Equality, Diversity and Inclusion Policy

Our Commitment

We are committed to providing outstanding client service by maintaining the highest standards of professional excellence. To meet this objective we maintain an Equality, Diversity and Inclusion (EDI) policy that supports equal opportunities for all and a working environment free from discrimination, harassment, sexual harassment and bullying.

Recruitment, training and promotion decisions are based on objective criteria and merit, regardless of the following protected characteristics under the Equality Act 2010: age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race (including colour, nationality and ethnic or national origin); religion or belief; sex; and sexual orientation. We also use inclusive language recognising gender identity and expression.

This policy applies to everyone working at Broadfield, including employees, partners, temporary or agency workers, trainees, work experience students, secondees, contractors and consultants. It also applies to job applicants and to conduct affecting former employees where relevant to the employment relationship (for example, references).

You must comply with this policy in all dealings with clients, colleagues and others encountered in the course of work. The policy applies on our premises, at client sites, during work-related social/corporate events, business travel and where you represent the firm. Any breach may be treated as misconduct and, where appropriate, gross misconduct.

Scope of the Policy

This policy covers the following matters:

recruitment, selection, learning and development and promotion;
terms and conditions of employment/terms of engagement;
disability;
discrimination, victimisation and harassment;
sexual harassment (including by third parties);
our obligations and responsibilities;
complaints procedure, investigation and disciplinary action; and
monitoring and data protection.

Recruitment, Selection, Learning and Development and Promotion

The firm ensures that information about job opportunities is circulated as widely as appropriate to reach all sections of the community. All applications are welcomed and are assessed against objective job and/or person specifications.

Where recruitment agencies are engaged, they are instructed that advertisements and processes must not be discriminatory and must reflect our equal opportunities commitments.

Job and person specifications include only criteria objectively required for the duties and responsibilities of the vacancy and are prepared before recruitment begins.

Targeted measures: In limited circumstances, and where lawful, we may take positive action to address disadvantage or under-representation (for example, outreach or encouraging applications from a particular group). Any such measures will comply with the Equality Act 2010 positive action framework: there must be evidence of disadvantage or low participation; actions must be proportionate; and in recruitment or promotion any tie-break decision will only be used between candidates of equal merit and will not amount to automatic preference.

We may invite applications from individuals at risk of redundancy or requiring redeployment for health or disability reasons before advertising more widely.

All new joiners are asked to complete a voluntary diversity monitoring form to assist with record-keeping and monitoring.

We aim to provide appropriate learning and development opportunities to enable colleagues to perform and progress. Opportunities are available on an equal basis, and promotion is based on merit and the needs of the role.

Barristers, experts and other subcontractors are selected on skills, experience, ability and cost, not on any protected characteristic. Client partners will agree appointments with clients as appropriate.

Terms and Conditions of Employment/Terms of Engagement

Terms and conditions of employment/engagement are free from direct and indirect discrimination. We do not impose requirements, conditions, criteria or practices that unjustifiably disadvantage any group. Grievance and disciplinary procedures operate without discrimination.

We recognise the benefits of flexible working arrangements and provide policies and toolkits to support work-life balance where operationally feasible.

Disability

We value the contribution of current and prospective colleagues from all sectors of the community and are committed to facilitating the employment of disabled people wherever practicable. We will:

take reasonable steps to ensure recruitment arrangements, the working environment and practices do not prevent disabled people from taking up suitable positions;
consider accessibility when acquiring/fitting out buildings and equipment and when devising working practices;
make reasonable adjustments to recruitment arrangements, the working environment, practices and terms/conditions to avoid substantial disadvantage;
ensure that any decision not to make a reasonable adjustment is not taken below Head of Department level and only after HR consultation, exploration of options, consultation with the individual and (where appropriate) expert advice;
support any colleague who becomes disabled in continuing in their role where practicable (with adjustments) or moving to an alternative suitable role if available;
encourage participation and consultation with disabled colleagues so that our practices recognise and meet their needs; and
continue to provide services and facilities to clients with disabilities.

Colleagues who know or believe they may be disabled are encouraged to speak confidentially with HR so we can support them and comply with our responsibilities.

The HALO Code

Our workplace champions the right of staff to embrace all Afro-textured hairstyles and protective styles. We acknowledge that Afro-textured hair is an important part of many Black employees’ racial, ethnic, cultural and religious identities and requires specific styling for hair health and maintenance. We celebrate Afro-textured hair worn in all styles including, but not limited to, afros, locs, twists, braids, cornrows, fades, hair straightened through heat or chemicals, weaves, wigs, headscarves and wraps.

Race-based hair discrimination can amount to unlawful discrimination under the Equality Act 2010. Any dress or appearance code will only be applied where necessary for legitimate aims, will be objectively justified and will be applied consistently across staff. Policies or practices that restrict hairstyles primarily used to maintain Afro-textured hair risk indirect discrimination. The HALO Code is gender-neutral.

