What is the policy about?
Equality and Diversity rights and responsibilities are enshrined in law (the Equality Act 2010) and are clearly important in the creation and maintenance of a harmonious society and working environment. Innersummit is committed to treating everyone fairly, we respect and value the diversity of our learners, clients, employees, suppliers, partners, employers and all other people we work with.

Why is it important?
Innersummit has a positive, outoutcome-basedew of equality, diversity and inclusion (ED&I). The legal and moral drivers for ED&I are clear. Yet, there are also very positive business benefit drivers for ED&I. Our research into high performing organisations and across the services we provide, is that ED&I are essential conditions for effective business innovation and change. We see the real benefits that multiple perspectives bring to problem solving and ideation. We have learnt that advanced organisations actively design teams to feature ED&I so that they function effectively through the innovation lifecycle – and far better than teams that do not. We understand the role of ED&I in the development and sustaining of a vibrant and high potential culture of innovation. Multiple sources and many our clients note that effective 21st Century leadership is defined by openness, collaboration and engagement, with organisational forms emerging to suit this less hierarchical, control-focussed way of working. ED&I, drawing on all the talents, is again a feature of today’s open, future- & change-focussed leaders. At the same time, many organisations see talent attraction, development and retention as a critical component of great performance and, where sought, competitive advantage. The lack of ED&I is now more widely recognised as a serious detriment to organisational health. Innersummit’s own experience in this field is positive. From the beginning, the company’s founders have actively recruited people with diverse backgrounds to create an international, inclusive and diverse organisation that lives innovation as a core value. We believe in ED&I not least because it works for us. Our own findings, based on a study of recent research, identifies several critical success factors for ED&I leadership. These include the drawbacks of typical top-down initiatives, the role of personal biases, ‘neuroleadership’ and the management of ‘choice architecture’ to affect outcomes, lessons for recruitment and the crucial, pivotal role of line managers. We would be happy to share these findings with you.

Innersummit’s Application
This policy applies to:

• Actual and prospective learners (‘learner’ is used as a common term to also denote client and customer where appropriate)
• Employees (individuals who work for the company either on a permanent, temporary, contractual or voluntary basis)
• Employers (individual or organisations who are in receipt of Innersummit’s services)

We will:
1. Provide learning and working environments that respect difference and protects the diversity of those working within them
2. Raise individual awareness of the importance of equality and diversity and good relations between people of different groups
3. Develop the awareness and skills of individuals to promote fairness, inclusivity and good relations
4. Ensure that everyone is enabled to achieve positive outcomes, whatever their background
5. Ensure fair and equal access to learning and recruitment and take action to promote equality
6. Make reasonable and practicable adjustments to enable individuals to participate in learning or work. Where this is not feasible, we will identify alternative options/solutions

What I need to do?
All Innersummit people are expected to:

1. Communicate and behave with courtesy, kindness and respect and in accordance with our policies and procedures
2. Inform their manager if they have any additional needs or are experiencing difficulties in learning or working with us
3. Value and respect individual differences and the contributions of others
4. Maintain a safe and secure learning and working environment
5. Let the management team know immediately if they are unhappy with any aspect of learning or working with Innersummit or have witnessed anything of concern.

1 Complaints/ grievances
We will make all individuals aware of the steps to follow should they wish to raise a concern, grievance or make a complaint. We will aim to resolve any concerns or problems as quickly as possible and if we cannot resolve it, we will explain why and say what we can do. For learners: The quickest and easiest way for a learner to raise a concern or make a complaint is to do so via their tutor, or supervisor. For employees: The company will take any complaint seriously and will seek to resolve any grievance which it upholds. Innersummit won’t penalise employees for raising a grievance, unless the complaint is both untrue and made in bad faith. Any employee (found to be) breaching this policy will be regarded as behaving in a manner that constitutes an act of misconduct and will be dealt with through the disciplinary procedure. For employers: If you wish to make a complaint or raise a concern of unlawful discrimination, bullying, harassment and/or unacceptable behaviour by a Innersummit employee, you should contact the Head of Programmes.

2 Customer outcomes
We will strive to ensure that learning and recruitment opportunities are available to all. No individual will be excluded from a learning or recruitment opportunity on the grounds of their age, disability, gender, race, sexual orientation, religion or belief.

