Policies

Equality and diversity

Company Statement

Virtual Internship Partners Ltd (VI) recognises and values people’s differences and will assist them to use their talents to reach their full potential.

VI will do all it can to ensure it recruits, trains and promotes people based on qualifications, experience and abilities for all roles within the organisation. VI will also exert its best efforts to ensure that no discrimination takes place in the delivery of its programs.

This policy is designed to ensure that VI complies with its obligations under equality legislation, including without limitation the UK Equality Act 2010, and demonstrates our commitment to treating people equally and fairly. The purpose of this policy is to:

• Foster VI’s commitment to providing an online educational and working environment free from unlawful discrimination;
• Advance equality of opportunity between people who share a protected characteristic and those who do not;
• Nurture good relations between people who share a protected characteristic and those who do not.

VI is unreservedly opposed to any form of discrimination on the grounds of age, disability, marriage or civil partnership, pregnancy and maternity, genetic disposition race, colour, national origin, ancestry, citizenship, veteran or military status, family status, religion or belief, sex, sexual orientation, sexual identity, gender reassignment, gender expression or gender identity, or any other legally protected characteristic in accordance with applicable laws (defined as Protected Characteristics).

Using fair and objective employment practices, the organisation aims to ensure that:

• All employees and potential employees are treated fairly and with respect at all stages of their employment.
• All employees (consultants/volunteers/participants) have the right to be free from harassment and bullying of any description, or any other form of unwanted behaviour. Such behaviour may come from other employees or by people (third parties) who are not employees of VI, such as customers or clients.
• All employees (consultants/volunteers/participants) have an equal chance to contribute and to achieve their potential, irrespective of any defining feature that may give rise to unfair discrimination.
• All employees (consultants/volunteers/participants) have the right to be free from discrimination because they associate with another person who possesses a Protected Characteristic or because others perceive that they have a particular Protected Characteristic, even if they do not.

Definition

Discrimination can take many forms, none of which are tolerated by VI. These include but are not limited to: .

• Direct discrimination is when an employee or applicant is treated less favourably than someone else because of their:
  • sex
  • marriage or civil partnership
  • gender reassignment
  • pregnancy and maternity leave
  • sexual orientation
  • disability
  • race
  • religion or belief
  • age

and that there is no genuine occupation requirement for it.

People also must not be discriminated against because they are on a part time or fixed term contract

• Indirect discrimination
  This is where there is a working condition, practice or rule that disadvantages one group of people more than another. In other words it is more difficult for people from one group to comply with the requirement. Even if it is done accidentally indirect discrimination is unlawful. Indirect discrimination is only allowed if it is necessary for the way the business works, and there is no other way of achieving it.
• Discrimination arising from disability
  This is where a disabled person is treated unfavourably because of something connected to their disability where it cannot be objectively justified. This only applies where the organisation knew or could reasonably be expected to know that the person was disabled.
• Associative Discrimination
  This is where someone is treated worse than someone else because they are associated with someone with a protected characteristic.
• Perceptive Discrimination
  This is where someone is treated worse than someone else because there has been an incorrect assumption that they have a protected characteristic. This applies even if the person does not possess the characteristic.
• Third Party Harassment
  This is where an employee or participant is harassed by a third party who is not an employee eg volunteers or service users.

Scope of Application

This policy applies to all persons working for VI or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. This policy also applies to students enrolling in VI programs and host companies hosting students.

The policy applies to all stages of employment including recruitment and selection, promotion and training.

Guiding Principles

VI has adopted the following guiding principles as the basis of this policy.

• Zero-tolerance of discrimination: any such action may be subject to criminal, civil and disciplinary sanctions.
• Strength in diversity: as an organisation, VI values the variety of different views, outlooks and approaches that a diverse workforce brings. This assists us to provide improved services and increase our understanding of our service users/partners.
• Equal treatment: we will do all we can to ensure no one will receive less favourable treatment or is to be disadvantaged by requirements or conditions, which cannot be shown to be justifiable.
• Responsibility across board: all those working for us or our behalf are responsible for engaging actively in the prevention, detection and report any incident of discrimination.
• Adequate reporting: implement appropriate mechanism for internal and external reporting of discrimination incidents.

Recruitment & Employment Process

VI is devoted to following a fair and ethical recruitment and employment process in compliance with this policy and applicable legislation. To that end, VI will carry out of the following actions:

• Using selection criteria that do not unlawfully discriminate in recruitment and promotion procedures;
• Requiring entry to employment /volunteering or progression within VI to be based on merit;
• Not discriminating in opportunities for recruitment, training, promotion or transfer of employees or volunteers;
• Ensuring that every individual is assessed according to his or her personal capability to carry out a given job/role;
• Ensuring that all employees are given equal treatment with regard to terms and conditions of employment, provided they do the same or broadly similar work, or work of equal value;
• Ensuring equal opportunities and non-discrimination in the operation of grievance and disciplinary procedures;
• Ensuring that all relevant requirements of the Equality Act in relation to disability are met and adhered to. This will include making reasonable adjustments to ensure access to employment or volunteering tasks and opportunities.
• Ensure that any amendments to any legislation relating to discrimination are met and adhered to.

Implementation

All staff, directors and volunteers will be involved in creating an equality environment and one that values diversity.

Communications

This policy may be communicated to job applicants and employees/ volunteers through the following means:

• Making available a copy of the policy to prospective applicants;
• Ensuring all new starters have the opportunity to discuss the policy with line managers/ colleagues;
• Providing Equality and Diversity training and guidance to staff, directors and volunteers;
• Including reference to abiding by the policy in staff/volunteer contracts.

