Equality Policy
1. STATEMENT OF INTENT
1.1 Haverfordwest Golf Club Limited shares the belief of Wales Golf that golf is everyone’s game. All who play
and all who aspire to play must have an equal opportunity to do so.
1.2 The club is committed to the principles of equity, equality and diversity throughout its membership; it’s paid
and volunteer workforce and any others with whom the club engages.
1.3 The club considers that everyone should play their part in making golf inclusive and aims to ensure that all
people, irrespective of background or protected characteristics, have a genuine opportunity to engage with golf.
We will not disadvantage any individual by imposing conditions or requirements which cannot be justified.
2. WHO DOES THIS POLICY APPLY TO?
2.1 This policy shall apply to, and be binding upon the club, it’s board of directors, staff, volunteers, coaches,
contractors, agents, and representatives working, holding office or acting for or on behalf of the club.
3. OTHER IMPORTANT DOCUMENTS
This policy works with other documents adopted by the club, in particular:
• Disciplinary procedures which may be used to deal with alleged breaches of this policy.
• Safeguarding Children and Adults Policy, which will be followed in respect of any matters which give rise to
a safeguarding concern.
• Code of Conduct which set out the standards of behaviour and conduct expected from members, those
who are attending club events, or representing, working for of otherwise engaging with the club in some
capacity.
• Complaints Procedure which may be used to deal with concerns raised about the actions of the Club.
• Data Protection Policy which sets out how we will handle personal data, including data collected to monitor
diversity in line with this policy.
4. POLICY IMPLEMENTATION
A. WHAT WE WILL DO
1. Promote fairness, equity, equality, diversity and respect for everyone working, volunteering or participating
in the sport of golf or otherwise engaging with the club.
2. Ensure that all competitions, events and activities are administered by the club are carried out in a fair and
equitable way (except where specific situations and conditions prevent this, or where we consider that
positive action is a proportionate way to achieve a legitimate aim).
3. Ensure that the course can be accessed by all members during peak times (except in the case of
competitions or external events).
4. Monitor and review club policies, procedures and regulations to ensure that they are consistent with the
requirements of this policy, including policies relating to admission to membership.
5. Where practical we will take steps to monitor the diversity of the club’s members, participants, players,
volunteers and others that we may engage with to measure and assess the impact of this policy.
6. Provide appropriate training and support to staff, volunteers, officials and others.
August 2026 17. 8. Make reasonable adjustments for those with a disability.
Publish this policy on the club website.
B. WHAT WE WON’T DO
1. 2. 3. Discriminate against anyone, either directly or indirectly, based on a protected characteristic.
Subject anyone to less favourable treatment based on them doing a protected act (victimisation).
Subject anyone to harassment in relation to a protected characteristic.
4. REPORTING PROCEDURES
If you are concerned about the behaviour or conduct of someone at a club event, someone representing the
club, or any other breach of this policy:
4.1 Please report the matter to any member of the Club Management Committee, giving as much detail as
possible.
4.2 If the matter is reported verbally, and you are able, please follow the verbal report in writing as soon as
possible.
4.3 The club will consider the appropriate way to deal with the matter, which may include referring the matter
to and/or seeking guidance from Wales Golf.
4.4. In the case where concerns are raised anonymously, it will still be considered, however the investigation
will be limited if there is insufficient information.
5. HOW WE WILL DEAL WITH BREACHES OF THIS POLICY
5.1 When we receive a report or a concern that relates to this policy, we will designate a member of the Club
Management Committee to consider the matter initially. They will consider the appropriate next steps,
which may include the following:
a. b. c. d. e. seeking further information in relation matters raised
seeking guidance from Wales Golf or any other appropriate body or organisation
referring the matter to another body or organisation
dealing with the matter informally
deciding which procedure is the most appropriate, such as the club’s disciplinary procedure, the
safeguarding policies or other relevant policy, to progress the matter formally.
5.2 The club will usually inform the person reporting the matter of the next steps and/or the outcome of the
matter. However, there may be circumstances in which we are not able to disclose full details to the reporting
individual. This may be because the law prevents us from doing so, because some information is confidential or
to protect the safety or wellbeing of those involved.
5.3 The club will ensure to maintain the appropriate records of all concerns raised which will be recorded and
saved within the club’s files.
6 KEY CONCEPTS, DEFINITIONS AND EXAMPLES
A. The Equality Act 2010 and Discrimination
Every individual and organisation to whom this Policy applies must not act in a way which is directly or indirectly
discriminatory based on a protected characteristic.
The Equality Act 2010 makes it unlawful to discriminate directly or indirectly against individuals or groups with
certain “protected characteristics”. The “protected characteristics” are listed in section 4 of the Act:
• Age
August 2026 2• Disability
• Gender Reassignment
• Marriage and Civil Partnership
• Pregnancy and Maternity
• Race
• Religion or Belief
• Sex
• Sexual Orientation
Direct Discrimination
Direct Discrimination is defined at section 13(1) of the Equality Act 2010: “A person (A) discriminates against
another (B) if, because of a protected characteristic, A treats B less favourably than A treats or would treat
others.”
For example, if an action or decision is taken by a club which treats females less favourably than males, this
would be considered direct discrimination on the grounds of sex, which is a protected characteristic.
