Nexus Spark GroupPolicy Owner: Directors, Nexus Spark Group
Effective Date: 1st October 2026
Review Date: 1st October 2027
1. Policy Statement
Nexus Spark Group is committed to promoting equality of opportunity, diversity, inclusion and fair treatment in all aspects of its business.
As a recruitment business and employer, Nexus Spark Group is committed to ensuring that employees, workers, candidates, contractors, clients, suppliers and other individuals with whom we interact are treated fairly, with dignity and respect.
We will not unlawfully discriminate against any person and will seek to ensure that recruitment, selection, employment and business decisions are based on objective and relevant criteria.
This policy reflects our obligations under the Human Rights Act 1998, the Equality Act 2010, and other applicable UK employment and equality legislation.
2. Scope
This policy applies to:
- All employees and directors of Nexus Spark Group.
- Temporary workers, contractors and consultants engaged by Nexus Spark Group.
- Candidates and prospective candidates.
- Applicants for employment within Nexus Spark Group.
- Clients and prospective clients.
- Suppliers and other third parties working with Nexus Spark Group.
- Any individual involved in a recruitment or selection process managed or supported by Nexus Spark Group.
The principles of this policy apply throughout the recruitment lifecycle, including advertising, sourcing, candidate attraction, screening, shortlisting, interviewing, assessment, selection, offer management and placement.
They also apply to Nexus Spark Group’s own employment practices, including recruitment, pay, training, promotion, development, performance management and termination of employment.
3. Legal Framework
Nexus Spark Group will operate in accordance with applicable equality and human rights legislation, including:
- The Human Rights Act 1998.
- The Equality Act 2010 and subsequent amendments.
- Relevant employment legislation and statutory codes of practice.
The Human Rights Act 1998 incorporates rights derived from the European Convention on Human Rights into UK law. Nexus Spark Group supports the underlying principles of dignity, fairness, respect and equal treatment reflected in those rights.
Under the Equality Act 2010, it is unlawful to discriminate against an individual because of a protected characteristic.
4. Protected Characteristics
Nexus Spark Group will not unlawfully discriminate on the grounds of any of the protected characteristics recognised by the Equality Act 2010:
- Age.
- Disability.
- Gender reassignment.
- Marriage and civil partnership.
- Pregnancy and maternity.
- Race, including colour, nationality and ethnic or national origin.
- Religion or belief.
- Sex.
- Sexual orientation.
Nexus Spark Group is committed to fair treatment regardless of whether an individual possesses a protected characteristic themselves or, where protected by law, is associated with someone who does or is perceived to possess one.
5. Forms of Discrimination
Nexus Spark Group will not tolerate unlawful discrimination, harassment or victimisation.
This includes:
Direct discrimination – treating someone less favourably because of a protected characteristic.
Indirect discrimination – applying a provision, criterion or practice that places people sharing a protected characteristic at a particular disadvantage and which cannot be objectively justified.
Harassment – unwanted conduct related to a protected characteristic that has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.
Victimisation – subjecting someone to a detriment because they have undertaken, or are believed to have undertaken, a protected act under equality legislation, such as raising a discrimination complaint.
Discrimination arising from disability – treating a disabled person unfavourably because of something arising in consequence of their disability where the treatment cannot be objectively justified.
Nexus Spark Group will also comply with its legal obligations to make reasonable adjustments for disabled people where applicable.
6. Recruitment and Selection
As a recruitment business, Nexus Spark Group recognises that equal opportunities principles are fundamental to the services we provide.
We will endeavour to ensure that:
- Job advertisements and candidate communications do not unlawfully discriminate.
- Candidate searches and sourcing strategies are based on legitimate requirements of the role.
- Candidates are assessed against objective criteria relating to their skills, experience, qualifications, capability and suitability for the role.
- Shortlisting and selection decisions are not influenced by unlawful discriminatory considerations.
- Candidates are not excluded from opportunities because of a protected characteristic unless a lawful exception applies.
- Reasonable adjustments are considered and made where required to enable disabled candidates to participate fairly in recruitment and selection processes.
- Recruitment records and decisions are handled professionally, consistently and appropriately.
