DEI Policy


1. Equal opportunities statement

1.1 CounterCraft Group is committed to promoting equal opportunities in employment. You and any
job applicants will receive equal treatment regardless of age, disability, gender reassignment,
marital or civil partner status, pregnancy or maternity, race, colour, ethnic or national origin,
religion or belief, sex or sexual orientation (Protected Characteristics).

2. About this policy

2.1 This policy sets out our approach to equal opportunities and the avoidance of discrimination at
work. It applies to all aspects of employment with us, including recruitment, pay and conditions,
training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and
termination of employment.
2.2 CounterCraft Directors are responsible for this policy and any necessary training on equal
2.3 This policy does not form part of any employee’s contract of employment and we may amend it
at any time

3. Discrimination

3.1 You must not unlawfully discriminate against or harass other people including current and
former employees, job applicants, clients, customers, suppliers and visitors. This applies in the
workplace, outside the workplace (when dealing with customers, suppliers or other work-related
contacts, and on work-related trips or events including social events).
3.2 The following forms of discrimination are prohibited under this policy and are unlawful:

  • 3.2.1 Direct discrimination: treating someone less favourably because of a Protected
    Characteristic. For example, rejecting a job applicant because of their religious views
    or because they might be gay.
  • 3.2.2 Indirect discrimination: a provision, criterion or practice that applies to everyone but
    adversely affects people with a particular Protected Characteristic more than others,
    and is not justified.
  • 3.2.3 Harassment: this includes sexual harassment and other unwanted conduct related to
    a Protected Characteristic, which has the purpose or effect of violating someone’s
    dignity or creating an intimidating, hostile, degrading, humiliating or offensive
    environment for them. Harassment is dealt with further in our Anti-harassment and
    Bullying Policy.
  • 3.2.4 Victimisation: retaliation against someone who has complained or has supported
    someone else’s complaint about discrimination or harassment.
  • 3.2.5 Disability discrimination: this includes direct and indirect discrimination, any
    unjustified less favourable treatment because of the effects of a disability, and failure
    to make reasonable adjustments to alleviate disadvantages caused by a disability

4. Recruitment and selection

4.1 Recruitment, promotion and other selection exercises such as redundancy selection will be
conducted on the basis of merit, against objective criteria that avoid discrimination. Shortlisting
should be done by more than one person if possible.

4.2 Vacancies should generally be advertised to a diverse section of the labour market.
Advertisements should avoid stereotyping or using wording that may discourage particular
groups from applying.
4.3 Job applicants should not be asked questions which might suggest an intention to discriminate
on grounds of a Protected Characteristic. For example, applicants should not be asked whether
they are pregnant or planning to have children.
4.4 Job applicants should not be asked about health or disability before a job offer is made, except
in the very limited circumstances allowed by law: for example, to check that the applicant could
perform an intrinsic part of the job (taking account of any reasonable adjustments), or to see if
any adjustments might be needed at interview because of a disability. Where necessary, job
offers can be made conditional on a satisfactory medical check. Health or disability questions
may be included in equal opportunities monitoring forms, which must not be used for selection
or decision-making purposes.

5. Disabilities

5.1 If you are disabled or become disabled, we encourage you to tell us about your condition sothat we can consider what reasonable adjustments or support may be appropriate.

6. Part-time and fixed-term work

6.1 Part-time and fixed-term employees should be treated the same as comparable full-time or
permanent employees and enjoy no less favourable terms and conditions (on a pro-rata basis
where appropriate), unless different treatment is justified.7. BREACHES OF THIS POLICY

7. Breaches of this policy

7.1 We take a strict approach to breaches of this policy, which will be dealt with in accordance with
our Disciplinary Procedure. Serious cases of deliberate discrimination may amount to gross
misconduct resulting in dismissal.
7.2 If you believe that you have suffered discrimination you can raise the matter through our
Grievance Procedure or Anti-harassment and Bullying Policy. Complaints will be treated in
confidence and investigated as appropriate.
7.3 You must not be victimised or retaliated against for complaining about discrimination. However,
making a false allegation deliberately and in bad faith will be treated as misconduct and dealt
with under our Disciplinary Procedure.


1. About this policy

1.1 This document sets out certain policies with regards to diversity and inclusion that you will need
to be aware of while working for us. You should familiarise yourself with it and comply with it at
all times. Any questions you may have with regards to its contents or what you have to do to
comply with it should be referred to your line manager or to the Directors of CounterCraft Group.
1.2 The guidelines set out in this policy apply to all employees unless otherwise indicated.
1.3 The Diversity and Inclusion Policy is reviewed regularly to ensure that its provisions continue to
meet our legal obligations and reflect best practice.

2. Purpose of the policy

2.1 We are an equal opportunities employer and do not discriminate on the grounds of gender,
sexual orientation (LGBTQ), marital or civil partner status, pregnancy or maternity, gender
reassignment, race, colour, ethnic or national origin, religion or belief, disability, family
responsibilities, or age.
2.2 The purpose of this Diversity and Inclusion Policy is to promote respect for the law, equality,
and inclusion for our staff in order to avoid any kind of beforementioned type of discrimination.
2.3 Through this Diversity and Inclusion Policy, CounterCraft pursues the following specific
objectives for the whole group:

  • 2.3.1 Encourage broad awareness of the benefits of having a diverse and inclusive
  • 2.3.2 Build a safe and healthy work environment free from any kind of harassment.
  • 2.3.3 Develop inclusive practices and procedures with a focus on diversity.

3. Principles

3.1CounterCraft’s commitment to diversity and inclusion is based on the following principles:

  • 3.1.1 Dignity and respect for all employees. No form of intimidation or harassment will be tolerated.
  • 3.1.2 A solid recruitment process free from discrimination bias.
  • 3.1.3 Equal opportunities in employment.
  • 3.1.4 Gender balance across all levels of the organisation.
  • 3.1.5 Provide employees with the necessary tools to make use of reconciliation measures.
  • 3.1.6 Encourage understanding between cultures and develop a global mentality in the group in order to work effectively within all cultures.
  • 3.1.7 Promote non-sexist and non-discriminatory language or communication.
  • 3.1.8 Reject disrespectful behaviours and promote positive role models
  • 3.1.9 Offer diversity education and inclusion training when necessary

4. How to raise a concern

We hope that in many cases you will be able to raise any concerns with your manager. However,
where you prefer not to raise it with your manager for any reason, you should submit your
concerns through the Whistleblowing Channel on the Intranet, which is managed by the HR
Department or, as a last option, contact any of the Founders of CounterCraft Group (David
Barroso, Daniel Brett, Fernando Braquehais). Contact details are at the end of this policy.
4.2 We will arrange a meeting with you as soon as possible to discuss your concern. You may bring
a colleague or union representative to any meetings under this policy. Your companion must
respect the confidentiality of your disclosure and any subsequent investigation.

5. Group vs. Individual company policies

5.1 The scope of this includes all employees of CounterCraft as a group. However, there may exist
specific policies for each subsidiary. In such cases, policies designed exclusively for
subsidiaries and those governed by local regulations will prevail above all.