Equal Opportunities Policy

Version 1.0 · December 2025 · Next review December 2026

1. Introduction

1.1 Purpose and Scope

This Equal Opportunities Policy sets out WealthVector Limited's ("the Firm") commitment to promoting equality of opportunity and preventing unlawful discrimination in all aspects of employment.

This policy applies to:

1.2 Policy Statement

WealthVector is committed to creating and maintaining a working environment that is free from discrimination, harassment, bullying, and victimisation. We value diversity and recognise that a diverse workforce with different perspectives and experiences strengthens our business and enables us to better serve our clients.

1.3 Legal Framework

This policy is designed to ensure compliance with UK equality legislation, including the Equality Act 2010, Employment Rights Act 1996, Human Rights Act 1998, and related regulations.

Breach of this policy may result in disciplinary action up to and including dismissal. Serious breaches may also constitute unlawful discrimination, which could result in personal liability for individual employees and potential legal claims against the Firm.

1.4 Regulatory Context

As an FCA-regulated firm, WealthVector must meet high standards of conduct and governance. Discrimination, harassment, or failure to promote equality may raise questions about an individual's fitness and propriety under FCA rules, constitute a breach of FCA Conduct Rules, impact the Firm's ability to meet FCA threshold conditions, or damage the Firm's reputation and regulatory standing.

2. Protected Characteristics

2.1 Definition of Protected Characteristics

The Equality Act 2010 protects individuals from discrimination based on nine protected characteristics:

2.2 Forms of Unlawful Discrimination

The Firm prohibits all forms of unlawful discrimination, including:

3. Commitment to Equality

3.1 Our Equal Opportunities Commitment

WealthVector is committed to providing equal opportunities in employment and will not discriminate on the basis of any protected characteristic or any other irrelevant factor. All employment decisions will be based solely on objective, job-related criteria, individual merit, qualifications and abilities, business requirements, and regulatory requirements where applicable.

3.2 Application Throughout Employment

This commitment applies to all stages of employment:

3.3 FCA Fitness and Propriety

For Senior Management Functions (SMFs) and Certification Functions, fitness and propriety assessments will be based on competence, knowledge, honesty, integrity, and financial soundness, without discrimination based on protected characteristics.

4. Recruitment and Selection

4.1 Fair Recruitment Practices

All recruitment will be conducted to ensure the widest possible pool of qualified candidates, selection based on merit and suitability, objective and consistent assessment methods, and no unlawful discrimination at any stage.

4.2 Job Descriptions and Person Specifications

Job descriptions will clearly define roles, specify essential requirements objectively, focus on skills and qualifications needed, avoid unnecessary requirements that could indirectly discriminate, and use neutral, inclusive language.

4.3 Interview Process

Interviews will be conducted fairly with job-related questions, consistent core questions for all candidates, interview panels of more than one person where practicable, reasonable adjustments for disabled candidates, and documented decisions with clear justifications.

Prohibited questions include those about:

5. Terms and Conditions of Employment

All employees performing the same or broadly similar work will be offered equal terms and conditions of employment regardless of protected characteristics. This includes pay, working hours, holiday entitlement, benefits, and redundancy terms. Pay decisions will be based solely on role requirements, individual performance, skills, and market rates, not on protected characteristics.

6. Training and Development

All employees will have equal access to training and development opportunities including mandatory regulatory training, role-specific technical training, management development, and professional qualifications support. Training will be allocated based on business need and individual development requirements, made accessible through reasonable adjustments, and scheduled with consideration of different working patterns.

7. Flexible Working and Reasonable Adjustments

7.1 Flexible Working Arrangements

All employees have the right to request flexible working from day one. Requests will be considered fairly and objectively against the criteria in the Flexible Working Policy, without discrimination based on protected characteristics.

7.2 Reasonable Adjustments for Disability

The Firm has a legal duty to make reasonable adjustments for disabled employees and job applicants. This includes adjustments to recruitment processes, the workplace, working arrangements and policies. Employees should inform their line manager of disability and adjustment needs. The Firm will consult to identify appropriate adjustments, which will be implemented promptly and reviewed regularly.

8. Preventing Discrimination, Harassment and Bullying

8.1 Zero Tolerance Approach

WealthVector has zero tolerance for discrimination, harassment, bullying, or victimisation. Such behaviour violates dignity, creates hostile environments, is unacceptable regardless of intent, may constitute gross misconduct leading to dismissal, and may expose individuals to personal legal liability.

8.2 Definitions

9. Responsibilities

9.1 Board and Senior Management

The Board and Senior Managers have ultimate responsibility for setting tone from the top, ensuring effective policy implementation, allocating adequate resources, monitoring compliance, reviewing diversity data and holding themselves and others accountable for breaches.

9.2 Line Manager Responsibilities

Line managers must implement this policy consistently, lead by example, make employment decisions objectively, treat all team members with respect, address inappropriate behaviour promptly, consider flexible working requests fairly, monitor team dynamics, provide equal opportunities, maintain confidentiality, and cooperate with investigations.

9.3 Employee Responsibilities

All employees must treat colleagues with dignity and respect, comply with this policy, challenge discriminatory behaviour when safe to do so, report discrimination if witnessed or experienced, cooperate with investigations, and undertake required training.

10. Reporting and Complaints

10.1 How to Raise Concerns

If you believe you have been discriminated against, harassed, or victimised:

10.2 Investigation Process

All complaints will be taken seriously, handled sensitively, investigated promptly and impartially, kept confidential to the extent possible, and conducted by someone independent. Investigations will include interviewing all parties, reviewing evidence, and determining appropriate action if upheld.

10.3 Protection from Victimisation

The Firm will not tolerate victimisation of anyone who makes a complaint in good faith, supports someone's complaint, provides evidence, or raises concerns. Victimisation is unlawful discrimination and will be treated as a disciplinary matter, potentially constituting gross misconduct.

11. Monitoring and Review

11.1 Diversity Data Collection

The Firm will collect diversity data voluntarily and confidentially to monitor policy effectiveness, identify patterns, analyse data in relation to recruitment, promotion, training, pay and terminations and report findings to the Board annually.

11.2 Policy Effectiveness

The Firm will monitor policy effectiveness by reviewing the number and nature of complaints, investigation outcomes, diversity data trends, training completion rates and employee feedback.

12. Policy Ownership and Review

12.1 Policy Owner

This policy is owned by the CEO and maintained by the Compliance Officer. Ultimate responsibility for compliance rests with the Board and Senior Management.

12.2 Review and Updates

This policy will be reviewed:

12.3 Training and Communication

All employees will receive a copy during induction, training on equality and diversity as part of mandatory onboarding, regular refresher training at least every two years, and updates when significant changes are made.

12.4 Questions and Guidance

Employees with questions should contact:

This policy should be read in conjunction with: