Equal Status Policy

1. Purpose

   The purpose of this policy is to establish the commitment of the Company in regard to meeting our legal obligations to our customers under relevant equality legislation (the Equal Status Acts 2000-2015) and acknowledging and valuing the diversity of our customers across the protected grounds under equality legislation. This Equal Status Policy is a key pillar of our wider commitment to quality customer service. It underpins a systematic approach to equality, diversity, and non-discrimination for all customers covered by the grounds under equality legislation. This policy should be read in conjunction with our Equal Opportunities and Dignity at Work Policy.

2. Scope

   This policy applies to all employees and customers using the services of the Company.

3. Background:

   Under the Equal Status Acts (2000-2015) it is unlawful for providers of goods and services to discriminate against, harass, sexually harass, or victimise a person, in the course of their accessing goods and services. The legislation places an obligation on service providers to provide ‘reasonable accommodation’ for people with disabilities to access services. It allows service providers to take positive measures to promote equality of opportunity for customers.

4. Our Policy

   We are committed to ensuring that all our customers experience a welcome and are treated with respect across all our services. We seek to understand and respond to the specific needs of the diversity of our customer base from across the equality grounds. We will take steps to ensure that:

   • our employees welcome the diversity of our customers and treat them in a manner that is free from discrimination, harassment, sexual harassment, and victimisation
   • all that is reasonable is done to ensure that customers with disabilities can access our services, and
   • all that is reasonable is done to address any specific barriers encountered by customers from across all the grounds covered by the legislation. This policy is based on and motivated by our values of:

     Dignity: showing respect for each customer and treating them fairly.

     Diversity: recognising people in their different identities and taking account of specific needs that arise from such diversity.

     Inclusion: placing the full diversity of our customers at the centre of what we do and ensuring a quality of service for all customers.

APPENDIX 1: Implementing this policy

1. Achieving our standard

   This policy sets out the standard we expect from managers and employees. It ensures that: all our customers are dealt with in a courteous and open manner; that our services are accessible, and free from any form of discrimination or harassment; and that our employees acknowledge and value the diversity of our customers in a consistent and professional manner.

   Training

   Training will be provided to employees on equality, diversity and non-discrimination, the provisions of this policy, and the skills to implement it.

   Communication

   Employees will be made aware of the provisions of this policy on recruitment and in our induction processes.

   Employees will be provided with updates as part of our ongoing internal communication processes. Employees will be encouraged to give feedback on the implementation of the policy on a regular basis.

   Customers of the Company will be made aware of our commitments under this policy. The policy will be available to customers on request in all our services. The existence of the policy and its core provisions will be made publicly available on our website. Information will be made publicly available for customers wishing to provide feedback, or to submit a complaint related to this policy on our website.

   Leadership

   The General Manager will be given responsibility for leading, supervising, monitoring, and reporting on the implementation and impact of this policy.

2. Complaints

   Customer complaints in regard to this policy will be addressed fairly, sensitively, and in a timely manner. Care and consideration will also be given to respecting people’s confidentiality (to the greatest extent possible) and ensuring there is no victimisation of those involved in making a complaint.

   The General Manager of the Company is nominated as the person to whom complaints under this Equal Status Policy can be made and/or referred. In the first instance, attempts will be made to resolve and/or respond to the complaint informally. This may include a written response to the complainant, where complaints are received in writing. In the case of written complaints received, a response will be issued to the complainant within one month of receiving the written complaint.

   Breaches of this policy may lead to disciplinary action (in the case of employees) and exclusion from the premises (in the case of customers).

3. Allocation of Responsibilities

   Managers

   Management and others in positions of authority have a particular responsibility to ensure that our customers, and people seeking to access our services, do not experience discrimination, harassment, sexual harassment or victimisation, in the course of accessing our services.

   Management, therefore, are required to:

   • lead by example, by treating customers with respect and in a manner that upholds their dignity and values their diversity,
   • take all reasonable steps to ensure that employees do not discriminate against, harass, sexually harass, or victimise customers, or people seeking to access our services,
   • take steps to ensure reasonable accommodation of people with disabilities accessing, or seeking to access our services, and to remove barriers that might be specific to any other groups covered by the legislation,
   • take all reasonable steps to ensure employees to prevent and deal with any incidents of harassment or sexual harassment between customers. This may include reporting any incidents as soon as practicable to the identified contact person,
   • ensure that an employee or customer reporting an incident under this policy is not victimised for doing so,
   • facilitate customers who wish to make a complaint or give feedback to the Company, in regard to prohibited behaviour under this policy, and ensure any such incidents are effectively and efficiently addressed,
   • monitor and follow up the situation, following any complaints submitted, to ensure such incidents do not recur,
   • ensure all publicity, advertising and promotional materials are not discriminatory and reflect our values of dignity, diversity, and inclusion.

   • Employees

     Employees are required to contribute to the provision of a service to the public that is free from discrimination, harassment, sexual harassment, and victimisation and respectful of diversity.

     Employees are, therefore, required to:

   • • treat all customers with respect and in a manner that upholds their dignity,
     • co-operate with management strategies to: ensure customers do not experience
     discrimination, harassment, sexual harassment, or victimisation, in accessing our services; ensure reasonable accommodation of customers with disabilities; and address specific barriers experienced by other groups covered by the equality legislation,
     • take all reasonable steps to prevent and deal with any incidents of harassment or sexual harassment between customers, with the support of management.
     • report any incidents of harassment or sexual harassment between customers, and any action that was required to deal with the incident, to their line manager.

APPENDIX 2: Legal Background

1. The Grounds

   The grounds on which discrimination is outlawed by the Equal Status Acts are as follows:

   • ‘the gender ground’
   • ‘the civil status ground’ (formerly marital status)
   • ‘the family status ground’
   • ‘the sexual orientation ground’
   • ‘the religion ground’
   • ‘the age ground’
   • ‘the disability ground’
   • ‘the ground of race’ (includes ‘race, colour, nationality or ethnic or national origins’)
   • ‘the Traveller community’ ground
   • “the housing assistance” ground (only in the provision of accommodation)

   The Acts also prohibit discrimination against a person on the basis of association with another person, acting as a witness on behalf of that other person, giving evidence on their behalf, legally opposing an act which is unlawful under the Acts, or who has given notice of an intention to take any such actions.

2. Reasonable accommodation

   Service providers must provide specific treatment or facilities to enable people with disabilities to access and enjoy their goods and services. This is referred to as ‘reasonable accommodation’. Service providers are not expected to go beyond a ‘nominal cost’ in providing these facilities. Casework under the legislation has shown that ‘nominal’ does not constitute a fixed low sum of money but is assessed on the basis of the scale of and resources available to the service provider.

   When people are accessing, or attempting to access the services of the Company, we are legally obliged to:

   - ensure that they do not experience discrimination, harassment, sexual harassment, or victimisation from our employees or subcontractors,

   - provide ‘reasonable accommodation’ for people with disabilities to access and enjoy our services, and

   - take appropriate steps to ensure that our customers are not harassed or sexually harassed by other customers.

   Making ‘reasonable accommodation’ involves engaging in discussion with our customers with disabilities on their specific needs and how best to meet those needs.