Equality, diversity and inclusion policy
Policy owner - Managing Director
Approved by - Board of Directors
Version 2.0
Effective date - September 2026
Review frequency - Annual
Next review - September 2027, or sooner following equality, employment,
REC or operational changes
1. Policy statement
DCM Recruitment Ltd is committed to promoting equality, diversity and inclusion throughout its employment practices and recruitment services. We aim to provide a working environment and recruitment service that is fair, respectful, accessible and free from unlawful discrimination, harassment and victimisation.
DCM will make recruitment and employment decisions on relevant skills, qualifications, experience, competence and suitability for the role. We will not knowingly participate in discriminatory recruitment instructions or practices.
2. Legal framework
This policy is principally based on the Equality Act 2010 and applies alongside other relevant employment, recruitment, safeguarding and data protection requirements.
The Equality Act 2010 protects against unlawful discrimination because of the following nine protected
characteristics:
• age;
• disability;
• gender reassignment;
• marriage and civil partnership;
• pregnancy and maternity;
• race;
• religion or belief;
• sex; and
• sexual orientation.
Protection can also apply where discrimination is because of a person's association with someone who has a protected characteristic or because they are perceived to have a protected characteristic, where the relevant provisions of the Equality Act apply.
3. Scope
This policy applies to all DCM Recruitment Ltd Directors, employees, recruitment consultants and representatives, as well as candidates, work-seekers and agency workers using DCM's services.
It applies throughout advertising, attraction, registration, shortlisting, interviewing, vetting, selection, introduction, placement, assignment management, training, complaints and internal employment decisions.
4. Forms of unlawful treatment
DCM will seek to prevent and address:
• direct discrimination;
Equality, diversity and inclusion policy | Version 2.0 | September 2026
• indirect discrimination;
• discrimination arising from disability;
• failure to make reasonable adjustments for disabled people;
• harassment related to a protected characteristic;
• sexual harassment; and
• victimisation because someone has raised, supported or been involved in an equality complaint or allegation.
Staff must not treat apparently neutral criteria as automatically fair. A requirement or practice that
disadvantages people sharing a protected characteristic may be unlawful unless it can be objectively justified where the law permits.
5. Inclusive recruitment
DCM Recruitment Ltd will use fair, transparent and objective recruitment methods. Selection criteria must relate to genuine requirements of the role and must not unnecessarily exclude or disadvantage applicants.
Staff involved in recruitment must:
• use clear, role-related and proportionate job criteria;
• avoid discriminatory wording in advertisements, searches, shortlists and client communications;
• assess candidates consistently against relevant evidence of merit and suitability;
• offer and implement reasonable adjustments during registration, assessment and interview processes where required;
• only ask pre-employment health or disability questions where the law permits, including to identify
reasonable adjustments or establish whether an essential function can be carried out;
• keep equality-monitoring information separate from selection decisions wherever practicable;
• avoid assumptions based on age, disability, family status, name, accent, race, religion, sex, sexual orientation or any other protected characteristic; and
• record and escalate any client request that appears discriminatory.
6. Disability and reasonable adjustments
DCM will take reasonable steps to ensure disabled candidates, workers and employees are not placed at a substantial disadvantage.
Reasonable adjustments may include adapting communication methods, providing information in an alternative
format, allowing additional time, changing interview arrangements, using an accessible venue, adjusting working arrangements or considering alternative ways for an individual to demonstrate suitability.
Staff must not reject a candidate merely because an adjustment is required. Any uncertainty about whether an adjustment is reasonable should be escalated to a Director rather than refused informally.
7. Positive action
The Equality Act permits limited positive action in certain circumstances to address disadvantage, particular needs or under-representation connected with a protected characteristic.
Positive action is not the same as positive discrimination. DCM will not select a less suitable candidate simply because they have a protected characteristic. Any proposed positive-action initiative must be considered carefully and approved by a Director before use.
8. Working with clients
DCM works with schools, trusts and other educational organisations and expects recruitment instructions to comply with equality law.
If a client asks DCM to select, exclude or favour candidates on a basis connected to a protected characteristic, staff must not automatically follow the instruction. The consultant must clarify the genuine role requirement and escalate the matter where necessary.
