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BrandHire Equity, Diversity & Inclusion Policy

Last Updated: 03 August 2026

1. Purpose, Status, Scope and Application

1.1 Purpose

1.1.1 This Equity, Diversity & Inclusion Policy (“Policy”) establishes the mandatory legal, operational and governance standards governing the provision of recruitment agency services by Brand Hire Ltd (“BrandHire”).

1.1.2 This Policy has been adopted to ensure that every Recruitment Activity undertaken by BrandHire is conducted lawfully, objectively, consistently and without unlawful discrimination.

1.1.3 The objectives of this Policy are to:

(a) safeguard equality of opportunity throughout BrandHire’s recruitment services;

(b) ensure compliance with applicable equality and recruitment legislation;

(d) prevent unlawful discrimination in all Recruitment Activities;

(e) ensure that Employer Client instructions are assessed independently against applicable legal requirements before implementation;

(f) provide an auditable governance framework capable of demonstrating legal compliance to regulators, courts, tribunals, Employer Clients, investors and other stakeholders; and

(g) support continuous improvement in recruitment practices through documented governance, monitoring and review.

1.1.4 This Policy forms part of BrandHire’s wider compliance framework and shall be interpreted consistently with all applicable legislation.

1.2 Status

1.2.1 This Policy is a controlled compliance document approved by BrandHire for the governance of its external recruitment activities.

1.2.2 Compliance with this Policy is mandatory in relation to every Recruitment Activity undertaken by or on behalf of BrandHire.

1.2.3 Where this Policy imposes standards exceeding statutory minimum requirements, BrandHire shall apply those higher standards unless prohibited by law.

1.2.4 Nothing contained within this Policy shall limit or diminish any statutory duty imposed upon BrandHire by applicable legislation.

1.3 Scope

1.3.1 This Policy governs BrandHire’s conduct towards:

(a) Candidates;

(b) prospective Candidates;

(d) prospective Employer Clients; and

(e) every Recruitment Activity undertaken on BrandHire’s behalf.

1.3.2 Recruitment Activities governed by this Policy include, without limitation:

(a) business development discussions concerning recruitment assignments;

(b) receipt of vacancy instructions;

(d) Candidate sourcing;

(e) talent mapping;

(f) Candidate registration;

(g) screening;

(h) interviewing;

(i) assessment;

(j) recommendation;

(k) introduction;

(l) communications with Candidates and Employer Clients;

(m) processing information relating to Candidates; and

(n) every ancillary activity undertaken in connection with BrandHire’s recruitment services.

1.3.3 This Policy applies irrespective of whether Recruitment Activities are undertaken through:

(a) BrandHire’s website;

(b) electronic communications;

(d) video conferencing;

(e) professional networking platforms;

(f) social media;

(g) university careers services;

(h) recruitment events;

(i) referrals; or

(j) any other communication channel.

1.4 Matters Outside Scope

1.4.1 This Policy governs BrandHire’s provision of recruitment agency services.

1.4.2 This Policy is not an internal employment policy governing:

(a) recruitment of BrandHire personnel;

(b) employee promotion;

(d) disciplinary procedures;

(e) employee grievances; or

(f) workforce management.

1.4.3 Internal employment matters shall be governed by separate policies where applicable.

1.5 Application

1.5.1 Every Recruitment Activity shall comply with this Policy.

1.5.2 Commercial considerations shall not justify departure from the standards established by this Policy.

1.5.3 Employer Client preferences shall not override BrandHire’s statutory obligations.

1.5.4 Where uncertainty exists regarding the interpretation of this Policy, the interpretation most consistent with applicable equality legislation shall be adopted pending further legal review.

2. Interpretation and Definitions

2.1 Interpretation

2.1.1 Unless the context otherwise requires:

(a) references to legislation include amendments, re-enactments, subordinate legislation and replacement legislation;

(b) references to statutory guidance include replacement guidance issued by the relevant authority;

(d) references to one gender include every gender;

(e) headings are included for convenience only and shall not affect interpretation.

2.1.2 References in this Policy to duties arising under the Equality Act include, where applicable to recruitment agency services, duties concerning direct discrimination, indirect discrimination, harassment, victimisation, positive action, occupational requirements and associated statutory protections.

2.1.3 Nothing contained within this Policy shall reduce or limit any statutory protection afforded to Candidates or Employer Clients.

2.2 Defined Terms

For the purposes of this Policy:

“Assessment” means every structured process used to evaluate Candidate suitability for a vacancy.

“BrandHire” means Brand Hire Ltd.

“Candidate” means any individual seeking, receiving or being considered for recruitment services provided by BrandHire.

