EQUAL OPPORTUNITIES POLICY

Last reviewed: September 2026

 

Purpose

Apex Pictures Ltd is committed to equality of opportunity and to providing a working environment in which people are treated fairly, with dignity and respect.

We want employment, freelance and production opportunities at Apex Pictures to be open to people on the basis of their ability, experience and suitability for the work.

This policy applies to employees, workers, freelancers, contractors, trainees, job applicants and others engaged by Apex Pictures. Where different legal rights apply to different types of working relationship, Apex Pictures will nevertheless apply the principles of this policy as widely as reasonably possible.

 

Questions about this policy should be directed to Carleton Rodgers.

This policy does not form part of any contract of employment or engagement and may be amended from time to time.

 

Our commitment

Apex Pictures will not unlawfully discriminate because of a person’s:

• age;

• disability;

• sex;

• pregnancy or maternity;

• marital or civil partnership status;

• gender reassignment;

• race, colour, nationality, ethnic or national origin;

• religious or philosophical belief;

• political opinion; or

• sexual orientation.

• ​

We will also respect an individual’s lawful decision to belong, or not to belong, to a trade union.

Apex Pictures is committed to maintaining a working environment free from unlawful discrimination, harassment, bullying and victimisation.

This applies throughout recruitment and selection, employment and engagement, pay and terms, training, promotion, allocation of work, production activity, disciplinary and grievance matters, and the ending of employment or engagement.

​

Northern Ireland equality law

Apex Pictures is registered and based in Northern Ireland.

Our equality responsibilities therefore arise principally under Northern Ireland equality and anti-discrimination legislation rather than the Equality Act 2010, which does not generally apply in Northern Ireland.

Relevant legislation includes, as amended from time to time:

• the Equal Pay Act (Northern Ireland) 1970;

• the Sex Discrimination (Northern Ireland) Order 1976;

• the Disability Discrimination Act 1995 as it applies in Northern Ireland;

• the Race Relations (Northern Ireland) Order 1997;

• the Fair Employment and Treatment (Northern Ireland) Order 1998;

• the Equality (Disability, etc.) (Northern Ireland) Order 2000;

• the Employment Equality (Sexual Orientation) Regulations (Northern Ireland) 2003; and

• the Employment Equality (Age) Regulations (Northern Ireland) 2006.

Apex Pictures will have regard to relevant guidance and Codes of Practice issued by the Equality Commission for Northern Ireland.

 

Discrimination, harassment and victimisation

Unlawful discrimination can take different forms depending on the circumstances and the relevant legislation.

Direct discrimination can occur where someone is treated less favourably because of an equality ground protected by law.

Indirect discrimination can occur where a requirement, policy or way of working that applies to everyone places people sharing a protected equality ground at a particular disadvantage and cannot be lawfully justified.

Harassment is unwanted conduct connected to a protected equality ground which has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive working environment.

Victimisation can occur where someone is treated adversely because they have raised, supported or been involved in a complaint or allegation of discrimination, or have exercised rights under equality law.

Not every form of discrimination is defined in exactly the same way under every piece of Northern Ireland equality legislation. Apex Pictures will apply this policy consistently with the legislation relevant to the circumstances.

Bullying or other unacceptable behaviour may also breach Apex Pictures standards even where it does not amount to unlawful discrimination.

 

Disability and reasonable adjustments

Apex Pictures will not unlawfully discriminate against a disabled person.

Where required, and where we know or could reasonably be expected to know that a person is disabled, we will consider reasonable adjustments to remove substantial disadvantages they may experience in recruitment or while working with us.

Adjustments will be considered according to the individual circumstances and may include changes to working arrangements, hours, locations, equipment, communication methods, access arrangements or recruitment procedures.

People are encouraged to let us know if an adjustment would help them take part fully and safely in recruitment or work.

 

Recruitment, selection and casting

Recruitment and selection decisions will be based on fair, objective and relevant criteria.

Job descriptions and person specifications will, so far as reasonably possible, contain only requirements genuinely necessary for the role.

Apex Pictures will not apply a particular characteristic as a requirement for employment or engagement unless doing so is lawful and genuinely necessary for the work concerned.

Where a genuine occupational requirement or other lawful exception is relied upon, it will be considered carefully and applied only where appropriate.

Reasonable adjustments will be considered for disabled applicants throughout the recruitment process.

Any lawful positive or affirmative action will be undertaken in accordance with Northern Ireland equality law and relevant Equality Commission guidance.

