Fairness, Inclusion & Respect Policy

Policy Statement

Mac Civils Limited is committed to providing a workplace in which every person is treated fairly, feels included and is shown respect, whether they work in our offices, on our sites or as part of our supply chain. We recognise that the construction and civil engineering industry has historically struggled to attract and retain a diverse workforce, and that a culture which tolerates poor behaviour, exclusion or so-called “banter” damages people, teams and performance. A fair, inclusive and respectful culture is not separate from good health and safety; it is part of it. People who feel valued and able to speak up are more likely to raise concerns, challenge unsafe practices, look after one another and do their best work.

This policy sets out the standards of behaviour we expect from everyone connected with our business, the arrangements we have in place to support them, and how we will measure our progress. It builds on, and should be read alongside, MAC-POL-007 Equal Opportunities & Diversity Policy, which sets out our legal duties in respect of equality and non-discrimination.

Scope

This policy applies to all directors, managers, employees, agency workers, trainees and apprentices of Mac Civils Limited. We also expect our subcontractors, suppliers, consultants and visitors to meet the standards set out in this policy while working on our behalf or on our sites. It covers all work-related settings, including offices, sites, welfare facilities, vehicles, training events, work-related social events and online communication, including messaging groups and social media where it relates to work or colleagues.

What Fairness, Inclusion and Respect Mean to Us

Objectives

• To create and maintain a culture where everyone is treated with dignity and respect, and where bullying, harassment, victimisation and discrimination are not tolerated.
• To ensure fair and transparent processes for recruitment, selection, pay, training, promotion and the allocation of work.
• To remove barriers that may prevent people from joining, staying and progressing in our business, and to attract a workforce that reflects the communities in which we work.
• To provide site welfare facilities, PPE and working arrangements that meet the needs of all people.
• To give everyone the confidence and the means to speak up, and to deal with concerns promptly, fairly and in confidence.
• To promote positive mental health and wellbeing alongside physical health and safety.
• To work with our supply chain to raise standards of fairness, inclusion and respect across our projects.
• To measure, monitor and continually improve our performance against this policy.

Expected Behaviours

Everyone covered by this policy is expected to:

• Treat colleagues, clients, members of the public and supply chain partners with courtesy, dignity and respect.
• Value the contribution of others and include colleagues in conversations, decisions and opportunities.
• Listen to different views and challenge ideas, not people.
• Use language that is professional and appropriate, avoiding comments, nicknames or jokes that could cause offence.
• Speak up, or report it, when they see or experience behaviour that does not meet these standards.
• Support new starters, apprentices and those returning to work so that they can settle in and succeed.

Unacceptable Behaviours

The following behaviours are unacceptable and will be treated as a disciplinary matter. This list is not exhaustive:

• Bullying, including intimidating, insulting, belittling or undermining behaviour, whether in person, in writing or online.
• Harassment relating to any protected characteristic, including sexual harassment and unwanted conduct of a sexual nature.
• “Banter”, jokes, nicknames, initiation pranks or “wind-ups” that demean, exclude or humiliate others, regardless of intent.
• Displaying, sharing or circulating offensive images, graffiti, messages or material, including in welfare facilities, vehicles and messaging groups.
• Deliberately excluding or isolating individuals, or spreading malicious rumours or gossip.
• Shouting, aggressive behaviour, threats or physical contact that is unwanted or intimidating.
• Victimising or retaliating against anyone who has raised a concern, made a complaint or supported someone else to do so.

The impact of behaviour on the person receiving it matters more than the intention behind it. Saying that a comment was “only a joke” is not an acceptable defence.

Inclusive Sites and Workplaces

We will plan and manage our sites and offices so that they work for everyone. In particular, we will:

• Provide clean, adequate and accessible welfare facilities in accordance with the Construction (Design and Management) Regulations 2015, including separate or lockable single-occupancy toilets and changing facilities, and sanitary disposal facilities.
• Provide PPE and workwear in a range of sizes and fits, including female-fit PPE, so that it fits the wearer properly and protects them as intended.
• Make reasonable adjustments for disabled workers and for those with long-term health conditions or neurodiverse needs.
• Consider requests for flexible working fairly and, where practicable, accommodate religious observance, caring responsibilities, pregnancy and the menopause.
• Ensure that site inductions, briefings and signage are clear and accessible, including for workers whose first language is not English.