“Conduct Regulations” means the Conduct of Employment Agencies and Employment Businesses Regulations 2003, as amended and in force from time to time.

“Data Protection Legislation” means the UK General Data Protection Regulation, the Data Protection Act 2018 and all associated legislation governing the processing of personal data.

“Employer Client” means any organisation or person engaging BrandHire to identify, assess or introduce Candidates.

“Equality Act” means the Equality Act 2010, as amended from time to time.

“Employment Agencies Act” means the Employment Agencies Act 1973, as amended from time to time.

“Occupational Requirement” means a lawful occupational requirement recognised under the Equality Act.

“Policy Owner” means the individual designated within the Document Control Schedule as responsible for governance of this Policy.

“Positive Action” means lawful measures permitted under the Equality Act to address disadvantage, differing needs or under-representation.

“Protected Characteristic” means a characteristic protected by the Equality Act.

“Reasonable Adjustment” means an adjustment required by law to remove or reduce substantial disadvantage experienced by a disabled Candidate.

“Recruitment Activity” means every activity undertaken by BrandHire in connection with identifying, assessing, introducing or placing Candidates, including all ancillary recruitment processes.

“Special Category Data” has the meaning given by Article 9 UK GDPR.

3. Legislative Framework

3.1 Governing Principles

3.1.1 BrandHire shall conduct every Recruitment Activity in accordance with applicable legislation in force within the United Kingdom.

3.1.2 This Policy has been drafted principally by reference to:

(a) the Equality Act 2010;

(b) the Employment Agencies Act 1973;

(d) the Data Protection Act 2018;

(e) the UK General Data Protection Regulation;

(f) applicable statutory Codes of Practice issued by the Equality and Human Rights Commission; and

(g) applicable statutory instruments and successor legislation.

3.1.3 Where legislation is amended after publication of this Policy, BrandHire shall interpret and apply this Policy consistently with the amended legal position until formal revision takes place.

3.2 Hierarchy of Obligations

3.2.1 Compliance with this Policy shall not relieve BrandHire of any obligation imposed by statute, common law or contract.

3.2.2 Where any inconsistency arises between this Policy and another BrandHire compliance document, the interpretation that best secures compliance with applicable equality legislation shall prevail.

3.2.3 BrandHire shall have regard to relevant statutory guidance and authoritative judicial decisions when interpreting this Policy and reviewing Recruitment Activities.

3.2.4 Where any instruction, request, contractual term, commercial expectation or operational practice is inconsistent with applicable legislation or this Policy, BrandHire shall comply with applicable legislation and this Policy. BrandHire shall not implement any Recruitment Activity on the basis that compliance with an Employer Client instruction, commercial objective or contractual arrangement requires or justifies a departure from applicable legal obligations.

3.3 Core Equality Principles

3.3.1 Every Recruitment Activity shall be undertaken according to the following principles:

(a) equality of opportunity;

(b) objective assessment;

(d) proportionality;

(e) consistency;

(f) accountability;

(g) evidential decision-making; and

(h) compliance with applicable legislation.

3.3.2 Recruitment decisions shall be based exclusively upon objective criteria relevant to the genuine requirements of the role unless legislation expressly provides otherwise.

3.3.3 BrandHire shall maintain sufficient documentary evidence to demonstrate compliance with this Policy during any audit, regulatory investigation or legal proceedings.

4. Equality Principles

4.1 General Principles

4.1.1 BrandHire is committed to conducting every Recruitment Activity in accordance with the principles of equality, fairness, objectivity, transparency and merit.

4.1.2 Every Candidate shall have an equal opportunity to be considered for recruitment opportunities on the basis of objective suitability for the relevant role.

4.1.3 Every Employer Client shall receive recruitment services delivered in accordance with applicable legislation irrespective of commercial value, duration of engagement or recruitment volume.

4.1.4 Recruitment decisions shall be based exclusively upon objective assessment of the competencies, qualifications, experience, skills and other lawful requirements genuinely necessary for successful performance of the relevant role.

4.1.5 Protected Characteristics shall not influence Recruitment Activities except where legislation expressly permits or requires differential treatment.

4.1.6 BrandHire shall not permit commercial objectives, operational convenience, client preference or historical recruitment practice to override statutory equality obligations.

4.2 Protected Characteristics

4.2.1 This Policy applies in respect of every Protected Characteristic recognised by the Equality Act.

4.2.2 Those Protected Characteristics comprise:

(a) age;

(b) disability;

(d) marriage and civil partnership;

(e) pregnancy and maternity;

(f) race, including colour, nationality and ethnic or national origins;

(g) religion or belief, including lack of religion or belief;

(h) sex; and

(i) sexual orientation.

