DRAFT v0.1 — 21/06/2026 — for internal review and legal sign-off; not legal advice.

Equality, Diversity & Inclusion Policy

CDOCC Limited

1. Purpose and commitment

CDOCC Limited is committed to being a fair place to work and a welcoming place to visit. We want every member of staff, every job applicant, every customer and every supplier to be treated with dignity and respect, and to be judged on merit — never on who they are or on assumptions about them.

We work in hospitality and lettings. Our teams and our customers come from many different backgrounds, and that variety is a strength. This policy sets out:

• What the law requires of us;

• What we will not tolerate;

• What we expect from everyone; and

• How to raise a concern.

This policy supports — and does not replace — our legal duties under the Equality Act 2010.

2. Scope

This policy covers the whole working relationship, from first contact to final day, including:

• Recruitment, selection and advertising;

• Terms and conditions of employment, including pay and benefits;

• Training, learning and development;

• Promotion, transfers and allocation of shifts, sections and duties;

• Discipline, grievance, redundancy and dismissal; and

• The conduct of our people toward customers, guests, tenants, landlords, contractors and suppliers.

It applies wherever work is done — on our premises, at customers' or tenants' properties, off-site, at work-related events and socials, and online (including messaging groups, email and social media used for work).

3. The law — the Equality Act 2010

The Equality Act 2010 protects people from discrimination. It is unlawful to discriminate against, harass or victimise a person because of a protected characteristic.

3.1 The nine protected characteristics

1. Age

1. Disability

1. Gender reassignment

1. Marriage and civil partnership

1. Pregnancy and maternity

1. Race (including colour, nationality, and ethnic or national origin)

1. Religion or belief (including a lack of religion or belief)

1. Sex

1. Sexual orientation

3.2 The forms of unlawful conduct

Direct discrimination — treating someone less favourably than another because of a protected characteristic.

Example: refusing to promote a capable bartender because of their age.

This includes:

• Discrimination by association — treating someone worse because of someone they are connected to (for example, a person who cares for a disabled relative).

• Discrimination by perception — treating someone worse because you think they have a protected characteristic, even if they do not.

Indirect discrimination — applying a rule, policy or practice that applies to everyone but puts people who share a protected characteristic at a particular disadvantage, where the rule cannot be objectively justified.

Example: requiring all staff to work Saturday shifts without good reason, which may disadvantage people of certain religions.

Harassment — unwanted conduct related to a protected characteristic that violates a person's dignity, or creates an intimidating, hostile, degrading, humiliating or offensive environment. It does not matter whether the conduct was intended to have that effect.

Sexual harassment, and our specific duty to prevent it, is dealt with in the [Anti-Harassment & Sexual Harassment Policy].

Victimisation — treating someone badly because they have made a complaint about discrimination, supported someone else's complaint, or given information in connection with one (a "protected act"). Nobody will be punished for raising a genuine concern in good faith.

3.3 The duty to make reasonable adjustments

Where a disabled member of staff or job applicant is placed at a substantial disadvantage compared with non-disabled people, CDOCC Limited has a legal duty to make reasonable adjustments to remove or reduce that disadvantage. This duty is anticipatory and ongoing — we will think ahead, and we will not wait to be asked before considering what we can do.

Reasonable adjustments can apply to recruitment as well as to the job itself. What is "reasonable" depends on the circumstances, including how effective the change would be, its cost, and the size and resources of the business.

4. What we will not tolerate

CDOCC Limited will not tolerate any form of discrimination, harassment or victimisation, whether by or against staff, customers, tenants, landlords or suppliers. This includes:

• Offensive jokes, banter, name-calling, "wind-ups" or comments related to a protected characteristic;

• Displaying or sharing offensive material, including online;

• Excluding, isolating or undermining a colleague because of who they are;

• Refusing service, or treating a guest or tenant differently, because of a protected characteristic; and

• Pressuring, threatening or retaliating against anyone who raises a concern.

Discrimination, harassment and victimisation may be treated as misconduct or gross misconduct under the [Disciplinary & Grievance Procedure], and may lead to dismissal.

5. Expectations of behaviour

Everyone at CDOCC Limited is expected to:

• Treat colleagues, customers, tenants, landlords and suppliers with dignity and respect;

• Judge people on merit, ability and conduct — not on assumptions;

• Speak up if they see or experience discrimination or harassment;

• Co-operate with any investigation; and

• Take responsibility for their own behaviour, including outside normal hours where it affects work.

6. Recruitment and the employment lifecycle

We will apply this policy at every stage of employment.

• Recruitment and selection — see the inclusive recruitment section below. Selection is on merit against the genuine requirements of the role.

• Terms and pay — pay, benefits and terms are set on a fair and consistent basis, free from bias linked to a protected characteristic.

• Training and development — access to training and development is open and fair, and reasonable adjustments are made so disabled staff can take part.

• Promotion and progression — opportunities are advertised or offered fairly, and decisions are based on skills, performance and potential.

• Allocation of work — shifts, sections, rooms, rounds and duties are allocated fairly and not used to disadvantage anyone.

• Discipline, grievance and dismissal — these are handled consistently under the [Disciplinary & Grievance Procedure], with the same standards applied to everyone.

7. Inclusive recruitment — practical points

To recruit fairly in a hospitality and lettings setting:

• Write to the job, not the person. Job adverts describe the duties and the genuine requirements of the role, and avoid wording that could deter applicants of a particular age, sex or background.

• State that we welcome everyone and that we will make reasonable adjustments to the recruitment process on request.

• Focus on what the role actually needs. Do not set requirements (for example around availability, physical tasks or qualifications) unless they are genuinely needed for the job.

• Offer adjustments at interview — for example a different format, more time, a quieter space, a sign-language interpreter, or a written copy of questions.

