Equality & Diversity Policy

1. Policy Statement

Imperial Security is firmly committed to promoting equality and diversity throughout every aspect of our business. We believe that a diverse and inclusive workforce makes us stronger, more effective and better positioned to serve our clients across the United Kingdom.

Imperial Security provides a comprehensive range of professional security services including Security Guards, Door Supervision, Event Security, Hotel & Concierge Security, Corporate Security, Retail Security, Close Protection Bodyguards, Educational Security, Construction Site Security, Warehouse Security, Key Holding, CCTV Monitoring, Mobile Patrol Security and Night Security. Across all of these service areas, we are resolute in our commitment to treating every person whether they are an employee, a client, a subcontractor, an agency worker or a member of the public with dignity, respect and fairness.

This policy sets out Imperial Security's approach to equality and diversity and reflects our obligations under the Equality Act 2010 and all other applicable United Kingdom employment and anti-discrimination legislation. This is not merely a legal obligation; it is a core value that underpins the culture and conduct of our entire organisation.

2. Purpose & Scope

2.1 Purpose

The purpose of this policy is to:

• Set out Imperial Security's commitment to equality, diversity and inclusion in the workplace and in the delivery of services.
• Confirm that discrimination, harassment or victimisation of any kind will not be tolerated.
• Define the protected characteristics covered under the Equality Act 2010 and how they apply within our organisation.
• Outline the responsibilities of management, employees, contractors and all associated personnel.
• Provide a clear framework for reporting and addressing equality and diversity concerns.

2.2 Scope

This policy applies to all individuals working for or with Imperial Security, including:

• All directly employed security guards, door supervisors, close protection officers and support staff.
• All contracted and sub-contracted security personnel deployed across client sites.
• Agency and temporary workers providing security services on our behalf.
• Senior management, directors and board members.
• Volunteers, work experience participants and apprentices.
• Job applicants and candidates at all stages of the recruitment process.

This policy covers all areas of employment including recruitment and selection, training and development, promotion, performance management, pay and benefits, disciplinary and grievance procedures, and working conditions. It also applies to the delivery of security services to clients and the conduct of our personnel towards members of the public.

3. Legal Framework

Imperial Security operates in full compliance with all relevant United Kingdom legislation, including but not limited to:

• The Equality Act 2010 the primary legislation governing equality and anti-discrimination in Great Britain.
• The Human Rights Act 1998 particularly Article 14, which prohibits discrimination in the enjoyment of the rights and freedoms set out in the European Convention on Human Rights.
• The Employment Rights Act 1996 protecting employees' rights in the workplace.
• The Race Relations Act 1976 (as amended and now incorporated into the Equality Act 2010).
• The Security Industry Authority (SIA) Licensing requirements, which include obligations regarding fair and non-discriminatory conduct.
• The Modern Slavery Act 2015 which underpins our commitment to protecting the rights and dignity of all workers.
• The Working Time Regulations 1998 and the National Minimum Wage Act 1998 ensuring fair treatment in respect of working hours and remuneration.

Imperial Security recognises its responsibilities both as an employer and as a service provider, and we actively seek to exceed the minimum statutory requirements wherever practicable.

4. Protected Characteristics

Under the Equality Act 2010, it is unlawful to discriminate against any person on the grounds of any of the following protected characteristics. Imperial Security is committed to ensuring that all aspects of our operations actively respect and uphold these protections:

4.1 Age

We do not discriminate against employees, workers or applicants on the grounds of age. Security professionals of all ages bring valuable experience, skills and perspectives to our organisation. Recruitment, promotion, training, deployment decisions and remuneration are based solely on individual capability and merit.

4.2 Disability

Imperial Security is committed to supporting disabled employees and applicants. We will make reasonable adjustments where necessary to remove barriers to employment or effective working. Our recruitment process is designed to be accessible, and we actively seek to retain and support employees who develop a disability during their employment.

4.3 Gender Reassignment

We fully respect the rights of transgender and non-binary individuals. No person will be treated less favourably because they are undergoing, have undergone or are proposing to undergo gender reassignment. We ensure that all personnel are addressed in a manner consistent with their gender identity.