 

Working at Apex Pictures

Decisions about pay, working conditions, access to training, development opportunities, allocation of work and other benefits will be made fairly and on objective, non-discriminatory grounds.

Everyone working with Apex Pictures is expected to treat colleagues, performers, contributors, suppliers, clients and members of the public with dignity and respect.

This expectation applies on company premises, filming locations, during travel connected with a production, at work-related events and social functions, and in work-related communications including email, messaging services and social media.

Apex Pictures will take reasonable steps to prevent bullying, harassment and discrimination and will respond appropriately when concerns are raised.

 

Responsibilities

The Company Directors have overall responsibility for the implementation of this policy.

Anyone responsible for recruitment, engaging freelancers, casting, managing crew or making employment-related decisions must apply this policy fairly and consistently.

Everyone working for or with Apex Pictures has a responsibility to:

• treat others with dignity and respect;

• avoid discriminatory, harassing or bullying behaviour;

• cooperate with reasonable steps taken to provide equal opportunities;

• raise concerns about behaviour that may breach this policy; and

• cooperate appropriately with any investigation.

 

Raising a concern

Anyone who believes they have experienced or witnessed discrimination, harassment, victimisation or other conduct contrary to this policy should raise the matter with a Company Director.

Concerns will be taken seriously and handled as sensitively and confidentially as reasonably possible.

No person will be subjected to retaliation for raising a genuine concern in good faith or for supporting another person who raises a concern.

Where appropriate, Apex Pictures may investigate a complaint and take action proportionate to the circumstances. Serious breaches may result in disciplinary action, termination of employment or engagement, or other appropriate action.

Nothing in this policy prevents anyone from obtaining independent advice or exercising their legal rights.

 

Equality monitoring

Apex Pictures will keep its equality practices under review.

Where statutory fair-employment registration, monitoring or reporting duties apply to the Company, Apex Pictures will comply with the requirements of the Fair Employment and Treatment (Northern Ireland) Order 1998 and associated regulations and Equality Commission guidance.

 

Any equality monitoring information collected will be handled appropriately, kept separate from selection decisions where required, and processed in accordance with data protection law.

 

Review

This policy will be reviewed at least annually and sooner where appropriate following:

• a significant change in relevant legislation or official guidance;

• a significant change in the Company’s activities or workforce;

• an incident or complaint that identifies a need for review; or

• other relevant learning or organisational change.

 

 

SAFEGUARDING CHILDREN AND YOUNG PEOPLE POLICY

Last reviewed: September 2026

 

Our commitment

Apex Pictures Ltd is committed to safeguarding and promoting the welfare of children and young people who take part in, visit or otherwise have contact with our productions.

For the purposes of this policy, a child or young person is anyone under the age of 18.

The welfare of the child is paramount.

Every child working with Apex Pictures should have a safe, positive and professionally managed experience, regardless of their background or personal circumstances.

Safeguarding is the responsibility of everyone involved in an Apex Pictures production.

 

Scope

This policy applies to employees, producers, directors, crew, freelancers, contractors, performers, contributors, volunteers and anyone else working on behalf of Apex Pictures where their work brings them into contact with children or young people.

It applies during:

• casting and auditions;

• rehearsals;

• filming;

• costume, hair and make-up;

• photography and publicity;

• travel arranged as part of a production;

• production meetings or workshops involving children;

• behind-the-scenes filming;

• online or electronic communication connected with a production; and

• any other activity organised by Apex Pictures involving children or young people.

 

Safeguarding framework

Apex Pictures will conduct its safeguarding arrangements with regard to the law, policy and guidance applicable in Northern Ireland, including:

• the Children (Northern Ireland) Order 1995;

• Co-operating to Safeguard Children and Young People in Northern Ireland;

• the Safeguarding Board for Northern Ireland Procedures Manual;

• the Children (Public Performances) Regulations (Northern Ireland) 1996;

• the Safeguarding Vulnerable Groups (Northern Ireland) Order 2007; and

• relevant Education Authority requirements concerning children in entertainment, performance licences and chaperones.

Apex Pictures will keep its procedures under review as legislation and official guidance change.

 

Safeguarding responsibility on productions

Where a production involves children, Apex Pictures will identify a named person with responsibility for safeguarding for that production.

The name and contact details of that person will be communicated to relevant cast, crew, parents or guardians and chaperones.

