Diversity and Inclusion Policy

How amarti treats people fairly, prevents discrimination and harassment, and builds a team where everyone can do their best work.

Document control
Reference	AM-POL-024
Version	1.0
Classification	Public
Owner	James Peachey, Co-founder
Approved by	James Peachey, Co-founder, on 30 September 2026
Next review	30 September 2027
Applies to	All amarti employees, contractors, associates, candidates and anyone working on an amarti engagement
Standards alignment	Equality Act 2010; Worker Protection (Amendment of Equality Act 2010) Act 2023; Employment Rights Act 2025; EHRC Code of Practice on Employment; ISO 30415:2021; ISO/IEC 27001:2022 A.6.3

1. Policy statement

amarti is committed to equality of opportunity and to a working environment in which everyone is treated with dignity and respect. We want a team that reflects the clients and communities we serve, and we know that diverse teams build better technology.

We will not tolerate discrimination, harassment, bullying or victimisation of any kind, whether by our people, our clients, our suppliers or anyone else we deal with. This policy explains what that means in practice, what we expect of everyone, and what to do if something goes wrong.

This policy is non-contractual and may be updated at any time. It is published so that clients, candidates and suppliers can see the standards we hold ourselves to.

2. Scope

This policy applies to every stage of working with amarti: recruitment and selection, terms and conditions, pay, training, development, promotion, flexible working, discipline, grievances and leaving. It covers conduct in the office, at client sites, when working remotely, at work social events, and online, including on social media as set out in the Social Media Policy (AM-POL-025).

It applies to employees, workers, contractors, associates and job applicants. Where a concern involves a client or supplier, amarti will act under this policy and under the terms of the relevant contract.

3. Our legal framework

amarti is a UK business and this policy is built on the Equality Act 2010. The Act protects people from discrimination because of nine protected characteristics:

Protected characteristic	What it covers
Age	A particular age or age range.
Disability	A physical or mental impairment with a substantial and long-term effect on day-to-day activities, including many neurodivergent and long-term health conditions.
Gender reassignment	Anyone proposing to undergo, undergoing or having undergone a process to change their sex. No medical treatment is required.
Marriage and civil partnership	Being married or in a civil partnership.
Pregnancy and maternity	Being pregnant, on maternity leave, or having recently given birth, including breastfeeding.
Race	Colour, nationality, and ethnic or national origin.
Religion or belief	Any religion or philosophical belief, or lack of belief.
Sex	Being a man or a woman.
Sexual orientation	Orientation towards people of the same sex, the opposite sex, or either sex.

The Act prohibits the following, all of which are breaches of this policy:

• Direct discrimination: treating someone less favourably because of a protected characteristic, including one they are thought to have or because of someone they are associated with.
• Indirect discrimination: applying a rule or practice to everyone that puts people who share a protected characteristic at a disadvantage, and which cannot be objectively justified.
• Discrimination arising from disability and failure to make reasonable adjustments.
• Harassment: unwanted conduct related to a protected characteristic that violates someone’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment.
• Sexual harassment: unwanted conduct of a sexual nature, and less favourable treatment because someone rejected or submitted to it.
• Victimisation: treating someone badly because they have raised a concern, made a complaint or supported someone else who has, in good faith.

We go further than the law requires. We will not tolerate anyone being treated unfairly because of their socio-economic background, caring responsibilities, working pattern, menopause symptoms, trade union membership, or whether they work part-time or on a fixed-term basis.

4. What we expect of everyone

• Treat colleagues, clients, candidates and suppliers with courtesy and respect, whatever their background.
• Do not make jokes, comments, remarks or “banter” about someone’s protected characteristics, even if you think no one will be offended. The effect on the person matters, not the intention.
• Use people’s correct names and pronouns.
• Make decisions about people (hiring, allocation to engagements, promotion, pay) on merit and on evidence, and be able to explain them.
• Challenge inappropriate behaviour if you feel able to, and report it if you do not.
• Complete equality and harassment training when asked, and apply it in your work.

Leaders have an extra responsibility to model inclusive behaviour, to notice when people are being excluded, and to act promptly on any concern raised with them.

5. Recruitment and selection

• Job adverts describe the skills and experience genuinely needed for the role, use inclusive language, and are placed where they will reach a diverse field of candidates.
• Every advert and invitation to interview offers reasonable adjustments to the process.
• Shortlisting and interviews use consistent, pre-agreed criteria. Wherever possible, more than one person is involved in the decision.
• We do not ask about health or disability before a job offer, except to make adjustments to the selection process or where the law allows.
• Right-to-work checks are carried out on every successful candidate in the same way, regardless of their nationality or appearance.
• Where we use AI or automated tools in recruitment, they are assessed for bias before use and a person always makes the final decision, in line with the Artificial Intelligence and Machine Learning Policy (AM-POL-023).

amarti may use lawful positive action under sections 158 and 159 of the Equality Act 2010, for example encouraging applications from under-represented groups. Positive discrimination, meaning appointing someone because of a protected characteristic rather than on merit, is unlawful and we do not do it.

6. Pay, development and progression

amarti pays people for the work they do and the skills they bring. Pay decisions are reviewed to check that there is no unjustified gap between people who share a protected characteristic and those who do not.

