Scorp Group · Policy Document

Non-Discrimination & Equal Opportunity

Process Description

Document Title

Process for Ensuring Non-Discrimination and Equal Opportunity

Document No.

SG-HR-PROC-005

Version

1.0

Effective Date

June 2025

Owner

Chief Human Resources Officer (CHRO)

Approved by

Board of Directors, Scorp Group Ltd

1.PURPOSE

This document describes Scorp Group Ltd's systematic management approach to prevent, detect, and remedy discrimination in all its forms throughout its operations and business relationships. Scorp Group is committed to ensuring that all individuals are treated with dignity and respect, and that no person is subject to unfair treatment on the basis of:

  • Colour, race, or ethnicity
  • Sex or gender identity
  • Religion or belief
  • Political opinion
  • National extraction or nationality
  • Social origin or socioeconomic status
  • Age
  • Disability (physical or mental)
  • Sexual orientation
  • Pregnancy or maternity
  • Marital or family status
  • Any other characteristic protected by applicable law
  • This process aligns with the following international frameworks:

  • ILO Convention No. 111: Discrimination (Employment and Occupation), 1958
  • ILO Convention No. 100: Equal Remuneration, 1951
  • UN Universal Declaration of Human Rights, Articles 1, 2, and 7
  • UN International Covenant on Civil and Political Rights (ICCPR), Articles 2 and 26
  • UN Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW)
  • UN Convention on the Rights of Persons with Disabilities (CRPD)
  • UN Guiding Principles on Business and Human Rights (UNGPs), Principles 12 and 16
  • OECD Guidelines for Multinational Enterprises (2023), Chapter V (Employment)
  • ISO 30415:2021 — Human Resource Management: Diversity and Inclusion
  • GRI Standard 406: Non-Discrimination (2016)
  • 2.SCOPE

    This process applies to:

  • All employees of Scorp Group Ltd (permanent, fixed-term, part-time, and temporary)
  • Job applicants and candidates during the recruitment process
  • Contractors and agency workers engaged at Scorp Group premises
  • Suppliers and business partners (via Code of Conduct requirements)
  • All geographies and business units within Scorp Group Ltd
  • 3.PROCESS DESCRIPTION

    STEP 1 — POLICY COMMITMENT AND GOVERNANCE

    1.1 Scorp Group maintains a publicly available Non-Discrimination and Equal Opportunity Policy, approved by the Board of Directors and reviewed annually.

    1.2 The CHRO holds executive accountability. Each Business Unit Head is responsible for implementation within their function.

    1.3 Non-discrimination and diversity KPIs are included in senior leadership performance management frameworks.

    Reference: UNGP Principle 16; GRI 2-23; ILO C111.

    STEP 2 — NON-DISCRIMINATORY RECRUITMENT AND SELECTION

    2.1 All job postings use inclusive, gender-neutral language and are reviewed by HR prior to publication.

    2.2 Structured, competency-based interview processes are used to minimise unconscious bias. Interview panels are required to include gender diversity where possible.

    2.3 Shortlisting and selection criteria are documented and applied consistently to all candidates.

    2.4 Background checks are only conducted where legally required and are proportionate to the role. No questions regarding protected characteristics (e.g. pregnancy, religion, age) are asked during recruitment.

    2.5 Scorp Group actively recruits from underrepresented groups through targeted outreach to diverse talent pipelines.

    Reference: ILO C111 Article 1; ISO 30415:2021; OECD Guidelines Chapter V.

    STEP 3 — EQUAL PAY AND COMPENSATION REVIEW

    3.1 Scorp Group conducts an annual Equal Pay Audit to identify and address gender pay gaps and disparities across protected characteristics.

    3.2 Compensation bands are established based on role level, skills, experience, and market data — not on the personal characteristics of the individual.

    3.3 Results of the Equal Pay Audit are reviewed by the CHRO and PSRC, and corrective actions are implemented within 90 days of identification.

    3.4 Pay gap data is disclosed in Scorp Group's Annual Human Rights & Sustainability Report, aligned with GRI 405-2.

    Reference: ILO C100; CEDAW Article 11; GRI 405-2.

    STEP 4 — TRAINING AND AWARENESS

    4.1 All employees complete mandatory anti-discrimination and unconscious bias training upon joining Scorp Group and at minimum every two years thereafter.

    4.2 Line managers receive enhanced training on inclusive leadership, fair performance management, and handling discrimination complaints.

    4.3 Training completion rates are tracked as a KPI (target: 100% of employees within 12 months of hire).

    Reference: OECD Guidelines Chapter V §5; ISO 30415:2021 §8.

    STEP 5 — COMPLAINT HANDLING AND INVESTIGATION

    5.1 Any employee who believes they have been subjected to discrimination may raise a complaint through:

  • Direct report to their HR Business Partner
  • Anonymous whistleblowing hotline (available 24/7, multilingual)
  • Written complaint to the CHRO
  • 5.2 All discrimination complaints are investigated by a trained HR representative (independent of the line manager involved) within 10 working days of receipt.

    5.3 Outcomes of investigations are documented. Substantiated complaints result in disciplinary action proportionate to the severity of the conduct, up to and including termination of employment.

    5.4 No employee will face retaliation for raising a discrimination complaint in good faith.

    Reference: UNGP Principle 29; GRI 406-1.

    STEP 6 — MONITORING AND REPORTING

    6.1 Scorp Group tracks the following non-discrimination KPIs:

  • Total number of discrimination complaints received (by type and ground)
  • % of complaints resolved within 30 days (target: >= 90%)
  • Gender pay gap ratio (target: < 5% unexplained gap)
  • Representation of underrepresented groups at all employment levels
  • Training completion rates
  • 6.2 KPIs are reported quarterly to the CHRO and annually in the Human Rights & Sustainability Report, aligned with GRI 406-1 and GRI 405.

    6.3 Supplier non-discrimination compliance is assessed via SAQ and third-party audits.

    Reference: GRI 406-1; GRI 405; UNGP Principle 20.

    4.INTERNATIONAL STANDARDS REFERENCED

  • ILO Convention No. 111 (Discrimination, Employment and Occupation), 1958
  • ILO Convention No. 100 (Equal Remuneration), 1951
  • UN Universal Declaration of Human Rights, Articles 1, 2, 7
  • UN Guiding Principles on Business and Human Rights, Principles 12, 16, 29
  • OECD Guidelines for Multinational Enterprises (2023), Chapter V
  • ISO 30415:2021 — Human Resource Management: Diversity and Inclusion
  • GRI Standards 405 (Diversity and Equal Opportunity) and 406 (Non-Discrimination)
  • CEDAW; CRPD; ICCPR