PERFORMANCE DEVELOPMENT
REVIEW (PDR) SCHEME
Document: Performance Development Review Scheme
Version: One
Author: Saaika Mubeen & Katy Pattinson
Approval Date : Approved by the Policy and Procedure Committee xxx 2016
Review Date: xxx 2019
1|P a g e
Contents
Section 1
WHAT ARE
(PDR’s)?
PERFORMANCE
DEVELOPMENT
REVIEWS
Purpose of PDRs
Benefits of PDRs
PDR Cycle
Links to Performance Management
Links Between Observation of Teaching, Learning &
Assessment (OTLA)
Link to Study Programme Performance and Strategic
Direction
Link to Capability
Line Mangers Overview of the PDR Process
General PDR Principles
Roles and Responsibilities
Disagreements
Section 2
SETTING PERFORMANCE OBJECTIVES
Effective Performance Objectives
Performance Factors
Measuring Performance
Assessing Performance Standards
In Summary
Section 3
FORMS (PDR microsite hyperlinked in title)
Management Teaching & Learning Support
PDR1 – Employee Preparation Form
PDR2 – Manager Preparation Form
PDR3 – Performance Development Review Form
PDR4 – Mid-Year Review Form
Management Business Support
PDR1 – Employee Preparation Form
PDR2 – Manager Preparation Form
PDR3 – Performance Development Review Form
PDR4 – Mid-Year Review Form
Teaching & Learning Support including Assessors (FE)
2|P a g e
PDR1 – Employee Preparation Form
PDR2 – Manager Preparation Form
PDR3 – Performance Development Review Form
PDR4 – Mid-Year Review Form
Teaching & Learning Support (UC)
PDR1 – Employee Preparation Form
PDR2 – Manager Preparation Form
PDR3 – Performance Development Review Form
PDR4 – Mid-Year Review Form
Business Support
PDR1 – Employee Preparation Form
PDR2 – Manager Preparation Form
PDR3 – Performance Development Review Form
PDR4 – Mid-Year Review Form
SECTION 1
WHAT ARE PERFORMANCE DEVELOPMENT REVIEWS (PDRs)?
Blackburn College’s Performance Development Review (PDR) scheme provides a formal
framework which enables both line managers and staff to take an overall view of the work of the
employee to assess performance, provide a framework for improvement, and support career
aspirations within the context of the organisation’s strategic priorities.
THE PURPOSE OF PDRs
The purpose of PDRs are to:
1. Review and recognise past performance against objectives set taking into consideration
individual circumstances
2. Reflect on personal performance, conduct and responsibilities
3. Review learning and development activities undertaken and consider career aspirations
4. Reflection on teaching/assessor responsibilities or centre/study area/department/team
performance where relevant
5. Conduct a role review to agree activities to stop, start, and continue to encourage a
continuous improvement approach to all roles within the College
6. Agree SMARTER performance objectives which demonstrate a direct link to supporting the
College to deliver its strategic objectives
7. Agree a Personal Development Plan (PDP) which sets out learning and development needs
for mandatory training, role development, and / or career development
3|P a g e
THE BENEFITS OF PDR
Effective PDRs can:

Define priorities and clarify expected levels and standards of performance

Ensure objectivity about an employee’s job performance and provide clear direction for
improvement

Reveal problems which may be restricting the progress of the employee or causing
inefficiencies and provide an early warning system for potential issues

Develop individuals skills and the skills required by the organisation for the future

Evaluate the effectiveness of training and development activities

Get the best out of people, make staff feel valued and engaged whilst keeping staff
motivated

