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Hawk Training | Our Equality and Diversity Policy

This document sets out the policy to be implemented throughout Hawk Training's Provision and Services:

1.0  Purpose

Hawk Training is an equal opportunity employer.

This Equality, Diversity and Inclusion Policy is designed to implement the commitment of Hawk Training to equality and inclusion. This policy has been agreed and signed off by Crawford Knott Managing Director.


We are committed to being a successful, caring and welcoming place for all of our employees and applicants for roles with us. We want to create a supportive and inclusive environment where our employees can reach their full potential, without prejudice and discrimination. We are committed to a culture where respect and understanding is fostered and the diversity of people's backgrounds and circumstances will be positively valued.


Equality of opportunity, valuing diversity and compliance with the law is to the benefit of all individuals in our Company as it seeks to develop the skills and abilities of its people. While specific responsibility for eliminating discrimination and providing equality of opportunity lies with managers and supervisors, individuals at all levels have a responsibility to treat others with dignity and respect.


Through this policy and procedure and the training and development of managers and staff, Hawk Training will do all it can to promote good practice in this area in order to eliminate discrimination and harassment as far as is reasonably possible. We will also continue to work towards our dedicated goal of encouraging and promoting equality and diversity within the workforce.


Our equality vision is to create and maintain an inclusive working and learning environment that respects and celebrates difference. This helps create an ethos and culture where all feel valued and empowered, regardless of the many ways that people are different. This may include, for example, age, disability, gender, marriage and civil partnership, pregnancy and maternity, race, religion and belief, sexual orientation, social-economic background or class, and trans gender.


We believe that this vision of equality and diversity brings tangible benefits for our learners, and for the employers that we work with.


For our learners, this includes a training environment personalised to their individual requirements where they can participate fully, give their best and achieve their full potential in a climate free from discrimination or harassment.

For our employers, equality brings benefits for core business, for example:

  • A more diverse workforce, bringing a wider range of individual strengths, experiences and perspectives
  • Increased employee satisfaction and motivation, which helps attract new staff and retain those already there, reducing recruitment costs and increasing productivity
  • Improved understanding of the diverse groups of potential and existing customers, providing a better service and providing access to markets that may not previously have been tapped into
  • Finding workers to fill skills gaps
  • Improved organisational image across a wider audience.

The Equality Act 2010 introduces the term ‘protected characteristic’ to refer to aspects of a person’s identity explicitly protected from unlawful discrimination. The Act also introduces a Public-Sector Equality Duty to eliminate discrimination, harassment and victimisation, advance equality and foster good relations. This policy is designed to implement these requirements. Appendix A provides further information on these legal requirements.




Hawk Training seeks to create and maintain an inclusive working and learning environment that respects and celebrates difference. This helps create an ethos and culture where all feel valued and empowered, regardless of the many ways that people are different. This may include, for example, age, disability, gender, marriage and civil partnership, pregnancy and maternity, race, religion and belief, sexual orientation, social-economic background or class, and trans gender.

Hawk Training has zero tolerance to any form of bullying, discrimination or harassment, on any of the above or other grounds

We expect all who work and learn at Hawk Training to abide by this policy statement. This includes staff, learners, employers, trustees and visitors.



During the apprenticeship programme we will introduce equality and diversity this will be done at key stages

  1. Induction – During the programme induction we will discuss equality and diversity and the learner’s rights during the apprenticeship. We will make sure the employer has an Equality and Diversity policy and that the apprenticeship is aware and is compliant with this.
  2. Learning and Assessment visits- At each visit we will ask the learner key questions regarding their wellbeing that will also cover Equality and Diversity. (Questions found in ILP)
  3. Programme Reviews- At each programme review will ask questions to test the learner’s knowledge on Equality and Diversity (questions found in ILP)
  4. Surveys – Learners will be surveyed during the programme and at the end of the programme, these surveys will help us identify any issues.
  • Moodle – Our e learning platform Moodle. Following the enrolment onto any of our qualifications, All Learners must complete mandatory modules on Safeguarding, Equality, Online Safety and Prevent and British Values. This will be the start of the on-going natural embedding into their curriculum.

