Equality, Diversity and Inclusion Policy (UK)
Equality Act 2010 — Protected Characteristics & Public Sector Equality Duty
[Company Name]
[Company Street], [Company City], [Company Postcode]
Effective Date: [Policy Date]
1. POLICY STATEMENT
1.1 [Company Name] is committed to promoting equality, diversity, and inclusion in all aspects of its work. We believe that a diverse workforce and an inclusive working environment are essential to our success and to the wellbeing of our employees.
1.2 [Company Name] is committed to ensuring that no employee, job applicant, contractor, or other person connected with the organisation is treated less favourably or subjected to disadvantage on the grounds of any protected characteristic as defined in the Equality Act 2010.
1.3 [Company Name] recognises that equality and diversity are not simply matters of legal compliance but reflect our values as an organisation. We are committed to creating a working environment in which everyone is treated with dignity and respect and in which individual differences are valued.
1.4 This policy applies to all employees, workers, officers, volunteers, and contractors of [Company Name], as well as to third parties such as customers, clients, suppliers, and visitors to our premises.
2. LEGAL FRAMEWORK
2.1 This policy is made in compliance with the following legislation and guidance:
- Equality Act 2010 — which consolidates previous equality legislation and defines the nine protected characteristics, the forms of prohibited conduct (direct discrimination, indirect discrimination, harassment, and victimisation), and the positive duty on employers to make reasonable adjustments for disabled persons.
- Public Sector Equality Duty (Equality Act 2010 s.149) — which requires public authorities to have due regard to the need to eliminate unlawful discrimination, advance equality of opportunity, and foster good relations between persons who share a protected characteristic and those who do not.
- Human Rights Act 1998 — which incorporates the European Convention on Human Rights into domestic law, including Article 14 (prohibition of discrimination) and Article 8 (right to respect for private and family life).
- Employment Rights Act 1996 — which provides the statutory framework for employment rights, including protections against unfair dismissal.
- ACAS Code of Practice on Disciplinary and Grievance Procedures — which sets out the standards expected of employers when handling disciplinary matters and grievances, including those arising from allegations of discrimination.
- ACAS guidance on equality, diversity, and inclusion — which provides practical guidance for employers on implementing effective equality and diversity policies.
2.2 This policy will be interpreted in a manner consistent with the requirements of the Equality Act 2010 and any guidance issued by the Equality and Human Rights Commission (EHRC).
3. SCOPE
3.1 This policy applies to all aspects of the employment relationship, including:
- recruitment, selection, and induction;
- terms and conditions of employment, including pay and benefits;
- training, development, and promotion opportunities;
- performance management and appraisal;
- disciplinary and grievance procedures;
- redundancy selection; and
- any other employment-related decisions.
3.2 This policy also applies to the conduct of employees outside of the workplace where such conduct has a material connection to the employment relationship, including conduct at work-related social events, business travel, and communications made using company devices or accounts.
3.3 All employees have a personal responsibility to behave in a manner consistent with this policy. Managers have an additional responsibility to actively promote equality and diversity within their teams and to address any behaviour that is inconsistent with this policy.
4. PROTECTED CHARACTERISTICS
4.1 Under the Equality Act 2010, the following are protected characteristics: age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; and sexual orientation.
4.2 This policy covers the following protected characteristics: [Protected Characteristics].
4.3 [Company Name] is committed to ensuring that no person is subjected to less favourable treatment, placed at a particular disadvantage, or subjected to unwanted conduct on the grounds of any of the above protected characteristics.
5. FORMS OF PROHIBITED CONDUCT
5.1 The following forms of conduct are prohibited by this policy and by the Equality Act 2010:
5.2 Direct discrimination (s.13 Equality Act 2010): Treating a person less favourably because of a protected characteristic than others would be treated in the same or similar circumstances.
5.3 Indirect discrimination (s.19 Equality Act 2010): Applying a provision, criterion, or practice that appears neutral but which puts persons sharing a protected characteristic at a particular disadvantage compared to others, where the provision, criterion, or practice cannot be justified as a proportionate means of achieving a legitimate aim.
5.4 Harassment (s.26 Equality Act 2010): 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, humiliating, or offensive environment for them.