Partners

In selecting our partners we will consider their commitment to Equality and Diversity by:

• Asking to see their policy
• Asking what they do in practice, including monitoring the policy
• Including reference to abiding by the policy in partner contracts.

Participants

We will make our services accessible to participants applying to or participating in VI programs:

• By ensuring that partners referring or funding participants disseminate this policy appropriately
• Including reference to abiding by the policy in the participation agreements signed by participants.
• Considering formats for promotional material, including the use of appropriate language/ formats / fonts/ size

Reporting

When alleged incidents are reported, VI will work with the individual to track incident management.

VI expects two kinds of incident reporting:

• Mandatory and immediate (within 24 hours of becoming aware of an alleged incident) reporting by all staff and VI partners of any alleged incident of discrimination.
• Mandatory reporting (within two working days) by all staff and VI partners of any alleged non compliance with this Policy.

All participants, VI staff and partners must report any alleged or suspected incidents of discrimination or non compliance with this policy committed by anyone in connection with VI’s business and programs, even if the said incidents are not directed at them. Reporting must be made in accordance with the following procedure:

For Participants

• VI can take corrective action only when it becomes aware of problems. Therefore, VI encourages any VI participant who believes they have subject to, or witnessed, any form of discrimination as prohibited by this Policy to come forward promptly with their inquiries, reports, or complaints and to seek assistance within VI. If you are a participant on one of VI’s programs and at any time during your program, you have been subject to, or think you may have witnessed instances of discrimination, whether in-person or in an online setting, and whether at the hands of a staff member at your host company, a fellow participant, or a VI staff member, then you should follow the following procedure.

• All allegations of discrimination will be dealt with seriously and promptly. Participants who believe they have been subject to, or witnessed, discrimination must not hesitate in using this procedure nor fear victimization.

• VI staff will provide, in confidence, advice and assistance to participants who were subject to, or witnessed, discrimination and assist in the resolution of any problems. If you are in any doubt as to whether an incident or series of incidents which have occurred constitute discrimination, then in the first instance you should approach your Intern Experience Manager on an informal confidential basis. They will be able to advise you as to whether the complaint necessitates further action, in which case the matter will be dealt with formally/informally as appropriate.

• You should report all instances or events which may constitute discrimination to your Intern Experience Manager, who will take appropriate action to resolve the issue. The means of resolving the issue will differ depending on the circumstances, but VI will consult you during each step of the process to ensure you are aware of the actions we are taking.

• If your Intern Experience Manager is involved in any way with the instances or events of alleged discrimination, and it would be inappropriate to report to them, you should report the issue to any other VI staff member with whom you have contact or to VI’s in-house legal counsel, Mr. Nadim Naccache ( legal@www.virtualinternships.com).

For VI Staff Members

• If you are a VI staff member and you believe you have been subject to, or think you may have witnessed instances of, discrimination in the context of a VI program, or receive a report from a program participant in accordance with this Policy, you should resolve the issue appropriately, taking particular note of confidentiality concerns. You should follow internal company policies and, within 24 hours of the occurrence of any such event, inform your line superior or the company’s in-house legal counsel, Mr. Nadim Naccache ( legal@www.virtualinternships.com).

For Third Parties

• If you are an employee of a host company or an independent contractor, consultant, volunteer or vendor and you witness or think you may have been subject to, or witnessed, discrimination in the context of a VI program, you should report the issue to your primary point of contact at VI who will work with you to resolve the issue appropriately.

Confidentiality

Instances of discrimination raised under this Policy will be treated confidentially and in the best interest of the victim. However, when an incident is identified it may be necessary for those managing the incident to reveal its substance to people such as other personnel, partners and external persons involved in the investigation process or law enforcement agencies.

Where there is a reasonable belief that a criminal offence has occurred, the matter will be reported to the appropriate law enforcement agency while taking into account risks to those who have been affected. When a referral is made to law enforcement, any action by VI will be in consultation with its concerned partner and be guided by appropriate law enforcement agencies. Any decision not to refer to law enforcement will be documented in order to record the reasons for the decision.

VI will take all reasonable precautions to store any records or files relating to matters of equality and diversity securely and to permit access by authorised persons only.

Unauthorised disclosure of information relating to a matter will be taken seriously and may result in disciplinary action, which may include dismissal.

Monitoring, Compliance and Review

VI will monitor compliance with this Policy through a range of approaches including performance assessments, reviews and due diligence. VI university partners and host companies are expected to put in place appropriate risk-based measures to ensure they comply with this policy. Non-compliance with requirements may lead to VI suspending or terminating an agreement with a university partner or host company.

This policy will be reviewed every two years by VI’s COO and In-House Legal Counsel to ensure that it remains up to date and reflects VI’s needs and practices. The policy may also be reviewed if legislation changes or if monitoring information suggests that policy or practices should be altered.

Supporting and Related Documentation

• VI Non-Discrimination, Anti-Digital Harassment and Bullying Policy;
• VI Policy on the Prevention of Sexual Exploitation, Abuse and Harassment;
• VI Child Protection Policy
• VI Risk Management Policy
• VI Anti-Bribery Policy
• VI Anti-Modern Slavery Policy
• VI Participation Agreement
• VI Participant Code of Conduct
• VI HR Global Employee Handbook
• VI staff contracts
• VI host company agreements