Additionally:
For learners: We will support all learners as far as reasonably possible (but subject to funding and health and safety requirements) to pursue the learning programme. In circumstances where this is not possible, we will identify alternative options/provision. For employees: Selection criteria (role profile) will be kept under constant review to ensure that they are justifiable and non-discriminatory. All applicants invited to participate in a selection process will be asked if any assistance / adjustment is required to enable them to fully participate. For employers: We will provide Innersummit services only to employers who support our commitment to equality and diversity and comply with related requirements.

3 Disclosure and additional support provisions
Before starting and during learning/employment, individuals will be given the opportunity (in confidence) to disclose any disability or learning difficulty they may have. This is to ensure we put in place additional or alternative support. We will explain why this information is being sought and how it will be used.
Additionally:
For employees:
Where an employee declares a disability, reasonable steps will be taken to accommodate this by making reasonable adjustments.

4 Induction and Equality Training
All individuals will receive an induction into their learning/employment and working environment. We will make everyone aware of our commitment to equality and diversity, and how to make us aware of any dissatisfaction or concern.

5 Learning and Working Environment
We are committed to creating open and conducive learning and working environments where everyone has the right to be treated with dignity and respect. We are opposed to and will not tolerate any form of bullying, harassment or unacceptable behaviour. We will ensure all individuals have clear routes to report incidents and/or concerns and for these to be managed fairly and fully.

Policy Links
Equality Act 2010: http://www.legislation.gov.uk/uksi/2011/2260/contents/made

References and further reading

Innersummit Techniques: Understanding Contracts of Employment/ Employee-centred Leadership Style / Employee Engagement ISO Accreditation files Equality and Human Rights Commission – https://www.equalityhumanrights.com/

The quickest and easiest way for a learner to raise a concern or make a complaint is to do so via their tutor, or supervisor.

For employees:

The company will take any complaint seriously and will seek to resolve any grievance which it upholds. Innersummit won’t penalise employees for raising a grievance, unless the complaint is both untrue and made in bad faith.

Any employee (found to be) breaching this policy will be regarded as behaving in a manner that constitutes an act of misconduct and will be dealt with through the disciplinary procedure.

For employers:

If you wish to make a complaint or raise a concern of unlawful discrimination, bullying, harassment and/or unacceptable behaviour by a Innersummit employee, you should contact the Head of Programmes.

What is the policy about?
Harassment is unwanted conduct which violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment. It may be on the grounds of sex, marital status, race, disability, religion or beliefs, sexual orientation, age or gender reassignment. For the purposes of this Policy this list should be considered non-exhaustive, and harassment or bullying on any grounds will not be tolerated by the Company. Harassment may be persistent or an isolated incident, obvious or subtle, face-to-face or indirect. Innersummit (IS) wishes to provide a stimulating and supportive working environment which will enable its staff to fulfil their personal potential and creativity. Such an environment cannot exist where any member of staff is subjected to harassment, intimidation, aggression or coercion. Also, IS wishes to ensure an open, transparent and safe working environment where all IS people feel able to speak up. Hence IS is committed to listen to the important concerns of all IS people. In instances about important concerns or knowledge of wrongdoing “blowing the whistle” the escalation route is the same as for harassment or bullying outlined in this policy.

Why is it important?
IS is fully committed to the principles of equality and diversity in the workplace and regards harassment as a form of discrimination. As such IS will not tolerate any form of bullying or harassment. The legal and moral drivers for preventing bullying and harassment are clears. Yet, there are also very positive business benefits: our research into high-performing organisations and across the services we provide, is that a working environment providing psychological safety enhances business performances. We have learnt that advanced organisations actively design safe working environments, where people can thrive and contribute more and better to the organisational objectives.

Other Key Terms
What is harassment?
Examples of behaviour which may constitute harassment or bullying include (but are not limited to):

• spreading malicious rumours; professional or social exclusion; insulting behaviour; • unwelcome sexual advances or physical contact; unfounded threats relating to job security; • calculated undermining of an employee’s competence, for example through a consistently unreasonable or unfair workload, overbearing supervision or unnecessary circulation of critical memoranda; • physical assault; • verbal abuse, threats, derogatory name-calling, ridicule, insults and offensive or embarrassing jokes; • offensive emails, texts or visual images; • derogatory graffiti/insignia or display of derogatory or offensive material; and inciting others to commit any of the above.

