Date: October 2025
Review Date: October 2026
Coordinator: Kirsten Roy
Nominated Governor: Vicki May
Version: v10.25

Refreshed for Worker Protection Act 2024 — signed off April 2026

This policy was refreshed on 2026-04-29 to align with the Worker Protection (Amendment of Equality Act 2010) Act 2023 — in force from 26 October 2024 — which places a preventive duty on employers to take reasonable steps to prevent sexual harassment of employees, including by third parties. Tribunals can uplift compensation by up to 25% where the duty has been breached. The refresh also touches Equality Act 2010, KCSIE 2025, and ACAS Code of Practice 2023.

Status: live — signed off 29 April 2026 by Proprietor and Governing Body.

Policy Statement and Purpose

The Haven is committed to eliminating discrimination, advancing equality of opportunity, and fostering positive relations across all parts of our hybrid learning community. We honour the equal worth of every learner, staff member, family, and partner, and we place diversity, inclusion, and anti-racism at the heart of our safeguarding culture.

This policy brings together our statutory duties under the Equality Act 2010, the Human Rights Act 1998, the Children Acts 1989 and 2004, and the UN Convention on the Rights of the Child. It should be read alongside The Haven’s Safeguarding Policy, Behaviour and Regulation Policy v10.25 and Staff Conduct Policy v10.25.

1. Guiding Principles

We are guided by the following principles:

  1. All are of equal value — regardless of disability, ethnicity, culture, gender identity, religion or belief, sexual identity, age, or socioeconomic background.

  2. We recognise and respect difference — equity may require differentiated approaches, not “sameness.”

  3. We foster positive attitudes and belonging — by promoting anti-racism, disability inclusion, gender equity, neurodiversity affirmation, and LGBTQ+ respect.

  4. We uphold fair practice in staff recruitment and development — ensuring equity of access, progression, and training.

  5. We reduce and remove barriers — by proactively identifying inequalities and making reasonable adjustments.

  6. We consult and involve widely — valuing the voices of learners, families, and staff in shaping provision.

  7. We contribute to wider society — supporting learners to challenge prejudice and contribute positively in their communities.

  8. We use evidence — equality monitoring data informs practice and objectives.

  9. We set measurable objectives — integrated into school improvement planning and reviewed annually.

2. Equalities in The Haven Context

Online Accessibility: All materials are designed to be screen-reader compatible, dyslexia-friendly, and accessible across devices.

Neurodivergent Support: Flexible timetables, sensory-aware teaching, and options for cameras/microphones off when regulation is needed.

Gender & Biological Health: Affirming spaces for menstruation, PCOS, and hormonal health discussions.

Anti-Racism as Safeguarding: Racism is recognised as harm; we maintain clear reporting, restorative response, and termly incident review.

Digital Equity: Support for families experiencing digital poverty, ensuring fair access to provision.

3. Curriculum, Ethos, and Organisation

● Teaching reflects diversity, avoids stereotypes, and challenges prejudice.

● Online resources and groupings are inclusive by design, with respect for pronouns, names, and cultural references.

● Staff model inclusive digital communication (e.g. accessible fonts, captions in live lessons).

4. Roles and Responsibilities

Head/DSL: Oversees implementation, ensures training, and takes action on discrimination.

All Staff: Expected to model inclusive practice, challenge prejudice, and make reasonable adjustments.

Governors: Monitor equality objectives and hold leadership accountable.

Learners and Families: Encouraged to share experiences to shape more inclusive practice.

4a. Preventive Duty — Worker Protection Act 2024

The Worker Protection (Amendment of Equality Act 2010) Act 2023, in force from 26 October 2024, places a positive duty on employers to take reasonable steps to prevent sexual harassment of employees, including by third parties (commissioners, parent carers, contractors, suppliers, and any other person the employee comes into contact with in the course of work).

The Haven discharges this duty through the following structural commitments:

  • Risk assessment. Sexual harassment risk is assessed annually as part of safeguarding governance, with attention to high-risk contexts (online sessions, lone working, in-person meetings, learner-facing roles, and contractor interactions).
  • Clear reporting routes. Staff can report harassment to the Kirsten Roy, Kirsten Roy, or directly to the Cathy Wassell or Vicki May where the concern is about senior staff. Anonymous reporting is supported.
  • Third-party scope. The duty extends to harassment by parent carers, commissioners, contractors and any other third parties; this is named explicitly in onboarding for staff and addressed in commissioner agreements.
  • No retaliation. Reporting harassment in good faith is protected; retaliation is itself a disciplinary matter.
  • Visible action. Reports are recorded, investigated, and reviewed termly by the Kirsten Roy and Vicki May. Anonymised patterns inform CPD and risk-assessment updates.
  • Training. Annual training covers what constitutes sexual harassment, the reasonable steps standard, intersectionality (especially for racialised and disabled staff), and active bystander practice.

Tribunals can uplift compensation by up to 25% where the preventive duty has been breached. The Haven’s standard is to act ahead of breach, not in response to one.

This duty operates alongside the existing prohibition of discrimination and harassment under the Equality Act 2010, and it does not displace the safeguarding-first response to harassment that involves children or learners (see Child Protection and Safeguarding Policy v01.26 and Managing Allegations Against Staff Policy v01.26).

5. Addressing Prejudice and Discrimination

● Zero tolerance for discrimination, harassment, or bullying, including racism, sexism, ableism, homophobia, transphobia, or xenophobia.

