Our commitment
Bubble Fresh (Bubblefresh Limited, company number 12691029) is committed to equality of opportunity and to eliminating unlawful discrimination. We value diversity and recognise what people with different backgrounds, skills, and experiences bring to our work. As a specialist cleaning company working with vulnerable adults and council partners, we understand that the people we serve may face multiple overlapping disadvantages. We will not tolerate discrimination, harassment, or victimisation on the grounds of any protected characteristic.
Scope
This policy applies to all employees, job applicants, contractors, and anyone working on behalf of Bubble Fresh. It covers recruitment, training, promotion, pay, working conditions, and service delivery. It also applies to how we treat our clients, their families, council officers, and anyone else we come into contact with through our work. We expect our partners and suppliers to share our commitment to equality.
Legal framework
This policy is guided by the Equality Act 2010. That Act protects people from discrimination, harassment, and victimisation in employment and services. It also reflects the Worker Protection (Amendment of Equality Act 2010) Act 2023, which places a preventative duty on employers to take reasonable steps to prevent sexual harassment. We comply with the Public Sector Equality Duty under section 149 of the Equality Act 2010. This requires public bodies, and by extension their partners and contractors, to have due regard to three needs: eliminating discrimination, advancing equality of opportunity, and fostering good relations between people who share a protected characteristic and those who do not.
Protected characteristics
Under the Equality Act 2010, the protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, ethnic origin, and national origin), religion or belief, sex, and sexual orientation. We do not discriminate on the basis of any protected characteristic, whether in how we treat our employees or how we deliver our services. We also recognise that people may experience disadvantage because of a combination of protected characteristics. This is sometimes called intersectionality. For example, an older person with a disability may face barriers that neither characteristic alone would create. We take this into account in our employment practices and service delivery.
Employment practices
We recruit, train, and promote on the basis of ability and merit. We word job advertisements to encourage applications from all sections of the community. Selection criteria are based on the genuine requirements of the role. We make reasonable adjustments for employees and applicants with disabilities, in line with our duty under sections 20 to 22 of the Equality Act 2010. This includes adjustments to recruitment processes, working arrangements, equipment, and workplace facilities. We conduct equality impact assessments on new or revised policies and service changes. These assessments help us identify and address any adverse effects on people with protected characteristics.
Reasonable adjustments for clients
Our duty to make reasonable adjustments extends to the services we provide. Under sections 20 to 22 and section 29 of the Equality Act 2010, service providers must make reasonable adjustments where a disabled person would otherwise be at a substantial disadvantage. In practice, this means we adjust how we communicate with clients, for example by using plain language, allowing extra time, or providing information in accessible formats. We accommodate physical access needs when visiting a client's home. We work flexibly to meet the needs of clients with mental health conditions, learning disabilities, or cognitive impairments. We discuss any specific needs with the client or their representative before starting work. If a client or their representative tells us about a specific need, we will do our best to meet it. If we cannot make a particular adjustment, we will explain why and discuss alternatives.
Cultural and religious sensitivity
Many of the people we work with come from different cultural and religious backgrounds. When visiting a client's home, our team members respect the client's cultural and religious practices. This includes removing shoes if asked, being aware of dietary or religious items in the home, and respecting prayer times or religious observances. We are sensitive to cultural expectations about who enters the home. For example, some clients may prefer a team member of a particular gender. We never make assumptions about a client based on their background. We brief our team before visits where we are aware of specific cultural or religious needs. We encourage clients and referrers to share any preferences or requirements so that we can plan accordingly.
Service delivery
We deliver our services with respect, sensitivity, and without judgment to all clients, regardless of their background, identity, or circumstances. We treat all clients with equal care, dignity, and professionalism. We recognise that vulnerable adults may have experienced discrimination or disadvantage in the past. We are committed to providing a service that is welcoming, inclusive, and free from prejudice. Our approach is set out in more detail in our Professional Boundaries Policy and our Safeguarding Policy.