Improve employee / manager relations and communication

Improve organisational performance and help the organisation to move forward

Help employees to understand their role and see how their performance contributes to
achieving our strategic objectives; Quality of Student Experience, Staff Recruitment &
Development, QAA / External Inspections and Finance
THE PDR CYCLE
Formal PDRs take place once a year and they will be reviewed as a minimum at the six month
interim mid-year review meeting.
These should be supplemented by regular and ongoing feedback (both positive and constructive)
which should be at the appropriate time (as something happens / does not happen) and through
formal mechanisms such as observations / peer reviews or one-to-one meetings.
How frequent these reviews / one to one’s are will depend on the size of the team and the needs
of the individual employee.
PDR is a continuous cycle with the meeting starting with the end of year review to reflect on
performance as well as looking forward through agreeing the future performance objectives. The
mid-year review reflects on performance against the newly set objectives:
4|P a g e
Performance
Development
Review
End of Year
Review
Mid Year
Review
HOW THE PDR SCHEME LINKS TO PERFORMANCE MANAGEMENT
PDR is part of Blackburn College’s Performance Management System. All objectives within the
Performance Management Framework are directly linked to delivering the College Strategic
Objectives with progress against objectives reviewed and evaluated at all levels.
The Business Planning process sets agreed objectives for centres / service areas / teams and
departments to support the delivery of the College Strategy. The individual business objectives
identified through the business planning process combine with the individual development
objectives to form the basis for the structured PDR discussion and PDP agreement. The link is
demonstrated by the following diagram:
5|P a g e
The PDR Timeline (detailed below) demonstrates the revised approach to target dates based on
staff group. Executive PDRs will be completed in the first target period followed by Management
PDRs in the second target period then academic and business support staff in the third target
period. The hierarchical approach to conducting PDRs ensures that objective setting is clearly
linked to business planning and that consistent messaging cascades through a team via the
management hierarchy structure.
Staff Group
SelectHR Annual
Target Completion
Date
Vice Principals
30 September
Top Management Tier (Executive Team &CLT)
15 November
Managers of Academic and Business Support
Staff
15 January
Academic & Business Support Staff Group 1
15 April
(last Appraisal held/scheduled prior to April of last
academic year)
Academic & Business Support Staff Group 2
31 August
(last Appraisal held/scheduled post April of last
academic year)
LINK BETWEEN OBSERVATION OF TEACHING, LEARNING & ASSESSMENT (OTLA)
OUTCOMES INCLUDING ACTION PLAN AND PDR
Included in the individual development objectives section of the PDR scheme is a clear link to the
Teaching and Learning Observation and Peer Review Processes which in turn links with the
College’s Organisational Development Plan.
All FE academic staff and certain staff in student facing roles undertake an annual learning
observation which leads to a developmental action plan, and UCBC academic staff undertake a
peer review with reflections on CPD requirements and opportunity to share practice. This is the
process by which academic staff demonstrate that they are providing an outstanding classroom
experience for the learner and that they are complying with the Quality Standards as set by the
College.
A good PDR involves both summative and formative components. Therefore, it is vital all staff
incorporate the outcomes of their observation including CPD requirements, opportunities to share
practice developmental action plan and feedback in the summative discussions to inform the
comprehensive performance development plan (PDP) to assist the employee in continuously
improving their practice. This will allow staff to focus on one developmental action plan targeted at
key essential development to complete during the PDR period and have reviewed at the mid-year
review.
6|P a g e
If staff have been placed on an action plan this must also be reviewed at the PDR and any further
identified actions included in the PDR development plan.
LINK TO STUDY PROGRAMME PERFORMANCE AND STRATEGIC DIRECTION
The individual development objectives also incorporates the Programme Development SelfAssessment Review (SAR) process within FE and the Annual Programme Review (APR) process
within UCBC. This ensures that the academic staff development plan is discussed in the context
of the performance and strategic direction of the study programmes / courses that academic staff
lead or deliver on.
LINK TO CAPABILITY
Where an employee’s performance falls below the required standard as identified in the end of
year rating “4 (Requires Improvement) - does not meet standards for performance and
behaviour. Requires immediate improvement and formal Performance Management and this will
be managed in line with the College’s Capability Policy & Procedure.
LINE MANAGERS OVERVIEW OF THE PDR PROCESS
Plan PDRs
Schedule Meeting (allow at least 2 hours if necessary)
Prepare for PDR Meeting
Agree date and time (give 2 weeks notice)
Arrange venue (private room)
Issue PDR1 forms and guidance (2 weeks in advance)
Gather information together and complete PDR2 Manager’s Preparation Form
Conduct the PDR Meeting - Beginning
Set up a comfortable room
Put the member of staff at ease and build rapport
Check the member of staff has prepared
Outline the agenda for the meeting and how long it is expected to last
Conduct the PDR Meeting – Main Body
Facilitate a balanced discussion – remember the conversation split should be 80% employee, 20%
manager so encourage the member of staff to think and talk openly as it is their PDR
Adopt a facilitative/coaching approach through using open questions
Review
performance
against the objectives and development requirements set last year and agree a
7|P a g e
performance standard
Discuss all sections in PDR3-Use forms as a guidance- ask other questions if necessary to assess
performance
Conduct the PDR Meeting – The End
Summarise discussion
Agree a date for sharing the typed up agreement for signature
End on a positive note
Post Meeting Actions
Update last year’s appraisal form and complete PDR 3 Form and share with employee for signature
Scan last year’s form, the PDR3 form and send the PDF and word version by email to
[email protected] copying in the employee
Diarise dates for reviews (one to one meetings, mid year review, or formal reviews)
Arrange development activities which do not require action by the OD Department
Ongoing Feedback
Give feedback throughout the year on performance
Hold regular one-to one meetings or supervisions (PDR5) and file locally
Review PDR objectives and development plan progress at mid year review (PDR4) and scan completed
form to [email protected]
GENERAL PDR PRINCIPLES
PDRs must:

Take place for all Blackburn College staff once a year, with a formal 6 monthly interim
review (or more if required).

Follow the corporate principles and use the forms documented in this guidance.

Be conducted on a one-to-one basis.

Be conducted by the person best placed to comment on the member of staff’s work. This is
usually the line manager unless another Colleague is more appropriate e.g. on a day-today basis the member of staff works more closely with another manager or supervisor.

Be supported by relevant guidance / briefing / training so that staff can participate
effectively.

Be consistently applied to all staff, including full time, part time, fixed term contract, and
8|P a g e
agency staff (where appropriate), with the exception of consultants.

Be completed on the forms provided applicable to that staff group./ the forms can be used
as guidance questions and other questions can be asked to assess performance
PDRs should be:

A culmination of good management practice – not a stand-alone activity that happens once
a year. Nothing in a PDR meeting should come as a surprise.

Based on facts and evidence and should not be based on opinion or personal values.

A two-way process with both the line manager and member of staff participating fully in the
preparation, discussion and follow up actions. PDR at its best incorporates elements of
assessment, performance management and personal development. To be effective, robust
and meaningful, the process should identify good performance and performance requiring
improvement at individual and/or team level.

Conducted according to these guidelines.
Performance Development Plan (PDP)
All staff must have an agreed PDP in place to ensure the development needs identified through
discussions are recorded and are linked to:



Role development or
Career development
Mandatory training
The PDP must be stretching and challenge the employee to gain continuous professional
development (CPD) in line with the College requirements (30 hours CPD if full time and pro rata if
part time with a minimum of 6 hours per academic year). Staff can record their development on
their CPD log on their desktop.
Managers must also review the Continuing Professional Development logs at the PDR and
ensure records are updated for College monitoring. A copy of the employee CPD log must be
attached to PDR3 and scanned across with the requested documents.
All PDP plans must include a target for digital literacy (staff must take their skills scan report to the
PDR) and development opportunity to gain industry updating (if applicable)
ROLES AND RESPONSIBILITIES (EXPECTATIONS)
The broad roles are described below.
Role of the Line Manager (or appropriate manager)
Line Managers must:
9|P a g e






Ensure all members of staff have an annual PDR and regular reviews
Ensure the member of staff has had a copy of the Performance PDR Scheme
Ensure that the member of staff understands the PDR scheme and is able to fully
participate in the process
Agree the date and time of the PDR with the member of staff
Book a suitable room which is free from interruptions
Collect and copy any information including;



Sickness Absence information over last 12 months (available through SelectHR)
Work / Role Adjustments previously agreed
Mandatory Training Compliance Information - course completed and expiry dates,
courses required to be completed and due dates
Managers of FE Academic Staff & Assessors only;
 Register completion rates / Assessor review completion rates
 Learning Observation Outcome and Action Plan if relevant
 Programme Review SAR Action Plans for all study programmes/course led or delivered
on
Managers of UC Academic Staff only;
 Annual Programme Reviews (APRs) for all study programmes/course led or delivered
on
Managers of Academic Management only;
 Performance Management Review Information for Academic Centre/Study Area
Managers of Business Support Management only;
 Performance Management Review Information for Service Area / Team











