Our Commitment

MMC is committed to creating an inclusive environment free of discrimination, harassment and bullying, where everyone is treated with dignity and respect. Having an inclusive environment is of benefit for all, creates positive outcomes, leads to better decision-making and allows all to succeed. This extends to our dealings with all people we come across as part of our business activities.

The law distinguishes between discrimination, harassment and bullying, and further information is at the back of this policy, but whatever the name, the behaviour can have very serious consequences for individuals. It can make people unhappy, may cause them stress and affect their health and family and social relationships, may affect their work performance and could cause them to leave their job. Severe cases can even lead to mental illness and suicide.

Employees found guilty of discrimination, harassment or bullying may face disciplinary penalties, up to and including dismissal, could be personally liable to pay compensation in legal claims, and may find their own family and social relationships are adversely affected. Serious harassment may be a criminal offence. Discrimination, whether direct or indirect, is unlawful.

MMC will not tolerate exclusionary behaviour of any kind. All such allegations will be investigated and, if appropriate, disciplinary action will be taken. We will also not tolerate victimisation of a person for making allegations of bullying or harassment in good faith or supporting someone to make such a complaint. Victimisation is a disciplinary offence.

It is important to note that MMC is committed to ensuring that all staff behave appropriately in all work environments. We will investigate any complaints made about staff from third parties in line with this policy.

The scope of this policy

The policy covers discrimination bullying and harassment in the workplace and in any work-related setting outside the workplace, e.g. business trips, virtual meetings and work-related social events by MMC staff towards others who are not part of MMC.

If the alleged harasser is not employed by the Company, e.g. if the worker's contract is with an agency, this policy will apply with any necessary modifications such as that the Company could not dismiss the worker but would instead require the agency to remove the worker, if appropriate, after investigation and disciplinary proceedings.

What is dignity for all?

Our wish is for everyone to be treated with dignity and respect and to create an environment where all can be heard. There are further details of what constitutes discrimination, harassment and bullying at the back of this document, but the core is behaviour which disadvantages or excludes another or makes someone else uncomfortable. The intention of the individual complained of is irrelevant. The person complaining does not need to have been on the receiving end of the unwanted behaviour themselves, witnessing it is sufficient.

Examples of inappropriate behaviour which might occur in venture capital and fundraising:

• offering business funding for going along with sexual advances;
• threatening not to promote a party’s products if sexual advances are rejected;
• only offering meetings in bars or hotels;
• questions about a person’s private life;
• threatening to withhold funding if sexual advances are rejected;
• only offering meetings in places which are inaccessible to an individual;
• unwelcome jokes, comments, gestures or nicknames;
• excluding or ignoring an individual because of their characteristics the characteristics of someone close to them:
• spreading malicious rumours or insulting someone;
• picking on someone or setting him/her up to fail;
• making threats or comments about someone's job security without good reason;
• ridiculing someone;
• rejecting a supplier because of their characteristics;
• isolation or non-cooperation at business events; and
• excluding someone from social activities.
• has the purpose of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person; or
• is reasonably considered by that person to have the effect of violating his/her dignity or of creating an intimidating, hostile, degrading, humiliating or offensive environment for him/her, even if this effect was not intended by the person responsible for the conduct.
• offering business funding for going along with sexual advances;
• threatening not to promote a party’s products if sexual advances are rejected;
• only offering meetings in bars or hotels;
• questions about a person’s private life;
• threatening to withhold funding if sexual advances are rejected;
• any behaviour where a person with power manipulates or demands action from the less powerful person.
• physical conduct ranging from unwelcome touching to serious assault;
• unwelcome sexual advances;
• the offer of rewards for going along with sexual advances, eg offer of funding, promotion, access to training;
• threats for rejecting sexual advances, eg suggestions that refusing advances will adversely affect the individual’s prospects; or rejecting a company’s pitch, withholding funding, or not recommending a company to other investors;
• demeaning comments about a person's appearance;
• unwelcome jokes or comments of a sexual or racial nature or about an individual's age, disability, sexual orientation or religion;
• questions about a person's sex life;
• unwanted nicknames related to a person's age, race or disability;
• the use of obscene gestures;
• excluding an individual because he/she is associated or connected with someone with a protected characteristic, eg his/her child is gay, spouse is black or parent is disabled;
• ignoring an individual because he/she is perceived to have a protected characteristic when he/she does not, in fact, have the protected characteristic), eg an employee is thought to be Jewish, or is perceived to be a transsexual;
• the open display of pictures or objects with sexual or racial overtones, even if not directed at any particular person, eg magazines, calendars or pin-ups;
• spreading malicious rumours or insulting someone;
• picking on someone or setting him/her up to fail;
• making threats or comments about someone's job security without good reason;
• ridiculing someone;
• isolation or non-cooperation at business events; and
• excluding someone from social activities.

More general examples of unacceptable behaviour include:

Day-to-day action

MMC encourages itself and all its employees to consider whether their actions, even if not unlawful, are contributing to an un-inclusive environment. Consideration should be given to social events to ensure that they are as inclusive as possible. For instance, events could be hosted during the working day, rather than just in the evening which exclude those with family commitments or long-commutes; or events where the focus is not around drinks. Are roundtables or speaking events structured so that as may people as possible can speak, not merely the most confident.

