Diversity and Inclusion Policy


As an employer and recruitment agency we recognise that our employees are our most valuable asset. We are committed to recognising, supporting and valuing the diversity of our employees. We are aware of our responsibility to promote equal opportunities both in our offices and through the service we provide to our customers. We are committed to providing an environment free from discrimination, harassment, or victimisation, where all members of our community are treated with respect and dignity.

We are committed to ensuring a person is not adversely affected due to their ethnicity, gender, sexual orientation, religion, age, disability, or other characteristics protected by law.

As a Company we are proud of our diverse workforce and are happy to be represented by people from different cultures, nationalities, ethnicity, gender, sexual orientation, age and religion. Having such a diverse workforce is important to us, as we believe that this brings success and creates a better place to work for everyone.

Recruitment and Selection

As a recruitment agency, we are aware of the vital role we play for our clients and believe we can actively assist in creating more job opportunities for the best talent regardless of their characteristics. Our aim is to be our client’s number one supplier and we achieve this by finding out what they want and then delivering it. What is clear in our industry and market is that businesses want to see a wide pool of talent. As an inclusive business, we support this goal and aim to send at least one diverse CV in every three. This means if there were three CVs, at least one would be from a candidate with a characteristic that is different from the other two.

In addition to this, we regularly review our processes to ensure that the methods and materials employed in the recruitment and selection of internal and external candidates will be free from bias and discrimination. To this end all advertisements, application forms, assessment materials, interview questions, job descriptions and selection criteria and will be fair and relevant to the role in question. All processes listed above are expected to have the highest effort to ensure the inclusivity of the applicants and the application processes.

Internal Practices

Information About our Employees

Currently, we collect minimum information from our employees due to the size of our business. Our current data shows gender, nationality, and age.

  • Gender: 50% Female, 48% Male, 2% Wished not to declare

  • Nationalities: 15

  • Age range: 22 - 58

Positive Action

In internal recruitment and promotion decisions, where candidates are as qualified as each other, i.e., in a tie break situation, we may consider a candidate’s particular protected characteristic and practice Positive Action, as outlined in the Equality Act (2010). We only use these measures in situations where it is evident that people who share the characteristic experience particular challenges in the workplace and/or are disproportionately under-represented in our company. We consider the merits of all the candidates or employees and will not automatically treat individuals who share a protected characteristic more favourably.

Discrimination, Harassment and Victimisation

We place great importance on the successful implementation of this policy not only to ensure that it stays within the legal framework, but also that it recognises the benefits of diverse and equal workplace. Disciplinary action may be taken against any employee who is found to have committed an act of discrimination, harassment, or victimisation in breach of this policy or the spirit of the policy.


To safeguard individual rights under this policy, any employee who believes that the Company has applied unfair treatment to him/her or another within the scope of the policy can:

  • Raise any matter formally or informally through the route below

  • Obtain informal, confidential advice, available at any stage from the HR and the Employee Assistant Programme

  • Be confident that any matter raised will be treated seriously and dealt with promptly

Employees can refer to our internal Grievance Policy for the procedures of formal and informal complaint actions and appeal. This policy outlines the key people, suggested actions that employees take and how the Company commits to respond to the actions including the time frame of the Company response. The policy can be obtained through the HR.

The Company is committed to address all complaints by candidates, contractors, clients, and suppliers, that may have been received verbally, by phone, by email, in writing, Google reviews and Nicoll Curtin’s website. The company commits to send the complainant an e-mail or letter (discretionary) acknowledging complaint and asking to confirm or explain the details set out within five days of the complaint. We will also let them know the name of the person who will be dealing with the complaint. All complaint information will be handled sensitively, telling only those who need to know and following any relevant data protection requirements.


We circulate a survey twice a year where we ask for anonymous feedback around a number of topics including leadership, clarity on role, group vision and culture. Our aim with these surveys is to create an open forum to discover any potential issues and solve them quickly. We believe we have fostered an environment where people can speak out, contribute and develop to the culture of our business regardless of their level, length of service or characteristic.