DCM will only apply an occupational requirement or other lawful exception where there is a proper legal basis and the requirement is genuinely necessary and proportionate.
DCM will support inclusive working environments and will take concerns about discriminatory treatment of agency workers seriously.
9. Harassment, sexual harassment and third-party conduct
DCM does not tolerate harassment or sexual harassment by employees, candidates, agency workers, clients or other third parties.
DCM will take reasonable preventative steps to reduce the risk of sexual harassment, including through policy, training, reporting routes, prompt investigation and appropriate action.
In readiness for the strengthened legal requirements taking effect in October 2026, DCM will work to an 'all reasonable steps' preventative standard and will consider risks arising from third parties such as clients, school staff, candidates and others encountered through work.
Any report of harassment or sexual harassment must be taken seriously, recorded and escalated promptly.
Where the matter also raises safeguarding concerns, the Safeguarding and Child Protection Policy must be followed without delay.
10. Equality concerns and complaints
Candidates, workers, employees and clients are encouraged to raise concerns about discrimination, harassment, victimisation or unequal treatment.
Equality-related complaints will be handled under the DCM Complaints Policy and Procedure or, for DCM employees raising an internal employment matter, the appropriate grievance procedure.
A person will not be disadvantaged for raising a genuine equality concern, supporting another person's complaint or participating in an investigation.
Where an equality concern identifies safeguarding, whistleblowing, data protection or regulatory issues, DCM will also use the relevant specialist procedure.
11. Responsibilities
11.1 Directors
• ensure this policy is implemented and reviewed;
• provide appropriate training, guidance and oversight;
• ensure equality concerns and complaints are investigated fairly;
• challenge discriminatory practices and client instructions; and
• monitor recurring issues and improvement actions.
11.2 Employees, consultants and representatives
• apply fair and objective recruitment practices;
• treat people with dignity and respect;
• offer reasonable adjustments appropriately;
• avoid discriminatory assumptions, language and decision-making;
• report or escalate discriminatory requests, conduct or complaints; and
• complete required equality and inclusion training.
11.3 Candidates and agency workers
• treat clients, colleagues and other workers with dignity and respect;
• comply with relevant equality and conduct requirements in the setting where they work; and
• report discrimination, harassment or victimisation experienced or witnessed during an assignment.
12. Equality monitoring and data protection
Where DCM collects equality-monitoring information, it will be collected and used lawfully, transparently and only for a defined purpose. Equality data will not be used to make recruitment decisions except where a lawful positive-action or other statutory provision applies.
Special category personal information will be handled in accordance with DCM's Data Protection & GDPR
Policy and Candidate and Work-Seeker Privacy Notice, with access restricted to authorised persons.
13. Training and staff awareness
Equality, diversity and inclusion training is mandatory for Directors, employees and consultants involved in recruitment or candidate/client management. It forms part of induction and ongoing professional development.
Training will include:
• the Equality Act 2010 and the nine protected characteristics;
• direct and indirect discrimination, harassment and victimisation;
• reasonable adjustments and lawful health/disability questions during recruitment;
• inclusive advertising, shortlisting and interviewing;
• how to respond to discriminatory client instructions;
• positive action and the difference between positive action and unlawful positive discrimination;
• sexual harassment prevention and third-party risks; and
• reporting, complaints and escalation routes.
Refresher training will be completed at least annually and when significant legal or DCM process changes occur. Policy acknowledgements and training records will be retained as compliance and REC audit evidence.
14. Monitoring and review
The Directors will monitor the effectiveness of this policy through recruitment activity, candidate and client feedback, equality-related complaints, reported discriminatory requests, reasonable-adjustment issues, training records and relevant legislative or REC developments.
Where monitoring identifies a recurring issue or barrier, DCM will consider corrective action, changes to procedure or further training.
This policy will be reviewed at least annually and sooner following a significant equality-related complaint, legal change, audit finding or material change in DCM's working practices.
Related documents
• Complaints Policy and Procedure
• Data Protection & GDPR Policy
• Candidate and Work-Seeker Privacy Notice
• Safeguarding and Child Protection Policy
• Safer Recruitment Policy
• Recruitment, Selection and Vetting Policy
• Staff Induction, Training and Development Pack