Introduction
The CLCs Code of Conduct Principle 6 requires the business to comply with the following.
- The service we provide is accessible and responsive to the needs of individual Clients, including those who are vulnerable;
- No-one – Client, employee, colleague, job applicant, trainee or other party – we deal with feels discriminated against (whether directly or indirectly), victimised or harassed;
- We accept responsibility where the service we provide is not of the expected standard and provide appropriate redress for the Client where necessary;
- Handling of complaints takes proper account of Clients’ individual needs, including those who are vulnerable;
- Complaints are dealt with impartially and comprehensively.
Our Commitment
We are committed to:
- Recognising diversity
- Preventing and tackling unlawful discrimination
- Promoting an equally high standard of service to all clients, irrespective of their age, disability, marital status, race, religion or belief, sex (including people who have had gender reassignment) or sexual orientation;
- Making reasonable adjustments so a person with a disability is not placed at a substantial disadvantage to a person without a disability
- All stakeholders and employees complying with the commitments of this policy
We will comply with Principle 6 of the CLC Code of Conduct which requires us to promote equality and diversity, and with the duties of the Equality Act 2010
We will neither enable nor tolerate any of the following:
Direct Discrimination
A person is treated less favourably than another person due to their age, disability, marital status, race, religion or belief, sex, or sexual orientation.
Indirect discrimination
A requirement or condition has a disproportionately adverse effect on a particular equalities group and said requirement/condition cannot be justified.
Victimisation
A person is treated less favourably than other persons because they have made allegations of discrimination.
Harassment
A person feels that the behaviour of another has violated their dignity, or created an intimidating, hostile, degrading, humiliating or offensive environment for them.
Clients
We will ensure that no individual client, or a client group, is discriminated against in accessing our services and functions or in the quality of service provided.
Instructions will not be refused on the basis of unlawful discrimination.
Our complaints handling-process is responsive to Client’s individual needs (particularly those that are vulnerable or have disabilities).
Employees
We will ensure that all partners, employees and applicants have equal employment opportunities. Our recruitment, appointment, appointment terms and conditions, promotion, training and benefits opportunities will not be discriminatory.
Policy Implementation & Evaluation
6.1 Emma Newby who is a Director of the Company is responsible for the implementation of this policy and ensuring all employees are aware of their duties under it, providing training and information as appropriate.
6.2 Emma Newby will monitor the extent of compliance with this policy across the organisation. Appropriate data will be collected to inform this review.
6.3 Allegations of discrimination will be investigated under our grievance procedures. We will take such allegations very seriously and where an employee or stakeholder is found not to have complied with the policy, we will take disciplinary action against them.
6.4 We will provide training to ensure staff are aware of their responsibilities under this Policy.
6.5 This policy will be updated as legislative and regulatory requirements are revised, in light of lessons learned by the business and in view of any good practice identified.
Delivery Of Outcomes
In order to deliver the above outcomes, we are required to act in the following way:
- We comply with Equalities legislation.
- We make reasonable adjustments to prevent persons with disabilities from being placed at a substantial disadvantage.
- We provide equal opportunities for all Directors, employees or applicants in employment and training.
- We make all reasonable efforts to ensure our service is accessible and responsive to Clients, including those with vulnerabilities.
- The complaints procedure is clear, well-publicised and free.
- We treat complaints seriously and provide appropriate redress options.
- We deal with complaints fairly and within 28 days.
- We identify and address systemic Client Complaints issues.
Procedures
In order to comply with the outcomes required we will carry out the following Procedures:
- Any allegation of (direct or indirect) discrimination, victimisation and harassment is investigated thoroughly by the Directors of the Company, resulting, where appropriate, in disciplinary action.
- From the outset we advise Clients in writing of their right to make a complaint, how to make it, to whom, and the timeframes involved This information will be contained in our terms of engagement and we will also make this formation available in a prominent place on our website and by other reasonable means on request by the Client
- We advise Clients in writing of their right to have their complaint escalated to the Legal Ombudsman and provide them with contact details and timeframes of that body. This information will be contained in our terms of engagement we will also make this information available in a prominent place on your website and by other reasonable means on request by the Client
- We keep a record of complaints received and any action taken as a result.
- We must act with integrity and in the best interests of the client
- Communication with Client must be clear whether done orally or in writing
- We must respond to and address individual characteristics effectively and sensitively
- We should consider the most appropriate method and style of communication based on the individual needs of the client
- Providing difficult or unwelcome news must be provide clearly and sensitively
- Provide information in a way that clients can understand considering their personal circumstances and any particular vulnerability
General
A Client may be vulnerable because of a range of characteristics, including (but not limited to)
- Basic skills: literacy and numeracy; complexity and confusion: difficulty of accessing and understanding large amounts of information; disability or other impairment; mental health issues; distress or sudden change in circumstances e.g. bereavement, divorce, illness or loss of employment; low income; age; caring responsibilities; limited knowledge of, or limited skills in, use of English; balance of power: lack of competition and or choice; or inexperience or lack of knowledge of a particular subject. Vulnerability can only be assessed on a case-by-case basis.
- On the grounds of age, disability, gender reassignment, marital and civil partnership status, pregnancy and maternity, race, religion or faith, sex or sexual orientation