Equal Opportunities Policy

CBRE NI – EQUAL OPPORTUNITIES POLICY

CBRE NI is committed to supporting the principle of equal opportunities, and opposes all forms of unlawful or unfair discrimination on the grounds of colour, race, nationality, ethnic origin, sex, pregnancy, marital or civil partnership status, disability, religion, belief, age, sexual orientation, gender-assignment, trade union membership or on the fact that an individual is a part-time worker or fixed term employee. Our aim is to recruit, train and promote the best person for the job and to create a working environment free from unlawful discrimination, victimisation and harassment in which all employees are treated with dignity and respect. All job applicants, employees and others who work for us will be treated fairly and will not be discriminated against on any of the above grounds.

All employees will be made aware of the requirements of this policy and will be obliged to co-operate to ensure that the policy is carried out effectively. Any form of discrimination may be unlawful and will be treated as a disciplinary offence resulting, if appropriate, in disciplinary action. This policy applies to the advertisement of jobs, recruitment, terms and conditions of employment, career development, counselling, training, promotion, grievance and disciplinary procedures and all other aspects of employment.

All employees are required to comply with the Equal Opportunities Policy when dealing with other employees (including temporary or agency staff and consultants), job applicants, clients, suppliers, customers and contacts of the Company, and anyone else with whom they come into contact during the course of their employment. In particular, all employees must take care to guard against more subtle and unconscious forms of discrimination which may not be immediately obvious. This may result from generalisations about the capabilities, characteristics or interests of a particular group which influence the treatment of individuals.

RECRUITMENT

The Company will ensure that information about vacancies will be circulated as widely as possible in the circumstances to ensure that it reaches all sections of the community regardless of colour, race, nationality, ethnic origin, sex, pregnancy, marital or civil partnership status, disability, religion, belief, age, sexual orientation, gender-assignment, trade union membership or on the fact that an individual is a part-time worker or fixed term employee. All applications will be welcomed and will be considered on the relative merits of the applicant against the job and/or person specification for the position. Job and person specifications will only include criteria which are objectively required for the duties and responsibilities of the vacancy.

If there is a genuine and lawful reason for limiting the vacancy to a particular group, this will be clearly stated, and the grounds for it, on any advertisements. Applicants should not be asked about health or disability before a job offer is made. There are limited exceptions which should only be used with HR approval. For example:

  • Questions necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments);

  • Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at interview or assessment;

  • To monitor diversity in the range of applicants; and

  • To take positive action to assist disabled applicants.

The Company is required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made. All prospective employees, regardless of nationality, must be able to produce original documents before employment starts to satisfy immigration legislation. A list of acceptable documents is available from the Managing Director (MD) or an Executive Director (ED).

TERMS AND CONDITIONS OF EMPLOYMENT

The Company will offer terms and conditions of employment that are free from all forms of direct and indirect discrimination and apply equally regardless of colour, race, nationality, ethnic origin, sex, pregnancy, marital or civil partnership status, disability, religion, belief, age, sexual orientation, gender-assignment, trade union membership or on the fact that an individual is a part-time worker or fixed term employee. No requirements or conditions will be imposed, directly or indirectly, which will or might place any group of employees at an unfair or unlawful disadvantage. Grievance and disciplinary procedures will be operated without discrimination on the grounds of colour, race, nationality, ethnic origin, sex, marital or civil partnership status, disability, religion, belief, age, sexual orientation, gender-assignment, trade union membership or on the fact that an individual is a part-time worker or fixed term employee or any other unlawful grounds.

TRAINING, CAREER DEVELOPMENT AND PROMOTION

The Company will ensure that opportunities for training, career development and promotion are made equally available to all employees. The principal method of identifying training needs will be through the appraisal procedures and promotion decisions will be based on merit alone.

DISABILITY CODE OF GOOD PRACTICE

The Company values the individual contribution of all employees and prospective employees from all sectors of the community at large. The Company recognises its social, moral and statutory duty to employ people with disabilities and will do all that is practicable to meet this responsibility. The Company operates, therefore, the following Code of Good Practice on Disability:

  • The Company will take steps to raise awareness of disability throughout the organisation, particularly targeting all staff involved in recruitment and selection processes.

  • The Company will take reasonable steps to ensure that the working environment, working practices and terms and conditions of employment do not prevent disabled people from taking up positions for which they are suitably qualified and, in all other respects, the best person for the job.