There are also other resources under the You Matter tile which is there to support the learner with wellbeing issues including Equality and Diversity.


Hawk Training will

  • ensure publications, marketing and promotional materials, key documents such as handbooks, and staff, employer and learner recruitment procedures endorse and support equality and diversity
  • seek to recruit the full diversity of staff, to bring a range of experiences and perspectives to the workforce and to provide a range of role models and ambassadors to our learners
  • ensure learner recruitment procedures will be free from bias and proactively promote equality and diversity. Recruitment procedures do not use any identifies regarding the learner. Learners are given opportunities to disclose any information they may feel relevant to the recruitment process such as requesting learner support for mental health reasons, but this is up to the individual. Learners have opportunity to disclose any information at each visit with their tutor and will then need to provide consent for this information to be shared, unless it is a safeguarding risk.
  • work with learners to plan the learning programme, materials, methods and resources to consider personal needs and aspirations and equality of opportunity without bias or discrimination. Each learner’s programmes are designed to be individual to their needs and information used to support that is only that which has been provided by the learner and is relevant to the programme.
  • make participants in the learning process aware that they have a legal and formal duty to play their part in this policy, and positive steps will be taken to ensure no form of unlawful discrimination occurs. This is reviewed with learners and employers at formal reviews.
  • ensure that learning takes place in a supportive environment free from discrimination or harassment. Questions are asked around the learner’s wellbeing at each visit and responses recorded on their ILP.
  • ensure that equality and diversity is built into all aspects of the apprenticeship programme processes.
  • Actively promote British values to help:
  • Create ‘safe spaces’ for dialogue and discussion
  • Provide opportunities to challenge views and bring a ‘counter-narrative’
  • Identify and protect students vulnerable to extremist ideologies
  • prepare learners to live and work In Britain’s complex multicultural society
  • continue to provide training in equality and diversity to learners and staff, so that all learners and staff at Hawk Training have the opportunity to develop their skills and confidence and to deal with equality & diversity issues in a professional manner
  • deal with all allegations of safeguarding, discrimination, harassment and victimisation sensitively and investigate fairly and thoroughly.
  • treat any form of discrimination, harassment or victimisation carried out by an individual as a matter for possible disciplinary action
  • lead by example in our dealings with learners, employers and any other contacts.
  • support employers to improve their equality and diversity practices.
  • use analysis of data to inform future planning, for example to improve the representation, participation and success of under-represented and under-achieving groups, and to challenge stereotyping.

Learners are responsible for

  • treating tutors, other learners and work colleagues with dignity and respect.
  • not doing anything that would discriminate or harass others because of their race, gender, disability, age, sexual orientation, religion, personal background or circumstance
  • reporting any issues of discrimination, bullying or harassment

Employers are expected to

  • abide by this equality, diversity and inclusion policy.
  • have their own equality and diversity policies in place, including those associated polices.


It is the responsibility of all staff, learners, and employers of learners to work together towards combating all forms of discrimination. This includes reporting all incidents of discrimination using Hawk Training procedures.

Breaches of this equality and diversity policy will be taken seriously and may be regarded as misconduct. For staff at Hawk Training, for example, this may result in disciplinary action. For learners, this may involve disciplinary action, including suspension or withdrawal from the training programme. For employers, this may involve cessation of a learning contract.




We will encourage the integration and inclusion of disabled learners into the Centre. Learners will be offered individualised programmes of development to assist to achieve their personal learning goals. All reasonable adjustments will be made to support disabled learners.

Learners will be invited to access additional support and refer to our Disability Discrimination Statement and Disclosure procedure

Hawk Training provides a wide range of additional support to meet their individual requirements. We respect the individual’s right to confidentiality, so any information provided will be kept private and will not be passed to anyone without the person’s explicit consent.

If a person has requested additional support, they may also arrange a confidential interview with a member of the safeguarding team.