4.4 Marriage & Civil Partnership

Imperial Security does not discriminate against employees or applicants on the grounds of their marriage or civil partnership status. This protection applies specifically in employment contexts, ensuring that no person is treated unfavourably because of their marital or civil partnership status.

4.5 Pregnancy & Maternity

We are committed to supporting pregnant employees and those on maternity leave. No employee will be treated unfavourably because of pregnancy, childbirth or maternity. We ensure that risk assessments are carried out where necessary for pregnant security officers deployed on client sites, and that appropriate deployment adjustments are made to protect the health and wellbeing of the employee and their unborn child.

4.6 Race

Imperial Security operates across London and throughout the United Kingdom, serving a diverse range of clients and communities. We celebrate the cultural diversity of our workforce and actively promote racial equality. We do not tolerate direct or indirect racial discrimination, racial harassment or racial victimisation of any kind, whether directed at employees, clients or members of the public.

4.7 Religion or Belief

We respect the religious and philosophical beliefs of all individuals. Employees are treated fairly regardless of their religion, faith tradition or non-religious belief system. Where reasonable and practicable, we accommodate religious observance, including prayer requirements, dietary needs and requests relating to dress codes, whilst ensuring compliance with SIA licensing, health and safety obligations and client site requirements.

4.8 Sex

Imperial Security is committed to gender equality. We provide equal opportunities for men, women and non-binary individuals across all roles, including operational security positions, management and administrative functions. Pay, promotion and working conditions are determined by ability, performance and experience not by gender.

4.9 Sexual Orientation

We treat all employees and applicants equally regardless of sexual orientation, whether they identify as heterosexual, gay, lesbian or bisexual. Imperial Security maintains a working environment in which every individual is valued and respected, and where homophobic, biphobic or transphobic behaviour is never tolerated.

5. Forms of Prohibited Conduct

Imperial Security prohibits the following forms of unlawful conduct, whether perpetrated by managers, security personnel, clients, subcontractors or third parties:

5.1 Direct Discrimination

Treating someone less favourably than another person because of a protected characteristic. For example, refusing to deploy a security officer to a client site because of their race, gender or religion.

5.2 Indirect Discrimination

Applying a provision, criterion or practice that disadvantages people who share a protected characteristic and which cannot be objectively justified by a legitimate aim. For example, imposing an unjustified uniform requirement that conflicts with religious dress practices.

5.3 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, humiliating or offensive environment. This includes verbal abuse, offensive language, derogatory jokes, physical conduct and digital or written communications.

5.4 Sexual Harassment

Any unwanted conduct of a sexual nature that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. Imperial Security takes an unequivocal zero-tolerance approach to sexual harassment in all forms, on our premises, at client sites and in any work-related context.

5.5 Victimisation

Treating someone unfavourably because they have made, or are suspected of making, a complaint about discrimination or harassment, or because they have supported someone who has done so. Imperial Security will protect all individuals from victimisation and treat any such conduct as a serious disciplinary matter.

5.6 Bullying

Whilst not expressly defined under the Equality Act 2010, bullying is behaviour that is offensive, intimidating, malicious or insulting, whether or not it is related to a protected characteristic. Imperial Security treats bullying as a serious disciplinary matter that falls within the scope of this policy.

6. Our Commitments

6.1 Recruitment & Selection

Imperial Security is committed to fair and transparent recruitment practices. All job vacancies are advertised without discriminatory criteria, and all candidates are assessed solely on their skills, qualifications, experience and potential. Our recruitment process includes:

• Job descriptions and person specifications that are free from discriminatory language or unjustifiable requirements.
• Interview and assessment processes that are structured, objective and applied consistently to all candidates.
• Recruitment panels that are trained in unconscious bias and equalities awareness.
• SIA licence verification and DBS checks carried out consistently for all candidates in accordance with role requirements and legal obligations.
• Reasonable adjustments made for disabled applicants at every stage of the recruitment process.