5.5 Victimisation (s.27 Equality Act 2010): Subjecting a person to a detriment because they have made or are suspected of making a complaint or allegation under the Equality Act 2010, or because they have given or are suspected of intending to give evidence in connection with proceedings under the Equality Act 2010.
5.6 Failure to comply with the duty to make reasonable adjustments (s.21 Equality Act 2010): Failing to take reasonable steps to avoid a substantial disadvantage faced by a disabled person that would otherwise not be faced by a non-disabled person.
6. RECRUITMENT AND SELECTION
6.1 [Company Name] is committed to ensuring that recruitment and selection processes are fair, open, and free from unlawful discrimination. [Recruitment Commitment]
6.2 Job descriptions, person specifications, and all recruitment materials will be reviewed to ensure that they do not contain requirements that are directly or indirectly discriminatory, unless such requirements can be objectively justified.
6.3 Pre-employment enquiries about health or disability will only be made to the extent permitted by s.60 of the Equality Act 2010, that is, for the purposes of: assessing whether the applicant would be able to carry out a function that is intrinsic to the work; assessing whether reasonable adjustments need to be made for the applicant at interview; monitoring diversity data; taking positive action; or where having a particular medical condition is an occupational requirement.
7. TRAINING AND DEVELOPMENT
7.1 [Company Name] is committed to providing equal access to training and development opportunities for all employees, regardless of any protected characteristic.
7.2 [Training Commitment]
7.3 Training and development opportunities will be assessed on the basis of business need and individual development requirements. Decisions about training, promotion, and career development will not be influenced by any protected characteristic.
8. REASONABLE ADJUSTMENTS
8.1 Under s.20 and s.21 of the Equality Act 2010, [Company Name] has a duty to make reasonable adjustments where a provision, criterion, practice, or physical feature of the workplace puts a disabled employee or job applicant at a substantial disadvantage compared to persons who are not disabled.
8.2 [Reasonable Adjustments Approach]
8.3 All reasonable adjustment requests will be handled confidentially and sensitively. The cost of a reasonable adjustment will not be passed on to the disabled employee or job applicant. [Company Name] will engage with Access to Work, a government programme operated by the Department for Work and Pensions, where this may assist in funding or identifying appropriate reasonable adjustments.
9. HARASSMENT AND BULLYING
9.1 [Company Name] will not tolerate any form of harassment or bullying in the workplace or in connection with work. Every employee has the right to work in an environment free from harassment, bullying, and intimidation.
9.2 Harassment is defined in s.26 of the Equality Act 2010 as unwanted conduct related to a protected characteristic that has the purpose or effect of: (a) violating a person's dignity; or (b) creating an intimidating, hostile, degrading, humiliating, or offensive environment for that person.
9.3 Examples of conduct that may constitute harassment include: offensive comments, jokes, or banter related to a protected characteristic; unwanted physical contact; displaying offensive materials; sending offensive messages by electronic means; and deliberately excluding a person from meetings or social activities because of a protected characteristic.
9.4 Bullying, while not specifically defined in the Equality Act 2010, is also prohibited by this policy. Bullying is defined as offensive, intimidating, malicious, or insulting behaviour, or an abuse or misuse of power through means intended to undermine, humiliate, denigrate, or injure the recipient.
9.5 Third-party harassment — that is, harassment of an employee by a customer, client, contractor, or other person who is not an employee of [Company Name] — will be taken seriously. Managers are required to take reasonable steps to prevent and address harassment of employees by third parties.
10. RAISING A CONCERN — GRIEVANCE PROCEDURE
10.1 Any employee who believes they have been subjected to discrimination, harassment, victimisation, or any other breach of this policy should feel confident in raising a complaint. [Company Name] takes all such complaints seriously and will investigate them promptly, confidentially, and impartially.
10.2 Employees are encouraged in the first instance to speak informally with their line manager, the Equality Officer, or the HR department. Where an employee does not feel comfortable raising the matter informally, or where informal resolution is not appropriate, the formal grievance procedure should be followed.
10.3 The applicable grievance procedure is: [Grievance Procedure Reference].
10.4 The Equality Officer designated to receive and co-ordinate responses to equality and diversity concerns is [Equality Officer Name], who may be contacted at [Equality Officer Email].
