Diversity Strategy and Equal Employment Opportunity & Non-Discrimination Policy
1) Purpose and Statement of Commitment
SP Lawyers (“the Firm”) is committed to fostering a workplace and professional environment where all individuals are treated with dignity, respect, and fairness. The purpose of this Policy is to:
• Affirm the Firm’s commitment to equal employment opportunity, non-discrimination, accessibility, and a respectful workplace.
• Establish clear expectations for conduct across all Firm-related settings, including work-related online conduct.
• Describe how concerns may be raised, how the Firm will respond, and the Firm’s commitment to non-retaliation.
• Set out the Firm’s Diversity Strategy, including governance, priorities, and how progress will be monitored.
2) Scope
This Policy applies to all individuals who interact with the Firm in connection with its business, including:
• Applicants and candidates for employment or engagement.
• Employees (full-time, part-time, fixed-term, probationary, and temporary).
• Partners, principals, directors, officers, and management (where applicable to the Firm’s governance).
• Contractors, consultants, agency workers, and other non-employee workers engaged by or through the Firm.
• Interns, trainees, clerks, and work-experience placements (paid or unpaid).
• Visitors to Firm premises and attendees at Firm-related events.
• Third parties interacting with the Firm (including clients, suppliers, and service providers) to the extent of the Firm’s ability to set expectations and manage conduct.
This Policy applies across the full lifecycle of engagement with the Firm, including (without limitation):
• Recruitment, selection, interviewing, and onboarding.
• Work allocation, supervision, performance management, training, professional development, promotion, compensation and benefits, recognition, and disciplinary processes.
• Secondments, business travel, conferences, marketing activities, and Firm-sponsored or Firm-related social events.
• Separation from the Firm, including resignation, redundancy, termination, and post-engagement references where provided.
Online conduct: This Policy also applies to work-related digital environments, including Firm systems, collaboration tools, video meetings, and social media or other online activity where it is connected to the workplace, affects working relationships, or impacts the Firm’s reputation or an individual’s dignity and safety.
3) Equal Employment Opportunity (EEO)
The Firm provides equal employment opportunity in all employment and engagement decisions. Decisions will be based on legitimate business factors such as role requirements, skills, experience, performance, potential, professional conduct, and the needs of the Firm and its clients.
The Firm is committed to fair and consistent processes, and to removing barriers that may disadvantage individuals or groups, including barriers related to access, opportunity, or workplace practices.
4) Non-Discrimination Commitment (Protected Characteristics)
The Firm does not tolerate discrimination, unequal treatment, or exclusionary practices on the basis of any characteristic protected by applicable law or by this Policy.
For purposes of this Policy, protected characteristics include (non-exhaustively):
• Race, color, ethnicity, nationality, national origin, ancestry, indigenous status, and cultural background
• Citizenship and immigration status (where lawful and relevant)
• Religion
• Age
• Sex, gender, gender identity, and gender expression
• Sexual orientation
• Pregnancy, childbirth, lactation, fertility-related circumstances, and parental status
• Marital status, civil/registered partnership status, and family status
• Caregiving responsibilities
• Disability, impairment, chronic illness, neurodiversity, and mental health conditions
• Medical condition and health status (to the extent protected)
• Genetic information and family medical history (to the extent protected)
• Veteran status, military service, reserve status, and lawful service-related obligations
• Political opinion or political affiliation (where protected)
• Union membership, lawful collective activity, or worker representation (where protected)
• Socioeconomic background, social class, and educational background
• Any other status protected by applicable law
Non-exhaustive list: The above list is intended to be comprehensive. It is not exhaustive, and the Firm will treat any status protected by applicable law as protected under this Policy.
5) Anti-Harassment, Anti-Bullying, and Respectful Workplace
5.1 Standard of conduct
The Firm is committed to a workplace free from harassment, bullying, intimidation, and hostility. All individuals covered by this Policy must conduct themselves professionally and respectfully.
5.2 Harassment
Harassment includes unwelcome conduct (verbal, physical, visual, or written) that has the purpose or effect of violating a person’s dignity, creating an intimidating, hostile, degrading, humiliating, or offensive environment, or unreasonably interfering with work. Harassment may be related to a protected characteristic or may be general abusive behavior.
