 Career Development

4.2.1  Any decision you make relating to a person’s promotion or career development must be free from discrimination.

4.2.2  We ensure that selection criteria and processes for recruitment and promotion are reviewed on a regular basis so that there is no discriminatory impact on a certain group.

4.3 Talking about disability

4.3.1  We understand that some people find it hard to discuss their disabilities and that disability can be invisible.

4.3.2  Psychological safety, where people feel able to speak up about their experiences without fear of negative consequences, is paramount to ensuring disability inclusion.

4.3.3  However, this is only possible if we treat people with dignity, trust and respect and we expect everyone to uphold these values.

4.3.4  We do not tolerate ableist language in our organisation. Ableist language is language that is negative, inappropriate or offensive towards people with a disability and may take the form of jokes or “banter”. If you adopt such language, we will take action against you including (for those to whom it applies) under our Disciplinary, Grievance & Capability Procedures.

5  Reasonable adjustments

5.1  If you have a disability, you do not have to tell us. However, we would encourage you to let us know so that we can support you, for example by making reasonable adjustments to our premises or to aspects of your role, or to our working practices.

5.2  If you are experiencing difficulties at work because of your disability, please contact your line manager/the HR team to discuss potential reasonable adjustments that may alleviate or minimise such difficulties. We may need to discuss your needs with you and your medical adviser to help us get the right support in place.

6  Support

6.1  If you have a disability, or you care for someone with a disability, and need emotional support or help with practical issues, please contact our employee assistance programme for free, confidential advice.

7  Training

7.1  The Company has implemented annual Equity, Diversity & Inclusion training for all colleagues to:
• raise awareness;
• develop inclusive thinking and actions;
• ensure we operate appropriately; and
• create a more inclusive and equitable workplace culture for everyone.

7.2  All new starters must complete the Equity, Diversity & Inclusion training as part of their onboarding programme.

8  Procedure

8.1  If you believe that discrimination or harassment is taking place (to you or to someone else), you could speak informally to your manager, Ops Board member or HR. You may also consider raising a formal grievance or if you are being harassed on grounds of your membership of a protected group, a complaint under the Company’s Bullying, Harassment & Sexual Harassment Policy.

8.2  Breaches of this policy will be taken seriously and are likely to result in disciplinary action, up to and including dismissal. All colleagues and managers should be aware that they, as well as the Company, can be held personally liable for acts of bullying, harassment, victimisation and unlawful discrimination in the course of their employment.

9  Monitoring

9.1.1  All colleagues will be asked to complete fields in our HR Information System (Bob) denoting their gender and nationality. This information will be used only for the purpose of monitoring the effectiveness of the Company’s Equality, Diversity and Inclusion strategy.

10  Compliance to Policy

10.1  Non-Compliance

10.1.1  Non-compliance with this policy is likely to result in disciplinary proceedings.

10.2  Exceptions

10.2.1  This policy sets out the baseline mandatory requirements. Where there is a need for departmental / team additions, contact should be made with the Chief Financial Officer or the Senior HR Manager.