Diversity and Inclusion Policy

As a Company operating in numerous countries around the world, we believe diversity brings benefits for our stakeholders, our business and our people. We believe a connected workforce that reflects the communities where we operate bringing different ideas and perspectives help us to continue to innovate and grow the business in a sustainable way.

We expect our people to treat each other with dignity and respect, creating an inclusive culture to support equal opportunities. We do not tolerate discrimination, bullying, harassment and victimisation on any ground, including age, race, ethnic or national origin, colour, mental or physical health conditions, disability, pregnancy, gender, gender expression, gender identity, sexual orientation, marital status or other domestic circumstances, employment status, working hours or other flexible working arrangements, or religion or belief.

Our commitment reflects the provisions of both the Universal Declaration of Human Rights (the UDHR) and the International Labour Organization Declaration on Fundamental Principles and Rights at Work (the ILO Declaration), including freedom of association.

ICG Diversity and Inclusion Policy

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This policy covers all permanent and fixed term employees, contractors, clients and individuals coming on to Company premises.

This policy is for guidance purposes only and does not form part of contracts of employment. ICG may, at its absolute discretion, amend this policy from time to time.

The Policy covers the following:

  • Diversity vs Inclusion Forms of discrimination Recruitment and selection
  • Promotion and career development Appropriate behaviour
  • Promoting and communicating equality and diversity Complaints of discrimination
  • Disciplinary Policy and Procedure
  • Grievance Policy and Procedure
  • Harassment and Bullying Policy and Procedure
  • Speak up Policy and Procedure

Recruitment and selection

The Company recognises the benefits of having a diverse workforce and will take steps to ensure that:

  • it endeavours to recruit from the widest pool of suitably qualified candidates possible and requesting diverse shortlists from third party partners;
  • employment opportunities are open and accessible to all on the basis of their ability, skills, experience, appropriate qualifications and aptitude for the job;
  • all recruitment agencies acting for the Company align with our equality and diversity requirements and their own requirement not to unlawfully discriminate;
  • all recruiting managers are trained and developed to ensure that their own individual ‘unconscious bias’ is noted and recognised so that they can consciously make recruitment decisions based on skill set, role knowledge and potential, track record and evidence of performance rather than any other

Promotion and career development

Promotion within the Company is made without reference to any of the protected characteristics and will be based solely on merit, looking at performance, potential and on the parameters/scope of the role.

The selection criteria and processes for recruitment and promotion will be kept under review to ensure that there is no unlawful discriminatory impact on any particular group which cannot be justified.

While positive action measures may be taken in accordance with the relevant anti- discrimination legislation to encourage under-represented groups to apply for promotion opportunities, recruitment or promotion 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. The Company may take appropriate positive action (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.

ICG New York

Appropriate behaviour

It is expected that everyone in the Company will conduct themselves in an appropriate manner, which can be characterised by:

  • treating others with dignity, trust and respect;
  • having an awareness of the effects our behaviour may have on others;
  • working collaboratively to achieve objectives;
  • communicating openly and honestly, clearly stating what we mean and what we expect of others;
  • giving and receiving constructive feedback as part of normal day-to-day activities, that is evidence based and delivered appropriately;
  • starting from the assumption that everyone is working to the best of their abilities, taking account of their current stage of their professional development;
  • highlighting and speaking up about any unacceptable behaviour (including bullying, harassment and victimisation) that they experience or This may involve actions, words or physical gestures that could reasonably be perceived to be the cause of another person’s distress or discomfort. Unacceptable behaviour does not have to be face-to-face, and may take many forms such as written, telephone or email communications or through social media. Unacceptable behaviour will be dealt with under the processes set out in our Anti-harassment and bullying policy.
  • ensuring all senior management and line managers set an appropriate standard of behaviour, lead by example and ensure that those they manage adhere to the policy and promote our aims and objectives in relation to equal opportunity, diversity and inclusion.

Promoting and communicating equality and diversity

This policy is published on Connected and is also available to job applicants on the Company’s website.

All those who act on the Company’s behalf will be informed of this policy and will be expected to comply with it.

In all its dealings, with clients and other third parties, the Company will seek to promote the principles of diversity & inclusion.

The Company will make every effort to reflect its commitment to diversity, inclusion and equality in its marketing and communication activities where appropriate.

Procedure for Making a complaint

Complaints of this nature will be taken very seriously. Most complaints can be resolved informally. As a first step, you should discuss your complaint informally with your manager and together you should attempt to resolve this. Either you or the manager may ask HR to assist with resolving matters. If an informal resolution is not possible or is not reached, the aggrieved party may invoke the formal procedure.

If your complaint is about your direct manager, you should raise it with their manager or with HR.

Responsibility and implementation

The CEO supported by the ED, Chief People & External Affairs Officer have overall responsibly for the effective implementation and operation of this policy. All senior Management within the Company are expected to support them in this. This policy is also supported by the Company’s Diversity and Inclusion Champions Group and HR team.

All management and employees of the Company are expected to pay due regard to the provisions of this policy and should ensure compliance with it when undertaking their jobs or representing the Company.

Acts of unlawful discrimination by employees or others may result in disciplinary action, which in serious cases could result in summary dismissal. Please see our Disciplinary Policy for more information. Failure to comply with this policy will be treated in a similar fashion.

Acts of unlawful discrimination by those acting on behalf of the Company will lead to appropriate action, which may include termination of services where appropriate.

Complaints of discrimination

The Company will investigate all complaints of unlawful discrimination made by employees, clients or other third parties in relation to the Company and take action where appropriate. All complaints will be investigated in accordance with the Company’s grievance or complaints procedure and the complainant will be informed of the outcome.

There will be no victimisation or retaliation against employees who complain about discrimination please see the Speak Up Policy for further information. However, making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under the Company’s Disciplinary Policy & Procedure.

ICG New York


The Company monitors gender and ethnicity and uses this data to inform its Global strategies and initiatives in order to:

  1. Assess pay gaps and publish gender pay gaps;
  2. Review the diversity of shortlists for recruitment/promotion and identifying areas of underrepresentation for particular groups;
  3. Identify particular individuals within a particular diversity strand to invite them to participate in specific initiatives, training programmes, consultation groups etc;
  4. Identify individuals/groups for mentoring schemes and to match them with mentors;
  5. Promote particular resources to individuals within a particular

All those persons referred to within the scope of this policy are required to adhere to is terms and conditions.

Individual managers are responsible for ensuring that this policy is applied within their own area. Any queries on the application or interpretation of this policy must be discussed with HR prior to any action being taken.

The HR department has the responsibility for ensuring the maintenance, regular review and updating of this policy.

Revisions, amendments or alterations to the policy can only be implemented following consideration and approval by the ED, Chief People and External Affairs Officer.