1. Purpose and scope
EdenFiftyOne Ltd (company no. 13347459) treats everyone with dignity and respect and does not tolerate discrimination, harassment or victimisation. Because our platform assesses pupils' work, we hold ourselves to a high standard on fairness, children's rights and privacy.
This policy applies to directors, staff, applicants, contractors and agency workers, and to our dealings with schools, colleges, learners, suppliers and partners. It covers all work activity, in person or online. It does not form part of any employment contract.
2. Legal framework
This policy reflects the Equality Act 2010, including the duty (from 30 October 2026) to take all reasonable steps to prevent sexual harassment and harassment by third parties; UK GDPR and the ICO Age Appropriate Design Code; and, as voluntary commitments, the UN Guiding Principles on Business and Human Rights and the UN Convention on the Rights of the Child.
3. Equality and discrimination
We will not discriminate because of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, or sexual orientation. This covers direct and indirect discrimination, failure to make reasonable adjustments, harassment, and victimisation of anyone who raises a concern in good faith.
Breaching this policy is a disciplinary matter and may lead to dismissal. Contractors who breach it may have their engagement ended.
4. Harassment
We take all reasonable steps to prevent harassment, including sexual harassment, whether by colleagues or by third parties such as school staff, customers, partners or contractors. To do this we will:
- keep a harassment risk assessment, covering online work, client visits and events, and review it annually
- train all staff at induction and regularly after that
- set clear conduct expectations for customers, partners and contractors
- respond promptly to every report, investigate fairly, and support anyone affected
No settlement or confidentiality agreement will stop anyone reporting harassment or making a protected disclosure.
5. Recruitment and employment
Decisions on recruitment, pay, promotion and development are based on skills, experience and performance, against clear criteria. We ask applicants whether they need adjustments, make reasonable adjustments for disabled staff, and consider flexible working and family or religious needs seriously. Where AI tools support people's decisions, a person makes the final decision.
6. Human rights commitments
Our biggest potential impact is on the young people whose work we assess. We commit to:
- Children's rights and privacy: design in the best interests of the child, collect only the data we need, never use pupils' data for advertising, and carry out DPIAs where pupils' rights could be affected.
- Fair AI assessment: test our models for bias across groups of learners, keep teachers able to review and override AI marks, explain to schools how marks are produced, and fix unfair patterns we find.
- Accessibility and safeguarding: work towards WCAG 2.2 AA, and report welfare concerns to the school's designated safeguarding lead.
- Supply chains and workers: no tolerance of forced or child labour or trafficking, equivalent expectations of our suppliers, at least the National Living Wage, and respect for the right to join a union.
7. Responsibilities
The Board approves this policy and reviews it annually. The policy owner, a Director, keeps it and the risk assessment up to date, arranges training and oversees investigations. Managers must act on inappropriate behaviour and pass reports to the policy owner. Everyone must treat others with respect and report concerns.
8. Raising a concern
Staff should raise concerns with their line manager, the policy owner or, if the concern involves the policy owner, another director. Anyone outside the company, including school staff, pupils, parents and suppliers, should use the contact email on our website.
We will acknowledge concerns promptly, investigate fairly and confidentially, and confirm the outcome in writing. Nobody will be treated badly for raising a concern in good faith. Safeguarding concerns about a child must also go to the school's designated safeguarding lead without delay. Free, confidential advice is available from Acas.
9. Training, monitoring and review
All staff complete equality and anti-harassment training at induction and annually. We keep confidential records of complaints and AI bias testing, which the Board reviews each year alongside this policy. The policy is published on our website.
- Approved by
- Director, for the Board of EdenFiftyOne Ltd
- Date approved
- 5/11/26
- Next review
- 5/11/27
- Version
- 1.1