1. GENERAL

1.1 Cream Recruit embraces diversity and will seek to promote the benefits of diversity in all of our business activities.
We will seek to develop a business culture that reflects that belief. We will seek to widen the media in which we recruit
to ensure as diverse an employee and candidate base as possible. We will strive to make sure that our clients meet their
own diversity targets.

1.2 Cream Recruit is committed to diversity and will promote diversity for all employees, workers and applicants and shall
adhere to such a policy at all times. We will review on an on-going basis all aspects of recruitment to avoid unlawful
or undesirable discrimination. Cream Recruit will treat everyone equally irrespective of sex, sexual orientation,
gender reassignment, marital or civil partnership status, age, disability, colour, race, nationality, ethnic or national origin,
religion or belief, political beliefs or membership or non-membership of a Trade Union or spent convictions, and places an
obligation upon all staff to respect and act in accordance with the policy. Cream Recruit is committed to providing training
for its entire staff in equal opportunities practice.

1.3 Cream Recruit shall not discriminate unlawfully when deciding which candidate/temporary worker is submitted for a vacancy
or assignment, or in any terms of employment or terms of engagement for temporary workers. Cream Recruit will ensure that each
candidate is assessed only in accordance with the candidate’s merits, qualifications and abilities to perform the relevant duties
required by the particular vacancy.

1.4 Cream Recruit will not accept instructions from clients that indicate an intention to discriminate unlawfully.

2. DISCRIMINATION

Unlawful discrimination occurs in the following circumstances:

2.1. Direct Discrimination

Direct discrimination occurs where one individual treats or would treat another individual less favourably on grounds
of sex, sexual orientation, gender reassignment, marital or civil partnership status, age, disability, colour, race, nationality,
ethnic or national origin, religion or belief, political beliefs (“the protected categories”).
It is unlawful for a recruitment consultancy to discriminate against a person on the grounds that they are members
of a protected category. -

• in the terms on which the recruitment consultancy offers to provide any of its services;
• by refusing or deliberately omitting to provide any of its services;
• in the way it provides any of its services.

Direct discrimination would also occur if a recruitment consultancy accepted and acted upon a job registration from an employer
which states that certain persons are unacceptable because they are members of a protected category, unless one of the
exceptions applies, for instance, the job demands a genuine occupational requirement or, in the case of age, the discrimination
can be lawfully justified.

2.2. Indirect Discrimination

Indirect discrimination occurs where an agency or employer applies a provision, criterion or practice generally, but which
is such that a proportion of persons in a protected category who can comply with it are considerably smaller than
the proportion of persons who are not in that protected category. Indirect discrimination would also occur if a recruitment
consultant accepted and acted upon an indirectly discriminatory instruction from an employer.

If the vacancy requires characteristics which amount to a genuine occupational requirement or the instruction is lawfully
discriminatory due to a statutory exception or objective justification, Cream Recruit will not deal further with the vacancy
unless the client provides written confirmation of such genuine occupational requirement, exception or justification.

2.3 Disabled Persons

2.3.1 Direct discrimination against a person occurs where, if for a reason which relates to the disabled person's disability,
an individual:
• treats him less favourably than he treats, or would treat others to whom that reason does not or would not apply, and,
• the employer cannot show that the treatment in question is justified.

Or

• If on the ground of a disabled person’s disability, he treats the disabled person less favourably than he treats or would treat
a person not having that particular disability, whose relevant circumstances, including his abilities, are the same as, or not
materially different from, those of the disabled person. This type of direct discrimination can never be justified.
2.3.2 Duty to make reasonable adjustments and to provide auxiliary aids and services.
This is a similar protection to indirect discrimination in the other protected categories.

Where a provision, criterion or practice applied by or on behalf of an employer, or any physical feature of the employer’s
premises, places a disabled person at a substantial disadvantage in comparison with persons who are not disabled, it will
be the duty of an employer to take such steps as are reasonable, in all the circumstances of the case, to remove the provision,
criterion, practice or physical feature.

Agencies must take reasonable steps to provide auxiliary aids or services if this would make it easier for the disabled person
to use their services. For instance, an appropriate auxiliary aid or service can include the provision of information on audiotape
or provision of a sign language interpreter. Cream Recruit will not discriminate against a disabled person on the grounds
of disability

• in the arrangements i.e. application form, interview or arrangements for selection for determining to whom a job should
be offered; or

• in the terms on which employment or engagement of temporary workers is offered; or

• by refusing to offer, or deliberately not offering the disabled person a job for reasons connected with their disability; or

• in the opportunities afforded to the person for receiving any benefit, or by refusing to afford, or deliberately not affording
him or her any such opportunity; or

• by subjecting him or her to any other detriment (detriment will include refusal of training or transfer, demotion, reduction
of wage, or harassment).