All staff are encouraged to familiarise themselves with Afro-textured hairstyles and their cultural significance and to avoid labelling such hairstyles as messy, unprofessional or inappropriate. Additional guidance may be issued, provided it is applied consistently across all staff.

Discrimination, Victimisation and Harassment

Discrimination

A person is discriminated against if they are treated less favourably because of a protected characteristic (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex or sexual orientation). Discrimination also includes harassment and victimisation on these grounds.

Indirect discrimination

Indirect discrimination arises where a provision, criterion or practice applies to everyone but puts people sharing a protected characteristic at a particular disadvantage compared with others, and the practice cannot be justified as a proportionate means of achieving a legitimate aim.

Victimisation

Victimisation occurs where a person is subjected to a detriment because they have done, are believed to have done, or may do a protected act—such as bringing proceedings under the Equality Act, giving evidence or information in connection with proceedings, making an allegation that the Act has been contravened, or doing any other thing for the purposes of or in connection with the Act.

Harassment

Harassment is unwanted conduct related to a protected characteristic that has the purpose or effect of violating a person’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment. Where the effect is relied upon, regard will be had to: (i) the complainant’s perception; (ii) the other circumstances of the case; and (iii) whether it is reasonable for the conduct to have that effect. Harassment includes bullying and victimisation.

Examples of behaviour that may amount to harassment include (non-exhaustive):

physical assault;
physical or verbal abuse, including threats;
suggestive comments or gestures;
suggestive or offensive emails or messages;
insulting or abusive behaviour or comments;
isolation or exclusion from workplace, corporate, social or sporting events;
persistent criticism or humiliation; and
unfair allocation of work or responsibilities.

Age Harassment

making ageist insults or threats;
making assumptions and judgements based on age;
banter or jokes degrading to a person’s age; and
ignoring or excluding a colleague because of their age.

Disability Harassment

ableist insults or threats (including nicknames, teasing, name-calling, gestures, jokes or pranks);
assumptions or judgements about a colleague based on disability;
intrusive questions about a disabled colleague’s private life; and
ignoring or excluding a colleague because of disability.

Homophobic and Transphobic Harassment

homophobic or transphobic insults and threats;
unnecessary or degrading references to sexual orientation or gender identity;
banter or jokes degrading to a person’s sexual orientation (real or perceived) or gender identity;
outing an individual as LGBTQ+ without permission;
ignoring or excluding a colleague because they are LGBTQ+;
spreading rumours or gossip about sexual orientation or gender identity;
intrusive questions about an LGBTQ+ colleague’s private life;
assumptions or judgements based on sexual orientation or gender identity; and
using religious belief to justify anti-LGBTQ+ bullying or harassment.

Racist Harassment

racist derogatory name-calling;
verbal threats, insults and racist jokes (including mimicry or gestures);
display of racially offensive material;
exclusion from normal workplace conversation or activities;
physical attack; and
encouraging others to commit any such acts.

Religion or Belief Harassment

repeated mocking or derogatory comments about religion, belief or observance;
exclusion from workplace conversation or activities because of religion or belief;
insults, ridicule or teasing regarding appearance, religious symbols or dress; and
conduct that denigrates, intimidates or is physically abusive because of religion or belief.

Sexual Harassment

Sexual harassment is unwanted conduct of a sexual nature. A single incident can be sufficient. Sexual harassment is prohibited irrespective of whether it is framed as “banter” or occurs outside normal hours during work-related events or business travel.

Examples include (non-exhaustive):

physical conduct of a sexual nature;
unwanted physical contact or proximity, including unnecessary touching or brushing against someone;
verbal conduct of a sexual nature, including unwelcome advances, repeated requests for social activity after refusal, or suggesting that sexual favours may benefit a career (or refusal may hinder it);
insults, ridicule or teasing of a sexual nature; insults related to gender or sexual orientation; offensive comments about appearance or dress; talk or jokes of a sexual nature;
display or transmission of sexually suggestive or pornographic material; and
sexual assault (a serious criminal offence).

Reasonable steps duty and third parties: We will take reasonable steps to prevent sexual harassment of employees in the course of their employment, including harassment by third parties (such as clients, customers or suppliers). Our prevention measures include risk assessments, clear contractual terms with third parties, staff training, communication of standards to third parties and accessible reporting routes.

Third-Party Statement

Zero tolerance of sexual harassment.
Applies to third-party suppliers, partners, contractors and sub-tenants interacting with our people on or off-site.
Confidential reporting routes to line managers or HR without fear of retaliation.
Prompt and thorough investigations with appropriate outcomes.
Consequences for third parties may include contract termination, bans from premises and legal action.
Ongoing prevention through training, communication and proportionate risk assessments.

Consequences of Discrimination, Victimisation and Harassment

Any behaviour involving discrimination, victimisation, harassment or sexual harassment will not be tolerated. Such behaviour may amount to gross misconduct and may result in disciplinary action, up to and including dismissal.

