Inclusion & diversity.

BREE Construction builds homes for the whole population. The team that designs, procures and delivers those homes has to reflect the population it builds for, on every project, on every site, at every level. That is the position from which this policy is written.

We are a residential contractor with operating entities active since 1955. Our schemes are commissioned by housing associations, local authorities, build-to-rent investors and universities. We work in inner London, the North East, the Midlands and Wales, on sites adjacent to communities whose composition is no more uniform than the country as a whole. Inclusion is not a side initiative for a contractor in this position; it is a precondition for delivering well.

This document sets out the standard we hold ourselves to, beyond the legal minimum, and the mechanisms we use to measure whether we are meeting it. It is reviewed annually and is owned at director level.

This policy sits inside, and goes further than, the framework set by the following UK legislation and codes:

• the Equality Act 2010, including the nine protected characteristics set out in section 4;
• the Public Sector Equality Duty (s.149, EA 2010), which we honour as a contractor delivering for local authorities and registered providers;
• the Health and Safety at Work etc. Act 1974 and the duty to ensure a working environment that is, so far as is reasonably practicable, safe and without risks to health, including psychosocial harm;
• the Public Interest Disclosure Act 1998 (PIDA), which protects employees who raise concerns about unlawful conduct, including discrimination;
• the ACAS Code of Practice on Discipline and Grievance, which governs how we respond when concerns are raised.

Where a project is delivered in Scotland, Wales or Northern Ireland, the relevant regional equivalents (e.g. the Equality Act 2010 as it applies in Scotland; section 75 of the Northern Ireland Act 1998) take precedence on points of variation.

Discrimination, harassment or victimisation on any of the following grounds, set out in s.4 of the Equality Act 2010, is prohibited inside BREE Construction and on every site we operate. The list is repeated in full on every site induction:

1. age;
2. disability;
3. gender reassignment;
4. marriage and civil partnership;
5. pregnancy and maternity;
6. race (including colour, nationality and ethnic or national origin);
7. religion or belief (including lack of belief);
8. sex;
9. sexual orientation.

The same prohibition extends, by policy rather than by statute, to socio-economic background, parental status, neurodivergence and ex-offender status, all of which are characteristics that intersect heavily with the construction workforce and with the communities we build in.

The construction sector has historically drawn from a narrow recruitment funnel. We design our process to widen it deliberately:

• Job design. Role specifications are tested for unnecessary qualifications, gendered language and criteria that act as proxies for protected characteristics. Where a requirement is genuinely operational (e.g. CSCS card, manual-handling capacity), it is stated; where it is a preference, it is removed.
• Sourcing. Vacancies are placed against at least one route that reaches outside the standard construction-recruiter shortlist, including local authority employability schemes, ex-forces routes and the CITB-supported Routes into Construction programmes.
• Shortlisting. CV review is conducted with personally-identifying information minimised where the role and recruiter capacity allow, particularly at site-team and graduate level.
• Interview panels. No interview at decision stage is conducted by a panel of one. Panels are constituted with deliberate attention to composition, and interviewers complete a short calibration on lawful questioning before participating.
• Apprenticeships and early careers. Every scheme of qualifying value is delivered with a defined apprenticeship and work-experience commitment, agreed with the client at contract and reported quarterly.

The barrier to a more representative workforce in construction is rarely entry; it is progression. We address that explicitly:

• Equal access. Internal training, mentoring and external qualification budgets are distributed against development plans, not informal sponsorship; allocation is reviewed annually for distribution across protected characteristics.
• Promotion criteria. Promotion paths (assistant → junior → senior, for surveying, project management and site management) carry transparent evidence requirements. Decisions are recorded against those requirements, not against subjective “readiness” judgements.
• Sponsorship of under-represented voices. Where a discipline shows materially uneven representation against the recruiting market, the senior leader for that discipline is required to identify, sponsor and report on development of internal candidates from under-represented groups.
• Career returners. Returns from career breaks (parental leave, carer responsibilities, illness, redeployment) are supported through a structured re-induction; no role is closed by absence alone.

A construction site is the most public face of this policy. Every BREE Construction site operates to the following non-negotiable standards, audited as part of our Considerate Constructors Scheme registration:

• Language and behaviour. Discriminatory language, harassment, sexualised conduct and bullying are disciplinary matters at first instance, not at second. Site induction sets the standard explicitly; site managers are accountable for enforcing it.
• PPE and equipment. Personal protective equipment is procured in inclusive size ranges and in specifications appropriate for diverse body types, hijab- compatible head protection included.
• Welfare facilities. Welfare on every site of qualifying scale provides separate sanitary facilities, sanitary product provision, lockable changing space and a quiet room. Larger sites, and longer programmes, additionally provide a parental-feeding space.
• Reasonable adjustments. Adjustments requested under s.20 of the Equality Act 2010 are assessed and implemented promptly; the reason for any decision not to adjust is recorded in writing.
• Visiting communities. Where a scheme is delivered adjacent to schools, community centres or mosques, our site managers maintain contact with the community lead, and our hours and access protocols flex accordingly.

A policy is only as strong as its complaint route. Anyone working on a BREE Construction project, employed directly, sub-contracted or visiting, can raise a concern through any of the following channels without prejudice to their position:

• their direct line manager or site manager;
• HR, contactable confidentially through the channel published on every site induction;
• an independent whistleblowing line (Protect, formerly Public Concern at Work), for matters they prefer to raise outside the company.

All concerns are acknowledged within five working days and investigated under the ACAS Code. Retaliation against anyone who raises a concern in good faith is itself a disciplinary matter under this policy and is protected by PIDA 1998. Outcomes of investigations are recorded; aggregated trends are reviewed by the director accountable for this policy at least quarterly.

A policy without numbers behind it is a marketing document. BREE Construction commits to the following measurement cadence, regardless of whether the underlying threshold obliges us by statute:

• an annual workforce composition snapshot published in our annual report, broken down by role family, seniority and the protected characteristics for which voluntary disclosure data is sufficient;
• a gender pay-gap report published annually from the financial year in which we cross the 250-employee statutory threshold, alongside a voluntary ethnicity pay-gap report from the same point;
• a retention and progression review, run internally every six months, examining whether attrition and promotion rates differ materially between protected groups;
• a concerns and complaints summary anonymised and reviewed by the board annually.

Accountability for this policy sits with a named director. Findings that the policy is not being met in practice are escalated to that director without filtering, and from there to the senior leadership team.

The standards above apply on BREE Construction-led sites; we extend them contractually to the businesses we sub-contract to:

• sub-contractors are required, as a condition of inclusion on the BREE Construction supply chain, to maintain and follow an equivalent inclusion and diversity policy and to confirm its existence in pre-qualification;
• site conduct standards apply to every operative on a BREE Construction site regardless of which business pays them, and breaches are the responsibility of the supply-chain partner’s own management as well as ours;
• material concerns about a supply-chain partner are surfaced into the same speaking-up channels open to direct employees (section 07 above), and into the partner’s own disciplinary process via our Procurement function.

This policy is owned by the BREE Construction board and reviewed at minimum annually, alongside the publication of the annual report. It is reviewed earlier where:

• relevant legislation changes (e.g. amendments to the Equality Act 2010 or to UK pay-gap reporting thresholds);
• a measurement cycle reveals a material gap against the standards set above;
• a concern, internal or external, requires a substantive response.

Comments on this policy, including from candidates, employees, sub-contractors, clients or members of the public, are welcomed. They can be sent to enquiries@breeconstruction.co.uk.