Purpose and scope

This policy sets out Border Crossing Media Holdings Limited’s commitment to equality of opportunity, diversity and inclusion, and to preventing unlawful discrimination, harassment, sexual harassment and victimisation.

It applies to all directors, employees, workers, job applicants, associates, contractors and others working for or on behalf of Border Crossing Media Holdings Limited, trading as Border Crossing UX.

It applies to recruitment, employment and work-related decisions, workplace conduct, company communications, work-related events and interactions with clients, suppliers and other third parties. It also applies to work-related communication and conduct through email, messaging platforms, video calls, social media and other digital channels.

Where the company operates in another jurisdiction, it will also comply with any equality or anti-discrimination laws that apply to its activities in that jurisdiction.

Policy statement

Border Crossing UX is committed to providing an inclusive working environment in which people are treated fairly, with dignity and respect.

In accordance with the Equality Act 2010, we do not tolerate unlawful discrimination, harassment, or victimisation related to any of the protected characteristics: age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex, or sexual orientation.

Beyond our statutory obligations, we do not tolerate bullying, harassment, or unfair treatment related to gender identity, caring responsibilities, socio-economic background, trade union membership or activity, or any other personal characteristic unrelated to a person’s work.

In line with our proactive duties under the Worker Protection Act 2023, we are dedicated to maintaining a working environment free from sexual harassment and take reasonable, preventative steps to protect our staff, including from third-party harassment by clients, partners, or suppliers.

Employment and work-related decisions are based on fair, transparent, and role-related criteria. We make reasonable adjustments for disabled applicants and colleagues, and we may use lawful, proportionate positive action to address disadvantage or under-representation. Any personal data collected to support our EDI commitments is processed confidentially and lawfully in accordance with the Data Protection Act 2018 and UK GDPR.

Responsibility

Overall responsibility for this policy lies with the Managing Director. The Company Directors are responsible for approving and overseeing the policy and the company’s preventative approach to discrimination, harassment and sexual harassment.

Everyone covered by this policy is responsible for following it and for raising concerns about conduct that may breach it.

The Company Directors and anyone involved in recruitment, management or supervision have additional responsibility for applying the policy fairly and consistently and for addressing concerns appropriately.

They must also model appropriate conduct, respond to warning signs and avoid dismissing or minimising concerns because the conduct was intended as humour, occurred outside ordinary working hours or involved a client or other third party.

Our commitments

Recruitment and employment practices

We will:

  • use fair, transparent and role-related procedures for recruitment, selection, deployment, development and promotion
  • review recruitment and selection practices periodically to identify and remove unnecessary barriers
  • actively reach out to a wider, more diverse pool of people when advertising roles
  • use lawful and proportionate positive action where appropriate
  • make reasonable adjustments during recruitment and throughout a person’s work with us
  • consider flexible and remote working arrangements fairly, taking account of the role and individual circumstances
  • ensure employment and work-related decisions are not influenced by irrelevant personal characteristics.

Inclusive working environment

We will:

  • take reasonable steps to prevent discrimination, bullying, harassment, sexual harassment and victimisation
  • consider risks arising from interactions between colleagues and with clients, suppliers, contractors and other third parties
  • provide proportionate equality, diversity, inclusion and anti-harassment guidance during onboarding and when responsibilities change
  • provide employees and relevant workers with refresher training on preventing and reporting sexual harassment at least annually
  • provide appropriate guidance to associates and specialist suppliers where their role or engagement creates a relevant risk
  • provide additional guidance to anyone involved in recruitment, management or supervision
  • use inclusive and accessible language in company communications
  • support a working environment in which people can contribute openly and do not feel required to conceal aspects of who they are
  • listen to different perspectives and consider equality, inclusion and accessibility in our research, design and other client work.

Prevention of sexual harassment

Sexual harassment is unwanted conduct of a sexual nature that has the purpose or effect of violating another person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.

Conduct can amount to sexual harassment whether or not the person responsible intended to cause offence. A single incident may be sufficient.

Sexual harassment may include:

  • unwanted physical contact or sexual advances
  • sexual comments, jokes, questions or gestures
  • comments about someone’s body, clothing, sex life or perceived sexuality
  • displaying, sending or sharing sexual images, messages or other material
  • asking someone for a date or sexual contact after they have declined
  • promising a benefit or threatening a disadvantage in connection with sexual conduct
  • intrusive staring or suggestive behaviour
  • sexual conduct through email, messaging, video calls, social media or another digital channel
  • conduct described as banter or humour where it has the prohibited purpose or effect.

Sexual harassment can occur:

  • between people of any sex, gender or sexual orientation
  • between colleagues or workers
  • between a manager and another person
  • between a Director and another person
  • involving an Associate or Specialist supplier
  • involving a client, research participant, supplier, visitor or other third party
  • at company, client or third-party premises
  • during travel for work, fieldwork, events or work-related social activity
  • during remote or hybrid work.

