Policies /
Race Relations Policy For Financial Year 2022/23

Race Relations Policy

Purpose And Status Of The Code

Fostering strong race relations is a crucial and non-negotiable facet of SSGC operations. It is pivotal in the development and enrichment of our workforce, as well as creating an effective and safe corporate environment. 

The Race Relations Act 1974 aims to give practical guidance which will help SSGC and our employees to understand not only the provisions of the Race Relations Act and their implications, but also how best we can implement policies to eliminate racial discrimination and to enhance equality of opportunity.

We are stringent in ensuring that all our employees, regardless of the racial group to which they belong, have a right to equal opportunities. We have developed a coherent and effective programme of equal opportunity to help SSGC remain a place where all employees can make the best of their abilities It is particularly important to us that all our workforce upholds this code, and that we together take a concerted approach towards the elimination of both race and sex discrimination. Our Equal Opportunities Statement offers further clarification on our work to ensure equal gender opportunities. 

Application Of The Code

We are proud of our application of the legal requirements and further recommendations outlined in the Race Relations Act. Where situations call for, and admit of, changes, we are careful in ensuring they follow the spirit of the code. 

Unlawful Discrimination

At SSGC we take unlawful discrimination as defined in the The Race Relations Act 1976 very seriously. This includes discrimination against a person, directly or indirectly.

We understand direct discrimination to consist of treating a person less favourably on racial grounds.  We treat as indirect discrimination the introduction of a requirement or condition which, although applicable to all employees, unduly and disproportionately affects a smaller proportion of a particular racial group. Neither form is acceptable at SSGC.

We understand, however, that the definition of indirect discrimination is complex. We trust the training and guidance we provide, along with the integrity of our workforce, to lead to a careful and sympathetic interpretation of this term.

As part of this policy, at SSGC we do not tolerate unlawful discrimination by victimisation. For example, we do not tolerate less favourable treatment being afforded to an employee who is suspected or known to have brought proceedings or given evidence to an investigation under this act. 

The Code And Good Employment Practice

We are clear about the integral role this race relations policy plays in upholding good employment practice. For example, the use of relevant selection criteria and rigorously observed selection procedures not only help to ensure new appointments are made solely on merit; they are also part of good employment practice.

Positive Action

A static policy is insufficient in enriching and deploying the abilities and potential of our workforce. That is why a key facet of our Human Resource Development Strategy involves actively creating opportunities for employees to develop their potential through encouragement, training, and careful assessments.

We recognise that our employees from racial minorities may have potential which, perhaps because of previous discrimination and other causes of disadvantage, they have not been able to realise, and which is not reflected in their qualifications and experience. Where members of particular racial groups have been underrepresented over the previous twelve months in particular work at our company, SSGC is allowed under the Act to encourage them to take advantage of opportunities for doing that work and to provide training to enable them to attain the skills needed for it. 

We may provide such training for persons currently employed by us, and in certain circumstances for others too, for example if they have been designated as training bodies. 

At SSGC we understand that asking the best of our employees confers on us the responsibility to offer them the best in turn. This is why we are consistently attentive to any avenue by which we might help improve their skills without discrimination. 


The Responsibility Of The Company

SSGC takes primary responsibility for providing equal opportunities to all job applicants and employees. We understand the importance of backing up abstract goals with concrete policy, and investing attention into ensuring the policy is upheld at all levels of our organisation. To this end we have created, implemented, and continue to monitor the efficacy of this policy - which is clearly and readily available to all employees. 


SSGC’s equal opportunity policy aims to ensure that:

  • No job applicant or employee receives less favourable treatment than another on racial grounds.
  • No applicant or employee is placed at a disadvantage by requirements or conditions which have a disproportionately adverse effect on their racial group and which cannot be shown to be justifiable on other than racial grounds.
  • Where appropriate, and where permissible under the Race Relations Act, employees of ours from underrepresented racial groups are given training and encouragement to achieve equal opportunity within our organisation.

In order to ensure that an equal opportunity policy is fully effective, SSGC carries out the following:

  • The allocation of overall responsibility of the policy to a member of senior management.
  • Discussing and, where appropriate, agreeing with employee representatives as to this policy’s content and implementation.
  • Ensuring that the policy is known to all employees and if possible, to all applicants.
  • Providing training and guidance for supervisory staff and other relevant decision makers (such as personnel and line managers, gatekeepers and receptionists), to ensure that they understand their position in law and under company policy.
  • Examining and regularly reviewing existing procedures and criteria, and changing them where we find that they are actually or potentially discriminatory under law.
  • Making an initial analysis of the workforce and regularly monitoring the application of the policy with the aid of analyses of the ethnic origins of the workforce and of job applicants.

