Diversity and Inclusion Policy

1. Purpose

This policy explains how Digitator Limited promotes equality, diversity and inclusion in its business decisions, working relationships and service delivery.

It is designed to be proportionate to Digitator’s current size and operating model as a small, director-led digital consultancy with no employees and work that is primarily delivered remotely.

Digitator will comply with the Equality Act 2010 and other applicable equality, employment and human rights requirements. The company will not unlawfully discriminate, harass or victimise anyone.

2. Scope

This policy applies to the Director and to any future employee, applicant, associate, freelancer, subcontractor, supplier or partner engaged in Digitator’s work.

It also applies to interactions with clients, client staff, research participants, website users and other members of the public.

The Director is responsible for applying the policy, keeping it under review and taking proportionate corrective action where a concern is identified.

3. Our commitments

Digitator will:

• Make decisions using objective and relevant criteria such as capability, experience, quality, value and business need.
• Provide equal access to opportunities and make reasonable adjustments for disabled people where needed.
• Communicate respectfully and challenge discriminatory, intimidating or exclusionary behaviour.
• Seek to understand and accommodate different communication needs, working patterns, cultures and perspectives.
• Protect personal and sensitive information and avoid the unnecessary collection or disclosure of equality-related data.
• Review its working practices and learn from feedback, complaints and changes in good practice.

4. Protected characteristics and broader inclusion

Digitator will not discriminate against someone because of:

• Age
• Disability
• Gender reassignment
• Marriage or civil partnership
• Pregnancy or maternity
• Race, including colour, nationality and ethnic or national origin
• Religion or belief
• Sex
• Sexual orientation

Digitator also seeks to be inclusive of people with different socioeconomic backgrounds, caring responsibilities, neurodivergence, education and career routes, working patterns and lived experiences, where these do not fall within a protected characteristic.

5. Recruitment and access to work

Digitator currently has no employees. If the company recruits or engages associates, freelancers or subcontractors, it will:

• Use clear, role-relevant requirements and avoid unnecessary barriers to participation.
• Consider reasonable adjustments to recruitment, onboarding and working arrangements.
• Assess candidates and suppliers consistently against the requirements of the work.
• Avoid assumptions based on personal characteristics or background.
• Select, pay and manage people fairly and in accordance with applicable law and agreed terms.

6. Inclusive client and digital service delivery

Digitator will consider inclusion and accessibility when planning and delivering SEO, AI search, paid media, analytics, content and digital consultancy services.

Depending on the project, this may include:

• Offering reasonable adjustments for meetings, workshops, training and communications.
• Using clear language and providing documents in accessible formats where reasonably requested.
• Supporting accessible content practices, including meaningful headings, descriptive link text, transcripts, captions and image descriptions where relevant to the scope.
• Avoiding stereotypes or discriminatory assumptions in audience, keyword, content and market analysis.
• Considering whether datasets, automated tools or AI-generated outputs may create or reproduce bias.
• Applying appropriate human review before material recommendations or client outputs are issued.

Digitator will respect each client’s equality, safeguarding, accessibility and conduct requirements when working on the client’s systems, premises or projects.

7. Suppliers and business partners

Digitator will not discriminate unlawfully when selecting or managing suppliers and business partners. Selection will be based on relevant capability, security, quality, value and delivery requirements.

Where proportionate, Digitator will seek to ensure that opportunities are accessible to small and diverse suppliers. The company will also encourage suppliers and business partners to maintain fair and inclusive working practices.

8. Unacceptable conduct

Discrimination, harassment, bullying, victimisation, hate speech and retaliation against a person who raises a concern are not acceptable.

This applies to spoken, written and digital communications, including email, messaging, video calls, social media and collaborative workspaces.

A serious or repeated breach may result in corrective action, removal from a project or termination of a supplier, associate or client relationship, subject to contractual and legal obligations.

9. Raising concerns and complaints

Anyone who believes this policy has not been followed may raise the matter confidentially with the Director by emailing damon.rutherford@digitator.com.

Concerns will be acknowledged promptly, considered impartially and handled as confidentially as reasonably possible.

Digitator will establish the relevant facts, provide the people involved with an appropriate opportunity to respond, record the outcome and take proportionate corrective action.

No person will be disadvantaged for raising a genuine concern in good faith. Where a concern relates to work for a client, the matter may also be handled under the client’s agreed reporting or safeguarding procedure.

10. Monitoring and review

The Director will review this policy at least annually and sooner if Digitator’s workforce, services or legal obligations materially change.

The review will consider:

• Complaints or incidents
• Requests for reasonable adjustments
• Feedback from clients and other stakeholders
• Supplier and recruitment practices
• Changes in legislation or client requirements

The policy will be communicated to anyone working on Digitator’s behalf and will be made available to clients, suppliers and other stakeholders.