10.5 No employee will be subjected to victimisation for making a complaint or raising a concern in good faith under this policy. Any person who victimises a complainant will be subject to disciplinary action.
10.6 If an employee is not satisfied with the outcome of the internal grievance procedure, they may refer their complaint to the Advisory, Conciliation and Arbitration Service (ACAS) or bring a claim in the Employment Tribunal. Certain claims under the Equality Act 2010 must be brought within three months (less one day) of the act complained of, subject to the ACAS early conciliation extension.
11. MONITORING AND REPORTING
11.1 [Company Name] is committed to monitoring the effectiveness of this policy and to taking action where monitoring reveals that equality objectives are not being achieved.
11.2 [Monitoring And Reporting]
11.3 Diversity data collected for monitoring purposes will be held securely, in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Monitoring data will be processed in anonymised or pseudonymised form wherever possible.
11.4 The Equality Officer ([Equality Officer Name]) is responsible for co-ordinating the collection and analysis of equality monitoring data and for reporting findings to senior management.
12. RESPONSIBILITIES
12.1 Senior Leadership is responsible for: demonstrating commitment to equality and diversity at the highest level; approving and reviewing this policy; ensuring that sufficient resources are allocated to equality and diversity initiatives; and setting equality objectives and reviewing progress against them.
12.2 The Equality Officer ([Equality Officer Name]) is responsible for: implementing this policy; advising managers and employees on equality and diversity matters; co-ordinating equality training; handling concerns and complaints relating to equality and diversity; monitoring and reporting on equality data; and keeping this policy up to date.
12.3 Managers are responsible for: promoting and upholding the principles of this policy within their teams; treating all employees fairly and with dignity and respect; implementing reasonable adjustments for disabled employees; addressing any conduct that is inconsistent with this policy promptly and effectively; and attending all required equality and diversity training.
12.4 All employees are responsible for: treating colleagues, customers, clients, and other persons with dignity and respect; not engaging in discriminatory, harassing, or victimising conduct; reporting any concerns about equality and diversity to their manager, the Equality Officer, or HR; and completing all required equality and diversity training.
13. DISCIPLINARY ACTION
13.1 Breaches of this policy are treated seriously by [Company Name] and may result in disciplinary action.
13.2 [Disciplinary Action]
13.3 Disciplinary proceedings will be conducted in accordance with the ACAS Code of Practice on Disciplinary and Grievance Procedures and the company's own Disciplinary Policy. Allegations of discrimination or harassment will be investigated thoroughly, fairly, and without undue delay.
14. POLICY REVIEW
14.1 This policy will be reviewed by the policy owner at least annually, or sooner following any significant change in the law, ACAS guidance, or organisational structure, or following any incident that highlights a deficiency in current equality provision.
14.2 The policy owner responsible for maintaining and reviewing this policy is: [Policy Owner].
14.3 The next scheduled review date is: [Review Date].
14.4 Amendments to this policy will be communicated to all employees and relevant stakeholders. The updated policy will be made available on the company intranet or staff notice board.
15. POLICY APPROVAL
This Equality, Diversity and Inclusion Policy has been reviewed and formally approved on [Approval Date] by [Approved By] on behalf of [Company Name].
This policy complies with the Equality Act 2010, the Human Rights Act 1998, the Employment Rights Act 1996, the ACAS Code of Practice on Disciplinary and Grievance Procedures, and ACAS guidance on equality, diversity, and inclusion.
Equality Officer: [Equality Officer Name] ([Equality Officer Email])
Policy Owner: [Policy Owner]
Approved By: [Approved By]
Effective Date: [Policy Date]
Next Review Date: [Review Date]
Authorised Signatory
[Approved By]
Signature
Date: ________________
What Is a Equality, Diversity and Inclusion Policy (UK)?
An Equality, Diversity and Inclusion Policy in the United Kingdom sets out the standards, responsibilities, and procedures the organisation expects everyone to follow, with its requirements set by the Equality Act 2010.
