DEI Policy and Procedure

(including Anti-Discrimination, Bullying, Harassment and Victimisation)


As a Group operating in numerous countries around the world, we believe diversity, equity and inclusion (DEI) brings benefits for our stakeholders, our business and our people. We support different perspectives to enhance our firm’s performance and wider contributions. To do this, we must enable an inclusive and equitable culture without bias or discrimination.

We are committed to maintaining a safe and supportive working environment which is free from discrimination, bullying, harassment and victimisation. All employees must treat current and former colleagues, candidates, clients, suppliers and other stakeholders with dignity and respect.

DEI Policy and Procedure

Including Anti-Discrimination, Bullying, Harassment and Victimisation

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All permanent and fixed term employees and contractors coming on to Group premises.

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

We expect our people to treat each other with dignity and respect, creating a diverse, equitable and inclusive culture. 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.

This policy covers discrimination, bullying, harassment and victimisation in the workplace and in any work-related setting outside the workplace, e.g. business trips and work-related social events. It does not cover bullying or harassment by customers, suppliers, vendors or visitors. In these cases, employees should report any such behaviour to their manager who will take the appropriate action.

ICG takes any allegations of this nature extremely seriously and undertakes thoroughly and fully to investigate any complaints received.

All discrimination, bullying, harassment and victimisation is deemed to be misconduct if proven and is a disciplinary offence, which will be dealt with under ICG’s Disciplinary Policy and Procedure.

Discrimination, bullying, harassment and victimisation may be gross misconduct and may lead to dismissal without notice. Individual employees may be also personally guilty of unlawful discrimination and, in some cases, risk civil actions against them and criminal prosecution.

Making a complaint, which an individual knows to be untrue, or giving evidence, which an individual knows to be untrue, may lead to disciplinary action being taken against that individual under ICG’s Disciplinary Policy and Procedure. Such an untrue complaint or giving of evidence may amount to gross misconduct and may lead to dismissal without notice.

An employee who has a complaint concerning any form of discrimination, bullying, harassment and victimisation should raise their concerns to their immediate line manager or to a senior member of the HR team in writing. It is also possible to report this entirely anonymously via the EthicsPoint Reporting System  for workplace issue reporting (whistleblowing) available on Connected from the HR Hub or from Compliance

If there is any conflict between the procedures set out in this policy and local legislation then local legislation will prevail. For example, some or any of the steps or procedures set out in this policy may not be required under local legislation, and therefore ICG will follow local legislation where appropriate.

The Policy covers the following:

  • Diversity, Equity and Inclusion (DEI);
  • Clarification of what constitutes discrimination, harassment, bullying and victimisation in the workplace; and the
  • Process for handling complaints regarding these behaviours.
  • Employee Handbook
  • Disciplinary Policy and Procedure
  • Grievance Policy and Procedure
  • Speak up Policy and Procedure

Forms of Discrimination

Discrimination can take a variety of forms. A brief summary of each of these is set out below.

Direct discrimination – occurs where a person is treated less favourably than another person because:

  • they have a protected characteristic;
  • they are thought to have a protected characteristic;
  • they associate with someone who has a protected characteristic.

Indirect discrimination – occurs when a provision, criterion or practice that applies to everyone but adversely affects people with a protected characteristic more than others and cannot be justified.

Discrimination arising from disability – occurs where a person is treated unfavourably because of something arising in consequence of their disability and that treatment is not justified.

Failure to make reasonable adjustments – occurs where the Company fails to take such steps (adjustments) as are reasonable to alleviate disadvantages caused by a disability.

Harassment – occurs when unwanted conduct related to a relevant protected characteristic takes place with the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.

Types of behaviours which may amount to harassment might include (but are not limited to):

  • persistent and unwelcome attention;
  • unwanted and unnecessary physical contact;
  • suggestions or requests for sexual favours;
  • insults, derogatory comments, ridicule or inappropriate teasing and “jokes”;
  • lewd, suggestive or over-familiar behaviour;
  • display or circulation of offensive material (e.g. pornography, racist/sexist memes);
  • freezing out of an individual by shunning him/her and ignoring his/her presence at work.

Harassment may be physical, verbal and/or non-verbal conduct. It can often be persistent and repeated. However, you should be aware that a single incident can be defined as harassment if it is sufficiently serious. The motive and/or intention of the person whose behaviour is called into question is irrelevant. Behaviour which is not intended to harass may still be unlawful if it could reasonably be considered to have that effect on the individual recipient or another person who has witnessed the behaviour (e.g. a person can be harassed even if the behaviour is not targeted at them).

Bullying – this covers a wide range of conduct. It may be characterised as offensive, intimidating, malicious or insulting behaviour, an abuse or misuse of power through means intending to undermine, humiliate, denigrate or injure the recipient.