  • The Company will bear in mind the desirability of avoiding barriers to the employment of disabled people when acquiring and fitting out buildings with equipment and devising working practices.

  • The Company will take steps to ensure that all disabled people have the same opportunities, subject to reasonable cost limitations/practicalities, as other staff to develop their full potential within the organisation.

  • Only a person of the level of Senior Director or above will take any decision not to make an adjustment which might enable or assist an employee or a prospective employee to be employed in a particular post. Before making such a decision, the relevant person will ensure that all possible adjustments have been fully investigated, including consultation with the employee or prospective employee concerned and any appropriate expert advice.

  • Any employee who becomes disabled whilst in employment will be given the full support of managers and the Company’s MD and EDs to maintain, or return to, a job appropriate to his/her experience and abilities.

  • The Company will encourage the participation of disabled employees to ensure that, wherever possible, its employment practices recognise and meet their needs and will consult disabled employees on action to make sure they develop and use their abilities at work.

  • The Company will continue to provide services and facilities to clients with disabilities.

Further guidance can be obtained on an entirely confidential basis from the MD or an ED. If you know or believe you might be disabled, you are encouraged to discuss this with your Line Manager or a member of the senior management team so that the Company can ensure you achieve your full potential and that it complies with its duties.

POLICY ON DISCRIMINATION, HARASSMENT AND VICTIMISATION

This policy is applicable to all employees of the Company. It forms part of the Company’s general policy on equal opportunities. The Company is committed to providing a workplace where everyone has the right to work in an environment which promotes equal opportunity and prohibits discriminatory practices. The Company will not tolerate any form of discrimination, harassment, or victimisation by or against employees. It is the obligation of all employees to behave in a way that supports this policy.

This policy is not designated to discourage normal social relations among colleagues or with the public. Its aim is to prevent discrimination or harassment. It is the responsibility of each individual to be sensitive towards the impact that he/she has on others and not to discriminate against or harass colleagues or condone discrimination or harassment by others. The policy applies not only to working at the Company’s premises, and those of any third party, but also includes travelling or staying away from home whilst on business or for a reason related to your employment.

DEFINITION OF DISCRIMINATION, BULLYING, HARASSMENT AND VICTIMISATION

Any behaviour under the following headings will not be tolerated. Disciplinary action, including dismissal for serious offences, will be taken against any person violating this policy.

DISCRIMINATION Discrimination by or against an employee is prohibited unless there is a specific legal exemption. Discrimination may be direct or indirect and it may occur intentionally or unintentionally.

  • Direct discrimination occurs where a person has been treated less favourably than another because of one or more of the protected characteristics under discrimination legislation.

  • Indirect discrimination occurs where someone is disadvantaged by an unjustified provision, criterion or practice that also puts other people with the same characteristic at a particular disadvantage. Any such provision, criterion or practice will need to be objectively justified.

HARASSMENT Harassment is a form of discrimination and is any unwanted conduct (which includes verbal or physical abuse, advances or any other behaviour which has the purpose or effect of violating another person’s dignity or of creating an intimidating, hostile, degrading, humiliating or offensive environment) related to a relevant protected characteristic.

The following types of behaviour may amount to harassment:

  • physical assault;

  • physical or verbal abuse; threats;

  • suggestive comments or gestures;

  • offensive gestures, language, gossip or jokes; insulting or abusive behaviour or comments;

  • isolation or exclusion;

  • bullying;

  • persistent criticism or humiliation;

  • unfair allocation of work or responsibilities.

This list gives examples only and is not exhaustive.

SEXUAL HARASSMENT Sexual harassment is one form of harassment. Generally, it involves conduct where a person persists in behaviour towards another and the person knows or ought reasonably to know that such behaviour is unwelcome to the other because it is perceived to be of a sexual nature and offensive. It is a form of sexual discrimination and as such is unlawful under current discrimination legislation.

The following types of behaviour may amount to sexual harassment:

  • unwanted physical conduct, including unnecessary touching, patting, pinching or brushing against another employee’s body;

  • verbal conduct of a sexual nature, for example making suggestive remarks or engaging in unwanted flirtation;

  • unwelcome sexual advances, continued suggestions of social activity outside work after it has been made clear that this is unwelcome;

  • non-verbal conduct of a sexual nature; for example making sexually suggestive gestures;

  • the display of sexually suggestive or pornographic pictures, the sending of sexually harassing messages or images through electronic mail;

  • sex-biased conduct;

  • the telling of sexist jokes;

  • conduct that denigrates or ridicules or is intimidatory or physically abusive of an employee because of his/her sex, marital or civil partnership status or sexual orientation.