The Equality Act 2010 defines nine protected characteristics: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. It prohibits a range of forms of conduct in connection with employment, including direct discrimination, indirect discrimination, harassment, victimisation, and failure to comply with the duty to make reasonable adjustments for disabled persons.
An EDI policy documents the employer's legal obligations under the Act and translates them into practical commitments about how the organisation will behave in relation to recruitment, training, development, performance management, grievance handling, and all other aspects of the employment relationship. It also sets out the responsibilities of the organisation, its managers, and individual employees in upholding equality and diversity standards.
The Equality and Human Rights Commission (EHRC) and ACAS both publish guidance for employers on equality and diversity, and the ACAS Code of Practice on Disciplinary and Grievance Procedures provides the framework within which complaints of discrimination and harassment should be addressed. An EDI policy that is implemented effectively, communicated clearly, supported by regular training, and enforced consistently is the foundation of a genuinely inclusive workplace and a central element of the employer's defence against Employment Tribunal claims.
The legal framework governing the Equality, Diversity and Inclusion Policy (UK) in United Kingdom draws on several key statutes and regulatory bodies. Under the Companies Act 2006, Companies House maintains the register of UK companies. Section 386 of the Companies Act 2006 sets accounting record obligations. The Competition and Markets Authority (CMA) enforces the Consumer Rights Act 2015. The Financial Conduct Authority (FCA) regulates financial services under the Financial Services and Markets Act 2000. The High Court of Justice has jurisdiction under the Senior Courts Act 1981. Parties executing a Equality, Diversity and Inclusion Policy (UK) in United Kingdom should confirm the document reflects current law, including any amendments enacted since the original drafting date. The Equality Act 2010 sets the foundational requirements.
When Do You Need a Equality, Diversity and Inclusion Policy (UK)?
An Equality, Diversity and Inclusion Policy is needed by any organisation that employs staff or engages contractors, workers, or volunteers in England and Wales. While the Equality Act 2010 does not expressly require private sector employers to have a written EDI policy, the absence of one significantly increases the risk of successful Employment Tribunal claims and may deprive the employer of the statutory defence available under s.109(4) of the Act.
Public sector organisations are subject to the Public Sector Equality Duty under s.149 of the Equality Act 2010, which requires them to have due regard to the need to eliminate unlawful discrimination, advance equality of opportunity, and foster good relations. Public authorities in England with 150 or more employees are also required under the Equality Act 2010 (Specific Duties) Regulations 2011 to publish equality information and equality objectives, making a written EDI policy an operational necessity.
Private sector employers need an EDI policy if they wish to demonstrate that they have taken all reasonable steps to prevent discrimination and harassment in the workplace, which is the test for the employer's statutory defence under s.109(4) of the Equality Act 2010. The Employment Tribunal regularly considers the existence, content, and implementation of an EDI policy when assessing whether an employer has met this standard. An employer with no written policy, or one that has a policy but fails to communicate it or enforce it, is unlikely to succeed in establishing the s.109(4) defence.
An EDI policy is also essential for organisations that operate in regulated sectors, including financial services (where the Financial Conduct Authority requires firms to have policies promoting diversity and inclusion), healthcare, education, and legal services. Many public sector procurement frameworks and large corporate supplier agreements now require suppliers to have a documented EDI policy and to provide evidence of compliance.
Organisations that are scaling up their workforce, entering new markets, or applying for public contracts will frequently be required to demonstrate their commitment to equality and diversity through a written policy and supporting documentation.
What to Include in Your Equality, Diversity and Inclusion Policy (UK)
A legally effective and operationally useful Equality, Diversity and Inclusion Policy for England and Wales should contain the following key elements, each drawn from the requirements of the Equality Act 2010 and ACAS guidance.
A clear policy statement that sets out the organisation's commitment to equality, diversity, and inclusion and identifies the values that underpin the policy. The statement should make clear that the policy applies to all aspects of the employment relationship and to all persons connected with the organisation.
A legal framework section that identifies the key legislation governing the policy, including the Equality Act 2010 (in particular ss.4-27 and s.149 for public authorities), the Human Rights Act 1998, the Employment Rights Act 1996, and the relevant ACAS Codes of Practice and guidance. This section demonstrates that the policy is grounded in law and not merely aspirational.
