Equality, Diversity & Inclusion

1. Introduction

Venesky-Brown are committed to promoting equal opportunities, valuing diversity and supporting an inclusive working environment for all our colleagues under the Equality Act 2010. We operate in increasingly diverse environments, both in the UK and Ireland, and this is evident in our workforce, clients, customers and suppliers. In the competitive business environment, we operate in, we understand that the performance and engagement of our employees is central to our success. Our commitment therefore, is to build an environment in which each colleague is able to fulfil their potential and maximise their contributions. At Venesky-Brown we welcome diversity, and fully appreciate that everyone has something unique to offer. We respect and understand these differences and aim to make the most of everyone’s talents.

Venesky-Brown are certified to ISO 9001:2015, our QMS procedures ensure compliance with all aspects of this policy.

2. What is EDI?

At Venesky-Brown, equality, diversity and inclusion are important principles.

Venesky-Brown Recruitment will treat everyone equally and will not discriminate on the grounds of an individual’s “protected characteristic” under the Equality Act 2010 (the Act) which are age, disability, gender re-assignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. We will not discriminate on the grounds of an individual’s membership or non-membership of a Trade Union. All staff have an obligation to respect and comply with this policy. Venesky-Brown Recruitment is committed to providing training for its entire staff in equality, diversity and inclusion.

To us, diversity is about understanding, recognising and valuing difference. We recognise that everyone is different. Likewise, equality means that we remove the barriers, eliminate discrimination and ensure equal opportunities for all employees.

To us, inclusion means that we focus on attracting and developing talent wherever it exists and we encourage everyone in our organisation to reach their full potential in whatever they do. We will continuously review all aspects of recruitment to avoid unlawful discrimination

Venesky-Brown Recruitment will not discriminate unlawfully when deciding which candidate/temporary worker is submitted for a vacancy or assignment, or in any terms of employment or terms of engagement for temporary workers.

Venesky-Brown Recruitment will ensure that each candidate is assessed in accordance with the candidate’s merits, qualifications and ability to perform the relevant duties for the role.

Our aim is to develop a culture where people’s differences are not only accepted, but they are valued, and used to enable everyone to thrive at work. We have developed an inclusive working environment where everyone feels they belong without having to conform, that their contribution matters and they are able to perform to their full potential, no matter their background, identity or circumstances.

Equality, Diversity & Inclusion (ED&I) are championed at the highest level in the organisation by the Directors and Senior Management. We have an Equality, Diversity & Inclusion Champion [Hannah Simpson, HR Manager] as well as two Fairness, Inclusion and Respect


  • Hannah Simpson, HR Manager, Tel: 0131 357 2140, Email: Hannah@venesky-brown.co.uk
  • Bob Mitchell, Operations Manager, Tel: 0131 357 2140, Email: Bob@venesky-brown.co.uk

As well as champions and ambassadors, we have created a Steering Committee which include members of all levers from across different departments of our organisation. The Steering Committee provides direction, promotes an inclusive workplace culture and facilitates the sharing of best practice across the organisation.

Venesky-Brown are accredited with Investors in Diversity following an assessment process. The journey and achievement of this standard gives a positive message to all of our stakeholders, internal and external. The Investors in Diversity Award is recognised as the national equality standard. Providing organisations with a bespoke approach for improving Fairness, Respect, Equality, Diversity, Inclusion and Engagement (FREDIE) practices in the workplace. The process of achieving this award helped us to place structured FREDIE standards at the heart of everything we do..

Venesky-Brown also participate in diversity campaigns throughout each year.

There are many benefits of embracing Equality, Diversity and Inclusion to Venesky-Brown, these include:

  • Reduced staff grievances
  • Reduced staff turnover
  • Increased staff development
  • Improved customer service and satisfaction
  • Improved links between employee activities and strategic objectives
  • Improved culture, attitudes, behaviours and conduct
  • Improved marketing approaches
  • Increased market share

3. Scope

The scope of this Equality, Diversity and Inclusion Policy covers all Venesky-Brown/Vescala/Venesky Brown Consult employees based in office locations and those with a hybrid model of working; covering the administration and management of the supply of professionals in construction, engineering, corporate services, admin, digital and IT.

