Equality, Diversity and Inclusion Policy

LOPEX UNICONS LTD (trading as UNICONS) is committed to fostering a culture of equality, diversity, and inclusion (EDI) in which every individual — student, employee, agent, counsellor, partner, or affiliate — is treated with dignity, respect, and fairness.

UNICONS recognises that diversity of background, experience, and perspective strengthens our organisation and enhances the quality of service we provide to the international students we serve. We are committed to ensuring that no person who interacts with UNICONS is subject to discrimination, harassment, or victimisation on the basis of any protected characteristic.

This commitment is not merely a legal obligation — it reflects the values at the core of our mission: to open doors to education for students from every nation, background, and circumstance. We recognise that achieving meaningful equality requires proactive effort and ongoing accountability, not simply the absence of active discrimination.

This policy applies to all UNICONS operations globally, including the United Kingdom-based head office, all remote and field-based staff, all agents and counsellors operating on the UNICONS platform, all partner institutions, and any third party operating on UNICONS' behalf.

The Equality Act 2010 identifies nine protected characteristics. UNICONS is committed to ensuring that no individual is unlawfully discriminated against on the basis of any of the following:

1. Age — this includes both older and younger persons; UNICONS recognises that age-based assumptions can disadvantage students, staff, and partners at either end of the age spectrum.

2. Disability — a physical or mental impairment that has a substantial and long-term adverse effect on a person's ability to carry out normal day-to-day activities. UNICONS is committed to making reasonable adjustments to remove barriers for disabled individuals.

3. Gender reassignment — the process of transitioning from one gender to another, which may or may not involve medical intervention. UNICONS affirms that transgender and non-binary individuals are entitled to equal treatment in all aspects of our services and operations.

4. Marriage and civil partnership — protection applies in the employment context, ensuring that married employees or those in civil partnerships are not treated less favourably in relation to their employment.

5. Pregnancy and maternity — UNICONS will not treat any woman unfavourably because of her pregnancy, a pregnancy-related illness, or because she has recently given birth or is on maternity leave.

6. Race — including colour, nationality, and ethnic or national origins. UNICONS serves an inherently international and racially diverse student community and is committed to eradicating racial discrimination in all its forms.

7. Religion or belief — including religious or philosophical beliefs and a lack of belief. UNICONS respects the diversity of faith, culture, and worldview represented across its student and partner community.

8. Sex — UNICONS is committed to gender equality across all areas of its operations, including equal pay, equal access to progression, and equal treatment in service delivery.

9. Sexual orientation — including heterosexual, gay, lesbian, and bisexual orientations. UNICONS affirms that all students and personnel are entitled to equal treatment regardless of sexual orientation.

UNICONS prohibits the following forms of unlawful conduct under the Equality Act 2010:

Direct discrimination: Treating a person less favourably than another because of a protected characteristic. For example, refusing to process an application because of the student's nationality or religion.

Indirect discrimination: Applying a provision, criterion, or practice that applies equally to all but which places persons sharing a protected characteristic at a particular disadvantage, and which cannot be justified as a proportionate means of achieving a legitimate aim. For example, requiring all applicants to provide a particular form of identity documentation that is less accessible to certain nationalities without offering alternative options.

Harassment: Unwanted conduct related to a protected characteristic that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment. Harassment may be verbal, written, physical, or digital in nature. UNICONS will not tolerate harassment in any form, including sexual harassment.

Victimisation: Treating a person less favourably because they have brought proceedings under the Equality Act 2010, given evidence or information in such proceedings, made an allegation of discrimination, or done anything related to the Act. Individuals who raise genuine concerns about discrimination will not suffer any detriment as a result.

Discrimination by association: Discriminating against a person because of the protected characteristic of someone they are associated with (for example, a carer of a disabled person).

Perception discrimination: Discriminating against a person because they are wrongly perceived to have a particular protected characteristic.

