1. Purpose and Commitment

Cutting Edge Projects Limited (“the Company”) is firmly committed to equal employment opportunity for all individuals. The Company believes that a diverse and inclusive workforce drives innovation, strengthens our culture, and enables us to deliver the best results for our clients and stakeholders.

This Policy sets out the Company’s commitment to ensuring that all employment decisions — including recruitment, selection, promotion, training, compensation, benefits, discipline, and termination — are made on the basis of merit, qualifications, and legitimate business requirements alone.

2. Scope

This Policy applies to:

• All current employees (full-time, part-time, temporary, and casual)
• Job applicants and candidates at all stages of recruitment
• Contractors, consultants, agency workers, and volunteers
• Directors, officers, and management at all levels
• Third parties acting on behalf of the Company

3. Protected Characteristics

The Company prohibits discrimination, harassment, and victimisation based on any of the following protected characteristics:

4. Forms of Prohibited Conduct

The following conduct is strictly prohibited under this Policy:

4.1 Direct Discrimination

Treating a person less favourably than another because of a protected characteristic. Example: Refusing to promote a qualified employee because of their religion.

4.2 Indirect Discrimination

Applying a provision, criterion, or practice that appears neutral but disproportionately disadvantages individuals with a protected characteristic, without legitimate justification.

4.3 Harassment

Unwanted conduct related to a protected characteristic that has the purpose or effect of violating a person’s dignity, or creating an intimidating, hostile, degrading, or humiliating environment. This includes verbal, physical, written, and digital conduct.

4.4 Sexual Harassment

Any unwanted conduct of a sexual nature, including unwanted physical contact, sexual comments, requests for sexual favours, or display of sexually offensive material.

4.5 Victimisation

Treating a person less favourably because they have made, or are suspected of making, a complaint under this Policy, or because they have supported or assisted another person in doing so.

5. Recruitment and Selection

The Company is committed to fair, transparent, and merit-based recruitment. To this end:

• Job advertisements will be inclusive and free from discriminatory language
• Person specifications will contain only genuine, job-related requirements
• Interview panels will be trained on unconscious bias and structured interviewing
• Selection decisions will be documented and based solely on objective criteria
• Reasonable adjustments will be made for candidates with disabilities throughout the recruitment process

6. Pay and Benefits Equity

The Company is committed to equal pay for equal work. All remuneration decisions are based on the role, experience, performance, and market rates — never on any protected characteristic.

The Company will conduct periodic pay equity reviews and take corrective action where any unjustified disparities are identified.

7. Reasonable Adjustments

The Company will make reasonable adjustments to remove barriers for employees and applicants with disabilities or other protected needs. This may include:

• Modifications to working hours, patterns, or locations
• Provision of specialist equipment, software, or assistive technology
• Adjustments to job duties or task allocation
• Additional support during training or assessment processes

Employees or applicants requiring adjustments should contact Human Resources. All requests will be considered promptly and in confidence.

8. Responsibilities

8.1 The Company

The Company is responsible for creating and maintaining a working environment free from discrimination and harassment, providing adequate training and resources, and enforcing this Policy fairly and consistently.

8.2 Managers and Supervisors

All managers are responsible for modelling inclusive behaviour, promptly addressing potential breaches of this Policy, supporting team members who raise concerns, and ensuring fair treatment in all people management decisions.

8.3 All Employees

Every employee is expected to treat colleagues, clients, and third parties with respect and dignity, to cooperate with any investigations, and to report breaches of this Policy.

9. Reporting and Complaints Procedure

The Company encourages anyone who believes they have experienced or witnessed a breach of this Policy to come forward without fear of reprisal.

Step 1 — Informal Resolution

Where comfortable, the affected individual may raise the matter directly with the person concerned or with their line manager, with the aim of resolving it informally.

Step 2 — Formal Complaint

If informal resolution is not appropriate or unsuccessful, a formal written complaint should be submitted to the Human Resources department or the Designated Equal Employment Officer.

Step 3 — Investigation

All formal complaints will be investigated promptly, confidentially, and impartially. The complainant and respondent will each have the opportunity to present their account and to be accompanied by a colleague or trade union representative.

Step 4 — Outcome and Appeal

The outcome of the investigation will be communicated in writing. Either party may appeal the outcome within 10 working days. An independent senior manager will conduct the appeal.

10. Disciplinary Consequences

Any employee found to have breached this Policy will be subject to disciplinary action under the Company’s Disciplinary Procedure. Depending on the severity and circumstances, this may include:

• Formal written warning
• Mandatory training or behavioural coaching
• Demotion or transfer
• Dismissal for gross misconduct

Where conduct may constitute a criminal offence, the Company reserves the right to report the matter to the relevant law enforcement authorities.

11. Confidentiality

All complaints, investigations, and related communications will be handled in strict confidence to the extent permitted by law. Information will be disclosed only to those with a legitimate need to know. Breach of confidentiality by any party involved in an investigation will itself be treated as a disciplinary matter.

12. Monitoring and Review

The Company will monitor the effectiveness of this Policy through:

• Regular workforce diversity and pay equity data analysis
• Anonymous employee surveys and inclusion audits
• Tracking of complaint volumes, types, and outcomes
• Annual review of this Policy by HR and senior management

This Policy will be reviewed at least annually, or whenever there is a material change in applicable law or Company structure, to ensure it remains current and effective.

13. Legal Framework

This Policy is designed to comply with applicable equal employment and anti-discrimination legislation, which may include (as relevant to the jurisdictions in which the Company operates):

• Equality Act 2010 (UK)
• Employment Rights Act 1996 (UK)
• Human Rights Act 1998 (UK)
• General Data Protection Regulation (GDPR) / UK GDPR
• ILO Discrimination (Employment and Occupation) Convention, 1958 (No. 111)
• Any applicable local employment law in jurisdictions where the Company operates

Nothing in this Policy limits any rights an individual may have under applicable law.

14. Related Policies

This Policy should be read alongside the following Company policies:

• Anti-Harassment and Bullying Policy
• Disciplinary and Grievance Procedure
• Whistleblowing Policy
• Data Protection and Privacy Policy
• Flexible Working Policy

Cutting Edge Projects Limited is an equal opportunity employer.

This document is the property of Cutting Edge Projects Limited. Unauthorised reproduction is prohibited.