Equal Opportunity Policy

A. Purpose and Scope

The purpose of this Equal Opportunity Policy is to communicate our commitment to equality of opportunity in employment, with the aims of ensuring that all employees and job applicants are treated fairly and equally. Sirma AI, trading as Ontotext, is committed to providing a working environment that is free from all forms of discrimination, as specified in the Law on Protection Against Discrimination and associated legislation.

The policy applies to all Ontotext employees (full-time and part-time employees and other workers, such as agency workers, temporary workers and contractors). All employees are expected to put this policy into practice.

All employees will have access to this policy, as it will be available through the Documents section of BambooHR. Job seekers and applicants will be sent a copy of the policy on request.

Any questions about the policy should be directed to HR.

This policy does not form part of employees’ contracts of employment and Ontotext may amend it at any time. Employees will be notified about amendments through Bamboo HR. The policy will be published on the corporate website.

The policy is reviewed at least annually.

B. Policy Statement

Ontotext is fully committed to providing equality in the workplace. We provide opportunities to employees, candidates for employment, suppliers, customers and all related parties fairly and irrespective of age, disability, gender, gender reassignment, sexual orientation, marital or civil partnership status, pregnancy or maternity, race (including color), ethnic or national origins and nationality, religion or belief (“the protected characteristics”). We aim to create a working environment that is free from discrimination and harassment in any form, in which all employees, customers and suppliers are treated with dignity and respect.

Ontotext will not unlawfully discriminate in the arrangements we make for recruitment and selection or in the opportunities afforded for employment, training or any other benefit. All decisions will be made fairly and objectively. We aim, as far as reasonably practicable, to ensure that all our working practices are applied fairly and consistently and, where necessary, we will take reasonable steps to avoid or overcome any particular disadvantage these may cause and to promote equality. One particular action that Ontotext has taken is to develop a Gender Equality Plan, which defines the targets, resources, responsibilities and expected action that will be taken to promote gender equality and avoid gender bias.

Ontotext respects an individual’s right to choose whether or not to belong to a trade union and membership status will have no bearing on an applicant’s suitability for employment or result in any detrimental treatment.

C. Specific Responsibilities

Ontotext management and HR have overall responsibility for the effective operation of this policy and for ensuring compliance with the Law on Protection Against Discrimination and associated legislation.

HR and the COO are responsible for monitoring and reviewing the policy and for ensuring that all employment-related policies, procedures and practices adhere to this policy.

All staff has a responsibility not to discriminate or harass other staff clients/customers and suppliers and to report any such behavior of which they become aware of their Manager/Supervisor or the HR Manager.

Managers/supervisors are responsible for implementing the Equal Opportunities Policy and must apply the policy as part of their day-to-day work.

D. Forms of Discrimination

The following are forms of discrimination that this policy aims to avoid:

Direct Discrimination

Occurs when a person is treated less favorably because of a protected characteristic that they either have or are thought to have. Direct discrimination can also occur by way of association, which is when a person is treated less favorably because, for example, their spouse or partner or other relative has the protected characteristic.

Indirect Discriminatio

Occurs when a provision, criterion or practice is applied equally to everyone but has a disproportionately adverse effect on people who share a particular protected characteristic. A person with the protected characteristic who is disadvantaged in that way has the right to complain.
To be justified the provision, criterion or practice must be necessary for legitimate business reasons in circumstances where less discriminatory alternatives are not reasonably available.

Victimization

Occurs where someone is treated unfavorably because he/she has raised a complaint under this policy or taken legal action, in relation to any alleged act of unlawful discrimination, against Ontotext or because he/she has supported someone else in doing this.

Harassment

This is unwanted conduct that violates an individual’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment. Harassment can take many different forms and may involve inappropriate actions, behavior, comments, emails or physical contact that causes offense or are objectionable.

Harassment may involve a single incident or persistent behavior that extends over a period of time and can occur even if someone did not mean to cause offense. It also means that a person can be subjected to harassment by behavior that is not aimed at them directly but which they nonetheless find unpleasant.

Harassment is always unacceptable and where it relates to a protected characteristic it will be considered an unlawful act of discrimination.

Discrimination arising from Disability

In addition to the above, it is unlawful to treat a person unfavorably because of something that is the result, effect or outcome of their disability, unless the treatment is necessary and can be objectively justified. Furthermore, employers have a duty to make reasonable adjustments to ensure that disabled applicants, employees or other workers are not substantially disadvantaged.

E. Creating Equal Opportunities in the Workplace

There are a number of ways in which Ontotext aims to ensure equal opportunities in the workplace, including:

  • Recruitment and selection

Recruitment and selection procedures will be free from bias or discrimination. Recruitment procedures will be conducted objectively and will be based upon specific and reasonable job-related criteria. Decisions regarding an individual’s suitability for a particular role will be based on aptitude and ability.

We will consider making appropriate reasonable adjustments to the recruitment process to ensure that disabled applicants are not substantially disadvantaged.

  • Career development and training

All staff will be given an appropriate induction to enable them to fulfill the responsibilities of their role.

All employees will be encouraged to develop their full potential and we will not unreasonably deny an employee access to training or other career development opportunities. These will be identified as part of an ongoing performance management process and will be determined objectively, taking into account the needs of the business and available resources.

Selection for promotion will be based on objective criteria and decisions will be made on the basis of merit.

  • Employment policies and practices

Ontotext aims to ensure that employment policies and practices, including any rules or requirements, do not directly or indirectly discriminate and are applied in a non-discriminatory manner. In particular, we will ensure that all disciplinary decisions are fair and consistent and that selection for redundancy is based on objective criteria.

Ontotext will consider making appropriate reasonable adjustments to the working environment or any work arrangements that would alleviate any substantial disadvantage these might cause to disabled staff.

We will aim, as far as reasonably practicable, to accommodate the requirements of different religions and cultures and will consider requests from employees to vary or change their working hours to enable them to care for a dependent (in compliance with Ontotext’s Remote Working Policy).

  • Working environment

All individuals have a right to be treated with dignity and respect and Ontotext takes reasonable steps to protect staff from discrimination, bullying or harassment and, in the event of a complaint, we will take appropriate action to prevent, as far as possible, a further occurrence.

All staff is encouraged to report any incidents of inappropriate or unacceptable behavior at work or that occurs during the course of employment, on or off premises, including at work social events (whether organized by Ontotext or not) or at formal or informal events involving staff, customers or other work-related contacts.

  • Raising a complaint of discrimination

If you believe you have been discriminated against, you should raise the matter to HR.

Any employee who is found to have committed an act of discrimination, or breached this policy in any other way, will be subject to disciplinary action.

Ontotext will also take seriously any malicious or, in its opinion, unwarranted allegations of discrimination and will take appropriate action, disciplinary or otherwise, where necessary.