Equality, Diversity & Inclusion Policy

Document title

Version

1.0

Status

Approved

Owner

Quality, Safety & Environmental Manager

Prepared by

Document reference

SGU-POL-008

Classification

Commercial in Confidence

Issue date

29 March 2026

Next review due

29 March 2027

Approved by

Darren Lewis

Version history

Version

Date

Description of change

Author

1.0

29 March 2026

First issue (with professional re-write)

______________

1.0

29 March 2026

Approved and signed by Director

D. Lewis

1. Purpose

Solar Group Utilities Ltd ("SGU" or "the Company") is committed to being an equal opportunities employer and to fostering a working environment that is fair, respectful and free from unlawful discrimination. The Company values diversity as a source of strength and recognises that treating people fairly is both a legal

obligation and sound business practice.

The purpose of this policy is to set out the Company's commitment to equality, diversity and inclusion, to explain how that commitment is delivered in practice, and to make clear the responsibilities of everyone connected with the Company. It supports compliance with the Equality Act 2010 and forms part of the

Company's integrated management system certified to ISO 9001:2015, ISO 14001:2015 and ISO 45001:2018.

2. Scope

This policy applies to all directors, employees, workers, agency staff, apprentices, self-employed contractors and job applicants, whether full-time, part-time, temporary or permanent. Given the nationally distributed nature of the Company's engineering workforce, it applies equally to those working at Company premises, at client sites, at wind, solar and battery installations, and while working remotely or travelling on Company business. The policy governs all aspects of the working relationship, including recruitment and selection, terms and conditions, pay and benefits, training and development, promotion, performance management, discipline and grievances, and the ending of employment. It also applies to the Company's dealings with clients, suppliers, visitors and other third parties.

3. Policy Statement and Legal Framework

The Company is committed to eliminating unlawful discrimination and to promoting equality of opportunity for all. No job applicant, employee, worker or other individual will receive less favourable treatment, or be disadvantaged by conditions or requirements that cannot be justified, on the grounds of a protected characteristic. This policy is underpinned by the Equality Act 2010 and related legislation, including the Employment Rights Act 1996, the Part-time Workers (Prevention of Less Favourable Treatment) Regulations 2000, the Fixedterm Employees (Prevention of Less Favourable Treatment) Regulations 2002 and the Human Rights Act 1998. The Company will comply with these requirements in full and will keep its practices under review as the law develops. The Company will not tolerate discrimination in any form, whether direct or indirect, intentional or unintentional. Nor will it tolerate harassment, victimisation or bullying. Any such conduct is treated as a serious matter and may result in disciplinary action up to and including dismissal.

4. Protected Characteristics

Under the Equality Act 2010, it is unlawful to discriminate against a person because of any of the following protected characteristics:

age;
disability;
gender reassignment;
marriage and civil partnership;
pregnancy and maternity;
race, including colour, nationality and ethnic or national origin;
religion or belief, including lack of belief;
sex;
sexual orientation.

5. Forms of Prohibited Conduct

The Company recognises and prohibits the following forms of unlawful conduct defined in the Equality Act 2010:

Direct discrimination — treating someone less favourably because of a protected characteristic than another person is or would be treated.
Indirect discrimination — applying a provision, criterion or practice that puts people sharing a protected characteristic at a particular disadvantage and that cannot be objectively justified as a proportionate means of achieving a legitimate aim.
Harassment — unwanted conduct related to a protected characteristic that has the purpose or effect of violating a person's dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment. This includes sexual harassment and third-party harassment.
Victimisation — subjecting a person to a detriment because they have made, supported or intend to make a complaint or allegation, or have given evidence, in relation to discrimination.
Discrimination arising from disability, and failure to make reasonable adjustments for a disabled person.

6. Recruitment, Selection and Employment

Selection for employment, promotion, training, remuneration and any other benefit is based solely on aptitude, skills, experience and ability to perform the role. Job criteria, person specifications and selection methods are kept relevant to the requirements of the role and are reviewed to ensure they do not create unjustified barriers. The Company monitors its employment practices and procedures, and amends them where necessary, to ensure that no unfair or unlawful discrimination — whether direct, indirect, overt or latent — arises. All employees are helped and encouraged to develop their full potential so that the talents of the workforce are fully used.