Sources Of Recruitment


Maintaining a strong company starts with building a workforce with breadth, integrity, and talent. We make sure this is clear to applicants from the moment they read our vacancy advertisements. We take concrete steps to ensure our advertisements neither indicate nor suggest an intention to discriminate against applicants from a particular racial group. For example:

  • We ensure the location and placement of advertisements does not exclude or reduce applications from a particular racial group. 
  • We do not prescribe a requisite length of residence or experience in the UK, and always clarify where a fully comparable qualification obtained overseas is as acceptable as a UK qualification.

In order to demonstrate our commitment to equality of opportunity, we include with all applicant literature an express statement of our commitment to remain an equal opportunities employer.

Employment Agencies

When recruiting through employment agencies, job centres, career offices and schools, we will never:

  • Give instructions to discriminate;
  • Bring pressure on them to discriminate.

We are also attentive to the risk of indirect discrimination when using particular agencies, job centres, careers offices and schools, which may cater only or mainly to applicants of a particular racial group. We will never confine our hiring practices to these organisations, unless there is sound justification. 

We are aware, also, of the various risks associated with other recruitment methods. This is why we are resolved to never: 

  • Recruit, solely or at first, through the recommendations of our existing employees if our workforce is wholly or predominantly white or black, and the labour market is multi-racial.
  • Use procedures by which applicants are mainly or wholly supplied through trade unions, if this means that only members of a particular racial group, or a disproportionately high number of them, come forward.
Sources For Promotion And Training

At SSGC we understand that employment opportunities do not end once a new hire has signed the contract. Promotions and training are also avenues for invaluable career progression, and constitute another area that requires similarly strict monitoring. That is why our non-discrimination policy is applied as rigorously to internal promotion and training as it is to the onboarding of new staff. 

Job and training vacancies at SSGC, and the application procedure, are made known to all eligible employees. We are careful that this is not done in such a way as to exclude or disproportionately reduce the numbers of applicants from a particular racial group. 

Selection Process 

At SSGC we also understand that discrimination can emerge on a more abstract level. So we are careful not to discriminate in the ways in which we afford access to opportunities for promotion, transfer and training. That includes a firm policy of not selecting with the aim of creating “racial balance.”

Selection Criteria And Tests

When assessing and selecting new members of the SSGC team, we are strict about our procedure. Ability, talent, and potential are at the forefront of our focus. We work hard to ensure our selection criteria and tests are best calibrated to deliver this without discrimination, and examine them to ensure:

  • That we do not demand a higher level or English or education than that strictly required to perform in the role;
  • That overseas degrees, diplomas and other qualifications which are comparable with UK qualifications are accepted as equivalents;
  • That we do not use irrelevant questions or exercises on subject material which may be unfamiliar to racial minority applicants;
  • That our selection tests relate specifically to the job’s requirements. 

Treatment Of Applicants

Shortlisting, Interviewing And Selection

All those who engage in SSGC’s recruitment process are engaging with our company - even if they do not go on to join our team. So we are committed to offering an experience that is representative of our values as a whole. We have put the following measures in place:

  • We instruct our gate, reception, and personnel staff, with written confirmation, to not treat casual or formal applicants from particular racial groups less favourably than others.
  • Staff responsible for short-listing, interviewing, and selecting candidates are:
  • Clear about the selection criteria and the importance of consistently applying them;
  • Trained in the effects that generalised assumptions and prejudices about race can have on selection decisions;
  • Made aware of the possible misunderstandings that can occur in interviews between persons of different cultural backgrounds.
  • Wherever possible, short-listing and interviewing is conducted by more than one person, and is checked at a more senior level.

Genuine Occupational Qualification

Providing our customers with the best possible service is a principal objective at SSGC. We recognise that there are occasions on which being of a particular racial group is a genuine occupational qualification for that job. For example, where the holder of a particular job provides persons of a racial group with personal services promoting their welfare, and those services can most effectively be provided by a person of that group. As such, we make careful allowances under these circumstances for selection on racial grounds. 

Transfers And Training

In order to avoid direct or indirect discrimination we ensure that:

  • Staff responsible for selecting employees for transfer to other jobs apply selection criteria without unlawful discrimination;
  • We examine - and change, if necessary - industry or company agreements and arrangements of custom and practice on job transfers that may appear discriminatory;
  • Staff responsible for selecting employees for training do not discriminate on racial grounds;
  • Selection criteria for training opportunities are not indirectly discriminatory.

Dismissal (Including Redundancy) And Other Detriment

All our employees deserve a non-discriminatory environment, even if a situation calls for dismissal.  We are careful, therefore, to ensure that dismissals and redundancies do not discriminate on racial grounds. For example, our staff responsible for selecting employees for dismissal and redundancy do not discriminate on racial grounds. Additionally, we examine our redundancy selection criteria to ensure that they are not indirectly discriminatory.

