Equality and Diversity Policy

Sarnia Asset Management Ltd

1.0 Introduction 

1.1 Sarnia Asset Management Limited (“Sarnia”) subscribes to the principles of equality of opportunity and aims to ensure that anyone involved or wishing to be involved in our business is able to do so in a discrimination-free environment. Sarnia also values diversity and recognises the contributions that people from different background or different experiences can bring to the organisation.

1.2 The Equality Policy is based on the following fundamental principles which Sarnia aims to uphold: 1.2.1 All persons must respect the rights, dignity and worth of every human being and their right to self-determination.

1.2.2 All staff, members, volunteers and job applicants are entitled to be treated fairly regardless of sex, gender reassignment, sexual orientation, age, marriage and civil partnership, parental or marital status, pregnancy and maternity, disability, religion or belief, colour, race including nationality or ethnicity and socio/economic background.

1.2.3 Equality must permeate throughout strategic and development plans.

1.2.4 All participants should be afforded equal opportunity to access services.

1.2.5 In some cases, positive action may be required to address past inequalities or under- representation.

1.2.6 It is everyone’s responsibility to ensure that no form of discrimination is tolerated in our organisation.

1.2.7 Any individual who believes they have received unfavourable treatment within the scope of the policy should raise the concern with Sarnia’s HR staff.

1.2.8 No individual who raises a concern in good faith, or those who support another person to raise a concern should be treated unfairly as a result of raising the concern.

2.0 Purpose Of The Policy 

2.1 The Equality Policy has been designed to ensure that no job applicant, employee, volunteer, participant or member is unlawfully discriminated against or receives less favourable treatment on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation (together these are known as the ‘Protected Characteristics’ under the Equality Act 2010)

2.2 This Policy has been produced to try to ensure that everyone is treated fairly and avoid practices that could discriminate directly or indirectly towards certain sections of society. In order to achieve equality, Sarnia recognises that in some instances, unequal distribution of effort and resources may be required. This may be necessary when sections of society are faced with barriers that prevent or restrict their participation in a fund management business. Sarnia supports the need for positive action to alleviate any barriers to participation.

2.3 Equality is about respecting peoples’ individuality. In doing this, Sarnia recognizes that its Policy must provide flexibility in order to ensure a service, which is adaptive to individuals’ needs, thus enabling all in our society to participate without prejudice or unnecessary barriers.

3. Responsibilities Of Sarnia Asset Management Limited

3.1 Sarnia strives to ensure that our business is free from discrimination. We endeavour to promote the highest standards and will:

3.1.1 Provide and implement a policy to protect employees and clients from discrimination.

3.1.2 Encourage individuals from all communities to become involved with our company.

3.1.3 Adopt good practice in recruitment, training and supervision of all employees and volunteers.

3.1.4 Respond to all concerns, and implement the appropriate disciplinary and appeals procedure.

3.2 Sarnia will work to ensure that inequality is avoided:

3.2.1 When selecting, recruiting and training individuals.

3.2.2 In the preparation and distribution of all materials and publications.

4. Responsibilities Of The Individual 

4.1 Everyone working for or with Sarnia is required to assist in ensuring that the company meets its commitment and avoids unlawful discrimination.

4.2 Individuals can be held personally liable as well as, or instead of, the company, for any act of unlawful discrimination. Individuals who commit serious acts of victimisation or harassment may be guilty of a criminal offence.

5. Legal Requirements 

5.1 Sarnia recognises its legal obligations under, and will abide by the requirements of, the Equality Act 2010, and any later amendments to such legislation or subsequent equality related legislation that may be relevant to the company.

5.2 It is unlawful to discriminate directly or indirectly in recruitment, employment or in the provision of services because of age, disability, sex, gender reassignment, pregnancy, maternity, race (including colour, nationality and ethnic or national origins), sexual orientation, religion or belief, or because someone is married or in a civil partnership.

5.3 Sarnia will within suitable intervals review this Policy to ensure it continues to reflect the current legal framework and good practice.

5.4 Sarnia recognises that the following is unacceptable: Discrimination, Harassment, Bullying and Victimisation 

5.5 Unlawful discrimination, which can take the following forms:

5.5.1 Direct Discrimination: treating someone less favourably than another person because of a Protected Characteristic.

5.5.2 Indirect Discrimination: an action, rule or policy that applies to everyone but disadvantages someone with a particular Protected Characteristic.

5.5.3 Associative Discrimination: direct discrimination against someone because they associate with another person who possesses a particular protected characteristic.

5.5.4 Discrimination by perception: direct discrimination against someone because others think they possess a particular protected characteristic.

5.5.5 Discrimination arising from disability: someone is treated unfavourably because of something connected with their disability.

5.5.6 Bullying: offensive, intimidating, malicious or insulting behaviour, and /or an abuse or misuse of power that is meant to undermine, humiliate or injure the person on the receiving end.

5.5.7 Harassment: unwanted or offensive conduct directed at oneself or another person.

5.5.8 Victimisation: treating a group or individuals in a detrimental way because they have made or intend to make a complaint or provide evidence in support of another complaint.

5.6 Sarnia regards acts of discrimination, bullying, harassment or victimisation as serious issues. Staff or members who, following disciplinary procedures, are found to have discriminated against, harassed, bullied or victimised any other person, will be dealt with appropriately.

5.7 GGC recognises it has a duty and is committed to making reasonable adjustments for disabled people.

5.8 GGC’s duty to make reasonable adjustments includes the removal, adaptation or alteration of physical features, if the physical features make it impossible or unreasonably difficult for disabled people to use services.

5.9 Sarnia, when acting as a service provider, has an obligation to think ahead and address any barriers that may impede disabled people from accessing its service.

6. Implementation Procedures 

6.1 Sarnia aims to promote equality and diversity across our industry in everything we do. In working towards mainstreaming equality, we will ensure equality is embedded as part of our company’s culture.

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