● Incidents are recorded, reviewed termly, and addressed through restorative approaches in line with The Haven’s Behaviour and Regulation Policy v10.25.

Equal Opportunities, Equality & Diversity Policy — Addendum (October 2025)

This addendum incorporates local authority feedback to clarify The Haven’s procedures for feedback, safeguarding, incident response, and inclusive curriculum review.
It should be read in conjunction with The Haven’s Child Protection and Safeguarding Policy v01.26, Behaviour and Regulation Policy v10.25, and Staff Code of Conduct.

🔹 1. Inclusive Curriculum Feedback and Review

The Haven’s curriculum is designed to be reflective, adaptive, and learner-informed, ensuring that all students see themselves represented and respected.

Feedback and review mechanisms include:

  • Termly student voice surveys and focus groups exploring how identity, belonging, and inclusion are reflected in the curriculum.

  • A “Living Curriculum Review” each term, led by the Curriculum and Inclusion Leads, analysing feedback from students, parent-carers, and staff.

  • Opportunities for learners to co-design content or resources that reflect their lived experiences, particularly around race, gender, disability, neurodiversity, and culture.

  • Integration of findings into curriculum planning, enrichment activities, and PSHE/Wellbeing themes.

All feedback loops are overseen by the DSL and Inclusion Lead, who ensure responses are logged and acted upon.

The Haven maintains connections with specialist organisations that provide additional support following incidents of discrimination or harm, including:

  • The Children’s Society – support following hate crime, bullying, or online harm

  • Young Minds – emotional wellbeing and mental health advocacy

  • Black Minds Matter UK, MindOut, and Galop – specialist identity-based mental health support

  • The Anne Frank Trust – anti-racism and social action programmes

  • NSPCC and Childline – 24-hour advice for young people affected by discrimination or abuse

Following an incident, learners may be referred or signposted to appropriate support services. Where emotional or identity-based harm has occurred, The Haven arranges restorative or reflective sessions with trained staff and offers parent/carer liaison where appropriate.

🔹 3. Protocols for Addressing Discrimination, Harassment and Bullying

All discriminatory incidents, whether online or in-person, are treated as safeguarding matters.

Step 1: Immediate Response

  • If an incident occurs in a live lesson, the tutor intervenes immediately using calm, restorative language.

  • If safety or dignity is compromised, the learner responsible is temporarily removed from the session while the situation is reviewed by the DSL.

  • The DSL and Behaviour Lead are alerted via an Incident Report Form.

Step 2: Safeguarding Oversight

  • The DSL determines whether the behaviour constitutes a safeguarding, hate, or bullying incident and records it accordingly.

  • Victims are offered safe-space support and the opportunity to meet with a trusted adult before rejoining class sessions.

Step 3: Restorative and Disciplinary Action

  • A Restorative Reflection Meeting is held with all parties involved, facilitated by pastoral staff.

  • Persistent or serious incidents result in referral to the commissioner and may trigger multi-agency involvement.**

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🔹 4. Digital Safety and Communication Controls

The Haven’s hybrid model includes digital platforms such as Pencil Spaces, Google Workspace, and Discord (moderated). The following controls are in place:

AreaControl Measures
Chat functionsModerated by staff during lessons; inappropriate messages can be deleted or muted immediately.
Lesson monitoringAll sessions are recorded; chat transcripts are reviewable by the DSL or senior leadership team if concerns arise.
Automated safety filtersKey words or offensive content are flagged to staff for review in real time.

Any incident detected in these digital environments triggers the same safeguarding reporting and restorative protocols as in-person harm.

🔹 5. Staff Training and Professional Development

All staff receive annual equality, diversity, and anti-racism training, including:

  • Understanding discrimination, microaggressions, and structural bias

  • Responding to online harm and hate speech

  • Inclusive language and cultural competency

  • Restorative practice and trauma-informed de-escalation

  • Embedding equality and inclusion across digital and curriculum design

Training is delivered through The Haven’s termly safeguarding CPD programme and is reviewed annually to incorporate feedback from staff and learners.

🔹 6. Immediate Aftermath and Ongoing Review

Following any incident of discrimination, harassment, or bullying:

  • The DSL contacts all parties (including parent/carers and commissioners where relevant) within one working day.

  • A support plan is created for affected learners, including referrals or additional mentoring.

  • The incident is analysed during termly safeguarding and inclusion reviews, which inform curriculum updates and tutor CPD.

  • Themes emerging from reviews (e.g. bias in curriculum examples, online behaviour norms) directly shape curriculum planning and digital conduct training.

🔹 7. Embedding Equality and Diversity in Student Induction

Equality and inclusion are introduced from a learner’s first contact with The Haven:

  • All new students and families receive an Inclusive Learning Agreement, explaining The Haven’s zero-tolerance approach to discrimination.

  • Equality and diversity expectations are integrated into co-designed behaviour agreements and online safety inductions.

  • Learners are reminded that The Haven is a place of belonging where everyone has the right to feel safe, valued, and represented.**

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🔹 8. Monitoring and Review

  • Incidents are logged by type (discrimination, harassment, bullying) and reviewed termly by the DSL, Inclusion Lead, and Governing Body.

  • Data informs curriculum improvement, training priorities, and accessibility developments.

  • The policy is reviewed annually, or earlier if national equality guidance or safeguarding legislation changes.**

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