Hawk Training’s Senior Management Team will monitor and evaluate the implementation of this policy, which will include the following:

  • Routinely analyse E&D learner statistical reports to identify areas of under-representation and achievement, for example statistics about learner recruitment, success and destination, by gender, age, ethnicity, learning difficulty, disability and safeguarding.
  • Report on equality gaps, targets, action and progress at Staff and Management meetings
  • Scrutinise reported incidents including incidents of abuse, bullying and harassment and unfavourable treatment;
  • Analyse ED&I staff statistical reports, such as outcomes from recruitment and selection, to ensure Hawk Training recruits and retains a diverse workforce.
  • Monitoring of learners and employers is also collected independently through ESFA learner and employer surveys and Ofsted learner and parent view platforms.




This equality and diversity policy should be read alongside other Hawk policies and strategies, including:

  • Staff recruitment and selection procedures
  • Dignity at work policy
  • Disclosure and confidentiality policy
  • Learning support policy
  • Safeguarding policy
  • Prevent Policy
  • Single Equality Strategy


Appendix A. Legal framework


The policy aims to achieve equality by removing any potential discrimination in the way that our employees are treated by fellow employees or the Company, including:

  • people with disabilities
  • people of different sexual orientations
  • transgendered and transsexual people
  • people of different races
  • people on the grounds of their sex
  • those of faith and of no faith
  • in relation to their age
  • in relation to their social class or medical condition
  • people who work part-time
  • those who are married or in a civil partnership
  • women who are pregnant, have recently given birth or are breastfeeding.

Discrimination can be either direct or indirect discrimination. Some of the above are protected characteristics under the Equality Act 2010 and discrimination is prohibited unless there is a legal exception under the Equality Act.

The Equality Act 2010 introduces the term ‘protected characteristic’ to refer to aspects of a person’s identity explicitly protected from unlawful discrimination. Nine are identified:

  • Race                                                              
  • Disability
  • Gender
  • Age
  • Sexual orientation
  • Religion and belief
  • Gender reassignment
  • Pregnancy / maternity
  • Marriage / civil partnership.


However, other aspects of a person’s identity, background or circumstance can cause them to experience discrimination, for example a person’s socio-economic status, class, or background. Hawk Training is committed to advancing equality and eliminating discrimination on these and other grounds. We recognise that there are other areas that fall outside of the Act -e.g. name, education, learning or social need.

The Equality Act 2010 introduces a Public Sector Equality Duty, in force from April 2011, https://www.equalityhumanrights.com/en/advice-and-guidance/public-sector-equality-duty, which requires Hawk Training and employers to give due regard to:

  • eliminate discrimination, harassment and victimisation
  • advance equality of opportunity
  • foster good relations.

‘Advance’ involves having due regard to the need to:

  1. remove / minimise disadvantages experienced by persons who share a relevant protected characteristic that are connected to that characteristic
  2. take steps to meet needs of persons who share a relevant protected characteristic that are different from the needs of persons who don’t share it
  3. encourage persons with a relevant protected characteristic to participate in public life or in any other activities where participation by such persons is disproportionately low

‘Foster good relations’ includes having due regard to tackle prejudice and promote understanding.


The Duty covers the nine protected characteristics:

The Equality Act 2010 recognises the following types of discrimination:

  • Direct discrimination, including associative and perception discrimination
  • Indirect discrimination
  • Harassment
  • Harassment by others
  • Victimisation
  • Discrimination arising from a disability
  • Failure to make reasonable adjustments


Direct discrimination occurs when someone is treated unfairly, or less favorably than another person, because they have a protected characteristic. This often arises because of assumptions, stereotyping or prejudice. Direct discrimination also covers association discrimination or perception discrimination. This is direct discrimination against someone because they associate with a person who has the protected characteristic or because they are perceived to have a protected characteristic.

Indirect discrimination occurs when a provision, criterion or practice is applied that appears to affect everyone equally but which in fact puts people who share a protected characteristic at a disadvantage.

