Equal Opportunities Policy

Introduction

The Cloud One Group Limited (the “Company”) embraces diversity and is committed to the principle of equality among its employees; providing equal opportunities for all, regardless of whether individuals are employees, customers, suppliers, agents or otherwise. We believe all employees and job applicants have the right to be protected from unfair treatment and we will only differentiate on merit and the ability to do the job.

Within the Company our objective is to provide a fair and equal working environment that is free from all forms of discrimination. Accordingly, all employees will be treated fairly in respect of any protected characteristics they may have. Protected characteristics are race, religion and belief, pregnancy and maternity, sex, marriage and civil partnership, disability, gender-reassignment, age and sexual orientation.

This policy applies to all areas of employment with the Company. In the main these are recruitment, promotion, training and development, secondments, transfers, performance management, remuneration, grievance and disciplinary procedures, selection for redundancy and dismissal.

It also applies to temporary staff, contractors and consultants and all third parties that the Company engages. Unless otherwise stated, all reference to employees includes potential employees, former employees, as well as agency workers, temporary workers and contractors.

Managers are responsible for implementing this Equal Opportunities Policy and for applying the policy as part of their day-to-day management of the Company.

All employees have a responsibility not to discriminate against fellow employees and to report any such behaviour of which they become aware.

Forms of Discrimination

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

Direct discrimination— occurs where a person is treated less favourably because of their race, religion and belief, sex, marriage or civil partnership, pregnancy and maternity, disability, gender re-assignment, age, or sexual orientation.

Associative discrimination— occurs where a person is discriminated against because they associate with someone who has a protected characteristic.

Perceptive discrimination— occurs where a person is discriminated against because they are perceived to have a protected characteristic, even if they do not actually have that characteristic.

Indirect discrimination— occurs where a provision, criterion or practice is applied to all employees but is liable to disadvantage individuals who share a particular protected characteristic. Indirect discrimination is still unlawful (unless it can be justified) even when the provision, criterion or practice causing the disadvantage has been unintentionally applied.

Victimisation— occurs where someone is treated in a disadvantaged way because of making a claim, making an allegation of discrimination or giving evidence or information in connection with another person’s claim.

Harassment— occurs where there is unwanted conduct relating to a relevant characteristic and the conduct has the purpose of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. It also covers associative and perceived characteristics. Harassment can take many different forms and may involve inappropriate actions, behaviour, comments or physical contact or gestures that cause offence or are objectionable. Physical contact includes, for example, perceived horseplay, touching, pinching, pushing, grabbing, shoving, punching and other forms of physical assault. Harassment may also include victimisation, bullying, lewd remarks, demands for sexual favours or the placing of items of a potentially offensive nature within view of employees or distributing such material by mail, mobile phone, text message, telephone, fax, email, photograph, uploads onto websites or any other electronic means. The Company will treat allegations of harassment seriously and take the necessary steps to deal with such allegations appropriately. This includes any allegations which may have arisen from third parties, for example customers or suppliers.

Disability Discrimination— The Company will ensure that employment policies and practices fully comply with current legislative provisions and will consider making appropriate reasonable adjustments to ensure that disabled applicants or employees are not disadvantaged or suffer discrimination arising from their disability.

Any employee found to be acting in a discriminatory manner, whether directed towards fellow employees, contract workers, suppliers, customers, clients or any other person that employees encounter while at work or on Company business will be dealt with under the Company’s Disciplinary Procedure. This could lead to their dismissal from the Company.

Employees should also be aware that in certain circumstances, should they be found guilty of discrimination they may be personally and legally liable for their actions.

Creating Equal Opportunities in the Workplace

The Company will seek to ensure equal opportunities in the workplace in various ways, including:

Recruitment and Selection Decisions— Recruitment and selection procedures will be free from bias or discrimination. They will be conducted objectively, and the Company will make decisions regarding an applicant’s suitability for a position based on relevant job-related criteria.