4.2.3 Protection shall apply equally where discrimination arises because a person:

(a) possesses a Protected Characteristic;

(b) is perceived to possess a Protected Characteristic; or

4.2.4 BrandHire further recognises that multiple Protected Characteristics may interact and that Recruitment Activities shall therefore be assessed having regard to the cumulative effect of recruitment decisions where appropriate.

5. Prohibited Conduct

5.1 General Rule

5.1.1 BrandHire shall not engage in, facilitate, authorise, encourage, procure or knowingly permit conduct prohibited by the Equality Act.

5.1.2 Compliance with this clause extends to every stage of Recruitment Activity from initial business development through to completion of the recruitment assignment.

5.1.3 BrandHire shall not implement any Recruitment Activity where there are reasonable grounds to believe that doing so would result in unlawful discrimination.

5.2 Direct Discrimination

5.2.1 No Candidate or Employer Client shall receive less favourable treatment because of a Protected Characteristic except where legislation expressly provides otherwise.

5.2.2 Direct discrimination is prohibited irrespective of whether it arises:

(a) intentionally;

(b) inadvertently;

(d) through reliance upon assumptions or stereotypes;

(e) pursuant to Employer Client instructions;

(f) through automated decision-making; or

(g) by omission rather than positive act.

5.2.3 BrandHire shall not rely upon assumptions concerning an individual’s capability, commitment, availability, reliability or suitability which arise from a Protected Characteristic rather than objective evidence.

5.3 Indirect Discrimination

5.3.1 Recruitment Activities shall not include any provision, criterion or practice which places persons sharing a Protected Characteristic at a particular disadvantage unless objectively justified.

5.3.2 Before implementing any provision, criterion or practice capable of adversely affecting a protected group, BrandHire shall consider:

(a) the legitimate objective pursued;

(b) the evidence supporting that objective;

(d) reasonably available alternative approaches; and

(e) whether a less discriminatory measure would achieve substantially the same objective.

5.3.3 Assessment methodologies shall be reviewed periodically to ensure continuing justification.

5.4 Objective Justification

5.4.1 Where BrandHire relies upon objective justification, that conclusion shall be supported by documented evidence.

5.4.2 Objective justification requires demonstration that the relevant measure:

(a) pursues a legitimate objective;

(b) addresses a genuine operational need;

(d) is proportionate;

(e) represents the least discriminatory reasonably available approach; and

(f) remains necessary following periodic review.

5.4.3 Administrative convenience, commercial pressure, market expectation or historical practice shall not, without more, constitute objective justification.

5.4.4 Documentation supporting objective justification shall form part of the recruitment record.

5.5 Harassment

5.5.1 BrandHire shall maintain Recruitment Activities free from unlawful harassment.

5.5.2 Unwanted conduct related to a Protected Characteristic shall be treated as prohibited where it has the purpose or effect of violating dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.

5.5.3 This prohibition applies equally to communications between:

(a) BrandHire and Candidates;

(b) BrandHire and Employer Clients;

(d) persons acting on BrandHire’s behalf.

5.5.4 Allegations of harassment shall be investigated in accordance with this Policy.

5.6 Sexual Harassment

5.6.1 BrandHire shall not tolerate conduct amounting to sexual harassment.

5.6.2 Where BrandHire becomes aware of conduct which may amount to sexual harassment during a recruitment assignment, BrandHire shall:

(a) investigate the matter;

(b) consider appropriate protective measures;

(d) determine whether continuation of the assignment remains consistent with this Policy; and

(e) document the action taken.

5.7 Victimisation

5.7.1 No person shall suffer detriment because that person has undertaken a protected act recognised by the Equality Act.

5.7.2 Protected acts include, without limitation:

(a) making a complaint;

(b) supporting another person’s complaint;

(d) participating in an investigation;

(e) refusing to participate in unlawful discrimination; or

(f) otherwise exercising rights protected by equality legislation.

5.8 Discriminatory Advertising

5.8.1 Every vacancy advertisement issued by BrandHire shall accurately reflect only the genuine requirements of the relevant role.

5.8.2 Advertisements shall be reviewed before publication to ensure that they:

(a) comply with applicable legislation;

(b) avoid discriminatory wording;

(d) encourage applications from suitably qualified persons; and

(e) accurately describe the role.

5.8.3 BrandHire shall refuse to publish advertisements reasonably considered capable of constituting unlawful discriminatory advertising.

5.9 Discriminatory Instructions

5.9.1 Employer Client instructions requiring unlawful discrimination shall not be accepted.

5.9.2 An instruction shall be treated as discriminatory irrespective of whether expressed directly, indirectly, implicitly or through coded language.