This list gives examples only and is not exhaustive. Sexual harassment by someone of the same sex as the victim is also covered by this policy.

BULLYING Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean being in a position of authority, but can include both personal strength and the power to coerce through fear or intimidation. Bullying can take the form of physical, verbal and non-verbal conduct.

Bullying can include:

  • physical or psychological threats;

  • overbearing and intimidating levels of supervision;

  • inappropriate derogatory remarks about someone’s performance.

Legitimate, reasonable and constructive criticism of an employee’s performance or behaviour, or reasonable instructions given to employees in the course of their employment, will not amount to bullying on their own. Bullying will be regarded as misconduct and may lead to disciplinary action being taken up to and including dismissal.

VICTIMISATION Victimisation is a form of discrimination. It occurs when a person treats another person less favourably on the grounds that the person has brought proceedings, given information about or raised a complaint about discriminatory behaviour, or supported someone else’s complaint. It would include bullying or intimidating a fellow employee where that employee has raised a grievance about discrimination suffered, for example, on the grounds of sex.

DUTIES OF SUPERVISORS

Where a supervisor (whether a manager or other person holding supervisory responsibilities) becomes aware of an allegation of harassment of an employee or of a member of the public in connection with the Company’s activities, he/she should (whether or not a formal complaint has been made) discuss it with the complainant and, report it to the Managing Director, where it is felt to be appropriate.

EMPLOYEE RESPONSIBILITY

Every employee must take reasonable steps to ensure that bullying and harassment does not occur and must report any incidents to the Managing Director. Employees who believe they are the victims of bullying, harassment or victimisation may raise the matter with their immediate supervisor and/or the MD/ED without the need to make a formal complaint. However, employees who believe they are victims of harassment or victimisation are encouraged to use the complaints procedure which is part of this Equal Opportunities Policy.

THE COMPLAINTS PROCEDURE

Failure to comply with the Company’s Equal Opportunities Policy or to co-operate with it operating effectively is a disciplinary offence which may lead to disciplinary action including the possibility of dismissal. It is the Company’s aim to resolve any complaints as quickly as possible. All complaints will be treated seriously and with appropriate confidentiality.

MAKING A COMPLAINT Employees who believe they have experienced or are experiencing any form of discrimination, harassment or victimisation should consider first whether it is appropriate to raise the matter directly with the person concerned to resolve the problem. If it is not appropriate to do so, employees should speak in the first instance to their Line Manager or Head of department. If an employee feels unable to discuss the matter with his/her Line Manager or Head of department then the appropriate point of contact is the MD or an ED.

Following initial discussions, an employee will be asked to choose whether they wish to use an informal approach or make a formal complaint using the Company’s grievance procedure. The matter will be dealt with promptly, fairly and impartially. Maximum care will be taken to ensure that the career and reputation of each party is not unjustly affected.

INVESTIGATION AND MEETING This step will be conducted in accordance with the Grievance Procedure. It may involve hearing detailed accounts from both the alleged discriminator or harasser and the complainant. Documents, electronic mail and other evidence may be considered. Those conducting the investigation will not be parties directly involved in the allegation.

DISCIPLINARY INTERVIEW Where it has been reasonably concluded that discrimination, harassment or victimisation may have taken place, those responsible will be subject to disciplinary procedures. Serious acts will be regarded as gross misconduct and may lead to instant dismissal. Consideration may be given to redeploying either party, with the wishes of the complainant normally coming first. Employees will be protected from harassment, victimisation or discrimination for making a complaint. Any acts of retaliation will be treated as a disciplinary offence.

EQUAL OPPORTUNITIES OFFICER

The Equal Opportunities Officer for the company is the Managing Director. The MD will, with the assistance and co-operation of senior management, take steps to ensure universal compliance with the policy.

MONITORING

To ensure that this policy is operating effectively, the Company may monitor employees and applicants’ ethnic group, gender, disability, sexual orientation, religion and age. Provision of this information is voluntary. Analysing this data helps the Company to take appropriate steps to avoid discrimination and improve equality and diversity.

January 2026 v4