Employment Conditions— Terms and conditions of employment, including pay and benefits, will be offered to employees fairly and equally.

Employment Policies and Practices— All employment-related policies, procedures and practices such as career development, promotion and access to training are non-discriminatory.

If Harassment is Observed

The Company believes that every employee should take responsibility for ensuring that other employees are not subjected to harassment. If you are aware of the possibility that another employee may be a victim of harassment either by a fellow employee, supplier, client or customer, then you should notify your manager immediately. Your allegations will be treated sensitively and provided you have acted in good faith and with good reason then your position with the Company will not be affected in any way.

Employees in supervisory positions have a responsibility for managing other employees and in doing so must exercise particular care in performing their role. They must ensure that this responsibility is not abused by actual or apparent harassment or discrimination of any employee under their control. Supervisors may not instruct a member of staff, or bring pressure to bear on them, to discriminate against, victimise or harass another individual. Nor may they suppress any complaint of discrimination or victimisation or harassment. The Company will regard any such conduct as gross misconduct.

Making a Complaint

If you feel that you have been the subject of discrimination, harassment, or victimisation, the Company will treat your concern seriously and sensitively. In such circumstances, you should adhere to the procedure set out below.

Informal Resolution

You should in the first instance address your concern to the person you believe is discriminating against, harassing or victimising you. Tell them, in writing or verbally, that you find their conduct unacceptable. If you feel unable to approach the person directly or, having attempted to address the issue with the person, there has been no change in their behaviour or conduct then you should contact your manager. You should contact a director if you feel uncomfortable raising the matter with your manager. If the matter cannot be dealt with informally to your satisfaction, you can raise a formal complaint following the procedure below.

Formal Resolution

You may make a formal complaint in writing to your manager, or if you feel uncomfortable doing this, you should put it in writing to a director. Your complaint should set out the following details:

• The name of the person about whom you are complaining.
• The nature of the conduct/inappropriate behaviour.
• Date and time of when the incident(s) occurred.
• Name(s) of any witness(es) to the incident(s).
• Any action already taken by you to stop the inappropriate behaviour.

A meeting will be arranged within seven days, wherever possible, of receiving the complaint to discuss your complaint and how it should be dealt with. You may be accompanied to the meeting by a Company employee or trade union representative.

Any contact made with your manager, or a director if applicable, will be treated in confidence in the first instance. Subject to you then giving your consent for the matter to be disclosed to relevant individuals, a full and thorough investigation will be carried out. If you do not want to be involved or do not consent to the matter being disclosed to relevant individuals, depending on the circumstances of the matter, the Company will still have an obligation to carry out an investigation and take appropriate action, but the extent to which this can be done may be restricted.

You will be advised of the outcome of the investigation.

If it is appropriate for the employee to be subject to disciplinary proceedings you will be notified of this, although for reasons of confidentiality for the employee concerned, you will not be made aware of the outcome of the proceedings.

If the Company’s Disciplinary Procedure is formally invoked against your alleged harasser, your complaints will be investigated with due consideration to your feelings and concerns. Provided you are acting in good faith and with good reason, the fact that you have made an allegation against another member of staff will not affect your position within the Company.

In certain circumstances it may be necessary for either the employee making the allegation, or the person being accused, to stay at home on special paid leave whilst investigations are being conducted, or the appropriate procedure followed.

If you make a complaint of harassment, you will not be victimised for doing so. Should any victimisation take place, then the perpetrator will be dealt with under the Company’s Disciplinary Procedure. However, if you maliciously or falsely make a claim of victimisation or harassment, you will be subject to the Company’s Disciplinary Procedure, which may result in your dismissal.

Raising a Complaint of Harassment by a Third Party

If you feel that you are being harassed by someone external to the Company, for example a customer or supplier, you should bring this to your manager’s immediate attention.

The Company will deal with all such allegations seriously and take reasonable steps to prevent it from occurring again.