Version 2.1 – September 2025

1. Introduction

Zuno OpCo Limited (CRN: 08086606) whose registered office address is at 3320 Century Way, Thorpe Park, Leeds LS15 8ZB (“Zuno”) is committed to promoting equality, diversity and inclusion (“EDI”) within the workplace and in all interactions with subcontractors. Zuno seeks to eliminate unlawful discrimination, harassment, and victimisation while fostering an inclusive environment.

This Policy complies with Zuno’s obligations under the Equality Act 2010 (“EA 2010”) and follows recommendations from the Equality and Human Rights Commission (“EHRC”) Employment Code of Practice.

Zuno is committed to ensuring that equality principles extend beyond direct employees, reaching all subcontractors engaged on its behalf.

2. Purpose

The purpose of this Policy is to:

2.1 reaffirm Zuno’s ongoing commitment to equality, diversity, and inclusion in all aspects of its operations;

2.2 establish fair and inclusive practices for Zuno’s employees and subcontractors; and

2.3 detail the procedures and responsibilities aimed at eliminating unlawful discrimination under the EA 2010.

3. Scope of Application

This Policy applies to:

All employees (including full-time, part-time, fixed-term, temporary, and agency workers).

Volunteers, interns, apprentices, and job applicants.

Subcontractors, suppliers, and all third-party agents engaged by Zuno.

All individuals and entities within this scope are expected to uphold the principles outlined in this Policy.

4. Protected Characteristics

Zuno is committed to eliminating discrimination and promoting equality in relation to the following protected characteristics, as defined in the Equality Act 2010:

Age

Disability

Gender reassignment

Marriage or civil partnership

Pregnancy and maternity

Race (including colour, nationality, or ethnic or national origin)

Religion or belief

Sex

Sexual orientation

5. Policy Commitments

5.1 Zuno’s Responsibilities

Zuno will:

Ensure compliance with all obligations under the Equality Act 2010 and any applicable statutory codes of practice.

Apply equality principles in its recruitment, selection, training, promotion, and employment practices.

Make reasonable adjustments to support employees and subcontractors with disabilities, as required by law.

Establish and implement clear procedures for addressing any breaches of this Policy.

Monitor and evaluate the effectiveness of this Policy regularly and amend it as necessary to ensure ongoing compliance.

5.2 Employee and Subcontractor Responsibilities

All employees and subcontractors will:

Promote equality and diversity in the workplace and in all dealings with colleagues, clients, and third parties.

Avoid behaviour that amounts to unlawful discrimination, harassment, or victimisation.

Ensure adherence to this Policy and report any witnessed breaches in a timely manner.

Subcontractors are additionally required to ensure that any personnel or representatives working on behalf of Zuno comply with this Policy.

6. Positive Action

Zuno reserves the right to implement lawful positive action measures aimed at addressing underrepresentation or disadvantage experienced by individuals with protected characteristics. Actions will be in accordance with Sections 158 and 159 of the EA 2010 and may include targeted recruitment initiatives, development programmes, or additional support mechanisms where appropriate.

7. Grievance and Complaint Procedures

7.1 For Employees

Employees who believe they have been subjected to unlawful discrimination, harassment, or victimisation can raise their concerns through Zuno’s HR Department or Whistleblowing process. Concerns will be handled confidentially and resolved promptly.

7.2 For Subcontractors

Subcontractors who suspect a breach of this Policy must escalate concerns to the designated point of contact in the HR Department. Misconduct will be investigated under the relevant contractual terms, and appropriate remedies will be applied where breaches are established.

Zuno will ensure that all complaints are investigated thoroughly, treated in confidence, and resolved without retribution.

8. Monitoring, Reporting, and Review

8.1 Equality Monitoring

Zuno will collect and monitor data to ensure compliance with this policy. This data will be anonymised, and all processing will comply with the UK GDPR and Data Protection Act 2018.

8.2 Regular Review

The Policy will be reviewed annually to reflect any changes in legislation, best practices, or operational needs. Updates will be communicated to all employees and subcontractors via email or the Zuno App.

8.3 Subcontractor Monitoring

Zuno will require all subcontractors to provide evidence of compliance with equality obligations. Monitoring mechanisms may include spot checks, audits, and periodic compliance reports.

9. Additional Requirements for Subcontractors

Subcontractors engaged by Zuno must adopt and adhere to equality policies that align with the principles set forth in this Policy. Additionally, subcontractors shall:

Include equality and non-discrimination clauses in their employment and operational policies.

Provide regular training on equality and diversity to their workforce.

Permit Zuno to audit compliance as part of subcontracting arrangements.

Failure to comply with these requirements may lead to contract termination or other appropriate remedies pursuant to the subcontract agreement.

10. Data Protection Compliance

Equality monitoring and data collection will adhere strictly to the requirements under the UK GDPR and the Data Protection Act 2018. Information collected for monitoring purposes will be processed lawfully, fairly, and transparently, limited solely to the purposes outlined in this policy.

11. Training Obligations

Zuno will provide regular training for employees on:

Recognising and preventing discrimination, harassment, and victimisation.

Implementing inclusive practices in line with this policy.

Understanding the specific responsibilities under the Equality Act 2010.

12. Definitions

Discrimination: Treating an individual unfairly because of a protected characteristic as defined above.

Harassment: Unwanted conduct related to a protected characteristic that creates an intimidating, degrading, or hostile environment.

Victimisation: Detriment caused to someone for asserting their rights under equality law, such as making a complaint or supporting a complaint of discrimination.

13. Implementation and Communication

This Policy will be communicated to all employees and subcontractors upon adoption and during onboarding processes. Managers are responsible for ensuring compliance within their teams and subcontracting arrangements.

This Equality Policy serves as a key document to uphold principles of fairness and to ensure compliance with legal and ethical obligations under the EA 2010.