The production Safeguarding Lead will be responsible for helping ensure that:

• appropriate safeguarding arrangements are in place;

• relevant licences, permissions and chaperone arrangements have been addressed;

• safeguarding concerns are recorded and acted upon appropriately;

• cast and crew understand how to report a concern; and

• the needs and welfare of children are considered throughout the production.

Overall responsibility for safeguarding remains with the Company Directors.

 

Child performance licences and permissions

Where a child takes part in a film, broadcast, recorded performance or other activity requiring a child performance licence, exemption or other approval, Apex Pictures will comply with the requirements of the Education Authority Children in Entertainment and Employment Team.

Apex Pictures will determine in advance whether an individual performance licence, exemption, Body of Persons Approval or other arrangement is required and will obtain the necessary approval before the child performs.

We will comply with the conditions attached to any licence or approval, including those relating to:

• permitted working and performance hours;

• breaks and rest periods;

• schooling and education;

• supervision;

• travel;

• accommodation where relevant;

• health and welfare; and

• record keeping.

A child will not be asked to take part in a performance where the activity would place their health, safety or welfare at unacceptable risk.

Parents, guardians and chaperones

Parents and guardians should be given clear information about the production and their child’s involvement.

Where required under performance-licensing arrangements, children will be supervised by their parent or guardian or by an appropriately approved and registered chaperone.

Where Apex Pictures uses a chaperone who requires Education Authority approval, that person must hold the appropriate current approval.

The role of the chaperone is to safeguard the child’s welfare. Production requirements, schedules or creative considerations must never take priority over a chaperone’s legitimate safeguarding responsibilities.

 

Safer recruitment and AccessNI

Apex Pictures will take reasonable steps to ensure that individuals placed in roles involving responsibility for children are suitable for those roles.

Where a role is eligible for, or legally requires, an AccessNI check or barred-list check, the appropriate check will be obtained before the person undertakes that work.

Apex Pictures will not knowingly permit a person who is barred from regulated activity with children to undertake regulated activity.

Criminal-record information will be handled securely and fairly in accordance with applicable law and AccessNI requirements.

A criminal record will not automatically prevent a person from working with Apex Pictures unless the law prohibits the engagement or the information makes the person unsuitable for the particular role following an appropriate assessment.

 

Conduct around children

Everyone working on an Apex Pictures production involving children is expected to maintain appropriate professional boundaries.

Adults should:

• communicate with children respectfully and in an age-appropriate way;

• avoid unnecessary physical contact;

• avoid being alone with a child in an isolated or private setting wherever reasonably possible;

• avoid favouritism or relationships that could be perceived as inappropriate;

• never use threatening, humiliating, sexually suggestive or discriminatory language or behaviour;

• never supply children with alcohol, illegal drugs, nicotine products or other age-restricted substances;

• not engage in private or secret electronic communication with a child;

• not add or contact child performers through personal social-media accounts in connection with the production; and

• raise any concern about a child’s welfare without delay.

Necessary professional contact between a child and members of departments such as costume, hair, make-up, sound or medical/welfare personnel must be managed with appropriate privacy, supervision and safeguarding arrangements.

 

Sensitive scenes and material

Apex Pictures recognises that filmmaking may involve difficult themes, simulated violence, distressing material or other sensitive content.

Where a child is involved, scenes and production methods will be planned to protect the child’s physical and emotional welfare.

Children will not be unnecessarily exposed to material, performances or activity that is inappropriate for their age or that could cause harm.

Where possible, filmmaking techniques such as separate coverage, editing, visual effects, stand-ins or other production methods will be used to avoid exposing a child to distressing or unsuitable activity.

Any sensitive material involving a child will be discussed appropriately in advance with the child’s parent or guardian, relevant chaperone and, where applicable, the Education Authority or licensing authority.

The child’s views will be listened to and taken seriously, having regard to their age and understanding.

No creative or production objective takes priority over a child’s welfare.

 

Changing, costume and personal privacy

Children must be provided with appropriate privacy when changing clothes, using toilets or preparing for scenes.

Access to changing areas will be limited to people whose presence is genuinely required.

Where costume, make-up, microphones or other equipment require close physical contact, this should be explained beforehand and carried out professionally with appropriate supervision.

Any concern or discomfort expressed by a child must be taken seriously.

Photography, behind-the-scenes material and publicity

Images and recordings of children will only be created and used in accordance with the permissions, contracts and production arrangements applicable to the project.

Where behind-the-scenes photography, publicity, social-media material or other use falls outside the principal production arrangements, appropriate additional permission will be obtained where required.

