INTRODUCTION

Equal opportunities are based on respect of individual human dignity, fairness and justice. It recognises that certain sections of the Community have not only been affected in the past by discrimination, but are still denied opportunities for developing their talents to the full. The success of our business relies upon our attracting and retaining people from the widest possible backgrounds with the widest, most diverse range of attitudes, opinions and beliefs.

An Equal Opportunities Policy is a statement of intent, derived from these values. Such a Policy, when backed by operational objectives, provides a basis for endeavours to achieve equal opportunities within the whole sphere of an organisation's activities.

It is the policy of Birmingham City Football Club to provide equal opportunities for all employees. The Company will also take every action possible to avoid discrimination on the grounds of sex, sexual orientation, race, ethnic origin, religious beliefs or disability.

In addition, the Company deplores any form of harassment amongst employees. If any employee is found guilty of harassment, disciplinary action will be taken which could lead to dismissal. In cases of serious harassment, criminal action may be taken against the perpetrator.

It is the duty of all Supervisors and Managers to uphold this policy and to report any known actions of discrimination or harassment to a Director immediately. All employees are responsible for their own behaviour and are expected to act in a manner that avoids and discourages any form of discrimination or harassment.

Because discrimination is deeply rooted however, and takes many forms, some of which are not easily recognisable, even people with the best of intentions often discriminate unintentionally. The Club believes, therefore, that the adoption of an explicit Equal Opportunities Policy will: -

" Raise the general level of consciousness throughout the Club.

" Set out and clarify expectations for staff, directors and customers, and the other agencies with whom we work to provide professional football and associated services.

" Ensure compliance with the relevant sections of the Race Relations Act 1976, the Sex Discrimination Act 1975, and the Football Spectators Act.

" Facilitate the monitoring of practice.

EQUAL OPPORTUNITIES POLICY STATEMENT

Birmingham City Football Club is an Equal Opportunities employer. In everything we do we seek to respect people for who they are, not what they are. We judge people only for the way they do their job and for what they can contribute. We aim to achieve an environment in which everyone feels free to contribute to the organisation and to maximise their potential without unfair obstruction. It is our policy to ensure that all existing, potential employees, customers or any associate of the Football Club receive equal consideration, and experience no discrimination, harassment or less favourable treatment either directly or indirectly. The Football Club is committed to the elimination of unlawful or unfair discrimination on the grounds of gender, race, disability, colour, ethnic and national origin, nationality, sexuality, marital status, responsibility for dependants, religion and trade union activity.

The Club will, within the terms of its Memorandum and Articles of Association and available resources, aim to achieve equality of opportunity, both in the provision of its services, and in the recruitment and employment of staff.

In pursuit of this aim, the Club will not discriminate, either directly or indirectly on the grounds of race, gender, age, nationality, ethnic or natural origin, political or religious belief, sexual orientation, disability or marital status, by applying conditions or requirements which cannot be shown to be justified.

To this end, the Club commits itself to ensuring that:

No event, action or behaviour is condoned or promoted within the Club which is threatening, insulting, demeaning or otherwise unwelcoming to any individual or section of the community on the grounds of race, gender, age, nationality, ethnic or national origin, political or religious belief, sexual orientation, disability or marital status.

Action will be taken to prevent any words or behaviour infringing by spectators, in accordance with the notices displayed in various places in St Andrew's Stadium. This action may take the form of exclusion from a match or matches and, if the words or behaviour are repeated, banning the person or persons concerned from attendance at future matches for a period to be decided by the Club's Board of Directors.

THE LEGISLATIVE OBLIGATIONS

Birmingham City Football Club Equal Opportunities Policy has been developed within the framework of existing legislation, the relevant acts of parliament being:-

2.1 Sex Discrimination Act 1975 (and its amendments 1986)
This act makes it unlawful to discriminate directly or indirectly on the grounds of sex or marital status, or to apply requirements or conditions which have a disproportionately disadvantageous effect on people of a particular sex or marital status where these cannot be justified. It also applies to discriminatory employment advertising and makes it unlawful to apply pressure to discriminate or to aid discrimination by another person.

2.2 Equal Pay Act 1980 (and its amendments 1983)
This act established the right of women and men to equal treatment in relation to contractual terms and conditions of employment when they are employed on the same or broadly similar work, or on work, although different, of equal value.

2.3 Race Relations Act 1976
This Act makes it unlawful to discriminate directly or indirectly on the grounds of colour, race, nationality (including citizenship) or ethnic or national origin, or to apply requirements or conditions which have disproportionately disadvantageous effect on people of a particular racial group which cannot be justified on non-racial grounds. It also applies to discriminatory employment advertising and makes it unlawful to apply pressure or to aid discrimination by another person.