Cream Recruit will accordingly make career opportunities available to all people with disabilities and every practical effort
will be made to provide for the needs of staff, candidates and clients. Wherever possible Cream Recruit will make reasonable
adjustments to hallways, passages and doors in order to provide and improve means of access for disabled
employees and workers. However, this may not always be feasible, due to circumstances creating such difficulties
as to render such adjustments as being beyond what is reasonable in all the circumstances.

3. AGE DISCRIMINATION

Cream Recruit will not discriminate directly or indirectly, harass or victimise any person on the grounds of their age.
We will encourage clients not to include any age criteria in job specifications and every attempt will be made to persuade
clients to recruit on the basis of competence and skills and not age. Cream Recruit is committed to recruiting and retaining
employees whose skills, experience, and attitude are suitable for the requirements of the various positions regardless of age.

No age requirements will be stated in any job advertisements on behalf of the company.
Cream Recruit will request age as part of its recruitment process but such information will not be used as selection, training
or promotion criteria or in any detrimental way and is only for compilation of personal data, which the company holds on all
employees and workers and as part of its equal opportunities monitoring process.

4. PART-TIME WORKERS

This Diversity Policy also covers the treatment of those employees and workers who work on a part-time basis.
Cream Recruit recognises that it is an essential part of this policy that part time employees are treated on the same terms,
with no detriment, as full time employees (albeit on a pro rata basis) in matters such as rates of pay, holiday entitlement,
maternity leave, parental and domestic incident leave and access to our pension scheme. Cream Recruit also recognises
that part time employees must be treated the same as full time employees in relation to training and redundancy situations.

5. HARASSMENT POLICY

5.1 Cream Recruit is committed to providing a work environment free from unlawful harassment on grounds of sex,
sexual orientation, gender reassignment, marital or civil partnership status, age, disability, colour, race, nationality,
ethnic or national origin, religion or belief, political beliefs or any other basis protected by legislation is unlawful
and will not be tolerated by Cream Recruit.

5.2 This policy prohibits unlawful harassment by any employee or worker of Cream Recruit.

5.3 Examples of prohibited harassment are: -

5.3.1 Verbal or written conduct containing derogatory jokes or comments,
5.3.2 Slurs or unwanted sexual advances
5.3.3 Visual conduct such as derogatory or sexually orientated posters,
5.3.4 Photographs, cartoons, drawings or gestures which some may find offensive,

5.3.5 Physical conduct such as assault, unwanted touching, or any interference because of sex, race or any other protected category basis, Threats and demands to submit to sexual requests as a condition of continued employment
or to avoid some other loss, and offers of employment benefits in return for sexual favours,
5.3.6 Retaliation for having reported or threatened to report harassment.
5.4 If you believe that you have been unlawfully harassed, you should make an immediate report to Jenny M Muir
followed by a written complaint as soon as possible after the incident. Your complaint should include:

• Details of the incident
• Name(s) of the individual(s) involved
• Name(s) of any witness(es)

5.5 Cream Recruit will undertake a thorough investigation of the allegations. If it is concluded that unlawful harassment
has occurred, remedial action will be taken.

5.6 Any employee(s) who Cream Recruit finds to be responsible for unlawful harassment will be subject to the disciplinary
procedure and any sanction may include termination. A person who discriminates or harasses may be personally liable
for payment of compensation to the person offended, in addition to any compensation payable by Cream Recruit.
There is no statutory cap on the amount of compensation which may be awarded in discrimination cases.

Under the Criminal Justice Act 1994, harassment became a criminal offence, punishable by a fine of up to £5,000 and/or
a prison term of up to 6 months. Under the Protection from Harassment Act 1997, the penalties for aggravated harassment
are an unlimited fine and/or 5 years imprisonment.

6. GENDER REASSIGNMENT POLICY

6.1 Cream Recruit recognises that any employee or worker may wish to change their gender during the course
of their employment with the Company.

6.2 Cream Recruit will support any employee or worker through the reassignment provided that full medical counselling
has been undertaken and Cream Recruit has access to any relevant medical reports.

6.3 Cream Recruit will make every effort to try to protect an employee or worker who has undergone, is undergoing or intends
to undergo gender reassignment, from discrimination or harassment within the workplace.

6.4 All employees and workers will be expected to comply with Cream Recruit’s policy on harassment in the workplace.
Any breach of such a policy will lead to the appropriate disciplinary sanction.

6.5 Where an employee is engaged in work where the gender change imposes genuine problems, Cream Recruit will make every
effort to reassign the employee or worker to an alternative role in the Company, if so desired by the employee.

6.6 Any employee or worker suffering discrimination on the grounds of gender reassignment should make recourse
to the Company’s grievance procedure.

7. COMPLAINTS AND MONITORING PROCEDURES

7.1 Cream Recruit has in place procedures for monitoring compliance with this policy and for dealing with complaints
of discrimination. These are available from Christine Booth and will be made available immediately upon request.

7.2 Any discrimination complaint will be investigated fully.