What is whistleblowing?
Whistleblowing is the term used when an employee passes on information concerning wrongdoing. The wrongdoing will typically (although not necessarily) be something they have witnessed at work. To be covered by whistleblowing law, an employee who blows the whistle must reasonably believe two things: (1) They are acting in the public interest. This means in particular that personal grievances and complaints are not usually covered by whistleblowing law. (2) An employee must reasonably believe that the disclosure tends to show past, present or likely future wrongdoing falling into one or more of the following categories: • criminal offences (this may include, for example, types of financial impropriety such as fraud); • failure to comply with an obligation set out in law; • miscarriages of justice; • endangering of someone’s health and safety; • covering up wrongdoing in the above categories

IS Application
This policy applies to:
• actual and prospective learners (‘learner’ is used as a common term to also denote client and customer where appropriate) • employees (individuals who work for the company either on a permanent, temporary, contractual or voluntary basis) • employers (individual or organisations who are in receipt of Innersummit services)

We will:
1. Provide learning and working environments that respect difference and protects the diversity of those working within them 2. Raise individual awareness of the importance of preventing bullying and harassment. 3. Consider recognised act of bullying and harassment as disciplinary offence and may constitute gross misconduct. 4. Ensure that everyone can access clear and transparent procedures to log complaints and grievances. 5. Demonstrate, through visible leadership at all levels of the organisation, that we welcome and encourage all Innersummit people to make disclosures

What I need to do?
All IS people are expected to:
1. Be responsible for their own behaviour and should ensure that they comply with this policy at all times. 2. Any employee who feels that they have been subjected to harassment or bullying by any other member of staff, or a third party, or have an important concern, should raise the matter as soon as reasonably practicable. 3. Inform their manager or Director Chris Andreou in the absence of that manager or where their complaint is against that specific manager. 4. If the complaint is against directors, inform Non-Executive board member, Toni Stavri. Any issues should be raised internally first. If an external route is needed, any employee can inform IS ‘s legal advisor. 5. As a Manager, be responsible for implementing this Policy and bringing it to the attention of employees. 6. As a Manager, take any complaint seriously and deal with it promptly, confidentially, fairly and consistently.

1 Complaints/ grievances
Informal Procedure

If the employee feels able, they should speak up at the time when they feel harassed or bullied. It is important to be direct and for the employee to state explicitly that they feel they are being harassed and that the behaviour is unacceptable to them. The employee can also discuss the matter with another colleague or their supervisor and ask them to speak to the harasser on their behalf. Where the informal procedure has not resolved an employee’s complaint, a formal grievance can be raised by the employee.

Formal Procedure

Any employee who feels that they have been subjected to harassment or bullying may at any time decide to deal with the issue through formal procedures, regardless of whether informal steps have been taken or not.

>They could write a letter which clearly identifies the offending behaviour and requests that it stops immediately. The employee should sign and date any such letter and ensure that a copy is kept for any possible future formal complaint. It is also advisable that the employee keep an ‘incident diary’ of any offending behaviour. Where employees are not happy with the outcome of the formal grievance procedure they can appeal this decision internally.

The Company will investigate any informal or formal complaint thoroughly and fairly.

Consequences of Breach

Harassment is a disciplinary offence and will be dealt with according to the Company’s Disciplinary Procedures. Bullying, harassment, victimisation or discrimination may constitute gross misconduct, punishable by summary dismissal without notice.

Employees should bear in mind that harassment or bullying may also constitute a criminal offence punishable by a fine and / or imprisonment.

2 Customer outcomes
Third Party Harassment

Third party harassment refers to harassment of an employee by any person who is not an employee of the Company. Third party harassers may include:

• customers or clients of the Company; • suppliers of the Company; • independent contractors.

Any employee who believes that they have been the victim of third party harassment should immediately inform their immediate line manager of the incident.

Where an employee has been harassed on more than one occasion, the Company will take such steps as are reasonably practicable to prevent any recurrence.

For the purposes of third party harassment, it is immaterial whether the third party harasser is a different person in each instance of harassment.

3 Induction and Anti-Bullying and Anti-Harassment Training
All individuals will receive an induction into their learning/employment and working environment. We will make everyone aware of our commitment to prevent bullying and harassment, and how to make us aware of any dissatisfaction or concern.

4 Learning and Working Environment
We are committed to creating open and conducive learning and working environments where everyone has the right to feel safe from bullying and harassment. We will ensure all individuals have clear routes to report incidents and/or concerns and for these to be managed fairly and fully.