2.4 Disabled Persons (Employment Acts 1944 and 1958)
These acts provide specific provisions for the employment of people with disabilities. Under the provisions of the quota scheme employers with more than 20 staff have an obligation to employ at least 3% registered disabled people.

2.5 The Chronically Sick and Disabled Persons Act 1970 (and its amendments 1976)
These acts impose obligations on employers to provide access to premises and facilities for people with disabilities.

2.6 The Rehabilitation of Offenders Act 1974
This Act provides that if a convicted person completes a specified period without being convicted of further offences, the conviction can be regarded as spent. These offences then do not have to be revealed and may not be used as grounds for exclusion from employment or promotion. Certain occupations are not covered by the Act.

IMPLICATIONS OF THE LEGISLATION

If these legal requirements are contravened, both Birmingham City FC and the individual concerned will be rendered liable to legal proceedings. However, if the employer (Birmingham City FC) can prove that they have taken the necessary steps to prevent acts of discrimination, only the individual will be considered liable for the unlawful act. In addition, any employee who is found to discriminate against any fellow colleague or associate or customer or participates in any discriminatory behaviour will be subject to disciplinary action which may include dismissal. This applies primarily to the Race relations Act 1976 and the Sex Discrimination Act 1975 and 1986. It is essential that all people bound by this policy are aware of their obligations under the law as ignorance is no defence.

DEFINITIONS OF TERMS AS USED IN THE POLICY

This policy document refers to four categories of discrimination which are defined as follows:-

3.1 Direct Discrimination - Results from treating a person less favourably on grounds of gender, gender reassignment, race, disability, colour, ethnic and national origin, age, nationality, sexuality, marital status, responsibility for dependants, or religion.

3.2 Indirect Discrimination - Arises when a condition or requirement, although applied equally to the above groups listed in the policy statement, has the effect of excluding, penalising or treating less favourably any of these groups, and cannot be shown to be justifiable and will be to the detriment of those who cannot comply with it.

3.3 Victimisation - Occurs if a person is given less favourable treatment than others, because they have exercised their rights under the policy or the relevant legislation.

3.4 Harassment - Is defined as any behaviour, deliberate or otherwise, directed at an individual, that is found to be offensive or objectionable to the recipient, and that might threaten an employee's job security or create an intimidating environment.

PROGRAMME OF ACTION

The following actions outline the steps which Birmingham City FC will take to develop and implement good employment and Human Resources practices in pursuit of its equal opportunities policy.

RECRUITMENT

It is impossible for any Football Club to apply the principles of equal opportunities to the recruitment of players, since this depends largely upon the personal and professional judgement of the Manager. This judgement will however, be exercised within the principles set out in this policy. In the recruitment of non-playing staff, within its overall aims and subject to the need to maintain its services, often at short notice, the Club will use its best endeavours to: -

" Advertise job vacancies internally and externally and as widely as possible to ensure that people with appropriate knowledge and skill from all groups and both sexes are attracted.
" Avoid discriminatory language and all jargon.
" Never allow one person to short-list.
" Be aware of personal prejudices, and how they can affect judgement.
" Ensure that job titles are not sex biased and are accurate.
" Avoid over inflated or unnecessary job criteria in person specifications when recruiting new employees.
" Check that job requirements are really necessary to do the job and are not reflections of traditional practices that may be operating to the disadvantage of men or women, minorities, the disabled or older people.
" Guard against sex/race stereotyping, particularly in illustrations, advertisements and recruitment literature.
" Ensure that recruitment methods used are fair to all potential applicants and do not effectively screen out minorities or members of one sex.
" As a general rule, not use age as a primary discriminator in recruitment and selection.
" Ensure that only trained or experienced interviewers conduct preliminary selection interviews.
" Ensure that interviewers avoid questions that could be construed as discriminatory.
" Maintain clear interview notes and records of all applicants.
" Monitor all decisions made to ensure that they are consistent with an Equal Opportunities Policy.

JOB DESCRIPTIONS

Every job without exception must have a written job description listing the duties and responsibilities. Employees with the responsibility for writing job descriptions must ensure that the duties and responsibilities specified are based solely on the genuine requirements of the job. Failure to do this could result in indirect discrimination e.g. specifying that unsocial working hours are necessary when it is not a general requirement of the job.