5.9.3 Receipt of a potentially discriminatory instruction shall require:

(a) immediate legal review;

(b) documented consideration of the relevant legal obligations;

(d) refusal to implement unlawful instructions; and

(e) retention of a complete audit trail.

5.10 Occupational Requirements

5.10.1 BrandHire recognises that Occupational Requirement exceptions are available only in the limited circumstances prescribed by the Equality Act.

5.10.2 BrandHire shall independently assess every asserted Occupational Requirement before implementing any Recruitment Activity relying upon it.

5.10.3 An asserted Occupational Requirement shall not be accepted unless BrandHire is reasonably satisfied that it is:

(a) lawful;

(b) genuine;

(d) proportionate; and

(e) supported by sufficient evidence.

5.10.4 Employer Client assertions shall not, without independent assessment, establish the existence of a lawful Occupational Requirement.

5.10.5 Where BrandHire is not satisfied that the statutory requirements have been met, the relevant instruction shall be declined and the reasons recorded.

5.11 Equality Risk Escalation

5.11.1 Recruitment Activities presenting a material equality compliance risk shall be suspended pending review.

5.11.2 Equality compliance risks requiring escalation include:

(a) alleged Occupational Requirements;

(b) potentially discriminatory advertising;

(d) requests to disclose Protected Characteristic information;

(e) proposed departures from documented assessment methodology;

(f) significant requests relating to automated recruitment technology; and

(g) any matter reasonably capable of exposing BrandHire or an Employer Client to regulatory enforcement or legal proceedings.

5.11.3 The outcome of every equality risk review shall be documented together with the legal analysis, conclusions reached and action taken.

6. Operational Recruitment Standards

6.1 General Operational Standard

6.1.1 Every Recruitment Activity undertaken by BrandHire shall be conducted in accordance with documented procedures designed to ensure consistency, transparency and compliance with applicable legislation.

6.1.2 Recruitment methodology shall be capable of independent review and supported by contemporaneous records sufficient to demonstrate the objective basis of every material recruitment decision.

6.1.3 Recruitment procedures shall be applied consistently throughout each recruitment assignment unless amendment is objectively justified, documented and applied equally to all affected Candidates.

6.2 Duties Owed to Candidates

6.2.1 BrandHire shall provide recruitment services to every Candidate fairly, professionally and without unlawful discrimination.

6.2.2 Every Candidate shall be afforded an equal opportunity to demonstrate suitability for the relevant vacancy through objective assessment.

6.2.3 BrandHire shall communicate honestly, accurately and respectfully throughout the recruitment process.

6.2.4 Candidates shall not be subjected to unnecessary enquiries concerning Protected Characteristics except where:

(a) disclosure is required by law;

(b) disclosure is necessary to facilitate Reasonable Adjustments;

(d) the Candidate voluntarily provides the information; or

(e) another lawful basis exists under Data Protection Legislation.

6.2.5 No Candidate shall be excluded from Recruitment Activities because a Reasonable Adjustment has been requested or implemented.

6.3 Duties Owed to Employer Clients

6.3.1 BrandHire shall provide Employer Clients with recruitment services that comply with applicable legislation irrespective of commercial considerations.

6.3.2 Employer Clients shall receive advice where BrandHire reasonably considers that proposed recruitment practices may present equality compliance risks.

6.3.3 BrandHire shall not implement instructions that are inconsistent with applicable legislation or this Policy.

6.3.4 Where lawful recruitment cannot be achieved following engagement with an Employer Client, BrandHire shall decline or withdraw from the relevant assignment.

6.4 Vacancy Instructions

6.4.1 Before commencing any recruitment assignment, BrandHire shall obtain sufficient information to establish the genuine requirements of the vacancy.

6.4.2 Vacancy instructions shall include, where applicable:

(a) essential qualifications;

(b) essential competencies;

(d) reporting arrangements;

(e) remuneration;

(f) working arrangements;

(g) location;

(h) lawful Occupational Requirements, where asserted; and

(i) any other information reasonably necessary to conduct an objective recruitment process.

6.4.3 Vacancy instructions shall be reviewed before recruitment activity commences to identify legal, operational and equality compliance risks.

6.5 Vacancy Advertising

6.5.1 Vacancy advertisements shall accurately describe the role and its genuine requirements.

6.5.2 Every advertisement shall undergo equality compliance review before publication.

6.5.3 BrandHire shall refuse to publish advertising which appears reasonably capable of constituting unlawful discriminatory advertising.

6.5.4 Material amendments made for equality compliance purposes shall be retained as part of the recruitment record.

6.6 Candidate Sourcing

6.6.1 Candidate sourcing strategies shall seek to identify suitably qualified Candidates through recruitment channels capable of supporting equality of opportunity.