• Ask job-related questions only. Do not ask about health, disability, pregnancy, plans to have children, religion or similar matters during selection, except in the limited circumstances the law allows (for example to make adjustments to the recruitment process itself).

• Keep notes. Record the reasons for selection decisions so they are fair, consistent and explainable.

8. Reasonable adjustments in a hospitality and lettings setting — practical examples

Adjustments are practical and case-by-case. In our settings they might include:

• Adjusting shift patterns or start times, or allowing more breaks;

• Providing an anti-fatigue mat, a stool, or task aids behind the bar or in housekeeping to reduce standing or lifting;

• Re-allocating a non-essential part of a role (for example a particular heavy task) where this can reasonably be done;

• Providing written instructions, larger-print rotas, or a coloured overlay for staff with dyslexia;

• Allowing a support animal or assistive device;

• Adjusting how a tenant or landlord communicates with us (for example by email, large print, or with extra time); and

• Time off for treatment or appointments related to a disability.

If you may need an adjustment, please speak to your manager or your manager. You do not have to share more than you are comfortable with, and we will keep the conversation confidential.

9. How to raise a concern

If you experience or witness discrimination, harassment or victimisation:

• Informal route — if you feel able, you can raise it directly or ask your manager for help. Sometimes a quiet word resolves matters quickly.

• Formal route — you can raise a formal complaint under the [Disciplinary & Grievance Procedure].

• Harassment and sexual harassment — for unwanted conduct of a sexual nature, or harassment related to a protected characteristic, see the [Anti-Harassment & Sexual Harassment Policy], which sets out specific reporting routes and our duty to prevent sexual harassment.

All concerns will be taken seriously, handled confidentially so far as possible, and investigated fairly. No one will be victimised for raising a genuine concern in good faith. Customers, tenants and suppliers can raise concerns with [JOB TITLE / CONTACT].

10. Gender pay gap reporting — our position

Employers with 250 or more employees must publish their gender pay gap figures each year under the gender pay gap reporting regulations.

CDOCC Limited currently has fewer than 250 employees, so this duty does not apply at present. We record this position deliberately. We will keep our headcount under review and, if CDOCC Limited reaches the threshold, we will comply with the reporting requirements. We may choose to monitor and review pay differences voluntarily as good practice.

11. Responsibilities

Directors / senior management are responsible for:

• Setting the tone, leading by example, and making sure this policy is resourced and followed;

• Reviewing the policy and acting on monitoring information.

Managers and supervisors are responsible for:

• Applying this policy fairly and consistently in recruitment, day-to-day work and decisions;

• Challenging unacceptable behaviour, dealing with concerns promptly, and not retaliating;

• Considering and arranging reasonable adjustments; and

• Completing and supporting equality and diversity training.

All staff are responsible for:

• Following this policy, treating others with respect, and not discriminating, harassing or victimising;

• Reporting concerns; and

• Co-operating with investigations and training.

12. Monitoring

CDOCC Limited may collect and review anonymised information (for example on the make-up of applicants and staff, and on the outcomes of complaints) to check that this policy is working and to identify where we can improve. Any monitoring data will be handled in line with our data protection obligations and kept confidential.

13. Training

• All new staff will be made aware of this policy during induction.

• Managers and supervisors will receive equality, diversity and inclusion training appropriate to their role, including on preventing harassment and on reasonable adjustments.

• Training will be refreshed periodically.

14. Linked policies

• [Anti-Harassment & Sexual Harassment Policy]

• [Disciplinary & Grievance Procedure]

• [Recruitment Policy]

• [Data Protection / Privacy Policy]

15. Review

This policy will be reviewed at least annually (next review 21/06/2027), and sooner if there is a relevant change in the law or in the circumstances of CDOCC Limited.

Legal review checklist

Use this list to confirm the policy is current and complete before sign-off. This draft has not been checked by a solicitor — every box must be confirmed by a qualified adviser before use.

• [ ] Confirm the nine protected characteristics and the Equality Act 2010 wording are stated correctly and remain current as at the sign-off date.

• [ ] Confirm the definitions of direct discrimination (including by association and perception), indirect discrimination, harassment, victimisation and reasonable adjustments are legally accurate.

• [ ] Confirm alignment with the latest position on the employer duty to prevent sexual harassment (Worker Protection Act 2023, in force from 26 October 2024) and that cross-references to the [Anti-Harassment & Sexual Harassment Policy] are correct.

• [ ] Confirm the gender pay gap reporting threshold (250+ employees) and the recorded "does not currently apply" position are accurate for the relevant entity.

• [ ] Check for any new legislation or case law affecting EDI obligations since the draft date (including any change to the definition of "sex" and its interpretation).

• [ ] Confirm the rules on pre-employment health and disability questions (section 60, Equality Act 2010) are correctly summarised in the recruitment section.

• [ ] Confirm the policy correctly reflects each legal entity it will be issued under (CDOCC Limited placeholder resolved correctly — Duke of Cornwall / Bugle Inn Ltd; Luv Plymouth Lettings Ltd; Chy Lowen Holidays).

• [ ] Confirm references to monitoring and data collection comply with UK GDPR / Data Protection Act 2018, including the handling of special category data.

• [ ] Confirm the policy is consistent with the linked Disciplinary & Grievance and Recruitment policies and that all cross-references resolve.

• [ ] Confirm whether occupational requirements or positive action provisions need to be addressed for any specific role.

• [ ] Confirm the non-contractual status statement is appropriate and consistent with the contract of employment and staff handbook.

• [ ] Fill in all placeholders: CDOCC Limited, your manager, [CONTACT], and review/owner details.

• [ ] Set the final effective date and the next review date.