Equality And Diversity Policy


This policy applies to all Companies in Luminus Group.


Luminus upholds Values that promote fairness in all its activities, seeking to promote good relations and equality for all with whom it comes into contact.  The aim of this policy is to provide a framework that enables Luminus to meet its statutory, regulatory and moral obligations.

Policy Statement

Luminus acknowledges the complex and changing approaches to diversity in society and seeks to take account of this context to ensure equality in its business activities.  Through its Equality and Diversity Policy and associated strategies, actions plans and procedures, Luminus will seek to ensure that its approach to equality and diversity conforms to the law including:

  • The Equality Act 2010
  • The Protection from Harassment Act 1997
  • The Human Rights Act 1998
  • The Fixed Term Work Directive 2002
  • The Data Protection Act 1998
  • Work and Families Act 2006
  • The Equality Act (Sexual Orientation) Regulations
  • Commission for Racial Equality (Equality and Human Rights Commission) Code of Practice for Racial Equality in Housing 2006
  • Disability Rights Commission (Equality and Human Rights Commission) Disability Equality Duty 2006
  • The Tenant Services Authority’s Single Equalities Scheme 2010
  • The Homes and Communities Agency’s Single Equality Scheme 2009


Through our Equality Scheme we will conduct comprehensive impact assessments to identify how planned and existing policies will bring about outcomes for our customers.  We will involve customers, staff and other stakeholders throughout the process.  We will use the information collected to develop action plans and carry out regular reviews to ensure recommended actions are implemented and remain relevant to our customers, local context and our operating environment.

We will use the Audit Commission’s Key Lines of Enquiry as a business improvement tool and ensure the recommended standards of service delivery, as set out in the Diversity KLOE are achieved and integrated into all areas of our work.

This policy seeks to be comprehensive and includes:


Luminus will not unlawfully discriminate against any of the staff it employs, agency workers or contractors who deliver services on its behalf.  Luminus will treat people fairly according to their merits and abilities, as required for the work they carry out and will deal appropriately with allegations of direct discrimination, associative discrimination, indirect discrimination, discrimination by perception, harassment, harassment by a third party and victimisation.  To meet the objectives of this Equality and Diversity Policy Luminus will seek to:

  • ensure that any person or group of persons applying for a job or a contract are able fairly and equally to access to our services;
  • identify under-representation and potential barriers to in employment opportunities, taking appropriate action in recruitment relating to under-represented or minority groups, and providing training and other types of assistance where appropriate to help achieve this aim;
  • collect appropriate information and monitor records, within the provisions of the law, relating to prospective and current employees and, as appropriate, utilise this in processes of continuing improvement of policy, procedures and effective management;
  • apply our approach to equal opportunities when hiring contractors and other agencies to work for us,
  • review our employment services to people from diverse backgrounds through equality impact assessments, involving employees as appropriate to assure management that the outputs add value to the operation of the business.

Service Delivery

Luminus will not unlawfully discriminate against individuals or any particular groups when delivering services.  Luminus is committed to excellence and will use a variety of training and development methods to enable employees to fulfil the requirements of the law.

Luminus will implement the following actions to achieve the objectives of this Equality and Diversity Policy:

  • adopt the provisions of the Code of Practice for Racial Equality in Housing, the Disability Equality Duty and Equality Act 2010
  • develop procedures for handling harassment and nuisance to ensure prompt action is taken;
  • provide information to residents about our services in a way which is accessible to everyone, regardless of their background and personal circumstances;
  • collect and monitor relevant and appropriate information, as permitted by law and subject to the wishes for privacy of individuals, relating to people applying for housing and using our services;
  • monitor lettings, the take up of services and levels of participation in tenant involvement activities;
  • monitor customer satisfaction with the full range of services provided to identify disparities in satisfaction levels based on age, gender, disability, race, religion and sexual orientation;
  • where disparities exist in satisfaction levels across different groups of customers, we will investigate the cause of the dissatisfaction and ensure the issues are taken into account when planning new services and reviewing existing ones;
  • advise contractors, consultants and other agencies working for Luminus of our commitment to equal opportunities and request details of their own equal opportunities policy and practices;
  • subject to the exigencies of the business, assist potential contractors or consultants who are from an ethnic minority or have a disability, to fulfil the minimum requirements to undertake contracts with Luminus;
  • investigate and take appropriate action concerning allegations where an employee’s conduct infringes the requirements of this policy as regards employees;
  • ensure services are delivered in accordance with the requirements set out in our Equalities Scheme and related action plans;
  • provide appropriate training to enable non-executives and employees to comply with this policy.

Access to information and services

Luminus will take positive steps to ensure that all our customers, partners and people living in the community are able to enjoy fair and equal access to our services.  We will achieve this by identifying the needs and preferences of people with whom we work and deliver services to, using this information to make reasonable adjustments to the way we provide information and enable physical access to our sites.  We will ask residents to complete a customer profiling form at the time of their annual gas safety check, with the information provided being used only for the purpose of improving our services. We will ensure that all tenants complete a Customer Needs Survey at the beginning of their tenancy and are given the opportunity to complete other related surveys periodically to ensure our records are up to date.  We will provide information in a range of formats and languages and will deal promptly with requests for assistance.  We will provide training and assistance to staff to ensure they are sensitive to, and able to respond appropriately to the needs and preferences of people who wish to access our services.