6.6.2 BrandHire shall periodically review sourcing methodologies to determine whether unnecessary barriers to participation exist.

6.6.3 Candidate sourcing shall not deliberately or indirectly exclude protected groups unless objectively justified under applicable legislation.

6.7 Screening and Assessment

6.7.1 Screening criteria shall be determined before Candidate assessment begins.

6.7.2 Screening shall be based solely upon objective requirements relevant to successful performance of the role.

6.7.3 Assessment methodologies shall evaluate only matters legitimately connected with Candidate suitability, including:

(a) qualifications;

(b) technical competence;

(d) transferable skills;

(e) behavioural competencies;

(f) demonstrable achievements; and

(g) lawful Occupational Requirements where applicable.

6.7.4 Assessors shall disregard matters unrelated to objective suitability.

6.8 Assessment Governance

6.8.1 Assessment methodologies shall be documented before implementation.

6.8.2 Assessment criteria shall remain consistent throughout the recruitment process unless amendment is objectively necessary.

6.8.3 Where assessment criteria require amendment:

(a) the reasons shall be documented;

(b) affected Candidates shall be treated consistently;

(d) the amendment shall form part of the recruitment record.

6.8.4 Structured assessment methodologies shall, wherever reasonably practicable, incorporate predetermined evaluation criteria.

6.8.5 Recommendations made to Employer Clients shall accurately reflect the outcome of the documented assessment process.

6.9 Shortlisting

6.9.1 Candidates shall be shortlisted exclusively by reference to documented assessment criteria.

6.9.2 Every shortlisted Candidate shall satisfy the objective requirements established for the vacancy.

6.9.3 BrandHire shall maintain sufficient records to demonstrate why shortlisted Candidates were considered objectively suitable.

6.9.4 Where a Candidate is not shortlisted following full assessment, the recruitment record shall identify the principal objective reasons supporting that decision.

6.10 Recommendations

6.10.1 Candidate recommendations shall accurately describe the Candidate’s qualifications, experience and suitability.

6.10.2 Recommendations shall not disclose information relating to Protected Characteristics unless disclosure:

(a) has been expressly authorised by the Candidate;

(b) is required by law;

(d) is otherwise lawful under Data Protection Legislation.

6.11 Artificial Intelligence and Automated Recruitment

6.11.1 Where BrandHire utilises artificial intelligence, machine learning, automated screening software or comparable technologies, those systems shall operate only as decision-support tools.

6.11.2 Material recruitment decisions shall remain subject to meaningful human review.

6.11.3 BrandHire shall undertake reasonable due diligence before implementing automated recruitment technologies, including consideration of:

(a) equality compliance;

(b) transparency;

(d) reliability;

(e) data protection compliance; and

(f) the potential for discriminatory bias.

6.11.4 Automated recruitment technologies shall be subject to periodic review to identify unintended discriminatory outcomes.

6.11.5 Discovery of material bias shall require immediate investigation together with implementation of appropriate corrective measures.

7. Reasonable Adjustments

7.1 General Duty

7.1.1 BrandHire recognises its legal obligations concerning disabled Candidates.

7.1.2 Reasonable Adjustments shall be considered individually, objectively and without unnecessary delay.

7.1.3 Requests for Reasonable Adjustments shall not adversely affect a Candidate’s participation in Recruitment Activities.

7.2 Assessment of Requests

7.2.1 BrandHire shall engage constructively with the Candidate when determining appropriate adjustments.

7.2.2 Assessment shall consider:

(a) the Candidate’s individual circumstances;

(b) the Recruitment Activity concerned;

(d) operational practicality;

(e) proportionality; and

(f) applicable legal requirements.

7.2.3 Decisions concerning Reasonable Adjustments shall be documented.

7.3 Employer Client Engagement

7.3.1 Information concerning Reasonable Adjustments shall be disclosed to an Employer Client only with the Candidate’s consent or where otherwise lawful.

7.3.2 Employer Clients shall be informed of adjustments reasonably necessary to facilitate lawful participation in Recruitment Activities.

8. Positive Action

8.1 General Principle

8.1.1 Positive Action shall be undertaken only where expressly permitted by the Equality Act.

8.1.2 BrandHire shall distinguish clearly between lawful Positive Action and unlawful positive discrimination.

8.2 Implementation

8.2.1 Before implementing Positive Action, BrandHire shall document the evidence supporting its conclusion that:

(a) disadvantage exists;

(b) different needs exist; or

8.2.2 Any Positive Action measure adopted shall be proportionate to the identified circumstances.

8.2.3 Positive Action shall not remove the requirement for Candidates to satisfy the objective requirements of the relevant vacancy.

