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Equality, Diversity, Inclusion and Human Rights Policy

Black & White Group supports equal opportunity, inclusion, dignity and respect. Participating Businesses must make decisions fairly, prevent unlawful discrimination and respect internationally recognised human rights within their activities and supply chains.

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Our standards

Participating Businesses are expected to:

  1. provide access to work, development and services fairly;
  2. prevent discrimination, harassment, bullying and victimisation;
  3. make reasonable adjustments where required;
  4. consider accessibility when designing services and communications;
  5. base selection and advancement on relevant, objective criteria;
  6. respect freedom, privacy, dignity and lawful worker rights;
  7. prohibit forced labour, child labour and exploitation; and
  8. investigate concerns promptly and fairly.

Decisions must not be unlawfully influenced by age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex, sexual orientation or any other status protected by law.

Responsibilities

Leaders set expectations and act on concerns. Everyone working for or with a Participating Business must behave respectfully and cooperate with reasonable measures that support inclusion and accessibility.

Monitoring

Participating Businesses review complaints, workforce or supplier feedback and other relevant information proportionately. Any equality data is collected only for a clear lawful purpose and handled securely.

Reporting

Practical application

Recruitment, allocation, development, pay, performance, discipline, dismissal, procurement and customer decisions use relevant and objective criteria. Reasonable adjustments are considered through a timely, individual discussion and are not refused solely because a standard process was designed without them. Accessibility and inclusion are considered in work planning, premises, communications, digital services and emergency arrangements.

Harassment, sexual harassment, victimisation, bullying and discriminatory instructions are prohibited whether committed by a worker, manager, customer, supplier or third party. Managers take reasonable steps to prevent sexual harassment and respond to warning signs and reports. Customer preference does not justify unlawful discrimination.

Human-rights due diligence is proportionate to impact and influence, covering safety, privacy, property, fair treatment, labour conditions, modern slavery, vulnerable people and supply chains. Risks to people are prioritised, and remedy is considered where a business caused or contributed to harm.

Monitoring uses only lawful, relevant and sufficiently reliable information, protects confidentiality and avoids misleading conclusions from small samples. Findings inform adjustments, training, supplier engagement and corrective action. No diversity, pay or social-impact statistic is published without a defined dataset and review.

Concerns should be raised through the relevant Participating Business. Retaliation against a person raising a genuine concern is prohibited.

Approval

Approved by David Swaddle, Founder, on 30 August 2026.

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