THE PERSON SPECIFICATION

Each job must have a person specification. The person specification sets out the experience, skills, abilities, and qualifications required by an applicant to fulfil the duties of the job as outlines in the job description. The person specification will be used to draw up the criteria against which applications will be assessed at the short listing and interviewing stages. If a person specification already exists for a particular job this should be reviewed before the job is advertised.

The person specification must be strictly relevant to the job. The requirements must not be unnecessarily restricted so as to unjustifiably exclude any particular group or individual.

Care must therefore be exercised when:-

" requesting specific qualifications rather than evidence of ability to carry out the duties and responsibilities of the job;
" Using age criteria to determine responsibility or maturity, or imposing a restrictive age range.

The person specification must not include requirements which may lead to unfair or unlawful discrimination. Criteria contained in a person specification should be measurable in that it should be possible to determine whether a candidate possesses the qualifications, skills and abilities, experience and training appropriate to the job.

The person specification must be based on two types of criteria:-

" The essential criteria - essential requirements for the adequate performance of the job.
" The desirable criteria- desirable requirements which are not essential, nut could enhance work performance.

The person specification must be reviewed each time a job becomes vacant to ensure that stereotyping is eradicated; for example, attempting to replace the person leaving with someone of similar qualities and characteristics could be disadvantageous to persons of one race, gender or people with disabilities.

ADVERTISING VACANCIES

The following should be carried out in connection with job advertisements:-

" Advertisements must only request educational and other qualifications where it can be clearly shown that this is the requirement for the job or is an essential entry qualification to a recognised compulsory course of study.
" All Birmingham City Football Club employees must be made aware of existing vacancies via the staff notice boards.

INFORMATION TO APPLICANTS

All applicants must be given adequate and up-to-date information when they apply for a position with Birmingham City Football Club.

Along with the approved application forms, the Human Resources Department must also be in a position to provide candidates with an up-to-date job description.

SELECTION FOR SHORT LIST

All those responsible for preparing a short list for interview must have at their disposal a relevant job description, advertisement and person specification. Those concerned must use the job description and person specification in determining the short list criteria which must be designated essential or desirable. When short listing domestic circumstances, gender and racial origin should be disregarded. If a candidate is not short listed, the reason should be recorded on the application form. No one should be short listed unless they meet all the essential criteria. Once short listed applicants have been determined, the Human Resources Department will invite then for an interview.

INTERVIEW PANEL

Each panel must include a representative from the department concerned and a member of the Human Resources Department and/or a member of the management team.

THE INTERVIEW

" The Human Resources Department or Head of Department will be responsible for the administrative arrangements for the interview.
" Prior to the interview, discussions must take place between those present as to the intended pattern and conduct of the interview, together with job requirements. The essential and desirable criteria for selection and areas of questioning which relate to these points must be clearly established.
" All those involved in interviews must have available and make use of the job description and person specification for the vacant job.
" All those involved must be free from any other commitment during the interview period and must see all the interviewees.
" Interviewers must not ask questions about current and future personal and family circumstances. Candidates must not be subjected to more rigorous questioning because of their ethnic origin, gender or disability. Candidates must not be asked questions which refer to their gender or ethnic origin.
" Interviewers must avoid pre-conceptions and assumptions about individuals because of their gender, ethnic origin, disabilities, sexuality or age, or presume characteristics which would suggest unsuitability for employment.
" Selection decisions must be arrived at on the suitability of the candidate to do the job and must not be influenced by the traditional racial or sexual profile of the previous job holders.
" After each interview, those involved will independently assess the candidates individually against the essential and desirable criteria using the approved candidate assessment form.
" Discussions must take place based on the interviewer's assessment of each candidate, and a decision must be based on the collective comments and feelings of those involved in the interview process.
" All application forms and candidate assessment forms, duly completed by those Line Managers involved, must be submitted to the Human Resources Department where they will be held for a six month period.

AFTER THE INTERVIEW

" All candidates must be informed whether or not they have been successful.
" Offers of appointment and letters of rejection must be despatched promptly.
" External candidates should be given the reasons for rejection if this is requested.

THE PURPOSE AND SCOPE OF THIS CODE OF PRACTICE

This code of practice is primarily concerned with the recruitment and selection process and should be followed for all vacancies irrespective of the nature of the job.

This code sets down the principles and practices which all departments must follow. Any variations or alterations in the outlines procedure must be approved by the Managing Director.