6.2 Training & Development

All Imperial Security personnel have access to training and development opportunities on an equal basis. We invest in training programmes that enhance professional skills and promote equality awareness, including:

• Equality and diversity induction training for all new employees and deployed contractors.
• Ongoing professional development through SIA-compliant training courses.
• Management-level training on handling equality and diversity matters, including harassment investigations.
• Conflict resolution and communication training that promotes respectful engagement with colleagues, clients and members of the public.

6.3 Pay & Benefits

Imperial Security ensures that pay and benefits are determined by objective factors including role, skills, experience and performance. We do not tolerate pay inequality based on any protected characteristic. We are committed to taking action where pay disparities are identified, and to maintaining transparency in our pay structures.

6.4 Promotion & Career Progression

All employees have an equal opportunity to progress within Imperial Security. Promotion decisions are based on merit, capability and suitability for the role. We actively encourage individuals from all backgrounds to apply for opportunities within our organisation, and we seek to develop a diverse leadership team that reflects the communities we serve.

6.5 Service Delivery

Our commitment to equality and diversity extends beyond our workforce to the services we provide. Imperial Security's security personnel are expected to treat all members of the public including clients, visitors, customers and service users with equal respect and professionalism, irrespective of any protected characteristic. This applies across all service areas, from Retail Security and Event Security through to Educational Security and Close Protection services.

6.6 Working Environment

We are committed to providing all employees and workers with a safe, respectful and inclusive working environment. This includes:

• A zero-tolerance policy towards discriminatory language, jokes, gestures or behaviour in the workplace, on client sites or in any work-related setting.
• Clear and accessible reporting procedures for equality and diversity concerns.
• Regular review of workplace practices to identify and address potential inequality.
• An open-door culture in which employees feel able to raise concerns without fear of retaliation.

7. Responsibilities

7.1 Senior Management

The senior management of Imperial Security bears overall responsibility for the implementation, monitoring and review of this policy. This includes:

• Ensuring that the policy is effectively communicated throughout the organisation.
• Allocating sufficient resources to support equality and diversity initiatives.
• Leading by example and demonstrating an unequivocal commitment to the values set out in this policy.
• Ensuring that equality and diversity considerations are embedded in all business decisions and operational planning.

7.2 Managers & Supervisors

All managers and supervisors at Imperial Security are responsible for:

• Promoting and maintaining an inclusive working environment within their teams.
• Dealing promptly, fairly and confidentially with any complaints of discrimination, harassment or bullying.
• Taking appropriate action when they witness or become aware of discriminatory behaviour.
• Ensuring that recruitment, performance management and deployment decisions are made on an objective, non-discriminatory basis.
• Completing equality and diversity training as required.

7.3 All Employees & Contracted Personnel

Every individual working for or on behalf of Imperial Security is responsible for:

• Treating colleagues, clients and members of the public with dignity and respect at all times.
• Complying with this policy and all related equality and diversity procedures.
• Reporting any discriminatory behaviour, harassment or bullying that they witness or experience, using the procedures set out in this policy.
• Cooperating with any investigation into a complaint of discrimination or harassment.
• Not engaging in, encouraging or condoning any form of discriminatory, harassing or bullying behaviour.

8. Reporting & Complaints Procedure

8.1 Raising a Concern

Imperial Security encourages all employees, workers and associated personnel to raise concerns about equality and diversity matters at the earliest opportunity. Concerns can be raised informally or formally, depending on the nature and seriousness of the matter.

Informal concerns should be raised with a line manager or the HR department in the first instance. Where the concern involves the line manager directly, the individual should approach senior management or the designated HR contact.

Formal complaints should be submitted in writing to the HR department or senior management and will be handled in accordance with Imperial Security's Grievance Procedure. All complaints will be taken seriously, investigated promptly and handled with appropriate confidentiality.

8.2 Investigation

All formal complaints of discrimination, harassment or bullying will be investigated thoroughly and impartially. The investigator will be a suitably trained individual who has no direct involvement in the matter. Both the complainant and the respondent will have the opportunity to present their account of events and to be supported by a workplace colleague or trade union representative during any formal meetings.

