Modern Slavery & Diversity Policy

    Modern Slavery & Diversity Policy



1 Our commitment to equality and diversity

(a) Commitment

We, Rainer Security Products Ltd. are committed to eliminating unlawful discrimination and to promoting equality and diversity within our policies, practices and procedures.

We are also committed to promoting equality and diversity within the Company.

This applies to our professional dealings with clients, staff and work colleagues.

We shall treat everyone equally and with the same attention, courtesy and respect regardless of:

(a) age;

(b) disability;

(c) gender reassignment;

(d) race;

(e) religion or belief;

(f) sex;

(g) sexual orientation;

(h) marriage or civil partnership status;.

(i) pregnancy and maternity or

(j) caring responsibility.

(b) Legislation

We will take all reasonable steps to ensure that we and our staff do not unlawfully discriminate under the terms of the Contracts and any legislation in force from time to time relating to discrimination in employment and the provision of goods, facilities or services.

2 Meeting Clients Needs

(a) General statement

As a provider of publicly funded legal services Rainer Security Products Ltd will treat all clients equally and fairly and not unlawfully discriminate against them. The company will also, wherever possible, take steps to promote equal opportunity in relation to access to the legal services that we provide, taking account of the diversity of the communities that we serve.

(b) Identifying clients needs

Rainer Security Products Ltd is committed to meeting the diverse needs of clients. We will take steps to identify the needs of clients in our community and develop policies and procedures setting out how we will meet clients‟ needs and for entering the services we provide are accessible to all. We will take account, in particular, the needs of clients with a disability and clients who are unable to communicate effectively in English. We will consider whether particular groups are predominant within our client base and devise appropriate policies to meet their needs: including men and women; carers; children; the elderly; members of religious groups; ethnic groups or nationalities; and lesbian, gay or transgender people.

(c) Communications Plan

Rainer Security Products Ltd will devise policies and procedures to promote and raise awareness of policies and procedures for ensuring that our services are accessible for a diverse range of clients. Our communications plan sets out what steps we have taken or/ and will take to put in place customer service policies and procedures to make our services accessible to clients. It contains a list of policies and procedures; information about what steps we will take to put them in place; who is responsible for them; and how we will make our policies and procedures openly available for the public.

Partners/employees/directors will be informed of the Communications Plan and training provided where appropriate to ensure that it is effectively implemented. The Communications Plan is appended to this Policy.

3. Dealings with third parties

(a) General statement

Rainer Security Products Ltd will not unlawfully discriminate in dealings with third parties. This applies to dealings with other legal service providers and general procurement.

4 Employment

(a) General statement

As an employer, Rainer Security Products Ltd will treat all employees and job applicants equally and fairly and not unlawfully discriminate against them. This applies equally to voluntary positions and anyone undertaking work experience with us. This will, for example, include arrangements for recruitment and selection, terms and conditions of employment, access to training opportunities, access to promotion and transfers, grievance and disciplinary processes, demotions, selection for redundancies, dress code, references, bonus schemes, work allocation and any other employment related activities.

(b) Recruitment and selection

Rainer Security Products Ltd recognises the benefits of having a diverse workforce and will take steps to ensure that:

(i) we endeavour to recruit from the widest pool of qualified candidates practicable;

(ii) employment opportunities are open and accessible to all on the basis of their individual qualities and personal merit;

(iii) where appropriate, positive action measures are taken to attract applications from all sections of society and especially from those groups which are underrepresented in the workforce;

(iv) selection criteria and processes do not unlawfully discriminate on the grounds of sex (including marital status, gender reassignment, pregnancy, maternity and paternity), sexual orientation (including civil partnership status), religion or belief, age or disability; other than in those instances where the [organisation] is exercising permitted positive action or a permitted exemption;

(v) wherever appropriate and necessary, lawful exemptions (genuine occupational requirements) will be used to recruit suitable staff to meet the special needs of particular groups;

(vi) all recruitment agencies acting for the company are aware of requirements not to discriminate and to act accordingly.

 (c) Conditions of service

Rainer Security Products Ltd will treat all employees equally and create a working environment which is free from unlawful discrimination and which respects the diverse backgrounds and beliefs of employees. Terms and conditions of service for employees will comply with anti-discrimination legislation. The provision of benefits such as flexible working hours, maternity and other leave arrangements, performance appraisal systems, dress code, bonus schemes and any other conditions of employment will not unlawfully discriminate against any employee on the grounds of their age; gender and 

gender reassignment; marital status; race; religion or belief; sexual orientation or on the grounds of disability.

Where appropriate and necessary, the firm will endeavour to provide appropriate facilities and conditions of service which take into account the specific needs of employees which arise from their ethnic or cultural background; gender and gender reassignment; responsibilities as carers; disability; religion or belief or

sexual orientation.

(d) Promotion and career development

Promotion within the company (including partners/employees) will be made without reference to any of the forbidden grounds and will be based solely on merit. The selection criteria and processes for recruitment and promotion will be kept under review to ensure that there is no unjustifiably discriminatory impact on any particular group.

While positive action measures may be taken in accordance with relevant

anti-discrimination legislation to encourage applications from under-represented groups, appointments to all jobs will be based solely on merit. All employees will have equal access to training and other career development opportunities appropriate to their experience and abilities. However, the company will take appropriate positive action measures (as permitted by the anti-discrimination legislation) to provide special training and support for groups which are under-represented in the workforce and encourage them to take up training and career development opportunities.

