1. Purpose and scope
Chefs Bay Hospitality Limited is committed to a workplace, and to client placements, that are free from unlawful discrimination, harassment, and victimisation. Equality, diversity, and inclusion sit at the heart of how we recruit, manage, and place chefs, and how we run our office.
This policy applies to:
- Office staff at Chefs Bay
- Chefs and catering workers placed by Chefs Bay on assignment
- Recruitment processes, including candidates not yet placed
- Working relationships with clients, suppliers, and contractors
Because we are an employment business, our chefs work alongside people who are not employed by Chefs Bay. The Worker Protection Act 2023 duty to prevent sexual harassment of our workers extends to harassment by these third parties. This policy reflects that.
2. Regulatory framework
- Equality Act 2010, including the nine protected characteristics under section 4, the prohibitions on direct and indirect discrimination (sections 13 and 19), harassment (section 26), victimisation (section 27), the equal pay framework (sections 64 to 79), and the positive action provisions (sections 158 and 159)
- Worker Protection (Amendment of Equality Act 2010) Act 2023, in force 26 October 2024, creating the new section 40A positive duty on employers to take reasonable steps to prevent sexual harassment, including by third parties, and the section 124A tribunal uplift of up to 25%
- Equality and Human Rights Commission technical guidance on sexual harassment and harassment at work (updated September 2024) and the EHRC eight-step employer guide
- Protection from Redundancy (Pregnancy and Family Leave) Act 2023, with extended redundancy protection in force from 6 April 2024 under SI 2024/264
- EHRC guidance on menopause in the workplace, February 2024
- Public Interest Disclosure Act 1998, including section 43K extending whistleblowing protection to agency workers
- ACAS Code of Practice on Disciplinary and Grievance Procedures
- Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (the 250-employee threshold for mandatory gender pay gap reporting, which Chefs Bay does not meet)
- Employment Rights Act 2025, with phased commencement through 2026 and 2027
3. The protected characteristics
The Equality Act 2010 protects the following characteristics:
age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, sexual orientation.
We will not discriminate, harass, or victimise any worker, applicant, or colleague on the basis of any of these characteristics. We will make reasonable adjustments under sections 20 to 22 of the Equality Act 2010 where required, including in respect of menopause symptoms that meet the section 6 threshold for disability.
4. What discrimination, harassment, and victimisation mean here
Direct discrimination occurs where someone is put at a disadvantage on a discriminatory ground. It can be unintentional and still be unlawful.
Indirect discrimination occurs where a provision, criterion, or practice that looks neutral has a disproportionate adverse effect on a protected group, and cannot be objectively justified.
Harassment is unwanted conduct related to a protected characteristic that has the purpose or effect of violating dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment. A single incident can amount to harassment if it is sufficiently serious.
Victimisation is treating someone less favourably because they have raised a discrimination concern, supported one, or done anything else under the Equality Act in good faith.
Sexual harassment under the Worker Protection Act 2023 covers all of the above where the conduct is of a sexual nature, and the duty to prevent it now sits as a positive obligation on Chefs Bay as employer.
5. Third-party harassment: how we comply with the Worker Protection Act 2023
Our chefs work in client kitchens around managers, colleagues, customers, and visitors who are not Chefs Bay staff. The third-party harassment risk is real for us in a way that is not true of an office-only employer. We treat the Worker Protection Act 2023 duty as an active operational obligation, not a paper one.
Reasonable steps we take:
- Risk assessment per assignment. Where a placement is into a setting we have not worked in before, we assess third-party harassment risk before deployment and brief the chef accordingly.
- A reporting route that bypasses the client. Chefs report concerns directly to Chefs Bay, not only to the client, so a report cannot be intercepted or suppressed by the alleged harasser.
- Documented escalation. Reported incidents are logged on our internal record. The office contacts the client immediately for investigation. Where a pattern emerges or the chef is at risk, we escalate to lifting the placement and supporting the chef with a replacement booking.
- Witness statement support. Where a chef chooses to take an incident to tribunal, we support them with the documentation we hold.
- Briefing before placement. Chefs are told the reporting route at registration and reminded at the start of each new client engagement.
Office staff have completed harassment awareness training that covers Worker Protection Act 2023 sexual harassment alongside Equality Act 2010 protected-characteristic protections.
6. Recruitment and selection
Recruitment and employment decisions are made on objective criteria relevant to the role. Person and job specifications cover only the requirements necessary for effective performance of the role. Interviews are structured around the same criteria for every candidate. Personal or home commitments do not form the basis of a hiring decision unless they are demonstrably relevant.
We comply with the Rehabilitation of Offenders Act 1974 and the Exceptions Order 1975 (as amended) when handling criminal-conviction information. Spent convictions are considered only where the role is in scope of the Exceptions Order. The Police, Crime, Sentencing and Courts Act 2022 changes in force from 28 October 2023 are reflected in our practice.