4. Objectives

At Venesky-Brown and in line with legislation across the UK and Ireland, we aim to:

  • ensure equality, diversity and inclusion in the workplace are fully supported
  • offer fair treatment in every aspect of working life in Venesky-Brown. This applies to all employment policies and practices including those relating to:
    • Recruitment, selection and retention;
    • Terms and conditions of employment;
    • Working environment;
    • Learning and development;
    • Promotion and career progression;
    • Redundancy and re-deployment.
    • promote a culture where employees recognise the value that a diverse and inclusive workforce brings.
  • be recognised as an employer with a positive reputation for equality, diversity and inclusion practices
  • ensure that all job descriptions and job adverts are fully inclusive

5. Discrimination

Under the Act unlawful discrimination occurs in the following circumstances:

5.1 Direct Discrimination

Direct discrimination occurs when an individual is treated less favourably because of a protected characteristic. Treating someone less favourably means treating them badly in comparison to others that do not have that protected characteristic.
It is unlawful for a recruitment consultancy to discriminate against a person on the grounds of a protected characteristic:

  • in the terms on which the recruitment consultancy offers to provide any of its services;
  • by refusing or deliberately omitting to provide any of its services;
  • in the way it provides any of its services.

Direct discrimination can take place even if the individual does not have the protected characteristic but is treated less favourably because it is assumed he or she has the protected characteristic or is associated with someone that has the protected characteristic.

Direct discrimination would also occur if a recruitment consultancy accepted and acted upon instructions from an employer which states that certain persons are unacceptable due to a protected characteristic, unless an exception applies. The Act contains provisions that permit specifying a requirement that an individual must have a particular protected characteristic in order to undertake a job. These provisions are referred to as occupational requirements.

Where there is an occupational requirement then the client must show that applying the requirement is a proportionate means of achieving a legitimate aim, i.e. the employer must be able to objectively justify applying the requirement. An occupational requirement does not allow an employer to employ someone on less favourable terms or to subject a person to any other detriment. Neither does an occupational requirement provide an excuse against harassment or victimisation of someone who does not have the occupational requirement.

5.2 Indirect Discrimination

Indirect discrimination occurs when a provision, criterion or practice (PCP) is applied but this results in people who share a protected characteristic being placed at a disadvantage in comparison to those who do not have the protected characteristic. If the PCP can be objectively justified it will not amount to discrimination.

Indirect discrimination would also occur if a recruitment consultant accepted and acted upon an indirectly discriminatory instruction from an employer.

If the vacancy requires characteristics which amount to an occupational requirement or the instruction is discriminatory but there is an objective justification, Venesky-Brown Recruitment will not proceed with the vacancy unless the client provides written confirmation of the occupational requirement, exception or justification.

Venesky-Brown Recruitment will use best endeavours to comply with the Act and will not accept instructions from clients that will result in unlawful discrimination.

6. Harassment

Under the Act, harassment is defined as unwanted conduct that relates to a protected characteristic which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual. This includes unwanted conduct of a sexual nature.

Venesky-Brown Recruitment is committed to providing a work environment free from unlawful harassment.

Venesky-Brown Recruitment will ensure that the consultants do not harass any individual.
Examples of prohibited harassment are:

  • verbal or written conduct containing derogatory jokes or comments;
  • slurs or unwanted sexual advances;
  • visual conduct such as derogatory or sexually orientated posters;
  • photographs, cartoons, drawings or gestures which some may find offensive;
  • physical conduct such as assault, unwanted touching, or any interference because of sex, race or any other protected characteristic basis;
  • threats and demands to submit to sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment benefits in return for sexual favours;
  • retaliation for having reported or threatened to report harassment.

If an individual believes that they have been unlawfully harassed, they should make an immediate report to the HR Manager followed by a written complaint as soon as possible after the incident. The details of the complaint should include:

  • Details of the incident
  • Name(s) of the individual(s) involved
  • Name(s) of any witness(es)

Venesky-Brown Recruitment will undertake a thorough investigation of the allegations. If it is concluded that harassment has occurred, remedial action will be taken.

All employees and workers will be expected to comply with Venesky-Brown Recruitment’s policy on harassment in the workplace. Any breach of such a policy will lead to the appropriate disciplinary action.

Any individual who Venesky-Brown Recruitment finds to be responsible for harassment will be subject to the disciplinary procedure and the sanction may include termination.

7. Victimisation

Under the Act victimisation occurs when an individual is treated unfavourably because he/she has done a ‘protected act’ which is bringing a claim for unlawful discrimination or raising a grievance about discrimination or giving evidence in respect of a complaint about discrimination.

Venesky-Brown Recruitment will ensure that the consultants do not victimise any individual.

