1. Introduction

1.1 Comma Press is committed to encouraging and achieving a working environment which is underpinned by fairness to all individuals – be they employees, artists/writers, or audiences - where equality and diversity is recognised, encouraged and valued, and the concept of individual responsibility is accepted by all.

1.2 It is unlawful to discriminate directly or indirectly in recruitment or employment on grounds of sex, gender history or gender reassignment, pregnancy, age, race, nationality, ethnic or national origin, sexual orientation, religion or belief, or because someone is married or is a civil partner. It is also unlawful to discriminate unjustifiably on grounds of disability or to fail to make reasonable adjustments to overcome barriers to employment caused by disability.

1.3 Legal enactments

1.3.1 A person may complain of being harassed and or unfairly treated under UK and EU legislation. The following are the relevant statutes:

European legislation:
• The Equal Pay Directive 1975
• The Equal Treatment Directive 1976
• The Part-time Work Directive 1997
• The Fixed term Work Directive 1999
• The Race and Ethnicity Directive 2000
• The Equal Treatment Framework Directive 2000
• The Equal Treatment (Amendment) Directive 2002

United Kingdom legislation:
[From 1 October 2010, The Equality Act 2010 will distil and extend existing discrimination legislation (marked * below) in order to harmonise the UK legal framework for preventing discrimination.]
• The Equal Pay Act 1970 (as amended)*
• The Sex Discrimination Act 1975 (as amended)*
• The Race Relations Act 1976 (as amended)*
• The Disability Discrimination Act 1995 (as amended)*
• The Employment Rights Act 1996
• The Gender Re-assignment Regulations 1999
• The Part-time Work Regulations 2000
• The Employment Act 2002
• The Fixed-time Work Regulations 2002
• The Employment Equality (Sexual Orientation) Regulations 2003*
• The Employment Equality (Religion or Belief) Regulations 2003*
• The Employment Equality (Age) Regulations 2006*
• The Work and Families Act 2006
• The Equality Act 2006*
• The Equality Act (Sexual Orientation) Regulations 2007*

2. Purpose

2.1 Comma Press is committed to eliminating discrimination and encouraging diversity amongst our workforce and the artists with we work with. Our aim is that each employee or artist feels respected and able to give of their best. To that end the purpose of this policy is to provide equality and fairness, and not to discriminate on grounds of gender, marital status, race, ethnic origin, nationality, national origin, disability, sexual orientation, religion or age. We oppose all forms of unlawful and unfair discrimination.

2.2 This policy aims to promote an inclusive culture and working environment where:
• The diversity of all employees and artists is respected and valued
• All employees and artists have the opportunity to receive fair treatment in an environment free from discrimination and harassment
• Opportunities for promotion, training, and continued employment are provided to all staff based on merit and ability in relation their role.
• No employee or job applicant shall be disadvantaged by requirements that cannot be shown to be relevant to the job they applied for or hold.
• All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the organisation.
• No form of intimidation, bullying or harassment will be tolerated.

3. Scope

3.1 This procedure applies to all employees of Comma Press, and all individuals it works with (be they writers or artists).

3.2 This policy applies to all aspects of employment from the advertisement of jobs, recruitment, terms and conditions of employment, commissions, career development, counselling, training, promotion, grievance and disciplinary procedures, through to reasons for termination of employment.

4. Responsibilities

4.1 Comma Press is responsible for maintaining fair, consistent and objective procedures for matters relating to equality of opportunity and diversity and for ensuring that employees are appropriately trained.

4.2 The Managing Editor has overall responsibility for the internal organisation, control and management of the policy. This includes responsibility for the collation and retention of the records necessary to enable the organization to have in place an effective monitoring system:
• Managing her/his employees in a way which is consistent with this policy
• Setting a good example and ensuring all employees understand the standards expected from them.
• Following agreed procedures.
• Dealing firmly with breaches in accordance with Comma Press’ disciplinary policy.

4.3 All employees are responsible for:
• Co-operating with any measures introduced by the organisation in relation to equal opportunities
• Treating colleagues and others (including authors, artists, contractors, audiences, etc) with respect and in ways which are consistent with this policy
• Challenging and reporting breaches.

5. Monitoring of Equal Opportunities

5.1 Comma Press will conduct regular surveys of the writers/artists it works with.

5.2 All information collected will remain strictly confidential. Records will be kept in a format which enables analysis to be made of the numbers of:
• gender
• disability
• nationality
• ethnic origin
• religion or belief
• sexual orientation
• age

5.3 These analyses will be provided on a bi-annual basis to the Comma Press board of Directors for identification of trends and any remedial action.

5.4 By monitoring the various areas above Comma Press can check and review whether current recruitment, promotion, training and general employment practices are reaching and protecting the full range of possible candidates and help to guard employees against any potential for discrimination.

6. Discrimination and Harassment

6.1 Comma Press will not tolerate any form of discrimination or harassment, by or against its employees.

7. Review

7.1 This policy will be reviewed by the board of directors every two years.

(Updated January 2011)