7. Pregnancy, maternity, and family leave
Workers are protected from discrimination on grounds of pregnancy and maternity from the point of pregnancy notification. Following the Protection from Redundancy (Pregnancy and Family Leave) Act 2023 changes in force from 6 April 2024, the protected period for redundancy now runs from pregnancy notification to 18 months from the expected week of childbirth (or placement for adoption). Where a pregnant or recently-returned chef is on assignment via Chefs Bay and the assignment ends, we recognise our duty as employer to offer a suitable alternative role if redundancy applies, alongside any duty held by the host.
8. Menopause and reasonable adjustments
Menopause symptoms that have a substantial and long-term adverse effect on day-to-day activities can amount to a disability under section 6 of the Equality Act 2010, triggering the duty to make reasonable adjustments. Reasonable adjustments may include uniform changes, break frequency, ventilation discussions with the host, or shift-pattern flexibility. Workers should raise needs with the office (Michael Szalaty as EDI lead) so we can arrange the right adjustments.
9. Equal pay
Chefs Bay is committed to the principle of equal pay for men and women. Pay covers remuneration as well as benefits, training opportunities, and access to facilities provided as part of the engagement. Pay systems are transparent, based on objective criteria, and free from sex bias.
Women and men employed by Chefs Bay are entitled to equal pay where they are undertaking work that is substantially similar or of equal value, unless there are specific and documented reasons unconnected with sex (seniority, qualifications, experience) that explain a differential.
The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 apply to private and voluntary-sector employers with 250 or more relevant employees. Chefs Bay does not meet the 250-employee threshold and has no statutory duty to report gender pay gap data. We will publish a gender pay gap report voluntarily once we cross a meaningful measurement threshold.
Workers can raise pay queries informally with the Managing Director in the first instance. Where a query is not resolved informally, the formal grievance procedure is used.
10. Bullying and dignity at work
Bullying is any form of physical or verbal attack, threat, abuse of position, or unreasonable pressure that undermines confidence, ability, or dignity. Examples include name-calling, ridicule in front of customers or clients, setting impossible deadlines, excessive monitoring, or unjustified criticism. Bullying may overlap with harassment under section 26 of the Equality Act 2010 where it relates to a protected characteristic.
Every Chefs Bay employee, every chef on assignment, and every office contact has a responsibility to maintain a working environment that respects the dignity of others.
11. Whistleblowing
The Public Interest Disclosure Act 1998 protects workers, including agency workers under section 43K, who make a qualifying disclosure in the public interest. Qualifying disclosures cover criminal offences, breach of legal obligations, miscarriages of justice, health and safety risks, environmental damage, and deliberate concealment of any of these.
Chefs Bay treats any such disclosure in confidence. Detriment for making a qualifying disclosure in good faith is unlawful and will not happen. Disclosures should be sent to hr@chefsbay.co.uk.
12. Raising a concern
Concerns about discrimination, harassment, victimisation, or pay should be raised with the Managing Director (Michael Szalaty) as EDI lead in the first instance. Where the concern involves the EDI lead directly, write to hr@chefsbay.co.uk.
We follow the ACAS Code of Practice on Disciplinary and Grievance Procedures. Failure by an employer to follow the ACAS Code can result in tribunal awards being adjusted by up to 25% under section 207A of the Trade Union and Labour Relations (Consolidation) Act 1992. We treat the Code as the floor.
13. Roles and responsibilities
The Managing Director owns this policy and the EDI lead role. Office staff and chefs share responsibility for treating others with dignity and respect, for not engaging in any form of discrimination or harassment, and for reporting concerns through the routes set out above.
Specifically, every Chefs Bay employee must:
- Report any suspected discriminatory act or practice
- Refuse to induce or attempt to induce others to practise unlawful discrimination
- Cooperate with any measure introduced to ensure equality of opportunity
- Refuse to victimise anyone for raising or supporting a discrimination concern
- Refuse to harass, abuse, or intimidate others
14. Review
This policy is reviewed every 12 months, or sooner if Equality Act 2010 enforcement guidance, EHRC technical guidance, or the Employment Rights Act 2025 commencement orders change in ways that affect the duty.
15. Sign-off
Approved by:
Michael Szalaty
Managing Director, Chefs Bay Hospitality Limited
Date: 6 May 2026
Chefs Bay Hospitality Limited · Companies House 13588811 · VAT 389155944 · ICO ZB226754
Registered office: 1 Queen’s Park Road, Handbridge, Chester, CH4 7AD Operational base: Liscard Business Centre, 188 Liscard Rd, Wallasey, CH44 5TN
Policy CB-POL-002 · Version 2.0 · Effective 6 May 2026 · Next review 6 May 2027