A clear definition of the nine protected characteristics under s.4 of the Equality Act 2010 and the scope of protection afforded to each. This section should also define the forms of prohibited conduct under the Act, including direct discrimination (s.13), indirect discrimination (s.19), harassment (s.26), victimisation (s.27), and failure to make reasonable adjustments (ss.20-21).
Commitments in relation to recruitment and selection, training and development, and career progression, setting out the specific steps the organisation takes to confirm equality of opportunity at each stage of the employment lifecycle.
A section on reasonable adjustments that explains the employer's duty under ss.20-21 of the Equality Act 2010, the process for requesting an adjustment, and the approach the employer takes to assessing and implementing adjustments for disabled employees and job applicants.
A harassment and bullying section that defines both concepts, makes clear that neither will be tolerated, and explains how complaints will be handled.
A clear grievance procedure pathway that directs employees to the applicable formal grievance procedure and identifies a named Equality Officer or HR contact for informal enquiries and concerns.
Monitoring and reporting commitments that explain how the organisation collects, analyses, and acts on equality data, and how it measures progress towards equality objectives.
A responsibilities section that sets out the specific duties of the senior leadership, Equality Officer, managers, and all employees in upholding the policy.
Details of the disciplinary consequences for breaching the policy, cross-referenced to the organisation's formal Disciplinary Policy and the ACAS Code of Practice.
Policy owner, approval, and review details, including the name of the Equality Officer, the date of approval, and the date of the next scheduled review.
Additional compliance elements for a Equality, Diversity and Inclusion Policy (UK) used in United Kingdom include: Under the Companies Act 2006, Companies House maintains the register of UK companies. Section 386 of the Companies Act 2006 sets accounting record obligations. The Competition and Markets Authority (CMA) enforces the Consumer Rights Act 2015. The Financial Conduct Authority (FCA) regulates financial services under the Financial Services and Markets Act 2000. The High Court of Justice has jurisdiction under the Senior Courts Act 1981. Forms-legal.com provides this template as a starting point for United Kingdom-compliant documentation.
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Forms Legal. (2026). Equality, Diversity and Inclusion Policy (UK) (United Kingdom) [Legal document template]. Forms Legal. https://forms-legal.com/uk/business/policies/equality-diversity-policy-uk
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author = {{Forms Legal}},
title = {Equality, Diversity and Inclusion Policy (UK) (United Kingdom)},
year = {2026},
howpublished = {\url{https://forms-legal.com/uk/business/policies/equality-diversity-policy-uk}},
note = {Free legal document template. Based on Equality Act 2010}
}Also available for these jurisdictions:
Frequently Asked Questions
Strictly speaking, the Equality Act 2010 does not expressly require private sector employers to have a written Equality, Diversity and Inclusion (EDI) policy. However, under s.149 of the Equality Act 2010, public authorities are subject to the Public Sector Equality Duty, which requires them to have due regard to the need to eliminate unlawful discrimination, advance equality of opportunity, and foster good relations between persons who share a protected characteristic and those who do not. For public authorities with 150 or more employees, the specific duties in England (Equality Act 2010 (Specific Duties) Regulations 2011) require the publication of equality information and equality objectives at least every four years. For private sector employers, ACAS guidance strongly recommends having a written EDI policy as a key tool for preventing discrimination and demonstrating the organisation's commitment to equality. A written policy also provides a defence in Employment Tribunal proceedings: under s.109(4) of the Equality Act 2010, an employer may avoid vicarious liability for an employee's act of discrimination if it can show that it took all reasonable steps to prevent the employee from doing that act. Having a clearly communicated, up-to-date EDI policy, supported by training, is a central element of demonstrating that reasonable steps were taken.
Under s.4 of the Equality Act 2010, the nine protected characteristics are: age (s.5), disability (s.6), gender reassignment (s.7), marriage and civil partnership (s.8), pregnancy and maternity (s.17-18), race (s.9, which includes colour, nationality, and ethnic or national origins), religion or belief (s.10, which includes a lack of religion or belief), sex (s.11), and sexual orientation (s.12). Different protections apply to different characteristics. For example, the protection against discrimination on the ground of marriage and civil partnership applies only in the field of employment and does not extend to indirect discrimination. The protection for pregnancy and maternity is governed by specific provisions in ss.17-18. The duty to make reasonable adjustments (ss.20-21) applies specifically in relation to disability. Employers must confirm that their EDI policy accurately reflects the scope of protection afforded to each characteristic under the Act.