Supporting the Public Sector Equality Duty
Several of our council partners are subject to the Public Sector Equality Duty (PSED) under section 149 of the Equality Act 2010. As a contractor delivering services on their behalf, we support our council partners in meeting this duty. In practice, this means we collect and report equality monitoring data where a council partner requests it, with appropriate consent and in line with our Privacy Policy. We conduct equality impact assessments on service changes that may affect clients with protected characteristics. We respond to council requests for information about how our services affect different groups. We include equality considerations in our quality assurance and continuous improvement processes, as described in our Quality Assurance Policy.
Training and awareness
All employees receive equality and diversity training as part of their induction, with annual refreshers. Training covers the protected characteristics and what discrimination, harassment, and victimisation look like in practice. It also covers unconscious bias and how it can affect decisions, cultural and religious awareness relevant to working in clients' homes, how to make reasonable adjustments for clients and colleagues, professional boundaries and respectful communication, and how to report concerns. We keep records of all equality training and review training content annually to make sure it stays current. Further details of our training programme are set out in our Training and Development Policy.
Monitoring and data
We monitor our workforce composition to understand the diversity of our team and to spot any areas where particular groups may be under-represented or disadvantaged. We collect workforce diversity data on a voluntary and confidential basis. We use this data to inform our recruitment, training, and development practices. We also monitor service delivery to check that our services are accessible and fair to all clients, regardless of their background. Where we collect equality monitoring data, we process it in accordance with Article 9(2)(b) of the UK General Data Protection Regulation (UK GDPR) for employment and social security purposes, and Schedule 1 Part 1 of the Data Protection Act 2018. Equality monitoring data is kept confidential, used only in aggregated form for analysis, and retained in line with our Privacy Policy.
Harassment and discrimination
Harassment, bullying, and discrimination are unacceptable and will not be tolerated, whether directed at employees, clients, or anyone else. Under the Worker Protection (Amendment of Equality Act 2010) Act 2023, employers have a preventative duty to take reasonable steps to prevent sexual harassment in the course of employment. We take proactive steps to prevent all forms of harassment. These include regular training, clear reporting routes, and a culture where people feel safe to speak up. Discriminatory abuse is one of the ten categories of abuse recognised under the Care Act 2014. If we witness or suspect discriminatory abuse of a client, we will report it as a safeguarding concern in line with our Safeguarding Policy.
How to report a concern
If you experience or witness discrimination, harassment, bullying, or victimisation, please report it straight away. This applies whether you are an employee, a client, a family member, or a council officer. You can speak to any manager, call us on 01933 213045, or email pswurfzziesmvggeagnfcmrjyncmqz@bnecukvkbmhcblxrlqwvebvwfvqkrzzpebwzspcnhbvf.iajceuzoprq.nwausswktsn. If you are deaf, hard of hearing, or have a speech impairment, you can call us through Relay UK by dialling 18001 then 01933 213045. You can also write to us at Bubblefresh Limited, 6 Carnegie Street, Rushden, Northamptonshire, NN10 9SN. We treat all reports seriously and investigate promptly. We protect anyone who raises a concern in good faith from retaliation, in line with our Whistleblowing Policy. We will take disciplinary action where appropriate, up to and including dismissal.
Changes to this policy
We may update this policy from time to time. Any changes will be posted on this page with an updated date. Where we make material changes that affect the rights or protections described in this policy, we will notify affected parties directly. This includes employees, council partners, and other stakeholders who rely on the commitments set out here.
Contact us
If you have questions about this policy, contact us on 01933 213045 or email pcnwrmqriyavvisvaytccezfynvrqz@bqfpuwedbqqrbxymlydvegerfdkhryleeuarsakihron.gtgcmjqoszk.ejqumpdkcug. You can also write to us at Bubblefresh Limited, 6 Carnegie Street, Rushden, Northamptonshire, NN10 9SN. If you are deaf, hard of hearing, or have a speech impairment, you can call us through Relay UK by dialling 18001 then 01933 213045.
Review
The Director, Lance James, reviews this policy annually. We monitor our workforce composition and service delivery to identify and address any potential inequalities. Last reviewed: February 2026. Next review due: February 2027.
© 2026 Bubble Fresh. This policy is protected by copyright (Copyright, Designs and Patents Act 1988) and may not be copied, reproduced, or redistributed without our written permission. See our Terms of Use.