Examples (illustrative, not exhaustive) include:
• Slurs, derogatory comments, “jokes,” stereotyping, mockery, or unwanted nicknames.
• Unwanted sexual comments, flirting, propositions, invasive questions, or sharing sexual content.
• Displaying or circulating offensive images, memes, messages, or symbols.
• Deliberate misgendering or refusal to use a person’s affirmed name/pronouns.
• Excluding individuals from work activities for discriminatory reasons.
5.3 Bullying
Bullying includes repeated or serious inappropriate behavior that a reasonable person would consider intimidating, humiliating, degrading, or threatening, including abuse of authority. It can occur in-person or online.
Examples include:
• Shouting, belittling, or public humiliation.
• Unreasonable deadlines set to cause failure, or persistent unfair criticism not grounded in performance.
• Deliberate isolation, “freezing out,” or sabotaging work.
• Threats relating to job security or professional standing made inappropriately.
Legitimate management action: Reasonable, respectful management actions—such as setting performance expectations, giving constructive feedback, or taking disciplinary steps—are not bullying when carried out fairly and in good faith.
6) Reasonable Accommodations and Accessibility
The Firm will make reasonable efforts to provide accommodations and ensure accessibility for individuals with disabilities, health conditions, neurodiversity-related needs, religious observance needs, caregiving responsibilities, and other circumstances where accommodation is appropriate and feasible.
Accommodations may include (depending on role and circumstances):
• Accessible technology and assistive tools.
• Adjustments to workspaces, schedules, communication methods, or role practices.
• Modifications to recruitment processes (e.g., accessible interviews, alternative formats).
• Leave or time flexibility where feasible.
• Support for participation in Firm events and training.
Accommodation requests will be handled respectfully, promptly, and (to the extent reasonably possible) confidentially. The Firm may request information necessary to understand functional needs and identify effective options, and will focus on practical solutions rather than labels.
7) Recruitment, Hiring, Promotion, and Pay Equity Principles
The Firm’s talent decisions are designed to be fair, consistent, and evidence-based. The Firm will:
• Use role-relevant selection criteria and structured evaluation methods where practicable.
• Seek to broaden candidate pools and reduce barriers in recruitment and sourcing.
• Provide interview and selection guidance aimed at reducing bias and improving consistency.
• Make promotion and advancement decisions based on transparent expectations, performance, competencies, and potential.
• Strive for pay equity and fair compensation practices, including periodic review of compensation outcomes and drivers, with adjustments where warranted.
• Avoid inappropriate reliance on non-role-related factors (including assumptions based on personal background or protected characteristics).
8) Building and Sustaining an Inclusive Culture
The Firm will implement practical measures to support inclusion and belonging, including:
• Training and awareness: Regular training on respectful workplace standards, inclusive leadership, fair hiring, and bystander/intervention expectations (tailored to role and seniority).
• Mentoring and sponsorship: Programs that provide guidance, skills development, and equitable access to career opportunities, including sponsorship of high-potential talent.
• Flexible work (where feasible): Work arrangements that support productivity and wellbeing, subject to role requirements, client commitments, confidentiality, and operational needs.
• Inclusive events: Firm events designed to be welcoming and accessible, with attention to timing, venue accessibility, dietary and religious considerations, and inclusive conduct expectations.
• Inclusive work allocation: Monitoring (where feasible) to promote equitable distribution of high-value work, visibility opportunities, and developmental assignments.
9) Diversity Strategy
9.1 Governance and ownership
The Firm will maintain clear ownership of its diversity and inclusion efforts, including:
• Executive/management-level sponsorship to support accountability and resourcing.
• Clear escalation pathways for DEI risks, patterns, or significant complaints.
9.2 Objectives
The Firm’s Diversity Strategy aims to:
• Increase equitable access to opportunities within the Firm.
• Strengthen recruitment and retention of diverse talent.
• Support inclusive leadership and fair progression to senior roles.
• Enhance professional development and wellbeing across the Firm.
• Promote respectful, collaborative teams and a safe reporting culture.
• Engage responsibly with the broader community and professional ecosystem.