Policy Links
Equality Act 2010: http://www.legislation.gov.uk/uksi/2011/2260/contents/made

References and further reading
Understanding Contracts of Employment/ Employee-centred Leadership Style / Employee Engagement

Acas (Advisory, Conciliation and Arbitration Service) – https://www.acas.org.uk Department for Business Innovation & Skills: Whistleblowing; Guidance for Employers and Code of Practice – https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/415175/bis-15-200-whistleblowing-guidance-for-employers-and-code-of-practice.pdf Whistleblowing law is located in the Employment Rights Act 1996 (as amended by the Public Interest Disclosure Act 1998). It provides the right for a worker to take a case to an employment tribunal if they have been victimised at work or they have lost their job because they have ‘blown the whistle’.

What is the policy about?
Safeguarding is the term that describes the function of protecting all learners in general and adults at risk in particular from abuse, neglect, and radicalisation. It is an important priority and a key responsibility of Innersummit (IS ) and its employees. All suspicions or allegations will be taken seriously. Employees should be aware that the needs of the children and adults at risk are paramount.

Prevent is one element of the government’s counter-terrorism strategy. It aims to stop people from becoming terrorists or supporting terrorism. Counter-Terrorism and Security Act (2015) has placed a further statutory duty on all training providers to “have due regard to the need to prevent people from being drawn into terrorism”. It also aims to promote British Values which include: democracy, rule of law, equality of opportunity, freedom of speech, individual liberty / freedom of all men and women from persecution of any kind.

Why is it important?

IS’s mission is to deliver an outstanding experience to its learners and an excellent service to its clients. As a provider of high quality education, development, and qualification services, we have a clear duty of care to our clients and learners. As a provider of government funded schemes, we have an obligation to support the ethos and objectives of those schemes. In addition to these requirements, our research-based findings and insight confirm the importance of a psychological safe environment to deliver high performances. We believe that a safe place for learning is essential for achieving the best possible results in business and in personal development.

For these reasons, the following principles are essential elements of IS’s culture:

• The welfare of all learners in general and adults at risk in particular is IS’s primary concern. • All learners have a right to safeguarding from abuse whether that is work-based or otherwise evidenced. • It is everyone responsibility to report any concerns about abuse, neglect or radicalisation to the Designated Safeguarding Lead (DSL). • All incidents of alleged poor practice, misconduct and abuse will be taken seriously and responded to promptly and appropriately. • All data will be processed in accordance with the Data Protection Act. The scope of our Safeguarding and prevent policy and duties extend to Learners and Clients, Employees and Associates, Customers/Employers, Suppliers, Sub-contractors and External stakeholders and visitors.

Other Key Terms

What is abuse?

Abuse is any behaviour towards a learner that deliberately or unknowingly causes harm, endangers life or violates their rights. Abuse may be physical, sexual, emotional, psychological, financial or neglect.

Who is a vulnerable adult?

A vulnerable adult is defined as a person “who is or may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself or unable to protect him or herself against significant harm or exploitation” (Department of Health 2000).

Safe Learning Environment A safe learning environment is one:

• In which the health, safety and welfare of learners has been assessed and any special needs identified and catered for.

• In which staff are alive and vigilant to the possibility of abuse and take measures to prevent that possibility howsoever observed.

• Where there is a sound and known reporting system for any incident.

• Where staff take reasonable and practical precautions to avoid any suspicions of abuse being brought against them.

IS Application

Our approach is as follows:

• Prevention

It is better to take action before harm occurs. We help identify and report signs concern, abuse (verbal or otherwise), radicalisation and extremism, and suspected criminal offences. In all our work, we consider how to make people safer.

• Proportionality

Deliver a proportionate and least intrusive response appropriate to the risk presented in order to protect the welfare of any potential vulnerable adult. We discuss with the individual and where appropriate, with partner agencies what to do where there is risk of significant harm before we take a decision. Risk is an element of many situations and should be part of any wider assessment.

• Protection

To provide support and representation for those in greatest need, we have effective ways of assessing and managing risk. Our complaints and reporting arrangements for abuse and suspected criminal offences operate effectively and we promote active dialogue amongst our learning advisor and programme management teams.

• Partnership

Finding local solutions through services working with communities. We encourage sharing information locally.

• Accountability

Adopting accountability and transparency in delivering safeguarding. The roles of all employees are clear, together with the lines of accountability. Staff are trained to understand what is expected of them and others, and recognise their responsibilities to each other, act upon them and accept collective responsibility for safeguarding arrangements.

IS has a Designated Safeguarding Lead (DSL), whose role is to:

• Receive information from any employees who have safeguarding concerns and record it.