8. Disabled Persons

Discrimination occurs when a person is treated unfavourably as a result of their disability.

In direct discrimination occurs where a provision, criterion or practice is applied by or on behalf of an employer, or any physical feature of the employer’s premises, places a disabled person at a substantial disadvantage in comparison with persons who are not disabled.

In recruitment and selection there may be a requirement to make reasonable adjustments. For example, it might be necessary to have different application procedures for partially sighted or blind applicants that enable them to use Braille. With testing and assessment methods and procedures, tests can only be justified if they are directly related to the skills and competencies required for the job. Even then, it might be appropriate to have different levels of acceptable test results, depending on the disability. For example, an applicant with a learning disability might need more time to complete a test, or not be expected to reach the same standard as other non-disabled applicants.

Reasonable adjustments in recruiting could include:

  • modifying testing and assessment procedures;
  • meeting the candidate at alternative premises which are more easily accessible;
  • having flexibility in the timing of interviews;
  • modifying application procedures and application forms;
  • providing a reader or interpreter.
    Wherever possible Venesky-Brown Recruitment will make reasonable adjustments to hallways, passages and doors in order to provide and improve means of access for disabled employees and workers. However, this may not always be feasible, due to circumstances creating such difficulties as to render such adjustments as being beyond what is reasonable in all the circumstances.

Venesky-Brown Recruitment will not discriminate against a disabled person:

  • in the arrangements i.e. application form, interview or arrangements for selection for determining whom a job should be offered; or
  • in the terms on which employment or engagement of temporary workers is offered; or
  • by refusing to offer, or deliberately not offering the disabled person a job for reasons connected with their disability; or
  • in the opportunities afforded to the person for receiving any benefit, or by refusing to afford, or deliberately not affording him or her any such opportunity; or
  • by subjecting the individual to any other detriment (detriment will include refusal of training or transfer, demotion, reduction of wage, or harassment).

Venesky-Brown Recruitment will make career opportunities available to all people with disabilities and every practical effort will be made to provide for the needs of staff, candidates and clients.

8.1 Disability Confident Committed

Venesky-Brown Ltd are proud to be recognised as a Disability Confident Committed employer. The scheme supports employers to make the most of the talents disabled people can bring to the workplace and aims to help employers successfully recruit and retain disabled people and those with health conditions. By joining Venesky-Brown Ltd have committed to:

  • Ensuring our recruitment process is inclusive and accessible
  • Communicate and promote vacancies
  • Offer an interview to disabled people
  • Anticipate and provide reasonable adjustments as required
  • Support any existing employee acquiring a disability or long term health condition to stay in work.

8. Age Discrimination

Under the Act, it is unlawful to directly or indirectly discriminate against or to harass or victimise a person because of age. Age discrimination does not just provide protection for people who are older or younger. People of all ages are protected.
A reference to age is a reference to a person’s age group. People who share the protected characteristic of age are people who are in the same age group.
Age group can have various references:

  • Under 21s
  • People in their 40s
  • Adults

Venesky-Brown Recruitment will not discriminate directly or indirectly, harass or victimise any person on the grounds of their age. We will encourage clients not to include any age criteria in job specifications and every attempt will be made to encourage clients to recruit on the basis of competence and skills and not age.

Venesky-Brown Recruitment is committed to recruiting and retaining employees whose skills, experience, and attitude are suitable for the requirements of the various positions regardless of age. No age requirements will be stated in any job advertisements on behalf of the company.

If Venesky-Brown Recruitment requests age as part of its recruitment process such information will not be used as selection, training or promotion criteria or in any detrimental way and is only for compilation of personal data, which the company holds on all employees and workers and as part of its equal opportunities monitoring process. In addition if under age 22 to adhere to Conduct of Employment Agencies and Employment Business Regulations 2003 and other relevant legislation applicable to children or young candidates.

Where a client requests age or date of birth, this will have to be under an occupational requirement or with an objective justification which should be confirmed in writing.

10. Part-time Workers

This policy also covers the treatment of those employees and workers who work on a part-time basis, Venesky-Brown Recruitment recognises that it is an essential part of this policy that part time employees are treated on the same terms, with no detriment, as full time employees (albeit on a pro rata basis) in matters such as rates of pay, holiday entitlement, maternity leave, parental and domestic incident leave and access to our pension scheme. Venesky-Brown Recruitment also recognises that part time employees must be treated the same as full time employees in relation to training and redundancy situations.

