EDI Policy

Equality, Diversity and Inclusion Policy



FBA/Mall Galleries is committed to providing equal opportunities in employment and to avoiding unlawful discrimination.

This policy is intended to assist FBA/Mall Galleries with putting this commitment into practice. Compliance with this policy should also ensure that employees do not commit unlawful acts of discrimination.


This policy applies to all employees (whether full-time, part-time, fixed-term or permanent) and to job applicants, volunteers, contractors and agency workers.

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FBA/Mall Galleries’ policy is to comply with both the spirit and the letter of the law on equality and discrimination and we do not tolerate any form of discrimination or harassment.

Our commitment to equal opportunities is enhanced by the belief that creating a diverse and inclusive workplace brings many benefits for the organisation over and above legal compliance including:

  • increased creativity

  • better decision making

  • faster problem solving

  • retention of employees

  • attracting top talent

  • higher employee wellbeing

  • enhanced employee engagement

  • better reputation for the organisation

Staff responsibilities

Every staff member, worker and volunteer is required to assist us to meet the commitment to provide equal opportunities in employment and avoid unlawful discrimination. Individuals can be held personally liable as well as, or instead of, FBA/Mall Galleries for any act of unlawful discrimination. People who commit serious acts of harassment may be guilty of a criminal offence.

Acts of discrimination, harassment, bullying or victimisation against staff, workers, volunteers or service users are disciplinary offences and will be dealt with under the disciplinary procedure. Discrimination, harassment, bullying or victimisation may constitute gross misconduct and could lead to dismissal without notice.

The Law

It is unlawful to discriminate directly or indirectly in recruitment or employment because of "protected characteristics” which are:

  • Age
  • Disability
  • Sex
  • Gender reassigment
  • Pregnancy or maternity
  • Race (which includes colour, nationality, and ethnic or national origins)
  • Sexual orientation
  • Religion or belief
  • Marriage or civil partnership

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

It is unlawful to discriminate against or harass a member of the public or service user in the provision of services or goods or fail to make reasonable adjustments.

Examples of reasonable adjustments could include:

  • Changing the recruitment process so that a candidate can be considered for a job
  • Providing a special keyboard for someone with arthiritis
  • Allowing staff who become disabled a phased return to work

Types of Unlawful Discrimination

Direct discrimination

Treating someone with a protected characteristic less favourably than others

Indirect discrimination

Putting rules or arrangements in place that apply to everyone, but that put someone with a protected characteristic at an unfair disadvantage


Unwanted behaviour linked to a protected characteristic that violates someone’s dignity or creates an offensive environment for them

Associative discrimination

Where an individual is directly discriminated against or harassed because of their association with another individual who has a protected characteristic (although it does not cover harassment because of marriage and civil partnership, and, according to guidance from the Government and ACAS, pregnancy and maternity)

Perceptive discrimination

Where an individual is directly discriminated against or harassed based on a perception that they have a protected characteristic when they do not have that protected characteristic (other than marriage and civil partnership, and pregnancy and maternity)

Third-party harassment

Where an individual is harassed and the harassment is related to a protected characteristic (other than marriage and civil partnership, and pregnancy and maternity), by third parties such as service users


Treating someone unfairly because they’ve complained about discrimination or harassment

Failure to make reasonable adjustments

Where a reasonable adjustment hasn’t been made which puts a disabled person at a substantial disadvantage compared with someone who does not have that protected characteristic

Equal Opportunities in Employment

FBA/Mall Galleries will avoid unlawful discrimination in all aspects of employment including recruitment, promotion, opportunities for training, pay and benefits, discipline and selection for redundancy.


  • Person and job specifications will be limited to those requirements that are necessary for the effective performance of the job

  • Candidates for employment or promotion will be assessed objectively against the requirements for the job, taking account of any reasonable adjustments that may be required for candidates with a disability

  • Disability and personal or home commitments will not form the basis of employment decisions except where necessary

Working practices

  • If you request a change to your working hours we will take account of any needs that you have as a result of a disability

  • We will refuse such requests only if we consider we have good reasons, unrelated to any protected characteristic, for doing so

  • We will comply with our obligations in relation to statutory requests for changes to your hours

  • We will also make reasonable adjustments to our standard working practices to overcome barriers caused by disability


FBA/Mall Galleries respect and value staff as individuals, providing support and commitment so that everyone has a sense of belonging and is able to achieve their best.

All employees have a personal responsibility to treat colleagues, Board members, contractors, applicants, visitors, volunteers and members of the public in accordance with our Equality, Diversity and Inclusion policy and Code of Conduct.

In our employment practices and in providing services, we expect all employees to:

  • Support a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued

  • Act fairly and provide equality of opportunity

  • Recognise that everyone is different and that these differences must be equally respected

  • Be aware that you must not treat people less favourably because of a protected characteristic

  • Challenge discrimination so that we demonstrate our commitment to equality and diversity and do not exclude people or make them feel isolated

  • Not unlawfully discriminate, for example, as staff responsible for decisions on recruitment, selection, promotion or transfer

  • Not induce or attempt to induce others to practice discrimination, nor yield to pressure from others to discriminate

  • Not victimise or attempt to victimise individuals on the grounds that they have made complaints under the Equality Act or provided information about discrimination

  • Not harass, abuse or intimidate other employees, member organisations, partners etc; where employees commit such action they will be liable to disciplinary action

  • Draw to the attention of management apparent breaches of this Code of Practice

  • Line Managers and supervisors have a particular responsibility for ensuring that staff act appropriately

Dignity at Work

We uphold a dignity at work policy concerning issues of bullying and harassment on any ground, and how complaints of this type will be dealt with.

This includes the FBA Art Society Members and artists, Mall Galleries Friends, visitors, suppliers and other people not employed by FBA/Mall Galleries.

We will not discriminate unlawfully against art society members, Mall Galleries Friends or visitors to FBA/Mall Galleries.

You should report any bullying or harassment by art society members, Mall Galleries Friends, suppliers, visitors or others to your manager who will take appropriate action.


We will raise awareness of equal opportunities to managers and others likely to be involved in recruitment or other decision making where equal opportunities issues are likely to arise.

We will raise awareness of all existing and new employees and others engaged to work at FBA/Mall Galleries to help them understand their rights and responsibilities under the dignity at work policy and what they can do to help create a working environment free of bullying and harassment. We will provide additional training to managers to enable them to deal more effectively with complaints of bullying and harassment.


If you consider that you may have been unlawfully discriminated against, you should use our grievance procedure to make a complaint.

We will take any complaint seriously and will seek to resolve any grievance that it upholds. You will not be penalised for raising a grievance, even if your grievance is not upheld, unless your complaint is both untrue and made in bad faith.

Monitoring and review

This policy will be monitored periodically by FBA/Mall Galleries to judge its effectiveness and will be updated in accordance with changes in the law. In particular, we will monitor the ethnic and gender composition of the existing workforce and of applicants for jobs (including promotion), and the number of people with disabilities within these groups, and will review our equal opportunities policy in accordance with the results shown by the monitoring. If changes are required, we will implement them.

Information provided by job applicants and employees for monitoring purposes will be used only for these purposes and will be dealt with in accordance with relevant data protection legislation.

This is a non-contractual procedure which will be reviewed from time to time.


FBA/August 2023

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