Prepare for the PDR and completed the Manager Preparation Form (PDR2)
Be objective and base the discussions on facts and not opinions
Be a respectful and developmental discussion on the employees role
Use a facilitative/coaching rather than telling approach
Conduct PDRs in a fair and consistent manner
Take appropriate follow up action after the PDR meeting
Ensure copies of PDR paperwork are scanned and emailed to HR in a timely manner
Ensure objectives set fall within the SMARTER guidelines
The content of a Personal Development Plan should be sufficiently challenging and
ambitious to enable the employee to improve practice but manageable within the context of
competing professional priorities.
Ensure that development needs identified via the Observation process, the SAR process
and/or the APR process and subsequent action plans are captured in PDR discussions
and form part of the Personal Development Plan for the employee.
Ensure if any actions require an input from another colleague/manager they are notified
and agree to the action prior to sign off
10 | P a g e
Role of the Employee
Employees must:
 Familiarise themselves with guidelines relating to the PDR scheme
 Ask their line manager for clarification or explanation if things are not clear
 Prepare for the interview by thinking about the areas for discussion and gathering required
information;



Mandatory Training Compliance Information - course completed and expiry dates,
courses required to be completed and due dates
CPD Log – evidence of 30 hours CPD in last 12 months
Professional Membership information – Professional Body, Membership Level,
Membership Number, Expiry Date
FE Academic Staff & Assessors only;
 Register completion rates / Assessor review completion rates
 Learning Observation Outcome and Action Plan if relevant
 Programme Review SAR Development Action Plans for all study programmes/course
led or delivered on
UC Academic Staff only;
 Annual Programme Reviews (APRs) for all study programmes/course led or delivered
on
Academic Management only;
 Performance Management Review Information for Academic Centre/Study Area
Business Support Management only;
 Performance Management Review Information for Service Area / Team







Complete the employee preparation form (PDR1) and taking it to the PDR meeting
Take an active part in the PDR meeting – own your PDR
Base the discussions on facts and not opinions
Have a respectful and developmental discussion on the role
Take agreed follow up action after the PDR meeting
All staff must reflect on common individual objectives such as:
Acting as role models to students in their professional behaviour, appearance and attitude
to learning and work
 Participate in Marketing and business development activity to support College recruitment
through attendance at recruitment events, if required
Role of Centre/Service Heads (or their appointed officer)
Senior Managers must:
 Ensure their PDR practices within the centre/service conform to these guidelines including
ensuring that all objectives set fall within SMARTER guidelines
 Ensure PDRs take place for all staff prior to the allocated deadlines
 Ensure staff have the skills and knowledge to participate fully in the PDR process
 Ensure consistency and quality of the PDR process within their Centre/Service Area
 Deal with any disagreements that cannot be resolved by Line Manager and Employee
11 | P a g e