8.3 Employer Client Advice

8.3.1 Where an Employer Client proposes relying upon Positive Action, BrandHire shall explain the applicable statutory framework and the limitations imposed by the Equality Act.

8.3.2 Advice provided under this clause shall be documented as part of the recruitment record.

9. Data Protection, Confidentiality and Information Governance

9.1 General Principles

9.1.1 BrandHire shall process all personal data obtained during Recruitment Activities in accordance with applicable Data Protection Legislation.

9.1.2 Information relating to a Protected Characteristic shall be processed only where a lawful basis exists and, where required, an applicable condition for processing Special Category Data has been established.

9.1.3 BrandHire shall process only the minimum information reasonably necessary to fulfil the relevant recruitment purpose.

9.1.4 Personal data shall not be processed for purposes incompatible with those for which it was originally obtained unless permitted by law.

9.2 Collection of Equality Information

9.2.1 Information concerning Protected Characteristics shall be collected only where:

(a) required by law;

(b) necessary to facilitate Reasonable Adjustments;

(d) voluntarily provided by the Candidate; or

(e) otherwise permitted under Data Protection Legislation.

9.2.2 BrandHire shall not require disclosure of Protected Characteristics as a condition of participation in Recruitment Activities unless disclosure is required by law.

9.3 Confidentiality

9.3.1 Information relating to Protected Characteristics shall be treated as confidential.

9.3.2 Access shall be limited to persons requiring such information for legitimate recruitment, legal or compliance purposes.

9.3.3 Appropriate technical and organisational measures shall be maintained to preserve the confidentiality, integrity and availability of such information.

9.4 Disclosure

9.4.1 BrandHire shall not disclose information relating to a Candidate’s Protected Characteristics to an Employer Client unless:

(a) the Candidate has provided explicit consent;

(b) disclosure is necessary to facilitate an agreed Reasonable Adjustment;

(d) another lawful basis exists under Data Protection Legislation.

9.4.2 Disclosure shall be limited to the minimum information reasonably necessary to achieve the relevant lawful purpose.

9.5 Retention and Disposal

9.5.1 Information governed by this Policy shall be retained only for so long as required to fulfil the purposes for which it was collected or as otherwise required by law.

9.5.2 Disposal of recruitment records shall be undertaken securely and in accordance with BrandHire’s document retention procedures.

9.5.3 Where litigation, regulatory investigation or formal complaint is reasonably anticipated, routine destruction of relevant records shall immediately cease until lawful disposal becomes permissible.

10. Monitoring, Record-keeping and Evidential Governance

10.1 Purpose

10.1.1 BrandHire shall maintain monitoring and record-keeping arrangements sufficient to demonstrate compliance with this Policy.

10.1.2 Monitoring shall support:

(a) legal compliance;

(b) operational consistency;

(d) continuous improvement;

(e) regulatory accountability; and

(f) evidential integrity.

10.2 Recruitment Records

10.2.1 Recruitment records shall be prepared contemporaneously wherever reasonably practicable.

10.2.2 Records shall be sufficiently complete to enable an independent reviewer to understand:

(a) the Employer Client’s instructions;

(b) the recruitment methodology applied;

(d) the evidence considered;

(e) the decisions reached;

(f) the reasons supporting those decisions; and

(g) the individual responsible for each material decision.

10.2.3 Material amendments to recruitment records shall remain identifiable.

10.2.4 Recruitment records shall not be retrospectively reconstructed except where clearly identified and supported by contemporaneous evidence.

10.3 Equality Monitoring

10.3.1 Equality monitoring shall be undertaken only for legitimate compliance and governance purposes.

10.3.2 Wherever reasonably practicable, equality monitoring information shall be anonymised or pseudonymised before statistical analysis.

10.3.3 Equality monitoring shall remain separate from individual recruitment decision-making unless legislation expressly provides otherwise.

10.3.4 Monitoring shall not establish quotas or predetermined recruitment outcomes.

10.4 Compliance Metrics

10.4.1 BrandHire shall periodically review measurable indicators designed to evaluate compliance with this Policy.

10.4.2 Those indicators may include:

(a) equality compliance reviews completed;

(b) recruitment advertisements reviewed;

(d) discriminatory instructions refused;

(e) Reasonable Adjustment requests implemented;

(f) complaints investigated;

(g) audit actions completed;

(h) training completed; and

(i) corrective actions outstanding.