Wellbeing and Mental Health

We recognise that a respectful working environment supports good mental health, and that poor behaviour, isolation and stress can cause real harm. We will encourage open conversations about mental health, promote the support available to our people, train managers and supervisors to recognise the signs that someone may be struggling, and treat any concern raised with sensitivity and in confidence.

Roles and Responsibilities

Managing Director

Has overall responsibility for this policy, for providing the resources needed to implement it and for leading by example.

Directors and Managers

Are responsible for promoting fairness, inclusion and respect in their teams and on their projects, applying fair processes, and acting promptly when issues are raised or observed.

Site Managers, Supervisors and Foremen

Set the standard on site. They are responsible for delivering FIR briefings and toolbox talks, challenging unacceptable behaviour, and making sure concerns are reported and acted on.

HSEQ Manager

Maintains this policy, coordinates training and awareness, monitors performance, and reports on progress to senior management.

HR

Supports fair recruitment and employment practices, manages grievance and disciplinary processes, and maintains confidential records.

All Employees and Workers

Are responsible for their own behaviour, for treating others with respect, and for speaking up when they see or experience behaviour that falls short of this policy.

Supply Chain and Subcontractors

We expect our subcontractors and suppliers to share our commitment to fairness, inclusion and respect. This policy will be communicated through site inductions and pre-start meetings, and compliance may be considered as part of supply chain selection and performance review. Unacceptable behaviour by any subcontractor or supplier personnel on our sites will be addressed with their employer and may result in their removal from site.

Training and Awareness

• All new starters and site personnel will be briefed on this policy as part of company and site induction.
• FIR toolbox talks will be delivered on site as part of the toolbox talk programme.
• Managers, supervisors and those involved in recruitment will receive training in fair recruitment, inclusive leadership, unconscious bias and handling concerns.
• We will make use of recognised industry resources, including the Fairness, Inclusion and Respect programme materials provided through the Supply Chain Sustainability School.

Speaking Up and Reporting Concerns

Anyone who experiences or witnesses behaviour that does not meet the standards in this policy is encouraged to raise it as soon as possible. Concerns can be raised informally or formally with:

• Their line manager, site manager or supervisor.
• The HSEQ Manager or HR.
• A director, if they do not feel comfortable raising the concern with any of the above.
• Through the company Whistle-Blowing Policy, where the concern is serious or relates to wrongdoing.

Where appropriate, concerns may first be resolved informally. Formal complaints will be dealt with under the company Grievance Procedure. All concerns will be taken seriously, handled promptly and treated in confidence as far as possible. Nobody will be victimised or treated less favourably for raising a concern in good faith, or for supporting someone who has.

Investigation and Disciplinary Action

All formal complaints will be investigated fairly and impartially by a person independent of the matter. Any employee found to have breached this policy may be subject to formal disciplinary action in accordance with the company Disciplinary Procedure, which could result in dismissal. Where the conduct involves agency workers, subcontractors or suppliers, the matter will be raised with their employer and may result in removal from site or termination of the contract.

Monitoring and Measurement

We will monitor the effectiveness of this policy by:

• Recording and reviewing the number, type and outcome of FIR-related concerns and grievances.
• Carrying out periodic anonymous workforce surveys on culture, inclusion and wellbeing.
• Reviewing recruitment, retention, training and exit interview data, where available, to identify barriers or trends.
• Including FIR observations in site inspections and audits, including the condition of welfare facilities and the availability of suitable PPE.
• Reporting findings to senior management and setting improvement actions as part of management review.

Legislation and Guidance

• Equality Act 2010, including the duty to take reasonable steps to prevent sexual harassment of employees.
• Protection from Harassment Act 1997.
• Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999.
• Construction (Design and Management) Regulations 2015, Schedule 2 (welfare facilities).
• Public Interest Disclosure Act 1998.
• ACAS Code of Practice on Disciplinary and Grievance Procedures.
• Supply Chain Sustainability School – Fairness, Inclusion and Respect programme.

This policy will be made available to any interested parties upon request.

This policy will be reviewed on an annual basis and any amendments communicated to the relevant personnel.