Equal Opportunities & Diversity Policy

1. Policy Statement
Retail Media Group Ltd (“the Company”) is committed to achieving a working environment which
provides equality of opportunity and freedom from unlawful discrimination on the grounds of race, sex,
pregnancy and maternity, marital or civil partnership status, gender reassignment, disability, religion or
beliefs, age or sexual orientation. This Policy aims to remove unfair and discriminatory practices
within the Company and to encourage full contribution from its diverse community. The Company is
committed to actively opposing all forms of discrimination.
The Company also aims to provide a service that does not discriminate against its clients and
customers in the means by which they can access the services and goods supplied by the Company.
The Company believes that all employees and clients are entitled to be treated with respect and
dignity.
Any and all personal data used in connection with this Policy shall be collected, held, and processed
in accordance with the Company’s [Employee] Data Protection Policy.

2. Objectives of this Policy
2.1 To prevent, reduce and stop all forms of unlawful discrimination in line with the Equality Act
2010.
2.2 To ensure that recruitment, promotion, training, development, assessment, benefits, pay,
terms and conditions of employment, redundancy and dismissals are determined on the basis
of capability, qualifications, experience, skills and productivity.

3. Definition of Discrimination
Discrimination is unequal or differential treatment which leads to one person being treated more or
less favourably than others are, or would be, treated in the same or similar circumstances on the
grounds of race, sex, pregnancy and maternity, marital or civil partnership status, gender
reassignment, disability, religion or beliefs, age or sexual orientation. Discrimination may be direct or

indirect, and includes discrimination by perception and association.

4. Types of Discrimination
4.1 Direct Discrimination
This occurs when a person or a policy intentionally treats a person less favourably than another on
the grounds of race, sex, pregnancy and maternity, marital or civil partnership status, gender
reassignment, disability, religion or beliefs, age or sexual orientation.
4.2 Indirect Discrimination
This is the application of a policy, criterion or practice which the employer applies to all employees but
which is such that:
 It is it detrimental to a considerably larger proportion of people from the group that the person
the employer is applying it to represents;
 The employer cannot justify the need for the application of the policy on a neutral basis; and
 The person to whom the employer is applying it suffers detriment from the application of the policy.
Example: A requirement that all employees must be 6ft tall if that requirement is not justified by the
position would indirectly discriminate against employees with an oriental ethnic origin, as they are less
likely to be able to fulfil this requirement.
4.3 Harassment
This occurs when a person is subjected to unwanted conduct that has the purpose or effect of
violating their dignity or creating an intimidating, hostile, degrading, humiliating or offensive
environment.
4.4 Victimisation
This occurs when a person is treated less favourably because they have bought or intend to bring
proceedings or they have given or intend to give evidence.

5. Unlawful Reasons for Discrimination
5.1 Sex
It is not permissible to treat a person less favourably on the grounds of sex, marital status, civil
partnership, pregnancy or maternity, gender reassignment or transgender status. This applies to men,
women and those undergoing or intending to undergo gender reassignment. Sexual harassment of
men and women can be found to constitute sex discrimination.
Example: Asking a woman during an interview if she is planning to have any (more) children constitutes discrimination on the ground of gender.

5.2 Age
It is not permissible to treat a person less favourably because of their age. This applies to people of all
ages. This does not currently apply to the calculation of redundancy payments.
5.3 Disability
It is not permissible to treat a disabled person less favourably than a non-disabled person.
Reasonable adjustments must be made to give the disabled person as much access to any services
and ability to be employed, trained, or promoted as a non-disabled person.
5.4 Race
It is not permissible to treat a person less favourably because of their race, the colour of their skin,
their nationality or their ethnic origin.
5.5 Sexual Orientation
It is not permissible to treat a person less favourably because of their sexual orientation or ‘perceived’
sexual orientation. For example, an employer cannot refuse to employ a person because she/he/they
are homosexual, heterosexual or bisexual.
5.6 Religion or Belief
It is not permissible to treat a person less favourably because of their religious beliefs or their religion
or their lack of any religion or belief.

6. Positive Action in Recruitment
Under the Equality Act 2010, positive action in recruitment and promotion applies as of 6 April
2011. ‘Positive action’ means the steps that the Company can take to encourage people from groups
with different needs or with a past record of disadvantage or low participation, to apply for positions
within the Company.
If the Company chooses to utilise positive action in recruitment, this will not be used to treat people
with a protected characteristic more favourably, it will be used only in tie-break situations, when there
are two candidates of equal merit applying for the same position.

7. Reasonable Adjustments
The Company has a duty to make reasonable adjustments to facilitate the employment of a disabled
person. These may include:
7.1 Making adjustments to premises;

7.2 Re-allocating some or all of a disabled employee’s duties;
7.3 Transferring a disabled employee to a role better suited to their disability;
7.4 Relocating a disabled employee to a more suitable office;
7.5 Giving a disabled employee time off work for medical treatment or rehabilitation;
7.6 Providing training or mentoring for a disabled employee;
7.7 Supplying or modifying equipment, instruction and training manuals for disabled employees;
or
7.8 Any other adjustments that the Company considers reasonable and necessary provided such
adjustments are within the financial means of the Company.
If an employee has a disability and feels that any such adjustments could be made by the Company,
they should contact the Human Resources Department.

8. Responsibility for the Implementation of this Policy
All employees, subcontractors and agents of the Company are required to act in a way that does not
subject any other employees or clients to direct or indirect discrimination, harassment or victimisation
on the grounds of their race, sex, pregnancy or maternity, marital or civil partnership status, gender
reassignment, disability, religion or beliefs, age or sexual orientation.
The co-operation of all employees is essential for the success of this Policy. Senior employees are
expected to follow this Policy and to try to ensure that all employees, subcontractors and agents do
the same.
Employees may be held independently and individually liable for their discriminatory acts by the
Company and in some circumstances an Employment Tribunal may order them to pay compensation
to the person who has suffered as a result of discriminatory acts.
The Company takes responsibility for achieving the objectives of this Policy, and endeavours to
ensure compliance with relevant Legislation and Codes of Practice.

9. Acting on Discriminatory Behaviour
In the event that an employee is the subject or perpetrator of, or witness to, discriminatory behaviour,
please refer to our disciplinary and grievance procedures.

10. Advice and Support on Discrimination
Employees may contact any member of the senior management team or other employee representative.

Other contacts include:

Equality and Human Rights Commission
Manchester
Arndale House
The Arndale Centre
Manchester
M4 3AQ

London
Fleetbank House
2-6 Salisbury Square
London
EC4Y 8JX

Cardiff
Block 1, Spur D, Government Buildings
St Agnes Road
Gabalfa
Cardiff
CF14 4YJ

Glasgow
151 West George Street
Glasgow
G2 2JJ

Helpline Telephone Number:

Phone: 0808 800 0082
Textphone: 0808 800 0084
Website: www.equalityhumanrights.com

Citizens Advice Bureau
3rd Floor North
200 Aldersgate Street
London, EC1A 4HD
Website: www.citizensadvice.org.uk

Community Legal Services Direct
Telephone: 0845 345 4 345
Website: www.clsdirect.uk

11. The Extent of the Policy
11.1 The Company seeks to apply this Policy in the recruitment, selection, training, appraisal,
development and promotion of all employees. The Company offers goods and services in a
fashion that complies with the spirit of this Policy.
11.2 This Policy does not form a part of any employment contract with any employee and its
contents are not to be regarded by any person as implied, collateral or express terms to any
contract made with the Company.
11.3 The Company reserves the right to amend and update this Policy at any time.