8.3 Outcomes

Where an investigation finds that discrimination, harassment or bullying has occurred, Imperial Security will take appropriate disciplinary action, up to and including summary dismissal for the most serious cases. Where the individual responsible is a subcontractor or third party, appropriate action will be taken in accordance with the relevant contractual arrangements.

8.4 Protection from Victimisation

Any individual who raises a concern in good faith under this policy will be protected from victimisation or retaliation. Any act of victimisation will be treated as a serious disciplinary matter. Malicious or vexatious complaints, however, may themselves be subject to disciplinary action.

9. Monitoring & Review

Imperial Security is committed to monitoring the effectiveness of this policy and to taking action where disparities or shortcomings are identified. We will:

• Collect and review equality data in relation to recruitment, promotion, training, pay and disciplinary matters on a regular basis.
• Analyse data to identify any patterns suggesting unequal treatment or outcomes for groups with protected characteristics.
• Take appropriate remedial action where monitoring reveals areas of concern.
• Review this policy annually, or following any significant change in legislation, operational practice or the composition of our workforce.
• Publish relevant equality information in accordance with our obligations under the Equality Act 2010 (Gender Pay Gap Reporting and the Public Sector Equality Duty, where applicable).

The next scheduled review of this policy is March 2027. Earlier review may be triggered by legislative changes, significant client feedback, internal audit findings or any equality-related incident.

10. Positive Action

Where Imperial Security identifies that persons sharing a protected characteristic are underrepresented in a particular area of our workforce or are experiencing particular disadvantage, we may take proportionate positive action to address this. This may include:

• Targeted outreach and recruitment initiatives aimed at underrepresented groups.
• Mentoring and development programmes designed to support progression.
• Partnership with community organisations to widen access to employment in the security industry.

Positive action under this policy is distinct from positive discrimination, which remains unlawful. All appointments and promotions will continue to be made based on merit and objective assessment of individual capability.

11. Equality in Service Provision

As a provider of professional security services to businesses throughout the United Kingdom, Imperial Security recognises that our commitment to equality and diversity must extend to the communities in which we operate. Our security personnel are ambassadors for our values as well as for our clients' businesses.

We expect all deployed security officers whether working in Retail Security, Educational Security, Event Security, Corporate Security, Door Supervision, Hotel & Concierge Security or any other service area to demonstrate the following standards of conduct when dealing with members of the public:

• Treat every individual with dignity, respect and courtesy, regardless of any personal characteristic.
• Apply all access control, search and identification procedures consistently and without discrimination.
• Communicate professionally and respectfully at all times, using appropriate language and tone.
• Challenge and report behaviour by other security personnel that appears discriminatory or disrespectful.
• Follow any site-specific equality and diversity policies operated by the client, in addition to this policy.

Any complaint received from a member of the public, client or third party alleging discriminatory treatment by an Imperial Security officer will be investigated seriously and promptly in accordance with our complaints and grievance procedures.

12. Related Policies & Documents

This Equality & Diversity Policy should be read in conjunction with the following Imperial Security policies and procedures:

• Grievance Policy & Procedure
• Disciplinary Policy & Procedure
• Anti-Harassment & Bullying Policy
• Recruitment & Selection Policy
• Health & Safety Policy
• Modern Slavery & Human Trafficking Statement
• Whistleblowing Policy
• Data Protection & Privacy Policy

13. Breach of This Policy

Any breach of this policy by an employee, contractor or associated person will be treated with the utmost seriousness. Depending on the nature and severity of the breach, action taken may include:

• Informal counselling or a verbal warning for less serious, first-time or inadvertent breaches.
• A formal written warning in accordance with Imperial Security's Disciplinary Procedure.
• Demotion, redeployment or suspension pending investigation.
• Summary dismissal without notice for the most serious breaches, including acts of gross misconduct involving discrimination, harassment or bullying.
• Referral to the Security Industry Authority (SIA) where the conduct may affect an individual's suitability to hold or retain a security licence.

Imperial Security reserves the right to terminate contractual arrangements with subcontractors, clients or third parties where those parties engage in conduct that is contrary to the principles of this policy and where efforts to resolve the matter have proved unsuccessful.