Performance Appraisals

SSGC does not discriminate on racial grounds in employee performance appraisals, either. This goes for the staff responsible for appraisals, and the assessment criteria used - which are examined to ensure they are not discriminatory. 

Terms Of Employment, Benefits, Facilities And Services

The same applies to offering terms of employment and providing benefits, facilities and services for employees. All staff involved in this area are appropriately instructed, and eligibility criteria are similarly examined. 

In addition, we recognise that some SSGC employees may require extended leave from time to time in order to visit relatives in their country of origin or who have emigrated to other countries. It is important to us that our employees feel comfortable expressing their needs to us - and we expressly encourage them to apply for such extended leave if required. SSGC allows annual leave entitlement to be accumulated, or extra unpaid leave to be taken to meet these circumstances. As with all our policy allowances, we are careful to apply this policy consistently and without unlawful discrimination.

Grievance, Disputes And Disciplinary Procedures

Nothing is a stronger testament to a company’s core values and competencies than the way in which they manage grievances, disputes and disciplinary procedures. At SSGC we take this very seriously. No employee will be victimised for being involved in racial discrimination complaints. No employee’s complaint will be minimised on the grounds of racial “oversensitivity.”

In applying disciplinary procedures, we are careful to consider how one of our employee’s behaviour could possibly be affected by the following:

  • Racial abuse or other racial provocation.
  • Communication and comprehension difficulties.
  • Differences in cultural background or behaviour.

Cultural And Religious Needs

It is of utmost importance that our team feels respected and comfortable during the time they spend with SSGC. We are flexible and sympathetic as to the particular cultural and religious needs our employees might have, especially if they may conflict with existing work requirements. Wherever possible, and safe, we strive to accommodate them - this includes prayer times or specific manners of dress. 

Communications And Language Training For Employees

Communication is the bedrock of any good business. The better the communication, the safer, more effective, and less discriminatory our operations will be. That is why we take steps to help employees whose levels of English may put them at a disadvantage. This includes providing, where practical:

  • Interpretation and translation facilities, and training in English language and in communication skills.
  • Training for managers and supervisors in the background and culture of racial minority groups. 
  • The use of alternative or additional methods of communication, where employees find it difficult to understand health and safety requirements, for example:
  • Safety signs and translations of safety notices.
  • Instructions through interpreters.
  • Instruction combined with industrial language training.

Instructions And Pressure To Discriminate

At SSGC we will never unlawfully instruct or pressure others to discriminate on racial grounds, or discriminate in response to such instructions or pressure. We understand, too, that this can intersect with more complicated social pressures. As such, we: 

  • Provide all employees, and particularly those in positions of authority or influence, training on recent provisions of the law.
  • Instruct decision-makers not to give way to pressure to discriminate.
  • Treat such violations as a disciplinary offence.


If a coherent and honourable policy is to be upheld across all levels of our organisation, we understand that our team must trust it to work fairly and effectively. We treat allegations or complaints of racial discrimination with the utmost seriousness, and will never victimise those who come forward with complaints or information.

Monitoring Equal Opportunity

An equal opportunities policy without strict monitoring and strong outcomes is just hot air. That is why SSGC regularly monitors the effects of selection decisions and personnel practices and procedures. Moreover, we do so in consultation with employee representatives - both to ensure that the policy meets the needs of those it is designed to protect, and to verify its efficacy. 

Part of our strategy involves analysis of:

  • The ethnic composition of the workforce of each plant, department, section, shift and job category, and changes in distribution over periods of time.
  • Selection decisions for recruitment, promotion, transfer and training, according to the racial group of candidates, and reasons for these decisions.

Wherever possible, reasons for selection and rejection are recorded at each stage of the selection process. In addition, selection criteria and personnel procedures are reviewed to ensure that they do not include requirements or conditions which constitute or may lead to unlawful indirect discrimination.

We analyse this information carefully and regularly. But more than that, we understand the importance of honest self-interrogation. So we reflect on a number of key and concrete questions:

Is there evidence that individuals from any particular racial group:

  • Do not apply for employment or promotion, or that fewer apply than might be expected?
  • Are not recruited or promoted at all, or are appointed in a significantly lower proportion than their rate of application?
  • Are underrepresented in training or in jobs carrying higher pay, status or authority?
  • Are concentrated in certain shifts, sections or departments?

If the answer to any one of these questions is yes, we are committed to taking decisive investigatory and reparative action. Deliberate acts of unlawful discrimination by employees is treated as a disciplinary offence.

