Equality & Diversity Policy

Equality, Diversity & Inclusion Policy

Scope

Compliance with Equality, Diversity, and Inclusion, such as protection from discrimination and harassment, is a
“day one” right, and as a such, this policy applies to all Norwich City Football Club (“Club”) colleagues, including
those on temporary contracts or who have been working at the Club through a recruitment agency. The policy
also extends to temporary and casual workers and relevant third parties and contractors.

Norwich City Football Club is committed to being A Home for Everyone – an inclusive and safe environment where
everyone can thrive, and all feel welcome. We will do this by embedding a culture where every individual engaged
with the club is treated with respect and met with positivity and compassion. We are all responsible for upholding
the Club’s values by ensuring others feel included and valued, championing equality, and challenging all forms of
discrimination, increasing our knowledge to develop the confidence to do so.

We believe that together we are stronger; we celebrate diversity and will proactively work with our community to
ensure everyone has a fair opportunity to participate. This way Norwich City Football Club will build a culture to
be proud of – we will build A Home for Everyone.

This policy supersedes any previous policies prior to its issue date.

Policy Statement

Norwich City Football Club (the Club) endorses the principle of equality, diversity and inclusion (EDI) and will strive
to ensure that everyone who wishes to be involved in the Club whether as players, supporters (home and away),
staff, Board members, participants in outreach programmes and other people engaged with the Club’s activities
(for example, suppliers, corporate partners):

  • Has a genuine and equal opportunity to participate to the full extent of their own ambitions and abilities,
    without regard to their age, disability, gender reassignment, marital or civil partnership status, pregnancy
    or maternity, race, religion and belief, sex or sexual orientation; and
  • Can be assured of an environment in which their rights, dignity and individual worth are respected, and
    in particular that they are able to enjoy their engagement at the Club without the threat of intimidation,
    victimisation, harassment, bullying or abuse.

Legal obligations

The Club is committed to avoiding, actively challenging, and eliminating discrimination of any kind and will under
no circumstances condone unlawful discriminatory practices. The organisation takes a zero-tolerance approach
to intimidation, harassment, victimisation, bullying or abuse. Examples of the relevant legislation and the behaviours
are given in Appendix 1.

Positive action

As well as complying with legislation, the Club promotes EDI by taking positive steps to counteract the effects of
physical or cultural barriers – whether real or perceived – that restrict the opportunity for all sections of the
community to participate equally and fully.

The Club will therefore seek to institute, support or contribute to appropriate measures or initiatives that enable
access, as well as requiring participation in associated activities by people from any group that is underrepresented
in the Club or has difficulty accessing it.

Reasonable Adjustments

The Club is committed to removing barriers that may prevent disabled people from accessing employment,
development opportunities, services, facilities or participation in Club activities. Where appropriate, the Club will
make reasonable adjustments for disabled job applicants, employees, workers, volunteers, players, supporters
and other individuals engaged with the Club, to ensure they are not placed at a substantial disadvantage.
Requests for reasonable adjustments will be considered promptly, sensitively and on an individual basis, taking
account of the needs of the individual and the circumstances of the role or activity. The Club will work
collaboratively with individuals to identify appropriate adjustments and will review arrangements where
necessary.

Implementation

The following steps will be taken to publicise this policy and promote EDI in the Club:

  • A copy of this document will be published on Norwich City Football Club website
  • The Board will take overall accountability for ensuring that the policy is observed.
  • The Board will take full account of the policy in arriving at all decisions in relation to the activities of Norwich City Football Club.
  • The Club will implement regular audits, surveys or other initiatives designed to assess the level of participation from diverse groups of people in the Club, including employed roles, and will take account of the findings in developing measures to promote and enhance EDI .
  • The Club will provide access to a rolling programme of training (for example, online, face-to-face, briefings) for all its players, supporters (home and away), staff, Board members and other people engaged with the Club’s activities, to raise awareness of both collective and individual responsibilities.
  • It will be a condition of working with the Club that suppliers and corporate partners:
    • Commit to act in accordance with this policy; and
    • Support such measures and initiatives that the Club may institute or take part in to advance the aims of this policy

Responsibility, monitoring and evaluation

The Board will be accountable for ensuring the implementation of this policy. The Head of HR &EDI or equivalent will be responsible for the day-to-day implementation of EDI in the Club.

The Executive Committee will review all Club activities and initiatives against the aims of the policy and should report formally on this issue to the Board annually.

The Executive Committee will review any measures or initiatives that the Club may institute or take part in to promote and enhance EDI in the Club and will report their findings annually to the Board.

The Board itself will review the policy every two years (or when necessary due to changes in legislation), in line with the policy review process.

Complaints and compliance

The Club takes a zero-tolerance approach to discrimination and instances of hate, and considers all forms of
discriminatory behaviour, including (but not limited to) behaviour described in Appendix 1, as unacceptable. The
Club commits to ensuring individuals feel able to raise any grievance or complaint relating to such behaviour
without fear of being penalised for doing so.