10.4.3 Compliance metrics shall support governance and improvement and shall not determine recruitment outcomes.

10.5 Compliance Audit Programme

10.5.1 BrandHire shall maintain a documented compliance audit programme.

10.5.2 Compliance audits shall examine, where applicable:

(a) recruitment records;

(b) vacancy advertisements;

(d) Employer Client instructions;

(e) complaints;

(f) implementation of Reasonable Adjustments;

(g) Positive Action decisions;

(h) equality monitoring arrangements;

(i) governance documentation; and

(j) previous corrective actions.

10.5.3 Audit findings shall be documented and assigned a proportionate risk rating.

10.5.4 Corrective actions shall identify:

(a) the action required;

(b) the individual responsible;

(d) verification of completion.

10.5.5 Completion of corrective actions shall be independently verified wherever reasonably practicable.

11. Training and Professional Competence

11.1 Competence

11.1.1 Recruitment Activities shall be undertaken only by persons possessing sufficient knowledge and competence to comply with this Policy.

11.1.2 BrandHire shall ensure that those acting on its behalf understand:

(a) applicable equality legislation;

(b) objective recruitment methodology;

(d) lawful Positive Action;

(e) Reasonable Adjustments;

(f) confidentiality obligations;

(g) discriminatory Employer Client instructions;

(h) information governance; and

(i) reporting obligations.

11.2 Review of Competence

11.2.1 Professional competence shall be reviewed periodically.

11.2.2 Additional training shall be undertaken following:

(a) significant legislative change;

(b) material amendment of this Policy;

(d) substantiated complaints;

(e) material operational change; or

(f) identification of competency deficiencies.

11.2.3 Records of training and competence reviews shall be retained as compliance records.

12. Third-party Compliance

12.1 Application

12.1.1 Where any Recruitment Activity is undertaken by a contractor, consultant, freelance recruiter, outsourced recruitment provider or any other person acting on BrandHire’s behalf, BrandHire shall take reasonable steps to ensure that equivalent standards of equality, diversity and inclusion compliance are maintained.

12.1.2 BrandHire shall require such persons to comply with standards no less rigorous than those established by this Policy.

12.1.3 Where appropriate having regard to the nature, duration and risk profile of the engagement, BrandHire shall incorporate contractual obligations requiring compliance with applicable equality legislation and this Policy.

12.2 Oversight

12.2.1 BrandHire shall maintain appropriate oversight of Recruitment Activities undertaken on its behalf.

12.2.2 Oversight may include review of documented recruitment practices, compliance records, audit findings, complaints or other information reasonably necessary to assess compliance with this Policy.

12.2.3 Where material non-compliance is identified, BrandHire shall determine whether:

(a) corrective action is required;

(b) additional oversight is appropriate;

(d) termination of the relevant engagement is necessary.

12.2.4 Findings arising from oversight activities shall be documented and retained as compliance records.

13. Complaints, Investigations and Regulatory Co-operation

13.1 Right to Raise Concerns

13.1.1 Any Candidate or Employer Client who reasonably believes that a Recruitment Activity has been conducted inconsistently with this Policy may submit a complaint to BrandHire.

13.1.2 Complaints may relate to, without limitation:

(a) alleged discrimination;

(b) harassment;

(d) failure to implement a Reasonable Adjustment;

(e) discriminatory advertising;

(f) assessment methodology;

(g) Employer Client instructions;

(h) confidentiality of Protected Characteristic information; or

(i) any other matter governed by this Policy.

13.1.3 Nothing in this Policy shall prevent any person from exercising statutory rights or pursuing remedies available under applicable law.

13.2 Submission of Complaints

13.2.1 Complaints shall be submitted to:

Brand Hire Ltd
Email: privacy@brandhire.co.uk

13.2.2 Complaints should contain sufficient information to enable a fair investigation, including where available:

(a) relevant dates;

(b) the Recruitment Activity concerned;

(d) supporting documentation; and

(e) the outcome sought.

13.2.3 BrandHire shall acknowledge receipt of complaints within a reasonable period and maintain an appropriate record of the complaint.

13.3 Investigation

13.3.1 Every complaint shall be investigated fairly, objectively and without unreasonable delay.

13.3.2 The investigation shall seek to establish:

(a) the relevant facts;

(b) the applicable legal obligations;

(d) whether corrective action is required; and

(e) whether wider procedural improvements should be implemented.

13.3.3 BrandHire may request further information where reasonably necessary to complete its investigation.

13.3.4 Investigations shall be documented and retained as compliance records.

13.4 Outcome

13.4.1 Upon completion of an investigation BrandHire shall determine whether:

(a) no breach has occurred;

(b) additional enquiries are required;

(d) the relevant Employer Client relationship should continue; or

(e) any other action is required under this Policy.