Positive Action

We take advantage of legal provisions allowing SSGC to provide training for employees who are members of particular racial groups that have been underrepresented in particular areas of work. We do not, however, tolerate discrimination at the point of selection for work.

Such measures are important for the development of equal opportunity. Where there is under-representation of particular work, the following measures are taken wherever appropriate and reasonably practicable

  • Job advertisements designed to reach members of these groups and to encourage their applications: for example, through the use of the ethnic minority press, as well as other newspapers.
  • Use of the employment agencies and careers offices in areas where these groups are concentrated.
  • Recruitment and training schemes for school leavers designed to reach members of these groups.
  • Encouragement to employees from these groups to apply for promotion or transfer opportunities.
  • Training for promotion or skill training for employees of these groups who lack particular expertise but show potential: supervisory training may include language training.


The Responsibility Of Individual Employees

At SSGC we are committed to taking the lead in providing equal opportunities. However, to foster a deep and sound enactment of our policies, we recognise the role played by individual employees at all levels and of all racial groups in establishing good race relations. Their attitudes and activities are very important, and we are clear about the duties we expect of our team. 

We have a firm zero-tolerance policy towards the following:

  • Discrimination in the course of their employment against fellow employees or job applicants on racial grounds, for example, in selection decisions for recruitment, promotion, transfer and training.
  • Inducing, or attempting to induce other employees, unions or management to practise unlawful discrimination. 
  • Victimising individuals who have made allegations or complaints of racial discrimination or provided information about such discrimination.

By contrast, we have an equally form expectation that our employees will:

  • Co-operate in measures introduced by management designed to ensure equal opportunity and non-discrimination.
  • Where such measures have not been introduced, press for their introduction (through their trade union where appropriate).
  • Draw attention of management and, where appropriate, their trade unions to suspected discriminatory acts or practices.
  • Refrain from harassment or intimidation of other employees on racial grounds.

With the operational and social importance of communication in mind, we encourage individuals from racial minorities to recognise that in many occupations advancement is dependent on an appropriate standard of English and a sound understanding of industrial relations procedures. Therefore, we encourage our employees to:

  • Where appropriate, seek means to improve their standards of English.
  • Co-operate in industrial language training schemes.
  • Co-operate in training or other schemes designed to inform them of industrial relations procedures, company agreements, work rules, etc.
  • Where appropriate, participate in discussions with employers and unions, to find solutions to conflicts between cultural or religious needs and production needs.

The Responsibility Of Trade Unions

At SSGC we are supportive and encouraging of the crucial role trade unions play in our organisation’s business operations. We expect of this partnership an alignment in values concerning race relations. They too have a responsibility to ensure that their representatives and members do not discriminate against any particular racial groups in the admission or treatment of members, or as colleagues, supervisors, or subordinates.

Trade union officials at national and local level and shop floor representatives at plant level have an important part to play on behalf of their members in preventing unlawful discrimination and in promoting equal opportunity and good race relations. We encourage trade unions to press for equal opportunity policies so that measures to prevent discrimination at the workplace can be introduced with the clear commitment of both management and unions.

We expect trade unions not to discriminate in the admission or treatment of members, and to pay careful attention to members who raise concerns about discriminatory treatment - where such treatment is found to have occured, we expect this to be treated as a disciplinary offence. Additionally, we encourage trade unions to act positively by encouraging and providing training for members of particular racial groups which have been underrepresented in trade union membership or in trade union posts. We further expect trade unions to cooperate with the letter and the spirit of SSGC’s race relations policy, and direct them to this document or appropriate members of SSGC staff if there is any lack of clarity on expectations and procedures. 


The Responsibility Of Employment Agencies

Similarly, as outlined in our employment procedure, we expect any employment agencies with whom SSGC works to cooperate and comply with our company’s race relations policy. It is important to us that direct or indirect discriminatory practices are not admitted in any aspect of our company operations, and we understand this to extend to third party agencies we contract for hiring. 

We will never issue guidance or commentary that unlawfully violates this race relations policy, for example by specifying racial preferences in employee solicitation; we expect any employment agencies we use to be similarly zero-tolerance when it comes to their own practices.  

We are thorough and exhaustive in covering all aspects of SSGC business operations to ensure that healthy, non-discriminatory race relations are fostered and maintained at all levels of our company.

Approval For this Statement

This statement was approved by the Board of Directors on 27/10/2022 signed by Frano Lubura, Quality Manager/General Manager.

                                                                                                        SSGC Ltd, Registered in England and Wales
                                                                                Telephone: 0845643 6852; Registration Number 04494633, VAT
                                                             Registered Office: Unit 19 Ergo Business Park, Kelvin Road, Swindon,Wiltshire, SN3 3JW