9.3 Action plan themes
The Firm’s action plan will be reviewed periodically and may include initiatives across the following themes:
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Talent pipeline and outreach
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Retention, engagement, and wellbeing
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Leadership and accountability
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Professional development and progression
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Supplier, community, and ecosystem engagement
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Pro bono and impact (where aligned)
9.4 Metrics, monitoring, and continuous improvement
The Firm will monitor progress and identify improvement opportunities through appropriate measures, which may include:
• Recruitment and hiring data (e.g., pipeline composition, selection outcomes).
• Progression, promotion, retention, and turnover indicators.
• Pay equity review indicators and outcome drivers.
• Training completion and effectiveness measures.
• Workplace experience indicators (e.g., engagement survey results, qualitative feedback).
• Complaint themes and resolution timeliness (tracked in a manner that preserves privacy).
Aggregate data and confidentiality: Where the Firm collects demographic or workforce data, it will be handled responsibly and, where feasible, reviewed in aggregate to protect confidentiality. Access will be limited to those with a legitimate need to know, and reporting will avoid identifying individuals.
Periodic reporting: The DEI Lead/Committee will provide periodic updates to Firm leadership and, where appropriate, internal communications summarizing priorities, actions, and progress.
Continuous improvement: The Firm will use learnings from feedback, metrics, and case trends to refine practices, training, and controls.
10) Reporting and Complaints Procedure (Including Anonymous Reporting and Anti-Retaliation)
10.1 How to report
Individuals are encouraged to raise concerns as early as possible. Reports may relate to discrimination, harassment, bullying, retaliation, accessibility barriers, or other conduct inconsistent with this Policy.
Reports may be made by emailing: dei@splawyers.com
Where possible, a report should include:
• What happened (dates, times, and locations if known)
• Individuals involved and any witnesses
• Any relevant documents, messages, screenshots, or other information
10.2 Anonymous reports
The Firm will accept anonymous reports. Anonymous reporting may limit the Firm’s ability to investigate or provide feedback, but the Firm will still assess and respond to the extent reasonably possible.
10.3 What the Firm will do
The Firm will:
• Acknowledge reports within a reasonable timeframe (where contact details are provided).
• Conduct a timely, fair, and proportionate assessment.
• Determine appropriate next steps, which may include informal resolution, formal investigation, interim measures, training, coaching, disciplinary action, separation of parties, or other corrective actions.
• Seek to handle matters discretely and share information only with those who need it to assess, investigate, or address the issue.
10.4 Fair process and confidentiality
The Firm will aim to ensure a fair process for all parties involved. Confidentiality will be respected to the extent reasonably possible, recognizing that some disclosure may be necessary to investigate and resolve concerns, comply with obligations, or protect individuals and the Firm.
10.5 Non-retaliation
Retaliation is prohibited. The Firm will not tolerate retaliation against any person who:
• Raises a concern in good faith,
• Participates in an investigation or process under this Policy, or
• Supports another person in raising a concern.
Retaliation may include dismissal, demotion, reduced hours, unjustified negative reviews, threats, exclusion, harassment, or any other adverse treatment connected to reporting or participation.
Any suspected retaliation should be reported immediately to dei@splawyers.com and will be treated as a serious matter.
10.6 Misuse of the process
The Firm encourages good-faith reporting. Knowingly false reports or deliberate misuse of the reporting process may result in appropriate action. A report made in good faith that is not substantiated will not, by itself, result in adverse action.
11) Responsibilities
• All personnel: Comply with this Policy, treat others respectfully, and speak up or report concerns where appropriate.
• Leaders and managers: Model inclusive behavior, address issues promptly, ensure fair work practices, and support reporting without retaliation.
• DEI Lead/Committee (as applicable): Oversee implementation, advise on practices, monitor trends, and support continuous improvement.
• People/Operations (as applicable): Support fair recruitment, onboarding, performance processes, and recordkeeping consistent with confidentiality expectations.
12) Policy Review and Updates
This Policy will be reviewed periodically and updated as needed to reflect operational experience, evolving best practices, and applicable legal requirements. The Firm may supplement this Policy with internal procedures, guidance, and training materials to support implementation.
Effective date: 1 January 2023 Contact: dei@splawyers.com