" Departmental Managers are responsible for ensuring that all employees engaged in the recruitment and selection process are aware of, understand and are able to implement this code of practice.
" Any breach of this code by an employee will be considered as an act of misconduct and may result in disciplinary action against that employee.
" All employees and other individuals with responsibility for recruitment and selection (including progression), must pay special attention to their obligations under existing employment legislation as outlined in this policy document.
" In accordance with Birmingham City Football Clubs policy, all members of short listing, selection and interviewing panels will be trained in and demonstrate an understanding of equal opportunities and employment policy.

Birmingham City FC will take steps to ensure that:-

" All sections of the community and Birmingham City FC workforce are fully informed of job opportunities within Birmingham City FC and are encouraged to apply.
" The criteria for selection and progression are determined solely on the basis of the requirements of the job,
" People are selected and appointed solely on the basis of their relevant, assessable experience and abilities.
" All members of the selection and interviewing panels will be trained and expected to demonstrate an understanding of Birmingham City Football Clubs equal opportunities policy.

TERMS AND CONDITIONS OF EMPLOYMENT

" Observance of the Birmingham City FC equal opportunities employment policy is a condition of employment.
" Birmingham City FC will review existing terms and conditions of service to ensure that they do not discriminate and will amend and develop them where necessary to bring them in line with the equal opportunities policy.

TRAINING, DEVELOPMENT AND PROMOTION

The Club views staff as its most valuable resource and believes that staff development and promotion opportunities should be available to all, regardless of race, gender, age, nationality, ethnic or natural origin, political or religious belief, sexual orientation, disability or marital status. In pursuance of this, the Club's continued aim will be to ensure that within available resources: -

" All staff undertake relevant training.
" Promotion opportunities will be brought to the attention of all employees and decisions made on the basis of the individual's ability, requirements of the job and other objective relevant criteria.
" Provide the training required to implement this equal opportunities policy.
" Ensure that all employees will have an equal and direct access to training and development opportunities regardless of gender, race, disability, colour, ethnic or national origin, nationality, sexuality, marital status, responsibility for dependants, religion and trade union activity.
" Evaluate all training provisions, both internal and external, to ensure that it complies with this equal opportunities policy.
" Examine selection criteria for training and promotion opportunities to ensure they do not indirectly discriminate.
" Monitor the progress of all trainees against the equal opportunities policy and its requirements.
" Ensure that equal standards are being operated when undertaking performance reviews and assessments.
" Where appropriate encourage all staff to put themselves forward for training and promotion.

DISMISSAL AND REDUNDANCY

Dismissal and redundancy decisions are not made on the basis of gender, race, disability, colour, ethnic or national origin, nationality, sexuality, marital status, responsibility for dependants, religion and trade union activity.

DISCIPLINE

Acts of discrimination, victimisation and harassment as defined in this document, perpetrated by an employee against other employees, clients or members of the public will result in disciplinary action. This will also apply to employees who attempt to induce other employees to discriminate, victimise or harass.

FAILURE TO COMPLY WITH OR ADHERE TO BIRMINGHAM CITY FOOTBALL CLUB'S EQUAL OPPORTUNITIES POLICY WILL BE TREATED AS A DISCIPLINARY OFFENCE.

GRIEVANCE

Birmingham City will treat seriously and take prompt action on any employee's grievance concerning discrimination, victimisation or harassment. Any employee who considers they have been subjected to discrimination, victimisation or harassment should make their complaint to a senior member of management. Any complaint will be treated in confidence and if preferred, may be raised on behalf of the complainant by a colleague. However if formal action is to be taken against the perpetrator it will be necessary for a senior member of management to speak to the complainant direct in order to ensure that the facts are correct. The grievance policy (updated 2004) can be found in the Staff Handbook.

IMPLEMENTATION OF THE POLICY

Birmingham City Football Club will ensure that its equal opportunity in employment policy is implemented at all levels and locations within the company.

Overall responsibility for implementation of the policy resides with Birmingham City Football Club (the employer); the responsibility for day to day operation rests with all Departmental Managers.

Line Managers must ensure that all employees in their department are aware of the policy, and understand their role in its implementation.

REVIEW OF THE POLICY

It is Birmingham City Football Clubs intention to keep this policy and its existing codes of practice, management guidelines, instructions, procedures etc under review, to ensure that Birmingham City FC's commitment to equality of opportunity as set out in this policy statement is adopted and implemented.

ACCOUNTABILITY

Consistent with its adoption of an Equal Opportunities Policy, the Club will ensure that: -

Its Board of Directors and Senior Managers accept responsibility for implementing the Policy throughout the organisation; Relevant training and support will be made available to staff to ensure that the highest standards of practice are maintained.