All our team also have regular catch ups with their managers to ensure they are clear on responsibilities. These catch ups also allow a specific time to ask if our employees need any help or support.


Every member of our leadership team has been trained about unconscious bias and how this can impact hiring processes. A team of internal recruiters have also been trained on unconscious bias and have been empowered to challenge the leadership team on any bias they see.

All new starters are taken through an onboarding programme where they learn how to remove bias from the recruitment process to ensure the best talent is put forward to our clients.

D&I Objective Statement

We believe in taking a holistic and iterative approach to EDI across our Company and believe there are always more steps to take towards promoting equal opportunities. The steps that we commit to take until the next review date of this policy are:

  • Rolling out the unconscious bias training to the entire team

  • Creating a new training session for the team about writing inclusive job adverts

  • Collecting more compelling information from our employees for EDI monitoring purposes

  • Continuing to receive best practice guidance from APSCo and seeking for other trade bodies or organisations to improve our processes

  • Hiring an L&D Specialist to assess EDI training gaps, implement and promote a training programme

  • Creating and rolling out an EDI survey twice a year

  • Creating a budget for external event or conference allowance for staff members who would like to take an extra step in upskilling themselves around EDI

  • Continuing to improve this policy with more international legal references


The official review date of this policy is within a year of its approval. However, we will regularly review this policy not only to ensure we are up to date from a legal perspective but also to check that it reflects us as a business.

Our policies are shared across the Company and kept on our shared internal learning platform. This means that any conversations about making reasonable adjustments is easy to have and ensures we go about these conversations and plans correctly.


Appendix - Definitions

Types of Discrimination, Harassment and Victimisation

Direct Discrimination

Direct discrimination is where one person is treated less favourably than another because of a protected characteristic, whether the person possesses the protected characteristic.

Indirect Discrimination

Indirect discrimination means that an organisation must not have benefits, employment rules, policies, selection criteria or any other practices which, although they are applied to all employees, have the effect of disadvantaging those who possess a protected characteristic. Indirect discrimination is not unlawful if it can be justified. This means that there must be a real business need and that the practice is proportionate to the aim i.e. it is necessary and there is no alternative means available.


Harassment includes behaviour that is distressing, frightening or offensive in any way. It may be intentional bullying, which is obvious or violent, but it can also be unintentional, insidious, and subtle. It may involve name calling, nicknames, teasing or other behaviour which is not with malicious intent, but which is upsetting.


Victimisation is treating someone badly because they have done a ‘protected act’ (or because one believes that a person has done or is going to do a protected act). A ‘protected act’ is, making a claim or complaint of discrimination, or helping someone else to make a claim by giving evidence or information.


The UK Equality Act (2010) definitions of protected characteristics


Where this is referred to, it refers to a person belonging to a particular age (for example 32-year-olds) or range of ages (for example 18 to 30 year olds).


A person has a disability if she or he has a physical or mental impairment which has a substantial and long-term adverse effect on that person's ability to carry out normal day to- day activities.

Gender Reassignment

A person is proposing to undergo, is undergoing or has undergone a process (or part of a process) for the purpose of reassigning the person´s sex by changing physiological or other attributes of sex.

Marriage and civil partnership

Marriage and civil partnership means someone who is legally married or in a civil partnership. Civil partnership is between partners of the same sex.

Pregnancy and maternity

Pregnancy is the condition of being pregnant or expecting a baby. Maternity refers to the period after the birth, and is linked to maternity leave in the employment context. In the non-work context, protection against maternity discrimination is for 26 weeks after giving birth, and this includes treating a woman unfavourably because she is breastfeeding.


Refers to the protected characteristic of Race. It refers to a group of people defined by their race, colour, and nationality (including citizenship) ethnic or national origins.


Religion has the meaning usually given to it but belief includes religious and philosophical beliefs including lack of belief (such as Atheism). Generally, a belief should affect your life choices or the way you live for it to be included in the definition.


A man or a woman.

Sexual orientation

A person’s sexual orientation towards people of the same sex (lesbians and gay men), towards people of the opposite sex (heterosexual) or towards people of the same sex and the opposite sex (bisexual).