Our Obligations

We believe everyone has the right to work in an environment that promotes equality of opportunity and prohibits discriminatory practices. We do not tolerate discrimination, victimisation, harassment or sexual harassment.

Training: We provide mandatory firmwide training on EDI and on recognising and preventing harassment and sexual harassment for all colleagues, with refresher training annually. New joiners receive induction training.

Speaking up: We encourage a culture of transparency and speaking up. Please refer to the Conduct section of the Office Manual for our grievance procedures and to our Speaking Up policy (links available on the intranet).

SRA workplace environment requirements: This policy forms part of our arrangements to comply with the SRA Standards and Regulations, including workplace environment rules. We have systems and controls to prevent and address bullying, discrimination and harassment; we treat colleagues fairly and with respect; we investigate concerns promptly and proportionately; and, where required, we escalate or report serious issues. Oversight of this policy, related investigations and learning actions rests with the firm’s Compliance Officer for Legal Practice (COLP) working with HR and the Partnership.

Employee Support

Anyone who raises concerns about matters covered by this policy (including sexual harassment) will be protected from retaliation. Complaints are handled confidentially and shared only on a need-to-know basis. Line managers and HR are available to support colleagues, and all employees and partners have access to the Employee Assistance Programme (EAP) provided by Health Assured (0800 030 5182).

Our Responsibilities

Our collective responsibility

All colleagues must comply with this policy and report incidents or alleged incidents to a partner/manager or HR. Where possible, concerns should be raised with the individual involved to seek informal resolution. The complaints procedure below is available to support you.

Duties of partners and managers

Partners and managers are responsible for implementing this policy and ensuring compliance. Where an allegation of discrimination, victimisation, harassment or sexual harassment is made, they must discuss it with the complainant and seek advice from HR.

Complaints Procedure

Failure to comply with this policy or to co-operate with its effective operation is a disciplinary matter. Our aim is to resolve complaints quickly and, where appropriate, informally. All complaints are treated seriously and with appropriate confidentiality.

Making a complaint

If you experience discrimination, harassment, sexual harassment or bullying, consider first whether to raise the matter with the person concerned. If that is not appropriate, speak to your partner/manager or HR. After initial discussions, you may choose to:

take no further action;
discuss the complaint directly with the individual concerned;
ask your partner/manager or HR to help resolve the matter informally; or
make a formal written complaint to HR to be handled under the grievance procedure (see Office Manual).

If a client or a client’s employee is involved, we will agree appropriate action with the complainant.

Investigation

Once a formal written complaint is made, the firm will investigate carefully and discreetly. Both parties will be heard; others may be asked to provide information; and relevant documents or communications may be reviewed. Those conducting the investigation will be impartial and not directly involved in the allegations. A record of the process, outcome and any steps taken will be provided to the complainant.

In serious cases (for example, where others could be at risk), we may investigate and take disciplinary action even if no formal written complaint is made. Allegations of criminal behaviour may be referred to law enforcement.

Risk Assessments

Risk assessments should minimise or, ideally, eliminate risks to create a safe working environment. Factors include:

Working environment – whether the set-up or context is conducive to inappropriate behaviour;
Working culture – any history of harassment or tolerance of unacceptable behaviours;
Policies and practices – gaps in training or awareness;
Workforce demographics – groups who may be at greater risk due to power imbalances or isolation (e.g., interns, apprentices, remote workers); and
External interactions – risks arising from clients, vendors or other third parties.

A risk assessment template is available in the Conduct section of the intranet.

Disciplinary Procedure

If an investigation indicates substance to a complaint, the disciplinary procedure may be initiated. Modifications may be made to reflect the sensitivity of allegations. While we normally seek the complainant’s agreement before starting disciplinary action, there may be occasions where we proceed irrespective of that view. Matters will be handled promptly, fairly and impartially, and we will protect those who raise concerns in good faith from retaliation. Malicious or knowingly false complaints may themselves result in disciplinary action.

Monitoring

As required by the Solicitors Regulation Authority (SRA), we collect and monitor diversity data to understand the make-up of our workforce and to identify areas for action to improve diversity.

Data protection: The firm stores and processes personal information about employees, partners and other categories of worker for employment, administrative and regulatory purposes. For diversity monitoring, our lawful basis under UK GDPR is compliance with legal obligations and/or our legitimate interests in managing our workforce. Where data constitutes special category data, we rely on the employment, social security and social protection condition and/or the substantial public interest condition for equality of opportunity or treatment under the Data Protection Act 2018.

We use anonymisation and aggregation wherever possible; access is role-based and limited to those who need it; data is retained only as long as necessary and in line with our retention schedule; and disclosures are made in aggregated form unless required by law or a regulator. For further information, please refer to the firm’s Privacy Notice on the intranet.

This policy reflects the law and firm’s practice as of February 2026. HR is responsible for reviewing this policy annually from both legislative and operational perspectives, in consultation with the COLP.

Pay Invoice