7. Reasonable Adjustments and Disability

The Company is committed to making reasonable adjustments to remove or reduce disadvantage faced by disabled applicants, employees and workers, in accordance with its duties under the Equality Act 2010. This may include adjustments to premises, working arrangements, equipment, duties or recruitment processes. Individuals who consider that they may require an adjustment are encouraged to raise this with their line manager, the QSE Manager or the Company's retained HR adviser, Auxil Ltd. Each request is considered on its merits, in consultation with the individual and, where appropriate, with occupational-health or specialist advice. The Company will also take reasonable steps to improve access to information, for example by providing documents in alternative formats where required.

8. Equal Pay

The Company is committed to the principle of equal pay for all employees. Individuals are entitled to the same contractual pay and benefits for carrying out the same work, work rated as equivalent, or work of equal value, in accordance with the Equality Act 2010. Pay and benefit decisions are made objectively and free from bias related to any protected characteristic.

9. Diversity and Inclusion

The Company values people as individuals with diverse backgrounds, opinions, cultures, lifestyles and circumstances, and seeks to create a working environment in which those differences are recognised, respected and valued. Equality, diversity and inclusion are treated as everyday practice rather than as a compliance exercise.

The Company is committed to:

creating an environment in which the individual contributions of staff are recognised and valued, and in which everyone is treated with dignity and respect;
providing training, development and progression opportunities on a fair and consistent basis;
supporting an inclusive culture in which employees feel able to raise concerns, and to seek assistance with matters affecting them — for example caring responsibilities or the effects of domestic abuse — regardless of their background, identity or circumstances;
signposting employees to the Employee Assistance Programme provided through Vitality where personal support is needed;
reviewing employment practices and procedures to ensure they remain fair and inclusive.

10. Unconscious Bias

The Company recognises that unconscious bias — where views about an individual are formed without the decision-maker being aware of it — can affect decisions about recruitment, promotion, development and day-to-day working relationships. The Company works to guard against such bias in all employment decisions, with a focus on promoting diversity and inclusion. In support of this the Company applies measures such as referring to defined, role-relevant criteria when making selection decisions, making significant decisions collectively between management and the HR function, and using diverse decision-making panels where practicable.

11. Responsibilities

The Director responsible for Equality, Diversity & Inclusion is Darren Lewis (Director), who provides leadership on EDI and oversees this policy. The Board of Directors holds ultimate responsibility for this policy and for ensuring that adequate resources are available to implement it. The Directors lead by example and champion equality, diversity and inclusion throughout the Company.

The QSE Manager has particular responsibility for implementing, monitoring and reviewing this policy, ensuring that personnel policies and procedures are administered so as to promote equality of opportunity and eliminate unlawful discrimination.
Managers and supervisors are responsible for applying this policy fairly and consistently within their teams, for setting an appropriate standard of behaviour, and for dealing promptly and appropriately with any concerns raised.
All employees, workers and contractors are responsible for treating colleagues, clients and others with dignity and respect, for co-operating with measures introduced under this policy, and for reporting any discrimination, harassment or victimisation of which they become aware.
The Company's retained HR and health & safety adviser, Auxil Ltd (CMIOSH), provides professional advice and support on the application of this policy where required.

12. Raising Concerns and Complaints

Any employee, worker, contractor, job applicant or client who believes they have been subjected to discrimination, harassment, victimisation or bullying is encouraged to raise the matter without fear of reprisal. Employees should raise concerns with their line manager, the QSE Manager or, where more appropriate, through the Company's grievance procedure. Complaints from clients or other third parties are handled through the relevant complaints procedure. All complaints are treated seriously, dealt with confidentially so far as reasonably practicable, and investigated fairly and promptly. Individuals who raise a genuine concern, or who assist with an investigation, will not be victimised for doing so. Making a complaint in good faith that is not upheld will not of itself result in any detriment.

13. Breaches of this Policy

Any breach of this policy is treated as a serious matter. Conduct amounting to discrimination, harassment, victimisation or bullying by an employee, worker or contractor is regarded as misconduct and may lead to disciplinary action in accordance with the Company's disciplinary procedure, up to and including summary dismissal in cases of gross misconduct. Individuals should also be aware that, in certain circumstances, they may be held personally liable in law for acts of unlawful discrimination or harassment committed in the course of their work, in addition to any liability of the Company.

14. Review

This policy is reviewed at least annually, and additionally following any significant change in legislation, organisational structure or working practices, to ensure it remains effective and legally compliant. Responsibility for the review rests with the QSE Manager, with support from Auxil Ltd, and revisions are approved by the Board of Directors.

Authorisation

This document is issued and authorised on behalf of Solar Group Utilities Ltd:

Signed:

Position:

Name: Darren Lewis

Date: 29 March 2026