Indirect Discrimination
Indirect Discrimination is defined at section 19(1) of the Equality Act 2010: “A person (A) discriminates against
another (B) if A applies to B a provision, criterion or practice which is discriminatory in relation to a relevant
protected characteristic of B’s.”
Indirect discrimination occurs where less favourable treatment is not the main effect or objective of an action or
decision.
The nature of indirect discrimination is that the discriminatory effect can be an unexpected or unforeseen effect
of a good faith decision. Complaints of indirect discrimination should be considered carefully and objectively
and not dismissed out of hand purely because the effect was not an expected or intentional one.
If, for example, a club has a rule or practice that certain competitions are only played on Saturdays, this would
prevent members with certain religious beliefs from taking part in the competition. Although it may not have
been the intention of the golf club, the effect is the less favourable treatment of members on the grounds of
religion or belief, which is a protected characteristic. This is indirect discrimination.
Actions and Intentions
An action or decision can still be considered discriminatory even if the less favourable treatment is
unintentional. It may not always be obvious to the perpetrator that their actions are discriminatory. Indirect
discrimination is often unintentional, but it is not a defence to an allegation of discrimination to say that the
perpetrator did not mean to discriminate against a person or group.
Discrimination can arise out of actions and decisions but can also arise out of omissions and failure to take
actions or decisions.
Reasonable Adjustments
Everybody to whom this policy applies is under a duty to make reasonable adjustments to avoid discriminating
against any individual or group with the protected characteristic of disability.
August 2026 3The duty is to make reasonable adjustments. It is not unreasonable for adjustments to cost time, money, or
other resources. However, an adjustment may not be reasonable if the cost is disproportionately high or making
the adjustment would be unfeasible.
The resources required to make an adjustment are an important factor to be considered in deciding whether an
adjustment is reasonable.
Positive Action
It can be lawful to make decisions that discriminate based on a protected characteristic in very limited and
exceptional circumstances, if the discrimination is a ‘positive action’ taken to address an underrepresented
group or protected characteristic.
Positive actions must be reasonable, justifiable, and clearly linked to a legitimate aim. Where a club decides to
take positive action in respect of an underrepresented group, it should carefully record its decision making and
the evidence it has considered, and review the practice regularly to ensure that the positive action does not
continue for longer than reasonably necessary.
Examples
In a golfing context, some examples of discrimination might include:
• Not allowing the use of golf buggies, as this increases the cost of maintaining the course. Permitting the use
of golf buggies may be a reasonable adjustment, and the increased course maintenance costs are a factor
to be assessed in deciding whether the adjustment is reasonable.
• Restricting the number of tee times available to women during peak hours on the golf course. Whilst it may
be permissible to limit access to the course at certain times, for example to allow a competition to be
played, a club will need to be certain that it is providing equal opportunity for all to access the course.
• Not allowing competitions to be played on alternate days to accommodate for certain religious beliefs.
B. Harassment
Harassment is defined in section 26(1) of the Equality Act 2010. Harassment occurs where a person engages in
unwanted conduct related to a protected characteristic (outlined in the Equality Act 2010), which has the
purpose of either:
• Violating the other person’s dignity; or
• Creates an intimidating, hostile, degrading, humiliating or offensive environment for the other person.
In determining whether conduct amounts to harassment, regard is had to:
• The perception of the victim
• Whether it is reasonable for the conduct to have the perceived effect
• The wider circumstances of the matter.
Sexual Harassment
Sexual harassment occurs where a person engages in unwanted conduct of a sexual nature, and the conduct
has the purpose or effects outlined above.
August 2026 4It also refers to the less favorable treatment related to sex or gender reassignment that occurs because of a rejection
of, or submission to, sexual conduct.
One Off Incidents
A single, isolated, or one-off incident can still amount to harassment. The key consideration is the purpose or
effect of the conduct.
Protection from Harassment Act 1997 & Worker Protection Act 2023
Harassment can still occur if not surrounding a protected characteristic. The protection from Harassment Act
1997 made it a civil, and a criminal, offence to carry out a course of conduct that amounts to harassment.
The Worker Protection (Amendment of Equality Act 2010) Act 2023 places a legal duty on employers to proactively take
reasonable steps to prevent sexual harassment occurring in the workplace.
Examples
In a golfing context, some examples of unlawful harassment might include:
• Employees making unwanted or inappropriate contact with colleagues at a golf club or facility.
• Targeting disabled golfers using buggies and demanding to see proof of a disability where this is not
required by the terms of a competition, for example.
• Disproportionate and public criticism or sanctioning of an individual’s behaviour by an organisation for
irrelevant or personal reasons. A clear disciplinary procedure will help to ensure that those facing
disciplinary action at a club are treated fairly.
C. Victimisation
Victimisation is defined in section 27(1) of the Equality Act 2010.
Victimisation occurs where a person suffers a detriment because they do a protected act or are believed to have
done a protected act.
Protected Act
A protected act includes making a complaint (whether in writing or not, formally or informally) or bringing legal
proceedings under the Equality Act 2010 in relation to discrimination, harassment, bullying, or any other issue
related to equality, diversity or protected characteristics.
Detriment
A detriment can be any less favourable treatment, including direct acts such as suspensions, fines, sanctions,
and verbal and physical aggression.
It is not necessary to show that somebody is being treated less favourably than somebody else who did not do a
protected act, only that they have been subject to a detriment because of a protected act.
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