Equality, Diversity, Inclusion and Dignity at Work Policy

Gelateria Danieli Ltd (the Company) is committed to providing equal employment opportunities and avoiding unlawful discrimination in employment and against clients, customers and the public.

Discrimination Law

It is unlawful to discriminate directly or indirectly in recruitment or employment because of age, disability, sex, gender reassignment (which includes all trans and non-binary identities), pregnancy and maternity, race (which includes colour, nationality and ethnic or national origins), sexual orientation, religion or belief, or because someone is married or in a civil partnership. These are known as protected characteristics.

Caste discrimination may also be unlawful as a form of race discrimination, and the Company treats it as such.

Discrimination after employment may also be unlawful, for example refusing to give a reference for a reason related to one of the protected characteristics.

It is unlawful for an employer to fail to make reasonable adjustments to its requirements, working practices or the physical features of the workplace where these put a disabled job applicant or employee at a substantial disadvantage.

It is also unlawful where a disabled employee is placed at a substantial disadvantage because of the employer’s unreasonable failure to provide an auxiliary aid or service.

This includes neurodivergent conditions — such as autism, ADHD, dyslexia and dyspraxia — where these have a substantial and long-term effect on a person’s ability to carry out normal day-to-day activities, as defined under the Act.

It is unlawful to discriminate directly or indirectly, harass or victimise a member of the public based on any of the protected characteristics in the provision of services, goods or facilities.

It is unlawful to fail to make reasonable adjustments to overcome barriers to using services caused by disability.

The duty to make reasonable adjustments includes the removal, adaptation or alteration of physical features if those physical features make it impossible or unreasonably difficult for disabled people to make use of services. In addition, service providers must think ahead and make reasonable adjustments to address barriers that may impede disabled people from accessing a service.

Dignity at Work

The Company is committed to creating a work environment free of harassment and bullying, where everyone is treated with dignity and respect.

Some harassment is unlawful discrimination, and serious harassment may also be a criminal offence.

Bullying

Bullying is offensive, intimidating, malicious or insulting behaviour, and/or an abuse or misuse of power, that is meant to undermine, humiliate or injure the person on the receiving end.

Examples of bullying include picking on someone, setting them up to fail, or making threats or comments about someone’s job security without good reason.

Harassment

Harassment is unwanted conduct related to a relevant protected characteristic, namely sex, gender reassignment (which includes all trans and non-binary identities), race (which includes colour, nationality and ethnic or national origins), disability, sexual orientation, religion or belief, and age, that:

  • has the purpose of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person; or
  • is reasonably considered by that person to have the effect of violating their dignity or of creating an intimidating, hostile, degrading, humiliating or offensive environment for them, even if this effect was not intended by the person responsible for the conduct.

Harassment can also occur through digital means, including via email, messaging apps, social media or other online platforms, whether or not it takes place during working hours, and is treated with equal seriousness.

Examples of harassment include:

  • physical conduct ranging from unwelcome touching to serious assault
  • unwelcome sexual advances
  • demeaning comments about a person’s appearance
  • unwelcome jokes or comments of a sexual or racist nature, or about an individual’s age
  • excluding an individual because they are associated or connected with someone with a protected characteristic, for example because their child identifies as LGBTQ+, spouse is Black, or parent is disabled
  • repeated name-calling related to an individual’s religion or belief
  • ignoring an individual because they are perceived to have a protected characteristic, whether or not they do have that protected characteristic, for example because an employee is thought to be Jewish or is perceived to be transgender
  • the use of obscene gestures
  • the open display of pictures or objects with sexual or racist overtones, even if not directed at any particular person or relating to their actual or perceived protected characteristic — for example printed material, explicit digital content, or images shared or displayed via screens, devices or messaging platforms.

Conduct may amount to harassment whether or not the person behaving in that way intends to offend.

Something intended as a joke may offend another person. Everyone has the right to decide what behaviour is acceptable to them and to have their feelings respected by others.

Behaviour that any reasonable person would realise would be likely to offend will amount to harassment without the recipient having to make it clear in advance that behaviour of that type is not acceptable to them, for example sexual touching.

It may not always be clear in advance that some other forms of behaviour would be unwelcome to, or could offend, a particular person, for example certain banter, flirting or asking someone for a private drink after work. In these cases, first-time conduct that unintentionally offends may not amount to harassment, but it may do so if the conduct continues after the recipient has made it clear, by words or conduct, that such behaviour is unacceptable to them.

A single incident can amount to harassment if it is sufficiently serious.

Sexual Harassment Prevention

The Company is committed to providing a workplace free from sexual harassment and discrimination. In line with the Worker Protection (Amendment of Equality Act 2010) Act 2023, the Company will take reasonable steps to prevent sexual harassment in the course of employment.

All employees are expected to adhere to a high standard of behaviour.

The Company will take reasonable steps to prevent sexual harassment, including responding promptly to concerns, addressing inappropriate behaviour, considering risks in the workplace, and supporting managers to deal with issues appropriately.

Managers are expected to act promptly where concerns are raised or where inappropriate comments or behaviour are observed.

The Company will also take complaints of sexual harassment by customers, clients, suppliers, contractors, visitors or other third parties seriously and will take appropriate action where concerns are raised.

If you think you are being bullied or harassed

Employees may be able to sort out matters informally. The person may not know that their behaviour is unwelcome or upsetting. An employee may feel able to approach the person themselves or with the help of someone else at the Company.

Employees should tell the person what behaviour they find offensive and unwelcome and say that they would like it to stop immediately.

If an informal approach does not resolve matters, or if the situation is too serious to be dealt with informally, a formal complaint may be made using the Company’s grievance procedure.

In the case of grievances about bullying or harassment, the normal grievance procedure is modified so that the employee can choose whether to raise the grievance with their manager or with another manager.

All complaints will be investigated promptly and, if appropriate, disciplinary proceedings will be brought against the alleged harasser. The employee will have the right to be accompanied by a fellow worker or trade union official of their choice at any meeting dealing with their grievance. The employee will be kept informed of the general progress of the investigation and, subject to data protection requirements, the outcome of any disciplinary proceedings.

The Company will treat complaints of bullying and harassment sensitively and maintain confidentiality to the maximum extent possible.

Employees have the right not to be victimised for making a complaint in good faith, even if the complaint is not upheld. However, making a complaint that is known to be untrue may lead to disciplinary action being taken.

Your Responsibilities

Every employee is required to assist the Company in meeting its commitment to provide equal opportunities in employment and avoid unlawful discrimination.

Employees can be held personally liable as well as, or instead of, the Company, for any act of unlawful discrimination. Employees who commit serious acts of harassment may also be guilty of a criminal offence.

Acts of discrimination, harassment, bullying or victimisation against employees or clients are disciplinary offences and will be dealt with under the Company’s disciplinary procedure. Conduct of this type will often be gross misconduct which can lead to dismissal without notice.

This policy will be reviewed annually, or sooner where required by changes in legislation or business circumstances.

last updated 16th july 2026

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