(e) Training Plan

Rainer Security Products Ltd will identify equality and diversity training needs and draw up a plan to address these as appropriate to their responsibilities. The plan will include details of the sort of training that will be provided, who will be trained, when training will be provided and who is responsible for ensuring that training is delivered. Employees and partners/employees/directors will be informed of this equality and diversity policy and training plan. The Training Plan is appended to this Policy.

(f) Working with other organisations

All those who act on the companies’ behalf will be informed of this equality and diversity policy and will be expected to pay due regard to it when conducting business on the companies’ behalf. In all its dealings, including those with any consortium members that Rainer Security Products Ltd will seek to promote the principles of equality and diversity.

5. Implementing the policy

(a) Responsibility

Ultimate responsibility for implementing the policy rests with the company. Rainer Security Products Ltd will appoint a senior person within it to be responsible for the operation of the policy. All employees and partners/employees/directors of the [organisation] are expected to pay due regard to the provisions of this policy and are responsible for ensuring compliance with it when undertaking their jobs or representing the company.

Acts of unlawful discrimination on any of the forbidden grounds by employees or partners/employees/directors of the company will result in disciplinary action. Failure to comply with this policy will be treated in a similar fashion. The policy applies to all who are employed in the company and to all partners/employees/directors.

Acts of unlawful discrimination on any of the forbidden grounds by those acting on behalf of Rainer Security Products Ltd will lead to appropriate action by the Legal Services Commission.

(b) Complaints of discrimination

The [organisation] will treat seriously all complaints of unlawful discrimination on any of the forbidden grounds made by employees, partners/employees/directors, clients, barristers or other third parties and will take action where appropriate.

All complaints will be investigated in accordance with the companies’ grievance or complaints procedure and the complainant will be informed of the outcome.

We will also monitor the number and outcome of complaints of discrimination made by staff, clients, partners/employees/directors, barristers, and other third parties.

(c) Monitoring

(1) Rainer Security Products Ltd will monitor and record equal opportunities information about staff, partners/employees/directors on the basis of age, gender, ethnicity, and disability.

(2) Where it is possible to do so, and where doing so will not cause offence or discomfort to those whom it is intended to protect, we will monitor the sexual orientation and religion or belief of staff, partners/employees/directors so as to ensure that they are not being discriminated against in terms of the opportunities or benefits available to them. We are aware that individuals may choose not to disclose their sexual orientation or religion or belief and that care will be taken to avoid inadvertent discrimination in such cases.

We will store equal opportunities data as confidential personal data and restrict access to this information. Equal opportunities information will be used for exclusively for the purposes of equal opportunities monitoring and have no bearing on opportunities or benefits.

Rainer Security Products Ltd will monitor all elements of:

(i) recruitment and selection process (applicants and existing staff and partners/employees/directors);

(ii) promotion and transfer;

(iii) training (all training opportunities not restricted to equality and diversity training);

(iv) terms and conditions of employment;

(v) take up of benefits (work life balance policies eg flexible working requests)

(vi) grievance and disciplinary procedures;

(vii) resignations, redundancies, and dismissals.

Rainer Security Products Ltd will provide equal opportunities information to the Legal Services Commission as required in relation to personnel and clients under the terms of the LSC Contracts.

(d) Review

Rainer Security Products Ltd will review the operation of this policy not less than twice a year (or more regularly if we identify any non-compliance or problem concerning equality and diversity issues with clients or personnel). We will take remedial action if we discover non-compliance under this policy or barriers to equal opportunities. When reviewing the policy we will consider the outcome of monitoring and review actions under our communications and training plans.



1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in our business dealings and relationships and are committed to preventing modern slavery in our own business and to helping prevent modern slavery in our supply chains.

1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery. Under the Modern Slavery Act 2015, we are legally required to disclose the steps we take to tackle modern slavery. We expect the same high standards from all of our employees and suppliers.

1.3 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, suppliers, seconded workers, volunteers, and interns.

1.4 This policy does not form part of any Rainer Security Products Ltd employee’s contract of employment and we may amend it at any time.


2.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

2.2 The Legal and Human Resources departments have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal procedures.

2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy. Guidance on the policy can be obtained from the Legal and Human Resources teams.


3.1 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3.2 You must notify your manager (or your main point of contact at Rainer Security Products Ltd, if you are a supplier) as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.

3.3 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains or any supplier tier at the earliest possible stage. 

Rainer Security Products Ltd; All Rights Reserved Rainer Security Products Ltd Registered in England No 2240635

3.4 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager (or your main point of contact at Rainer Security Products Ltd, if you are a supplier) as soon as possible.

3.5 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitute any of the various forms of modern slavery, you should raise it with your manager (or your main point of contact at Rainer Security Products Ltd, if you are a supplier).

3.6 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment by Rainer Security Products Ltd as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Chief Human Resources Officer immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our grievance procedure.


4.1 Guidance on this policy forms part of the induction process for all individuals who work for us and will be provided otherwise as necessary.


5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

5.2 We may terminate our relationship with other individuals and organisations working for us or on our behalf (including suppliers) if they breach this policy.