Access to training, certifications, client engagements and promotion is based on ability, performance and development needs. We keep a record of who is allocated to engagements and who receives development opportunities, so that we can spot patterns and correct them.

The Employment Rights Act 2025 introduces gender pay gap and menopause action plans. These are mandatory only for employers with 250 or more employees, from April 2027. amarti is below that threshold but follows the same principles voluntarily in proportion to our size.

7. Reasonable adjustments and flexible working

amarti will make reasonable adjustments for disabled employees and candidates to remove barriers they face at work. Adjustments might include equipment or software, changes to working hours, a phased return after absence, or changes to how work is allocated or assessed. You do not need a formal diagnosis to ask. Speak to James Peachey, and we will discuss what would help and agree it in writing.

All employees have the right to request flexible working from their first day of employment. We will consider every request fairly, consult you before any refusal, and only refuse for a genuine business reason that we explain to you.

We will support employees through pregnancy, maternity and other family leave as set out in the Maternity, Paternity and Family Leave Policy (AM-POL-001), and will make reasonable accommodations for religious observance, carers and people experiencing menopause symptoms.

8. Harassment, sexual harassment and third parties

amarti has a legal duty to take reasonable steps to prevent sexual harassment of our people. From 30 October 2026, under the Employment Rights Act 2025, that duty becomes a duty to take all reasonable steps, and employers also become liable for harassment of their workers by third parties (including clients, client staff, suppliers and members of the public) across all protected characteristics.

We meet this duty by:

• Carrying out and recording a harassment risk assessment, reviewed annually and whenever we start an engagement in a new client environment.
• Briefing every client engagement lead on this policy and making clear to clients that we expect our people to be treated with respect.
• Training everyone on what harassment looks like and how to report it, and keeping a record of attendance.
• Acting promptly on every report, and supporting the person affected, including, where needed, removing them from an engagement without detriment to them.
• Reviewing each incident to learn whether our preventative steps worked.

If you are harassed by someone at a client or supplier, report it to James Peachey straight away. You will not be blamed, and you will not lose work or opportunities as a result. amarti will raise it with the client and take action to protect you.

9. Raising a concern

Informally

If you feel able to, you can tell the person that their behaviour is unwelcome and ask them to stop. You can also talk to James Peachey informally for advice without starting a formal process.

Formally

You can raise a formal complaint in writing to James Peachey. If your concern is about James, raise it with Amardeep Sirha instead. We will acknowledge your complaint within two working days, investigate it fairly, confidentially and without unreasonable delay, and tell you the outcome in writing. You have the right to be accompanied at any meeting by a colleague or a trade union representative.

Where amarti is too small for an independent investigation internally, we will appoint an external HR adviser to investigate.

Protection

• Nobody will be victimised for raising a concern in good faith, or for supporting or giving evidence for a colleague who has. Victimisation is itself a disciplinary matter.
• Disclosures about sexual harassment are protected disclosures under whistleblowing law.
• amarti will not use confidentiality or settlement agreements to stop anyone reporting discrimination or harassment to the police, a regulator, a legal adviser or a medical professional.
• Deliberately false and malicious allegations are rare, and will be treated as misconduct.

You can also contact Acas for free, impartial advice, or the Equality Advisory and Support Service.

10. Equality monitoring and data

amarti may ask candidates and employees to share diversity information so that we can check this policy is working. Answering is always voluntary and every question has a “prefer not to say” option.

This is special category personal data under the UK GDPR. It is collected only for equality monitoring, held separately from recruitment and personnel files with access limited to James Peachey, reported only in anonymised form, and never used to make decisions about individuals. Further detail is in the Privacy Policy (AM-POL-013).

11. Roles and responsibilities

Who	Responsibility
James Peachey, Co-founder	Owns this policy. Receives concerns, oversees investigations, carries out the harassment risk assessment, reviews monitoring data, and reports on progress.
Amardeep Sirha, Co-founder	Alternative point of contact for concerns. Ensures AI and technical tools used on people decisions are assessed for bias.
Engagement leads	Brief client teams on our standards. Notice and act on concerns during an engagement. Allocate work fairly.
Everyone	Follow this policy, complete training, challenge or report unacceptable behaviour, and support colleagues.

12. Training and review

Everyone completes equality, diversity and harassment training at induction and refreshes it every year. Leaders and engagement leads also complete training on inclusive recruitment and handling complaints.

This policy is reviewed annually by James Peachey under the Policy Governance Framework (AM-POL-011), and sooner if the law changes. Employment Rights Act 2025 measures continue to commence through 2027, and this policy will be updated as they do.

13. Compliance

Breach of this policy is handled under the Disciplinary Policy and Procedure (AM-POL-004). Harassment, discrimination and victimisation may constitute gross misconduct. For contractors and associates, breach may result in immediate termination of the engagement. Individuals can be personally liable under the Equality Act 2010 for their own acts of discrimination or harassment.

Questions about this document

The first point of contact for this document is James Peachey (info@amarti.io). Where a query is best handled by another member of the leadership team, it will be routed as follows:

Contact	Area	Email
Amardeep Sirha, Co-founder	Alternative contact for concerns involving James Peachey; technical and platform matters	info@amarti.io