Asset Management

Luminus will provide appropriate levels of services for people with a disability and those who live in their households.  We will achieve this by maintaining records of adapted houses and will use this information when considering bids for homes under Home-Link, the sub-regional Choice Based Lettings Scheme we work within.  We will clearly communicate to our customers and other stakeholders our approach to providing aids and adaptations, to include providing appropriate assistance to people who wish to apply through the Disabled Facilities Grant Programme.  We will also ensure that aids and adaptations are recycled in an appropriate and sensitive way.

Resident Involvement

We will work with our customers to identify potential ways of encouraging participation in our Tenant Involvement Framework.  This will include considering the needs and aspirations of all our customers through the Tenant Involvement impact assessment process.  Through our Tenant Involvement Statement and Strategy we will provide a range of methods and opportunities for people to participate, to include the formation of special interest groups and consultation panels for people from different groups and those with specific needs.  We will provide opportunities for people to participate from their own home where this is their preference and seek to assist people to attend meetings to ensure they are not excluded because of disability, isolation or any other factors.  We will take into account the diversity of our customers and communities when selecting tenant and leaseholder non-executives.

Dealing with Harassment

We will work through appropriate strategies and procedures to ensure that tenants can enjoy their legal rights, including being able to live safely and peacefully, recognising that other agencies will also have responsibilities.  To help us to achieve these aims we have adopted the following approach to dealing with harassment:

  • allegations of harassment, against or by a tenant, employee or contractor will be dealt with promptly, firmly and sensitively;
  • no action will be taken without first consulting the person being harassed.  We will support and protect the victim;
  • where the perpetrator is known and is a tenant, employee or contractor, Luminus will take appropriate action against the perpetrator.  Where the perpetrator is not a tenant, employee or contractor and/or is not known, we will take every reasonable practical step to ascertain who was involved in harassing the victim and will take appropriate action;
  • we will support Stop Hate UK; a nationwide scheme which supports individuals and communities affected by Hate Crime.

Dealing with Domestic Violence

We will put in place strategies and procedures to ensure that everyone can enjoy the right to live safely and peacefully, without threat of, or being a victim to domestic violence.  We will adopt a sensitive approach which will include providing appropriate information and support to victims. We will work proactively with relevant partners, including the police, local authorities and other agencies to provide a comprehensive service and help bring about solutions which are appropriate to the circumstances of individual cases.

Community Cohesion and Integration

We will contribute to local partnerships to support and promote community cohesion initiatives.  This will include membership of Huntingdonshire’s Diversity Forum.  Our approach to Community Development will take into account the most effective and relevant ways to promote community cohesion and integration.

Procurement and supply diversity

We will ensure that services delivered by our contractors on our behalf are consistent with our approach to equality and diversity as set out in this policy.  We will monitor all suppliers of goods and services to ensure their organisational policies and cultures promote equal opportunities and include measures to tackle discrimination and harassment.  We will not employ the services of any organisation which is not able to demonstrate they comply with these requirements.  We will also provide support to small organisations who wish to work with us but who do not have the resources to adopt the approach we require.


Luminus will provide appropriate training, support and guidance to non-executives, seeking to encourage diversity in participation at this level.  Luminus will also ensure that all residents who are involved in carrying out impact assessments of our related policies and procedures are provided with an appropriate level of training to enable them to understand relevant issues and make an effective contribution.

Performance management

Through Luminus Group’s Performance Management Framework all relevant areas of activity will be monitored to ensure compliance.  Performance in achieving the objectives of this policy will be reported periodically at Boards, in the Annual Report to Tenants and internal Annual Statement of Compliance.

Related Policies

Luminus will reflect the aims and objectives of its Equality and Diversity Policy within the following related policies:

  • Anti-social Behaviour (incorporating Harassment) Policy
  • Joint Tenancies, Relationship Breakdown And Domestic Violence Policy
  • Tenant Involvement Policy
  • Customer Care Policy
  • Housing Needs and Lettings Policy
  • Repairs, Maintenance and Improvements Policy
  • Procurement and Selection of Contractors Policy
  • Development and Standards Policy
  • Services for the Elderly, Vulnerable, Disabled and People with Special Needs Policy
  • Development and Standards Policy


The Group Chief Executive has overall responsibility for the effective implementation of this Equality and Diversity Policy though Directors, Heads of Service and Managers.


Luminus will liaise with the appropriate groups representing employees, customers and partners on a regular basis to assess the effectiveness of its Equality and Diversity Policy.


The Head of Executive Services will review this policy every three years, or as required by changes to regulatory or statutory obligations and our local operating environment.