Images of children will not knowingly be used in a way that is exploitative, degrading or likely to place them at risk.

Care will be taken not to publish unnecessary personal information about a child or information that could compromise their safety or privacy.

 

Online communication

Production-related communication with children should normally take place through a parent, guardian, agent or other appropriate adult.

Where direct communication with an older child is genuinely necessary for production purposes, appropriate adults should be included and the communication must remain professional and transparent.

Private, secretive or disappearing-message communication between an adult working for Apex Pictures and a child is not acceptable.

Recognising and responding to concerns

Anyone working with Apex Pictures who:

• is concerned about the welfare or safety of a child;

• sees or hears something that may indicate abuse, neglect, exploitation or other harm;

• receives a disclosure from a child; or

• has concerns about the behaviour of an adult towards a child

must take the concern seriously and report it promptly to the production Safeguarding Lead or a Company Director.

If the concern relates to the Safeguarding Lead, it should be reported to a Company Director. If it concerns a Company Director, it should be reported to another Director and, where appropriate, directly to the relevant statutory authority.

The person receiving the concern should not conduct their own investigation or attempt to determine whether abuse has occurred.

If a child makes a disclosure, the adult should:

• listen carefully;

• remain calm;

• avoid asking leading or unnecessary questions;

• not promise confidentiality;

• explain that the information may need to be shared with people who can help keep the child safe;

• make an accurate written record as soon as possible; and

• report the concern without delay.

 

Referring concerns outside Apex Pictures

Where there is reason to believe that a child may be at risk of harm, Apex Pictures will follow the current Safeguarding Board for Northern Ireland procedures and make an appropriate referral to the relevant Health and Social Care Trust Children’s Services Gateway Service.

If a child is in immediate danger or urgent police assistance is required, 999 should be called.

Concerns about suspected criminal behaviour may also be referred to the Police Service of Northern Ireland.

Apex Pictures will cooperate appropriately with statutory safeguarding agencies and will not delay an appropriate referral while attempting to resolve a matter internally.

 

Allegations concerning cast or crew

Any allegation or concern about the conduct of a person working on an Apex Pictures production towards a child will be taken seriously.

Apex Pictures will take immediate proportionate steps to protect the child and manage any continuing risk. Depending on the circumstances, this may include changing duties, increasing supervision or temporarily removing an individual from contact with children while advice is sought.

Where appropriate, concerns will be referred to the relevant statutory authorities.

Apex Pictures will not attempt to investigate matters that should properly be investigated by social services or police.

Where safeguarding concerns meet the legal criteria for a referral to the Disclosure and Barring Service, Apex Pictures will comply with any applicable referral duty.

 

Confidentiality and record keeping

Safeguarding information will be shared only with people who need it for the purpose of protecting a child, responding to a concern or complying with legal obligations.

Concerns, disclosures, decisions and referrals will be recorded accurately and stored securely.

Records should distinguish clearly between:

• what was seen or heard;

• what the child or another person actually said;

• factual information;

• actions taken; and

• professional opinion or interpretation.

Information will be handled in accordance with applicable data protection law, but data protection will not be used as a reason to withhold information where sharing it is necessary and lawful to safeguard a child.

 

Training and awareness

People working in roles with safeguarding responsibilities will receive or undertake safeguarding information, instruction or training appropriate to the nature of their role and contact with children.

Crew working directly with children will be made aware of the relevant safeguarding arrangements for the production.

Apex Pictures will encourage anyone who is uncertain about a safeguarding matter to raise it rather than assume someone else will do so.

 

Production planning

For productions involving children, safeguarding will form part of production planning and risk assessment.

Where relevant, consideration will be given to:

• the nature of the material;

• the child’s age and individual needs;

• working hours and breaks;

• schooling;

• travel and accommodation;

• location security;

• changing and welfare facilities;

• chaperone provision;

• physical and emotional risks;

• sensitive scenes;

• publicity and online exposure; and

• emergency and reporting arrangements.

 

Safeguarding arrangements will be proportionate to the production and the needs of the children involved.

 

Review

This policy will be reviewed at least annually and sooner where required because of:

• changes to legislation or Northern Ireland safeguarding guidance;

• changes to Education Authority performance-licensing requirements;

• changes to SBNI procedures;

• a safeguarding incident or concern;

• learning from a production; or

• another significant change affecting the safety or welfare of children.

Last reviewed: September 2026