UNICONS may, where lawful and appropriate, take positive action under section 159 of the Equality Act 2010 in order to address disadvantage or under-representation experienced by groups sharing a protected characteristic.

Positive action allows UNICONS to favour a candidate or participant with a protected characteristic where:

• Persons with that characteristic are at a disadvantage connected to that characteristic, or are under-represented in a particular role, activity, or service access group; and
• The positive action taken is a proportionate means of addressing that disadvantage or under-representation.

Positive action is distinct from positive discrimination, which is unlawful. UNICONS will not set quotas or make decisions based solely on protected characteristics. Positive action may include, for example:

• Targeted outreach or information campaigns for students from underrepresented backgrounds;
• Adapting recruitment materials or processes to be more accessible to candidates from particular groups;
• Providing additional support or mentoring to students who face particular barriers to participation.

Any positive action initiative will be reviewed by UNICONS management to confirm it meets the conditions of section 158 or section 159 of the Equality Act 2010 before implementation.

UNICONS is committed to ensuring that all students receive fair, respectful, and consistent service regardless of their protected characteristics. This means:

• Equal access: All students who meet the applicable eligibility criteria for a service are entitled to access that service without discrimination. Eligibility criteria will be objectively defined and consistently applied.

• Language and accessibility: UNICONS will make reasonable efforts to ensure that its platform and communications are accessible to students whose first language is not English, and to those with disabilities that affect reading, communication, or digital access.

• Non-discriminatory guidance: Agents and counsellors must not steer students toward or away from particular institutions or courses on the basis of protected characteristics (including nationality, race, or religion) rather than on the basis of the student's genuine academic profile and preferences.

• Respectful conduct: All personnel interacting with students must treat them with dignity and respect. Discriminatory language, assumptions, or behaviour toward students will be treated as a serious disciplinary matter.

• Complaints: Students who believe they have been treated in a discriminatory manner may raise a complaint in accordance with the UNICONS Complaints Policy. All EDI-related complaints will be escalated to the EDI Lead for investigation.

UNICONS is committed to fair and non-discriminatory recruitment, selection, development, and management of its workforce. Specifically:

• All job advertisements will be written in inclusive language and will not contain requirements that could indirectly discriminate unless they are genuine occupational requirements justifiable under the Equality Act 2010;
• Shortlisting, interviewing, and selection decisions will be made on the basis of skills, experience, and objective criteria only;
• Interview panels will, where possible, be diverse;
• All employees are entitled to equal pay for equal work. UNICONS will conduct periodic pay equity reviews to identify and address any unjustified pay gaps;
• Employees who are pregnant, on maternity, paternity, adoption, or shared parental leave are entitled to the full protections set out in applicable law and in UNICONS' family-friendly employment policies;
• UNICONS will make reasonable adjustments for disabled employees in accordance with the Equality Act 2010, including adjustments to the recruitment process, the working environment, and working arrangements.

The selection and ongoing management of agents and counsellors through the UNICONS platform must be conducted on a fair and non-discriminatory basis. UNICONS will:

• Apply objective, published eligibility criteria to all agent and counsellor applications, applied consistently regardless of the applicant's nationality, ethnicity, religion, or other protected characteristics;
• Not exclude an agent or counsellor from the UNICONS platform on the basis of a protected characteristic unless there is a lawful and objectively justified reason;
• Ensure that performance monitoring and enforcement action is applied consistently, and is not more readily applied to agents from particular national or ethnic backgrounds without objective justification.

Agents and counsellors are themselves required to operate in compliance with this EDI Policy. Evidence that an agent or counsellor has discriminated against students, or has behaved in a manner that is discriminatory, harassing, or exclusionary on grounds of any protected characteristic, will be grounds for immediate suspension or termination from the UNICONS platform.