Make the outcomes of PDR available for analysis to meet the requirements of equality
legislation
Role of the Director of Human Resources and Organisational Development
The Director of HR and Organisational Development must:
 Monitor how the PDR policy is implemented across Blackburn College
 Approve any changes to the scheme as necessary
 Report on compliance with the scheme to the Executive Management Team
 Ensure quality of PDRs and provide support and development where quality standards are
not met
 Maintain links between the PDR process, the Quality Unit and the Organisational
Development Team
 Provide support and training for Line Managers and Staff through the Organisational
Development Team
DISAGREEMENTS
It is expected that the line manager and member of staff, with the intervention of a more senior
manager if necessary, can resolve most disagreements. Additionally, regular monitoring of the
scheme and appropriate training should alleviate most issues. However, where agreement cannot
be reached, the PDR forms completed by the line manager will be submitted to HR with a file note
confirming that the employee has not agreed with the content. This will be the recorded PDR for
the employee.
SECTION 2 - SETTING PERFORMANCE STANDARDS
EFFECTIVE PERFORMANCE OBJECTIVES
This PDR scheme involves setting performance objectives, which break jobs down into
achievable goals based on the business planning objectives of the Centre/Service Area and the
College Strategic Objectives. You need to ensure these objectives state very clearly what
performance is expected. You can’t assess performance unless you have objectives that make it
very clear to everyone what is being working towards and what does successful achievement of
the objective look like.
First, you need to work out the key responsibilities. Most jobs have a number of key
responsibilities, which are ongoing throughout the year. Within each of these areas will be key
objectives. These are statements of the key targets, which the jobholder should achieve to an
agreed standard, over a set period of time. These should tie in with Performance Management,
Blackburn College’s Vision and Values, and Strategic and Business Planning Priorities.
Clear targets and standards are essential to measure performance. They need to be mutually
acceptable to you and your staff. Targets are about achieving short-term goals, getting results,
and providing a challenge and a sense of achievement. They can be used to set, raise, or reestablish standards, change priorities or achieve a project that often gets neglected.
Standards are continuing yardsticks; they cover quality as well as quantity. Standards can be
12 | P a g e
deadlines - the completion of tasks to time. They can be numeric - the quality of items produced,
or procedural - the carrying out of correct stages and procedures. They can also be financial - the
working to budgets, or negative – i.e. the number of complaints received. They should be
recorded in the Performance Objective section of the PDR3 form.
Effective objectives need to be challenging: they cannot be ‘a given’ of the role the employee is to
do. The employee needs a challenge to work towards and the objectives need to stretch their
skills and abilities. Sometimes you will have to convince them that you have the confidence in
them that they can do it, even if they don’t.
A minimum of four annual key work objectives should be set for each employee every year,
managers should expect to be set considerably more.
Objectives should be set using form PDR3 and need to be set within SMARTER guidelines:
SPECIFIC
Specific means that the objective is concrete, detailed, focused and well defined. The objective
must be straight forward and emphasise action and the required outcome. Specific also means
that it’s results and action-orientated. Objectives need to be straightforward and to communicate
what you would like to see happen.
MEASURABLE
If the objective is measurable, it means that the measurement source is identified and we are able
to track the actions as we progress towards the objective. Measurement is the standard used for
comparison. Remember if you cannot measure it, you cannot manage it. It is important to have
measures that will encourage and motivate staff on the way as they see the change occurring,
this may require interim measures. Measurements (and visible progress) go a long way to help us
to know when we have achieved our objective. If setting a behavioural objective they should
describe measurable behaviour.
ACHIEVABLE
Objectives need to be achievable, if the objective is too far in the future, staff will find it difficult to
keep motivated and to strive to attain it. Objectives need to stretch you, but not so far that you
become frustrated and lose motivation. However, achievable does not mean easy. Achievable
means that the individual has access to the time, skill, knowledge and resources to get it done.
Ask the question; with a reasonable amount of effort and application can the objective be
achieved?
RELEVANT
This means two things; that the goal or target being set with the individual is something they can
actually impact upon or change and secondly it also supports the achievement of overarching
Team and College objectives. Ultimately ask how does this impact on the learner or our
customers and service users?
TIME-BOUND
Time -bound means setting a deadline for the achievement of the objective. Deadlines need to be
both achievable and realistic. If you don’t set a time you will reduce the motivation and urgency
required to execute the tasks. Agreed time frames create the necessary urgency and prompts
action, empowering individuals to prioritise their own workloads.
13 | P a g e
EVALUATED
In order to ensure that Objectives remain relevant there should be an evaluation of progress at
various stages and once the objective is completed. Feedback for the individual should include
the impact of achieving the objective, not just an acknowledgement that it was achieved.
REVIEWED
In order to measure progress and evaluate whether an objective remains relevant there should be
an agreed process of reviews. How frequent these reviews are will depend on the objective and
the individual but as a minimum there should be one interim review (at six months) between
setting the objective and the timescale for completion
PERFORMANCE FACTORS
Line managers must consider all relevant performance factors when assessing to what extent the
employee’s performance is meeting the requirements of the job.
External factors that affected the achievement of the objective should be taken into account. If the
employee achieved the objectives in the face of unforeseen obstacles then this would be worth
more than if they’d had it plain sailing.
Circumstantial factors should also be taken into account. You need to be aware that ill health or
personal, financial worries can have an effect on performance and will need to be dealt with
according to College policy.
You will also need to take into account general factors that people in work are expected to
maintain, such as standards of behaviour, dress, time-keeping and applying common sense and
initiative where necessary. Levels of commitment and motivation also need be taken into account.
It is not expected that individual objectives will be set relating to circumstantial factors unless
there are serious issues related to conduct or capability.
MEASURING PERFORMANCE
Performance Objectives
The objectives in the PDR system are assessed against the Performance Objectives set in form
PDR3 and should be rated as follows:
Exceeded – this is where an individual does not just meet the objective or minimum required
standard but performs significantly above expectations.
Met – this is where the individual achieves the objective as set out within timescales and the
resources allocated
Not Met with Reason – this is where an individual has been unable to achieve the objective due
to external or internal factors over which they had no influence. These factors should be
significant and clearly evidence how they prevented achievement of the objective
Not Met – this is where an individual has failed to meet a required standard or achieve an
objective and there are no significant influencing factors.
14 | P a g e
Overall Assessment Level
The start of the PDR meeting focusses on performance against set objectives and reflects on
personal responsibilities and teaching and learning/department/team responsibilities. The
manager should consider the employee’s overall assessment against this context and can choose
from one of the following four options:




1 (Outstanding) - consistently exceeds standards for performance and behaviour and acts
as a role model for colleagues.
2 (Good) - meets standards for performance and behaviour.
3 (Adequate) - does not meet some standards for performance and behaviours.
Performance Improvement Plan is required for standards not met.
4 (Requires Improvement) - does not meet standards for performance and behaviour.
Refer to HR.
The Manager should assess the achievement of objectives across each of the levels and consider
the reflections on personal responsibilities and teaching and learning/department/team
responsibilities. E.g.

if 5 Objectives were set and the individual was assessed as having met 4 objectives and
not met 1 objective and they have demonstrated commitment to their responsibilities then
their overall assessment level would be ‘2 (Good) - meets standards for performance and
behaviour’.

If 5 Objectives were set and the individual was assessed as having met 4 objectives and
not met 1 objective and they were non-compliant with mandatory training and had low
register completion rates their overall assessment level would be ‘3 (Adequate) - does not
meet some standards for performance and behaviours. Performance Improvement Plan is
required for standards not met’.
Where an individual achieves an overall assessment of 1 (Outstanding) then this should be
passed to the Manager’s line manager for formal recognition of exceptional performance. Where
an individual is awarded an overall assessment of 4 (Requires Improvement) then the College’s
capability procedures must be invoked to ensure formal performance management is put in place.
ASSESSING PERFORMANCE STANDARDS
Assessments should always be backed up by evidence and comments that describe how they
were achieved. Comparisons between employees are meaningless. Each employee's
performance level relates to the particular circumstances they had to work with, or against.
Assessments must however be consistent across all employees.
Agreement on the performance rating should be sought between the employee and manager.
Agreeing performance ratings can only work if the descriptions of the correct behaviour/action
required are agreed when the objectives are written up, as these objectives should describe the
required level of performance.
15 | P a g e
IN SUMMARY
With the right preparation and the use of effective objectives and performance levels, you will be
ready for a productive and positive PDR discussion. Both employee and manager need to prepare
for the PDR discussion.
Performance objectives need to be:
 Specific
 Realistic
 Measurable
 Achievable
 Relevant
 Evaluated
 Reviewed
Performance assessments should be:
 Descriptive
 Evidence Based
 Backed up by Written Comments
 Consultative
 Be Reached by Agreement where Possible
 Evaluated
 Reviewed
Personal Development Plans should be set for all employees. The College is committed to
Continuous Professional Development and it is not acceptable for any individual to identify no
Learning and Development needs as part of this process.
Managers are responsible for ensuring that at PDR minimum qualification requirements are
discussed and progress on achieving these monitored (e.g. attainment of a teaching qualification)
and fed back to the HR & OD team. Managers are also responsible for ensuring that development
needs identified via the Observation / Programme Area SAR and APR process and detailed in
action plans are captured in PDPs.
LINKED POLICIES
Observation of Teaching, Learning and Assessment
HR & OD Strategy
Capability Policy
Probation Policy
OD plan
College Strategic Plan
MONITORING AND REVIEW OF THE SCHEME
The PDR process has been revised and simplified and has been designed so that the appropriate
set of forms are relevant to the identified staff group.
It will continue to be reviewed to ensure that it is fair and fits with the needs of the College and
individuals every three years or sooner if required.
Compliance with the scheme will be monitored by the HR & OD team and reported to senior
management via a variety of mechanisms.
EQUALITY IMPACT ASSESSMENT
Blackburn College is committed to the promotion of equality, diversity and providing a supportive
environment for all members of our community. Our commitment means that this policy has been
16 | P a g e
reviewed to ensure that it does not discriminate (either intentionally or unintentionally) any of the
protected characteristics of age, disability, gender (including gender identity)race, religion or
sexual orientation and meets our obligations under the Equality Act 2010. Therefore, this policy
has no adverse impact on any of the above protected groups.
17 | P a g e