The company considers sexual-harassment risks as part of its working arrangements. The assessment may consider:

  • power imbalances
  • lone or remote working
  • work-related social events
  • travel and overnight stays
  • client and third-party interactions
  • research and fieldwork
  • informal or digital communication channels
  • alcohol
  • previous concerns, warning signs or recurring themes.

Preventative action may include changing working arrangements, improving reporting routes, setting conduct expectations, increasing supervision, providing targeted guidance or training, and raising expectations with clients or suppliers.

Accessibility and reasonable adjustments

We seek to identify and remove barriers affecting disabled people in our recruitment, workplace, communications, website, digital systems and services.

We will make reasonable adjustments and provide accessible formats, alternative ways to participate or other appropriate support where needed.

When selecting, designing or configuring systems and services used by employees, clients, suppliers or other users, we consider accessibility alongside the purpose, context and applicable requirements. Identified accessibility barriers will be considered and addressed proportionately.

Reporting and responding to concerns

Anyone who experiences or witnesses possible discrimination, bullying, harassment, sexual harassment or victimisation should report the concern promptly to either Company Director.

A person may also report a concern where they become aware of conduct affecting somebody else.

A concern involving one Director must be reported to the other Director and considered without the involvement of the Director concerned.

Where both Directors may be involved, or internal reporting would otherwise be inappropriate, the concern may be raised under the Whistleblowing Policy or with an appropriate independent adviser or authority.

A sexual-harassment complaint or another serious concern may be raised directly through the formal procedure. The person affected is not required to attempt informal resolution first.

Concerns will be considered promptly, fairly and sensitively. They will be handled as confidentially as reasonably possible, recognising that some information may need to be shared to assess and respond to the concern properly.

The company will:

  • listen to the person raising the concern
  • consider any immediate safety, wellbeing or working-arrangement needs
  • explain the available process and possible next steps
  • protect relevant records and evidence
  • carry out a fair and proportionate investigation where required
  • give the person whose conduct is under consideration a fair opportunity to respond
  • obtain independent HR or legal advice where appropriate
  • confirm the outcome and any action as appropriate.

Support may include:

  • a change to reporting, location or working arrangements
  • reasonable adjustments
  • time away from a particular activity or contact
  • signposting to independent support
  • an agreed communication route
  • protection from avoidable contact during an investigation.

Interim arrangements are neutral protective measures and do not determine whether a complaint has been substantiated.

Further support

Employees and workers should normally use the relevant internal employment, grievance or whistleblowing process where the concern relates to their work or treatment.

Associates, suppliers, research participants and members of the public may use our Complaints and feedback process where a concern relates to our services, work or conduct.

Acas provides independent information about workplace rights. The Equality Advisory and Support Service provides information and advice about the Equality Act 2010 and discrimination.

Victimisation and retaliation

No applicant, employee, worker, associate or other person covered by this policy will be victimised, disadvantaged or subjected to retaliation because they:

  • raised a genuine concern
  • supported another person’s complaint
  • gave evidence or information
  • participated in an investigation
  • rejected or objected to sexual conduct
  • exercised a legal equality or employment right.

Any suspected victimisation or retaliation must be reported and will be treated as a separate potential breach of this policy.

Outcomes and consequences

Where a complaint is substantiated, action will reflect the seriousness and circumstances of the conduct. It may include:

  • guidance, training or supervision
  • changes to working arrangements
  • formal disciplinary action
  • termination of employment
  • contractual action involving an Associate or Supplier
  • raising the matter with a client or third party
  • ending or changing a commercial relationship
  • reporting to an appropriate authority where required.

A fair and proportionate process will be followed before a disciplinary or contractual conclusion is reached.

Training and awareness

Employees receive information about equality, harassment, sexual harassment, reporting routes and protection from victimisation during induction.

Employees and relevant workers receive refresher training at least annually. Training is also reviewed or repeated following a material legal or policy change, an identified risk or a reported incident where further awareness is required.

People with recruitment, management or supervisory responsibilities receive additional guidance appropriate to their responsibilities.

Training completion is recorded.

Monitoring and review

The Company Directors review this policy annually and consider proportionate information about:

  • recruitment practices and applicant reach, where information is available
  • reasonable adjustments and identified accessibility barriers
  • reported concerns, breaches, outcomes and any recurring themes
  • equality, diversity and inclusion guidance provided
  • sexual-harassment risks and preventative action
  • induction and refresher training completion
  • reports involving clients, suppliers or other third parties
  • victimisation or retaliation concerns
  • actions taken to improve practices or address identified risks.

The outcome of the review and any required actions are recorded in the relevant meeting minutes.

Because the company has a small workforce, diversity information will only be collected, analysed or reported where it is meaningful, proportionate and consistent with data-protection and confidentiality requirements. The company will not publish percentages or breakdowns that could identify individuals or give a misleading picture of performance.

The policy may also be reviewed following a reported concern, identified weakness, relevant legal change or material change to the company’s workforce or operations.

It will also be reviewed following a sexual-harassment complaint or identified preventative-control weakness.

Last reviewed and approved

20 July 2026