Under the Equality Act 2010, direct discrimination (s.13) occurs where a person is treated less favourably because of a protected characteristic than a person who does not share that characteristic is or would be treated in the same or not materially different circumstances. The comparator may be a real or hypothetical person. Direct discrimination is generally incapable of justification, save in limited cases such as age discrimination (s.13(2)) and indirect disability discrimination (s.19). Indirect discrimination (s.19) occurs where a person applies to another a provision, criterion, or practice (PCP) that is, or would be, applied equally to persons who do not share the protected characteristic, but which puts or would put persons with whom the person shares the characteristic at a particular disadvantage compared to persons who do not share it, and which is not a proportionate means of achieving a legitimate aim. Unlike direct discrimination, indirect discrimination can be justified if the employer can show that the PCP is a proportionate means of achieving a legitimate aim. The justification defence requires an objective balancing exercise: the more significant the discriminatory impact, the stronger the justification must be.
Under ss.20-21 of the Equality Act 2010, employers have a duty to make reasonable adjustments where: (a) a provision, criterion, or practice applied by the employer puts a disabled person at a substantial disadvantage compared with persons who are not disabled; (b) a physical feature of the employer's premises puts a disabled person at a substantial disadvantage; or (c) a disabled person would be put at a substantial disadvantage without the provision of an auxiliary aid. In each case, the employer is required to take such steps as it is reasonable to take to avoid the disadvantage. The duty is anticipatory in relation to job applicants and reactive in relation to current employees. What is 'reasonable' depends on factors including: the effectiveness of the adjustment; the financial and other costs to the employer; the extent of the employer's resources; and the nature of the employer's activities. The Employment Tribunal in Latif v The Post Office [2020] EWCA Civ 1219 confirmed that the focus must be on the effect of the employer's step, not its nature. Employers are not required to create a new post for a disabled employee as a reasonable adjustment, but may be required to transfer the employee to a vacant post (Chief Constable of South Yorkshire Police v Jelic [2010] IRLR 744).
Having an EDI policy in place is an important element of the statutory defence available to employers under s.109(4) of the Equality Act 2010. Under s.109(1), anything done by a person in the course of their employment is treated as also done by the employer, regardless of whether it was done with the employer's knowledge or approval. However, under s.109(4), the employer will not be liable if it can show that it took all reasonable steps to prevent the employee from doing that thing or from doing things of that description. The Employment Appeal Tribunal in Canniffe v East Riding of Yorkshire Council [2000] IRLR 555 confirmed that the test is an objective one: the employer must show that it took all reasonable steps, not merely some steps. A written EDI policy that is communicated to all staff and supported by regular, quality training is a central element of this defence, but it is not sufficient on its own. Employers must also be able to show that they enforce the policy in practice, investigate complaints promptly and thoroughly, and take effective disciplinary action against those who breach it.
The Public Sector Equality Duty (PSED) is set out in s.149 of the Equality Act 2010. It applies to public authorities as listed in Schedule 19 to the Act, and to any person exercising public functions. It does not apply to private sector organisations unless they are exercising public functions under a contract with a public authority. Public authorities subject to the PSED must, in the exercise of their functions, have due regard to the need to: eliminate unlawful discrimination, harassment, victimisation, and any other conduct prohibited by the Equality Act 2010; advance equality of opportunity between persons who share a protected characteristic and persons who do not share it; and foster good relations between persons who share a protected characteristic and persons who do not share it. In England, public authorities with 150 or more employees are also subject to the specific duties under the Equality Act 2010 (Specific Duties) Regulations 2011 (SI 2011/2260), which require the publication of equality information and one or more equality objectives at least every four years.
This template is provided for informational purposes only and does not constitute legal advice. Laws vary by jurisdiction and change over time. Consult a qualified attorney for advice specific to your situation.Full disclaimer
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