Appropriate disciplinary action will be taken against any player, supporter (home and away), staff, Board member,
participant in outreach programmes and other people engaged with the Club’s activities who violate the Club’s
EDI Policy.

Responsibility and Key Contacts
Head of HR &EDI
Head of Safer Sport
General Counsel

Associated Policies
Harassment Policy and Procedure
Grievance Policy and Procedure
Disciplinary Policy and Procedure
“Speak Up” Policy and Procedure (Whistleblowing)

Policy Issue Date April 2025
Date of Next Update April 2027

This policy is next due for a general review on the above date. It may however be reviewed and updated earlier, in the event of a change in Club requirements, or relevant legislation.

This policy is reviewed regularly by the Human Resources Department. Recommendations for change should be reported to the Human Resources Department.

The Club will continue to review the effectiveness of this policy to ensure it is achieving its objectives.

APPENDIX 1 – Relevant legislation and forms of unacceptable discrimination
Legal Rights

The Equality Act 2010 brings together over 116 separate pieces of legislation into one single Act.
The Act provides a legal framework to protect the rights of individuals and advance equality of opportunity for all. It provides Britain with a discrimination law which protects individuals from unfair treatment and promotes a fair and more equal society.

Discrimination refers to unfavourable treatment on the basis of particular characteristics, which are known as the ‘protected characteristics’. Under the Equality Act 2010, the protected characteristics are defined as age, disability, gender reassignment, marital or civil partnership status, pregnancy and maternity, race, religion or belief, sex (gender) and sexual orientation.

Under the Equality Act 2010, individuals are protected from discrimination ‘on grounds of’ a ‘protected characteristic’1. This means that individuals will be protected if they have a characteristic, are assumed to have it, associate with someone who has it or with someone who is assumed to have it.

Forms of discrimination and discriminatory behaviour include the following:
Direct discrimination Direct discrimination can be described as less favourable treatment on the grounds of one of the protected characteristics.

Indirect discrimination

Indirect discrimination occurs when a provision, criterion or practice is applied to an individual or group that would put persons of a particular characteristic at a particular disadvantage compared with other persons.  

Discrimination arising from disability

When a disabled person is treated unfavourably because of something connected with their disability and this unfavourable treatment cannot be justified, this is unlawful. This type of discrimination only relates to disability.  

Harassment

Harassment is defined as unwanted conduct relating to a protected characteristic that has the purpose or effect of violating a person’s dignity, or which creates an intimidating or hostile, degrading, humiliating or offensive environment for that person.

Victimisation

It is unlawful to treat a person less favourably because he or she has made allegations or brought proceedings under the anti-discrimination legislation, or because they have helped another person to do so. To do so would constitute victimisation.

Bullying

Bullying is defined as a form of personal harassment involving the misuse of power, influence or position to persistently criticise, humiliate or undermine an individual.

Hate crime

1 The exception to this is pregnancy and maternity, which does not include protection by association or assumption – a woman is only protected
from discrimination on grounds of her own pregnancy.

The Police and the CPS have agreed the following definition for identifying and flagging hate crimes: "Any criminal offence which is perceived by the victim or any other person, to be motivated by hostility or prejudice, based on a person's disability or perceived disability; race or perceived race; or religion or perceived religion; or sexual orientation or perceived sexual orientation; or transgender identity or perceived transgender identity."

Intimidation

Intimidation or harassment is a personalised form of anti-social behaviour, specifically aimed at particular individuals, which could be based on their protected characteristics. The Act defines anti-social behaviour as “conduct that has caused, or is likely to cause, harassment, alarm or distress to any person.” Threats to kill, rape, serious violence, stalking and property damage, as well as intimidating behaviour that is face-to-face or by letter, telephone call or online are examples of intimidation that are all criminal offences.

Abuse

As an employer or manager, there may be situations where verbal abuse, threats or name-calling (and harassment) at work could be a crime, for example, if an employee tells you they have been physically attacked, sexually assaulted, the victim of a hate crime, for example racist or homophobic abuse, or threatened with violence. Such incidents may be a criminal offence and should be reported to the Police and other relevant agencies.

Hostility

There is no legal definition of hostility so the CPS uses the everyday understanding of the word which includes illwill, spite, contempt, prejudice, unfriendliness, antagonism, resentment and dislike.

Incitement to hatred

The offence of incitement to hatred occurs when someone acts in a way that is threatening and intended to stir up hatred. That could be in words, pictures, videos, music, and includes information posted on websites. Hate content may include:
messages calling for violence against a specific person or group
• web pages that show pictures, videos or descriptions of violence against anyone due to their perceived
differences
• chat forums where people ask other people to commit hate crimes against a specific person or group