• Assess the information promptly and carefully, clarifying and obtaining more information about the matter appropriately.

• Consult initially with the manager of the service where the concerns have occurred to ensure the concern has been reported and clarify the agency responsible for investigation.

• Make a formal referral to the police where required so to do.

The DSL is also to lead on training and education of us all as to our responsibilities. All employees of the company, learners, and subcontractors will be required to comply with this policy, taking shared responsibility for the safeguarding and safety of learners.

What I need to do?

All IS people are expected to:

• If they have a safeguarding issue brought to their notice, this must be treated as a priority over all other work.

• In case of disclosure or reasonable belief of safeguarding issue, it should be reported immediately, in the first instance, to the DSL. An oral, then written report should be provided to the DSL who will keep a confidential record of any such incidents.

• Guidance about a specific incident may be obtained from the DSL.

• The DSL will assess the situation and if considers that there has been or is reasonably likely to be an incident of abuse or neglect, will report the matter to the competent statutory agency.

• Abuse is a disciplinary offence.

Procedures for Safeguarding and Prevent

Safeguarding is the term that describes the function of protecting adults and children from abuse, neglect and radicalisation. All suspicions or allegations will be taken seriously. Employees should be aware that the needs of the adult or child at risk are paramount and must always act in the best interests of the adult or child at risk. If in doubt a referral to the Designated Safeguarding Lead (DSL) must be made.

When assessing any (potential) safeguarding issue, the criteria to be used are as follows:

• What the actual risks are – the likelihood and seriousness of an incident occurring (or reccurring) • The views of the learner or adult at risk in relation to the risk of harm • The person’s ability to protect themselves • The factors that increase or reduce the risk of harm

Learner and Client Outcomes

Safeguarding and Prevent impact on learners and clients because they are issues that, in our services, affect our clients’ employees – i.e. learners on our courses. If we do our job well, any issues arising will be handled sensitively and effectively and our customers will value our proactive approach.

Induction and Safeguarding Training

All individuals will receive an induction into their learning/employment and working environment. We will make everyone aware of our commitment to equality and diversity, and how to make us aware of any dissatisfaction or concern. Employees will receive on a regular basis an internal newsletter to keep them update with issues related to safeguarding and prevent. Regular training and workshops will be organised to ensure that safeguarding and prevent are embedded in IS practice.

Learning and Working Environment

We are committed to creating open and conducive learning and working environments where everyone has the right to feel safe. We will ensure all individuals have clear routes to report incidents and/or concerns and for these to be managed fairly and fully.

Policy Links

Safeguarding Policy https://www.gov.uk/government/publications/ofsted-safeguarding-policy

Prevent guidance https://www.gov.uk/government/publications/prevent-duty-guidance

References and further reading

See: • SAFE (Safer Activities for Everyone) standards https://www.safecic.co.uk

The following non-exhaustive list gives examples of offences that Innersummit will normally regard as misconduct that may result in a learner being excluded from Innersummit services:-

Theft, fraud, dishonesty or deliberate falsification of records;
Fighting, assault or other violent behaviour;
Deliberate use of Innersummit systems to access or distribute material of a pornographic, offensive, obscene or inappropriate nature;
Incapability at a Innersummit meeting due to the effect of alcohol or drugs; Possession, custody or control of illegal drugs at a Innersummit meeting or premises; Bullying, harassment, victimisation or discrimination;
Learners should bear in mind that any of the above may also constitute a criminal offence punishable by a fine and / or imprisonment.

Reasonable Adjustment is a legal term introduced under the Disability Discrimination Act 1995. Innersummit have a duty to make reasonable adjustments where arrangements or physical premises place the disabled person at a substantial disadvantage in comparison with persons who are not disabled. The following list provides a few examples:

Physical adjustments to premises
Acquiring specialised equipment or altering existing
Providing supervision or additional support
Offering flexible learning hours or patterns
Offering a flexible enrollment process
Providing additional learner training
Providing additional services, such as a sign language interpreter
Innersummit aim to offer appropriate levels of support and encourage the involvement of the learner’s employer and co-learners. Innersummit tutors will support the learner’s induction and provide on-site training support where needed.

Individual development plans are used to plan and monitor the student’s learning progress. Learning targets will include encouraging the social inclusion of the learner within the Innersummit programmes.

Innersummit identify the most ‘natural’ ways in which we can support people with disabilities in their learning, working in partnership with employers and all concerned. More intensive and personalised approaches are available if needed.