The following are some examples (on a non-exhaustive basis) of the type of behaviour which may amount to bullying:

  • spreading malicious rumours;
  • making inappropriate jokes or insulting someone;
  • shouting, swearing or using offensive language at employee;
  • ridiculing or demeaning someone – picking on them or setting them up to fail;
  • exclusion, victimisation, or unfair treatment;
  • overbearing supervision or other misuse of power or position;
  • making threats or comments about job security without foundation;
  • deliberately undermining and constant criticism without justification;
  • preventing individuals progressing by intentionally blocking promotion or training opportunities;
  • physical assault or horseplay.

Bullying may be physical, verbal and/or non-verbal conduct. It can often be persistent and repeated. However, you should be aware that a single incident can be defined as bullying if it is sufficiently serious. The motive and/or intention of the person whose behaviour is called into question is not necessarily a defence to such a claim.

Victimisation – occurs when an individual is treated less favourably than others because they have made allegations or complaints of unlawful discrimination to ICG or to an employment tribunal. Any employee who is found to have victimised another employee will be subject to disciplinary proceedings.

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:

  • behaviours aligned with ICG’s purpose and values;
  • 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 observe. 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; and
  • 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 diversity, equity and inclusion.

Complaints about discrimination, bullying, harassment and victimisation will be taken very seriously. ICG will investigate all formal complaints made by employees, clients or other third parties in relation to persons employed by or retained by ICG and take action where appropriate. Complaints will be investigated in accordance with the Grievance Policy and Procedure, and the complainant will be informed of the outcome.

ICG New York

Procedure for making a complaint

Many complaints can be resolved informally. The formal grievance procedure should usually only be invoked where informal discussions and action have taken place in an attempt to resolve the issues raised by you, and these discussions and steps have not provided a satisfactory resolution.

You should be aware that even if a complaint is raised in writing, ICG will, in appropriate circumstances, aim to resolve it informally before inviting the employee to attend a formal meeting. Your HR Business Partner will provide guidance on the most appropriate course of action.

Guidelines for handling what you perceive as discrimination, harassment, bullying or victimisation

ICG seeks to prevent discrimination, harassment, bullying or victimisation in the workplace and will respond effectively to any such complaint. If you feel you have been or are being discriminated

against, bullied, harassed or victimised then do not suffer in silence. In any case you should:

Stage 1: Keep a record of the incident(s)

This is very important. Make a note of the date, time and nature of any incident(s) and of the name of anyone who may have witnessed any incident.

Stage 2: Make it clear to the perpetrator of the behaviour that you object

You should ask the perpetrator of the behaviour to stop what they are doing. If you do not feel able to or do not consider it appropriate to confront the perpetrator yourself, you should ask for help from Human Resources, a trusted colleague or other supportive person, or from a senior employee. If you do not feel able to face the perpetrator, you might feel able to write to them in which case, write an email or memo explaining what it is about their behaviour that is upsetting you and ask them to stop. Keep a copy of this email or memo for your records.

Stage 3: Make a formal complaint

If the informal methods fail, or in the case of serious incidents, you should report the incident(s) to your manager, to Human Resources, or anonymously via the EthicsPoint Reporting System for workplace issue reporting (whistleblowing) available on Connected from the HR Hub or from Compliance at the earliest opportunity. The complaint should be made in writing where possible, and state details of the date, time, nature of the incident(s), the name(s) of witnesses to the incident and any action already taken to stop the perpetrator. However, in view of the sensitive nature of such a complaint, you may prefer to seek further advice from your HR Business Partner who can guide you on the most appropriate course of action.

There will be no victimisation or retaliation against employees who make formal complaints. Please see the Speak Up Policy and Procedure for further information.

However, making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under the Disciplinary Policy and Procedure.


ICG understands that you may wish for your identity to be kept confidential when raising concerns of this nature. If this is the case, you can raise complaints anonymously via the EthicsPoint Reporting System for workplace issue reporting (whistleblowing) available on Connected from the HR Hub or from Compliance. ICG will take all reasonable steps to keep your identity secret |However, disclosure of your identity to some parties, such as named HR, Compliance and Legal executives or the Speak up Champion of the Board may be unavoidable in certain cases of an investigation if more specific discussions and details are needed for the matter to be progressed or in the event of court proceedings. We will guide you through these at each step of a process.

The CEO supported by the Chief People & External Affairs Officer have overall responsibly for the effective implementation and operation of this policy. All management and employees of ICG are expected to pay due regard to the provisions of this policy and should ensure compliance with it when undertaking their jobs or representing ICG. 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.

Acts of unlawful discrimination by employees or others may result in disciplinary action, which in serious cases could result in summary dismissal. Please see the Disciplinary Policy and Procedure 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 ICG will lead to appropriate action, which may include termination of services where appropriate.

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

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 Chief People and External Affairs Officer.