11. Gender Reassignment

Venesky-Brown Recruitment recognises that any employee or worker may wish to change their gender during the course of their employment with the Company.

Venesky-Brown Recruitment will support any employee or worker through the reassignment.

Venesky-Brown Recruitment will make every effort to try to protect an employee or worker who has undergone, is undergoing or intends to undergo gender reassignment, from discrimination or harassment within the workplace.

Where an employee is engaged in work where the gender change imposes genuine problems Venesky-Brown Recruitment will make every effort to reassign the employee or worker to an alternative role in the Company, if so desired by the employee.

Any employee or worker suffering discrimination on the grounds of gender reassignment should have recourse to the Company’s grievance procedure.

12. Recruitment of Ex-Offenders

Where Venesky-Brown Recruitment has registered with the Disclosure and Barring Service (DBS) and has the authority to apply for criminal records checks on individual because they are working with children or vulnerable adults or both, we will comply with the DBS’s Code of Practice which includes having a policy on the recruitment of ex-offenders.

13. Training

We will provide diversity and inclusion training to managers and others likely to be involved in recruitment, performance management, talent management and other decision making where equal opportunities issues are likely to arise.

Our Equality, Diversity & Inclusion Policy is included in our Employee Handbook and Induction Packs. It is also made available on our company shared documents.

Employees at Venesky-Brown participate in annual Equality, Diversity and Inclusion training as well as refresher courses through the year. As partners of the Supply Chain Sustainability School, we ensure that our employees complete online training modules in relations to Equality, Diversity and Inclusion.

14. Reasonable Adjustments

Venesky-Brown will make any reasonable adjustments that are required to ensure the health, safety and convenience of our employees, this is our duty and responsibility as employers. As part of the job application process candidates are asked if they require reasonable adjustments made to facilitate job interviews. As part of our ISO 9001 QMS, DOC111 is used to ensure that clients provide us with detailed description of the working environment and job descriptions.

Venesky-Brown have made adjustments to our head office where interviews take place to meet the requirements of the Equality Act 2010. Adaptations have been made to pedestrian and vehicle access with designated parking provided for disabled badge holders, the accessible entrance to the building is clearly signed. Our access system is suitable for deaf and individuals who are hard of hearing. Main access doors can be operated at low level and are sufficiently wide to accommodate wheel chair users.

Specialist equipment including supportive chairs, height adjustable and standing desks are available. Interpreters are provided for people who are deaf or have a speech impairment. With respect to assignments Venesky-Brown can have the responsibility as employers to provide auxiliary aids or assistance for temporary workers.

15. Supply Chain

We are actively committed to advancing EDI among our supply chain. Venesky-Brown treat all of our suppliers with respect and actively build relationships to ensure we can effectively support and engage with our supply chain.

Venesky-Brown’s Approved Supplier Questionnaire (DOC89) includes a section on EDI to ensure that the importance of EDI is reflected throughout our supply chain.

16. Your Responsibility

We need your support, to meet our commitment to ensure equality, diversity and inclusion in employment and avoid unlawful discrimination. It is important to adhere to the spirit of the policy as you could be held personally liable as well as, or instead of, Venesky-Brown for any act of unlawful discrimination. We consider acts of discrimination against those we employ, or our customers, as disciplinary offences that may be dealt with under the disciplinary procedure

17. Complaints

Employees should disclose any instances of discrimination of which they become aware of to the HR Department (please see the Whistleblowing Policy, on the intranet). If you consider that you may have been unfairly treated or subjected to direct or indirect discrimination, you may use the grievance procedure to make a complaint, where every effort will be made to secure a satisfactory resolution.

Please refer to our Complaints Policy POL050.

18. Measuring Policy Effectiveness

Some ways in which we will measure the effectiveness of our ED&I policy include:

  • Collating and reviewing quantitative and qualitative data to identify any areas requiring action;
  • Publishing annual diversity data regarding the demographics of our workforce
  • Undertake regular audits and reviews
  • Highlight where barriers exist and show the positive impact of the company initiatives

19. Monitoring

We continuously review this Policy, together with all of our employment policies and practices to maintain our focus on equality of opportunity. To ensure that this Policy and other procedures are operating effectively, HR will continue to monitor and measure the records of our employees, benchmark our performance as a Company and ensure that any patterns or trends are identified and resolved.

Venesky-Brown are subject to Recruitment Employment Confederation (REC) equality legislation compliance test every two years.

The policy will be reviewed annually to ensure that it remains relevant.