Harassment occurs when someone behaves in such a way that their conduct has the purpose or effect of creating an environment that is offensive, hostile, degrading, humiliating or intimidating for a person, where:

  • this is related to a protected characteristic (except pregnancy and maternity or marriage and civil partnerships)
  • this is of a sexual nature (sexual harassment)
  • a person is treated less favourably because they have either submitted to or rejected sexual harassment, or harassment related to sex or gender reassignment (this is known as ‘consequential harassment’).

Harassment by others applies to age, disability, gender reassignment, race, religion or belief, sex and sexual orientation.

The Equality Act is clear in terms of the responsibilities of employers ensuing that employees and Learners are not placed at risk from this type of harassment. For example, employers are potentially liable if they are aware that harassment has taken place and have not taken reasonable steps to prevent it from happening again.

Discrimination arising from a disability occurs when a disabled person is treated less favourably than others because of something connected to their impairment

Failure to make reasonable adjustments occurs when an organisation fails to make reasonable adjustments for a disabled person, to avoid the disabled person being placed at a substantial disadvantage when compared with a non-disabled person.

Victimisation occurs when a person experiences disadvantage because they have supported someone in making a complaint or an allegation of discrimination, or because they personally have made an allegation of discrimination.


Appendix A Glossary

(adapted from information provided by the Equality and Human Rights Commission)





This refers to a person belonging to a particular age (e.g. 32 years old) or range of ages (e.g. 18-30 years old).


A person has a disability if he or she has a physical or mental impairment, which has a substantial and long-term adverse effect on that person’s ability to carry out normal day-to-day activities.

Direct Discrimination

This occurs when a person treats another less favorably than they treat, or would treat, others because of a protected characteristic.

Discrimination by Association

This is a form of direct discrimination, which occurs because of someone’s association with another person who has a protected characteristic. It may also occur because someone has campaigned to help people with a particular characteristic or has refused to act in a way that would disadvantage a person or group who have a particular characteristic.

Discrimination by Perception

This is a form of direct discrimination, which occurs when someone is treated less favourably because of a protected characteristic they are mistakenly thought to have.

Faiths and Beliefs

Faiths and beliefs include religious, philosophical and political beliefs as well as lack of belief. Generally, a belief should affect a person’s life choices or the way they live to be included in this definition.

Gender Reassignment

The process of transitioning from one gender to another, this may or may not include gender reassignment surgery.

Harassment Related to a Protected Characteristic

This occurs when someone is subject to unwanted conduct, which is related to a protected characteristic they have which has the purpose or effect or violating the individual’s dignity or creating an intimidating, degrading, humiliating or offensive environment for that individual. Harassment may take the form of spoken or written words or abuse, imagery, graffiti, physical gestures, facial expressions, mimicry, jokes, pranks, acts affecting an individual’s surroundings or other physical behaviour.

Indirect Discrimination

This occurs when applying a provision, criterion or practice, which puts someone from a particular group having one, or more protected characteristics at a particular disadvantage. Indirect discrimination may only be justified in exceptional circumstances if it can be shown that the action was reasonable in managing the business or organisation.

Marriage and Civil Partnership

Marriage can be defined as a union between a man and a woman but also as the union of a same-sex couple. Same-sex couples may also choose to have relationships legally recognised as civil partnerships.

Pregnancy and Maternity

Pregnancy is the condition of being pregnant or expecting a baby. Maternity refers to the period after birth, in the employment context this is linked to maternity leave; otherwise, protection against maternity discrimination is for 26 weeks after giving birth and includes less favourable treatment because of breastfeeding. After the 26-week period, any discrimination is Sex discrimination.

Protected Act

A protected act is bringing proceedings under the Act, giving evidence or information in connection with proceedings brought under the Act, done anything in relation to the provisions of the Act or making an allegation that another person has done something in breach of the Act.


Refers to a group of people defined by their race, colour, ethnic nationality or national origins.


Being a man or a woman.

Sexual Harassment

This occurs when a person engages in unwanted conduct, which is of a sexual nature. This may be verbal, non-verbal or physical conduct.

Sexual Orientation

Whether a person is attracted to their own sex, the opposite sex, both sexes or neither sex.


This occurs when an individual is subjected to detriment because they have done, are believed to have done or it is believed they will do a “protected act”.