UNICONS works in partnership with universities, colleges, and other educational institutions. As a condition of partnership, all partner institutions are expected to:

• Maintain and implement their own equality and diversity policy that is compliant with applicable equality legislation;
• Operate admissions processes that are fair and non-discriminatory, and that do not disadvantage students referred through UNICONS on the basis of protected characteristics;
• Report to UNICONS any instance in which a student referred through UNICONS has raised or experienced a discrimination or harassment concern;
• Cooperate with UNICONS in any investigation into an EDI-related concern involving a mutual student.

UNICONS will review partner institution EDI commitments as part of the onboarding due diligence process and may request updated policies or evidence of compliance on a periodic basis.

UNICONS has a duty under the Equality Act 2010 to make reasonable adjustments to remove or reduce disadvantage experienced by disabled students and staff.

For students: Where a student discloses a disability or specific learning need, UNICONS will: - Consider what adjustments can be made to the platform or service delivery process to remove barriers; - Signpost the student to additional support resources and partner institution disability services; - Not treat the disclosure of disability as a basis for offering a lower quality of service or for steering the student toward particular institutions without their informed consent.

For staff and contractors: Where an employee or contractor discloses a disability or health condition, UNICONS will: - Conduct an individual assessment of the adjustments that can reasonably be made; - Implement agreed adjustments without delay; - Review adjustments periodically to ensure they remain effective.

Reasonable adjustments may include changes to physical workspace, to digital tools and platform configurations, to working hours or patterns, or to processes and procedures. UNICONS will not decline to make an adjustment without considering whether it is genuinely disproportionate to the cost or impact involved.

UNICONS is committed to monitoring the effectiveness of this policy and to using data to identify and address areas of concern. Monitoring activities include:

• Workforce monitoring: Collecting equality data from employees (on a voluntary and anonymous basis) regarding protected characteristics, and reviewing the data annually to identify patterns in recruitment, progression, pay, and turnover;
• Student service monitoring: Reviewing data on student demographics, application outcomes, and complaint patterns to identify whether any group is experiencing disproportionately adverse outcomes;
• Complaint analysis: Reviewing EDI-related complaints and concerns on a periodic basis to identify systemic issues;
• Training completion: Monitoring completion rates for EDI training across the workforce.

An annual EDI report will be prepared by the EDI Lead and presented to UNICONS management, summarising findings and setting out actions to address identified gaps. Where appropriate, findings will be shared with the wider UNICONS community.

Any individual who believes they have been subject to discrimination, harassment, or victimisation in connection with their interaction with UNICONS may raise a complaint in the following ways:

• Online: Via the complaints form on the UNICONS platform;
• Email: enquiry@unicons.co.uk (marking the subject line: EDI COMPLAINT — CONFIDENTIAL);
• Post: LOPEX UNICONS LTD, 214 High Street, Second Floor, Hounslow, TW3 1HB, London, United Kingdom.

All EDI complaints will be: - Acknowledged within 5 working days of receipt; - Investigated impartially and without prejudging the outcome; - Escalated to the EDI Lead or, where the EDI Lead is implicated, to a senior manager or external investigator; - Responded to in writing with an outcome and, where the complaint is upheld, a remedial action plan.

Individuals are protected from victimisation for raising a genuine complaint in good faith. If a complaint is found to have been made in bad faith with the intent to harm another person, this will itself be a disciplinary matter.

Where a complaint involves conduct that may also engage UNICONS' safeguarding or disciplinary policies, those policies will be engaged in parallel.

Responsibility for implementation:

• UNICONS Director / Senior Management: Ultimate responsibility for EDI strategy, resource allocation, and compliance;
• EDI Lead: Day-to-day responsibility for implementing this policy, managing complaints, delivering training, and producing the annual EDI report;
• All personnel: Individual responsibility for treating every person with dignity and respect, completing required training, and raising concerns appropriately.

Review:

This policy is reviewed annually by the EDI Lead in consultation with senior management. It may be updated between scheduled reviews in response to legislative changes, significant incidents, or monitoring findings.

Contacts:

Approved by: Director, LOPEX UNICONS LTD Effective date: 1 September 2025 Next review date: 1 September 2026