A fair, inclusive and respectful business, including on other people’s premises
1. Our commitment
Vitalex is committed to equality, diversity and inclusion in everything we do. We value the differences people bring, we treat everyone fairly and with respect, and we do not tolerate discrimination. This policy reflects our obligations under the Equality Act 2010 and is routinely requested in NHS and public-sector procurement.
2. What this means
We will not discriminate against, harass or victimise anyone because of a protected characteristic: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, or sexual orientation. This applies to:
- ▪ recruitment, selection, pay, development and every other aspect of employment;
- ▪ our dealings with customers, suppliers, contractors and visitors; and
- ▪ the working environment, which must be free from bullying and harassment.
3. Preventing harassment
Section 40A of the Equality Act 2010 places a positive duty on employers to take reasonable steps to prevent sexual harassment of their workers. This is a preventative duty: we cannot wait for an incident and then respond. An employment tribunal can increase compensation by up to 25% where the duty has been breached.
From 30 October 2026 that standard rises. Employers must take all reasonable steps to prevent sexual harassment, and become directly liable where a worker is harassed by a third party (a customer, contractor, clinician or visitor) across all protected characteristics, unless all reasonable steps were taken to prevent it.
Why this matters more for us than for most businesses of our size
Our commercial model depends on colleagues working on other organisations’ premises: NHS theatres, private hospitals, dental practices and veterinary surgeries. Those are precisely the third-party settings the October 2026 duty is aimed at, and we do not control the behaviour of the people in them.
We are not expected to control every third party. We are expected to have anticipated the risk, put measures in place, and acted when something is reported.
3.1 The steps we take
- ▪ we carry out and record a harassment risk assessment covering our own workplace and field visits to customer sites, and review it at least annually;
- ▪ colleagues attending customer sites are briefed on how to report an incident and are told they may withdraw from any situation in which they feel unsafe, without needing permission and without commercial consequence;
- ▪ we act on reports of third-party harassment, including by raising the matter with the customer organisation and, where necessary, declining to attend that site again;
- ▪ we make clear to customers and suppliers that our colleagues are entitled to the same respect on their premises as on our own; and
- ▪ we treat harassment by anyone at Vitalex as a disciplinary matter.
3.2 Reporting
Any incident of harassment, whether by a colleague or by a third party, should be reported to the Managing Director, or to the Chief Executive Officer where that is not appropriate. Reports are taken seriously, handled confidentially and acted on. No one who reports harassment will suffer any detriment for doing so.
A report of sexual harassment is also a qualifying disclosure for whistleblowing purposes, so the protections in our Whistleblowing Policy apply to it in addition to those in this policy.
4. Inclusion in practice
- ▪ we make decisions on merit and on objective, job-related grounds;
- ▪ we make reasonable adjustments so that disabled people are not disadvantaged, in employment and as users of our website and services;
- ▪ we aim to make our communications and our website accessible, as set out in our Accessibility Statement; and
- ▪ we treat all complaints of discrimination seriously and confidentially.
5. Responsibilities
Everyone at Vitalex is responsible for treating others fairly and for supporting an inclusive culture. The Managing Director is responsible for implementing this policy, for maintaining the harassment risk assessment, and for handling any concern raised under it. Discrimination or harassment by anyone at Vitalex is a disciplinary matter.
6. Raising a concern
Anyone who believes they have been treated unfairly, or who has witnessed such treatment, should raise it with the Managing Director, or through the grievance or whistleblowing routes as appropriate. Concerns will be handled promptly and without fear of reprisal.
No settlement agreement or confidentiality clause used by Vitalex will prevent anyone from disclosing information about harassment or discrimination.
7. Review
The Board owns this policy and reviews it at least annually, and whenever the law changes.