13.4.2 Where appropriate and subject to legal and confidentiality obligations, BrandHire shall communicate the outcome of the investigation to the complainant.

13.5 Protection Against Detriment

13.5.1 No individual shall suffer detriment for raising a complaint honestly and in good faith or for participating in an investigation under this Policy.

13.5.2 Retaliation against any individual for exercising rights protected by this Policy shall constitute a serious breach of BrandHire’s governance standards.

13.6 Regulatory Co-operation

13.6.1 BrandHire shall cooperate appropriately with lawful requests, investigations or enquiries made by competent regulatory authorities, courts or tribunals.

13.6.2 Such cooperation shall be undertaken consistently with BrandHire’s obligations concerning confidentiality, legal professional privilege and Data Protection Legislation.

13.6.3 Following the conclusion of any investigation or proceedings, BrandHire shall determine whether amendments to this Policy or to Recruitment Activities are required.

14. Breach of This Policy

14.1 General

14.1.1 Compliance with this Policy is mandatory.

14.1.2 Any departure from the requirements of this Policy shall be assessed having regard to:

(a) legal risk;

(b) operational impact;

(d) seriousness;

(e) regulatory implications; and

(f) potential impact upon Candidates, Employer Clients and BrandHire.

14.2 Employer Client Non-Compliance

14.2.1 Where an Employer Client requires BrandHire to undertake Recruitment Activities inconsistent with this Policy or applicable legislation, BrandHire may:

(a) refuse the instruction;

(b) require amended instructions;

(d) withdraw from the assignment;

(e) terminate the commercial relationship; or

(f) decline future instructions.

14.2.2 Decisions under this clause shall be documented together with the reasons supporting them.

14.3 Corrective Action

14.3.1 Where BrandHire identifies a failure to comply with this Policy, corrective measures shall be implemented without unreasonable delay.

14.3.2 Corrective measures may include:

(a) review of Recruitment Activities;

(b) amendment of procedures;

(d) enhanced management oversight;

(e) revision of documentation;

(f) targeted compliance monitoring; or

(g) any combination of the foregoing.

15. Governance, Accountability and Management Review

15.1 Governance

15.1.1 This Policy forms part of BrandHire’s corporate governance framework.

15.1.2 Responsibility for oversight of this Policy rests with the Policy Owner.

15.1.3 Responsibility for compliance rests with every person undertaking Recruitment Activities on BrandHire’s behalf.

15.1.4 Compliance responsibilities shall not be delegated in a manner that removes accountability for lawful Recruitment Activities.

15.2 Responsibilities of the Policy Owner

15.2.1 The Policy Owner shall be responsible for:

(a) approval of this Policy;

(b) oversight of implementation;

(d) reviewing equality compliance;

(e) considering audit findings;

(f) reviewing significant complaints;

(g) approving material amendments; and

(h) ensuring appropriate governance arrangements remain in place.

15.3 Management Review

15.3.1 A formal management review shall be undertaken at least once during each review cycle.

15.3.2 The review shall consider:

(a) legislative developments;

(b) significant judicial decisions affecting recruitment practice;

(d) audit findings;

(e) equality monitoring information;

(f) complaints;

(g) implementation of corrective actions;

(h) operational developments; and

(i) recommendations for improvement.

15.3.3 Minutes of every management review shall be prepared and retained as compliance records.

15.3.4 Where material legal or operational risks are identified, the Policy Owner shall ensure that corrective measures are implemented and subsequently reviewed for effectiveness.

15.4 Continuous Improvement

15.4.1 BrandHire shall periodically review Recruitment Activities to identify opportunities to strengthen equality compliance.

15.4.2 Continuous improvement shall be informed by:

(a) compliance audits;

(b) complaints;

(d) Employer Client feedback where available;

(e) legislative developments;

(f) regulatory guidance; and

(g) operational experience.

16. Review of This Policy

15.1.1 This Policy forms part of BrandHire’s corporate governance framework.

15.1.2 Responsibility for oversight of this Policy rests with the Policy Owner.

15.1.3 Responsibility for compliance rests with every person undertaking Recruitment Activities on BrandHire’s behalf.

15.1.4 Compliance responsibilities shall not be delegated in a manner that removes accountability for lawful Recruitment Activities.

16. Review of This Policy

16.1 Scheduled Review

16.1.1 This Policy shall be reviewed at least annually.

16.1.2 Earlier review shall take place where required by:

(a) legislative change;

(b) material regulatory guidance;

(d) operational change;

(e) significant audit findings;

(f) substantiated complaints; or

(g) any other circumstance indicating that amendment is necessary.

16.1.3 Amendments shall take effect following approval by the Policy Owner.