- Clients are encouraged to follow fair and non-discriminatory recruitment practices.
Nexus Spark Group will not knowingly act upon a client’s instruction to discriminate unlawfully against an individual or group of individuals.
Where a client makes a request that appears discriminatory, Nexus Spark Group will challenge or seek clarification of that request and will not implement an unlawful instruction.
Any occupational requirement relating to a protected characteristic will only be considered where it is lawful, genuinely relevant to the role and capable of being objectively justified under applicable legislation.
7. Client Responsibilities
Nexus Spark Group expects clients using its recruitment services to support fair and lawful recruitment practices.
Clients should provide role requirements that are based upon legitimate business and occupational needs.
Where Nexus Spark Group believes that a job specification, candidate requirement, selection criterion or hiring decision may create an unlawful discriminatory effect, we may raise this with the client and recommend an alternative approach.
Nexus Spark Group reserves the right to decline or withdraw from an assignment where complying with a client’s instruction would, or could reasonably be considered to, result in unlawful discrimination.
8. Equal Opportunities Within Nexus Spark Group
Nexus Spark Group will apply the same principles to its own workforce.
Decisions concerning recruitment, employment, remuneration, training, promotion, development, performance and termination will be based on legitimate business requirements, individual capability and performance rather than unlawful discriminatory factors.
Employees will be provided with equal access to appropriate opportunities for development and progression, subject to legitimate business and performance considerations.
9. Disability and Reasonable Adjustments
Nexus Spark Group is committed to removing or reducing disadvantages experienced by disabled individuals.
Where required by law, reasonable adjustments will be considered in relation to recruitment, employment and the provision of our recruitment services.
Candidates and employees are encouraged to inform Nexus Spark Group where an adjustment may assist them in participating fully in a recruitment, assessment or employment process.
Requests will be considered individually, sensitively and confidentially where appropriate.
10. Dignity and Respect
Everyone covered by this policy is expected to treat colleagues, candidates, clients and other individuals with dignity and respect.
Bullying, harassment, discriminatory language, inappropriate behaviour or conduct that undermines these principles will not be tolerated.
This applies to conduct taking place in person, remotely, online, through email, telephone, social media, messaging platforms or any other business communication channel.
11. Complaints and Concerns
Any employee, candidate or other person who believes that they have been subjected to discrimination, harassment, victimisation or other treatment contrary to this policy is encouraged to raise the matter with a Director of Nexus Spark Group.
Concerns will be taken seriously and handled fairly, sensitively and, where reasonably possible, confidentially.
No individual should suffer retaliation or detrimental treatment for raising a genuine concern about discrimination or equal opportunities in good faith.
Where an allegation concerns an employee or representative of Nexus Spark Group, appropriate investigation and action will be considered.
12. Responsibilities
The Directors of Nexus Spark Group have overall responsibility for the implementation and review of this policy.
Everyone working for or representing Nexus Spark Group has a responsibility to:
- Understand and comply with this policy.
- Treat individuals fairly and respectfully.
- Avoid discriminatory conduct or decision-making.
- Raise concerns where they become aware of potentially discriminatory practices.
- Support an inclusive and professional working and recruitment environment.
Breaches of this policy by employees may be dealt with under the appropriate disciplinary procedures and serious breaches may constitute gross misconduct.
13. Monitoring
Nexus Spark Group will periodically review its recruitment and employment practices to ensure that they remain consistent with this policy and applicable legislation.
Where appropriate and lawful, Nexus Spark Group may use information or feedback to identify potential barriers to equality of opportunity and improve its recruitment processes.
Any equality monitoring information collected will be handled appropriately and in accordance with applicable data protection legislation.
14. Positive Action
Where permitted by the Equality Act 2010, Nexus Spark Group may support lawful and proportionate positive action designed to address disadvantage, meet particular needs or encourage participation by groups that are disproportionately underrepresented.
Positive action will not be used as a basis for unlawful positive discrimination.
15. Policy Review
This policy will be reviewed at least annually and earlier where there are significant changes to relevant legislation, regulatory guidance or Nexus Spark Group’s business activities.
The Directors are responsible for approving material amendments to this policy.