The nature of venture capital and fundraising means that events often happen in the evenings or weekends – these are also work. If you are somewhere because of who you work for, for instance the after-party after a conference dinner, this is work.

We will not tolerate harassment or bullying of individuals by MMC staff at these events and will investigate any allegations made of inappropriate behaviour.

External Reporting

Any reports of harassment or inappropriate behaviour by MMC staff towards third parties will be treated seriously. The CEO will appoint himself or another relevant partner to investigate the complaint. We will endeavour to maintain the complainant’s anonymity and share details only to those who need to know. It may be appropriate to involve a third party specialist in some situations. We will endeavour to investigate and report to the complainant in a timely manner. MMC may deploy a full range of responses from training and monitoring to dismissal in the most serious cases.

Complaints of discrimination, harassment or bullying by MMC staff member should be addressed to Bruce Macfarlane (bruce@mmc.vc) or Victoria Ferguson (Victoria@mmc.vc) (both on 020 7938 2220) in the first instance.

Making this policy work

The Company will review the outcomes of cases where complaints of bullying and harassment have been made to check that the proper procedures have been followed and to identify any points that can be learned from those cases and implement any necessary changes.

The Company will also periodically monitor how successful it is being in creating an inclusive workplace free of bullying and harassment by other means which may include confidential staff surveys.

Further details

What is discrimination?

The law

It is unlawful to discriminate directly or indirectly in recruitment or employment because of age, disability, sex, gender reassignment, pregnancy, maternity, race (which includes colour, nationality and ethnic or national origins), sexual orientation, religion or belief, or because someone is married or in a civil partnership. These are known as "protected characteristics”.

Discrimination after employment may also be unlawful, eg refusing to give a reference for a reason related to one of the protected characteristics.

Staff should not discriminate against or harass a member of the public in the provision of services or goods, including founders or co-investors seeking funding. It is unlawful to fail to make reasonable adjustments to overcome barriers to using services caused by disability. The duty to make reasonable adjustments includes the removal, adaptation or alteration of physical features, if the physical features make it impossible or unreasonably difficult for disabled people to make use of services. In addition, service providers have an obligation to think ahead and address any barriers that may impede disabled people from accessing a service.

Types of unlawful discrimination

Direct discrimination is where a person is treated less favourably than another because of a protected characteristic. An example of direct discrimination would be refusing to employ a woman because she is pregnant.

In limited circumstances, employers can directly discriminate against an individual for a reason related to any of the protected characteristics where there is an occupational requirement. The occupational requirement must be crucial to the post and a proportionate means of achieving a legitimate aim.

Indirect discrimination is where a provision, criterion or practice is applied that is discriminatory in relation to individuals who have a relevant protected characteristic (although it does not explicitly include pregnancy and maternity, which is covered by indirect sex discrimination) such that it would be to the detriment of people who share that protected characteristic compared with people who do not, and it cannot be shown to be a proportionate means of achieving a legitimate aim.

Associative discrimination is where an individual is directly discriminated against or harassed for association with another individual who has a protected characteristic.

Perceptive discrimination is where an individual is directly discriminated against or harassed based on a perception that he/she has a particular protected characteristic when he/she does not, in fact, have that protected characteristic.

Failure to make reasonable adjustments is where a physical feature or a provision, criterion or practice puts a person with disabilities at a substantial disadvantage compared with someone who does not have that protected characteristic and the employer has failed to make reasonable adjustments to enable the disabled person to overcome the disadvantage.

If you are disabled, or if you become disabled after we have made an investment you are encouraged to tell the Company about your condition and any adjustments to your working arrangements which would help you to do your job or interact with us, so that the proper support can be provided. If appropriate, the Company may seek medical advice and further information from or about you on these issues.

What is bullying and harassment?

Bullying is offensive, intimidating, malicious or insulting behaviour, and/or an abuse or misuse of power that is meant to undermine, humiliate or injure the person on the receiving end.

Harassment is unwanted conduct related to relevant protected characteristics, which are sex, gender reassignment, race (which includes colour, nationality and ethnic or national origins), disability, sexual orientation, religion or belief and age, that:

Conduct may be harassment whether or not the person behaving in that way intends to offend. Something intended as a "joke" may offend another person. Different people find different things acceptable. Everyone has the right to decide what behaviour is acceptable to him or her and to have his or her feelings respected by others. Behaviour which any reasonable person would realise would be likely to offend will be harassment without the recipient having to make it clear in advance that behaviour of that type is not acceptable to him or her, eg sexual touching. It may not be so clear in advance that some other forms of behaviour would be unwelcome to, or could offend, a particular person, eg certain "banter", flirting or asking someone for a private drink after work. In these cases, first-time conduct which unintentionally causes offence will not be harassment but it will become harassment if the conduct continues after the recipient has made it clear, by words or conduct, that such behaviour is unacceptable to him or her.

Harassment may also occur where a person engages in unwanted conduct towards another because he/she perceives that the recipient has a protected characteristic (for example, a perception that he or she is gay or disabled), when the recipient does not, in fact, have that protected characteristic. For example, it would be harassment for an individual to tease repeatedly an individual because of an incorrect belief that that the recipient is deaf. Similarly, harassment could take place where an individual is bullied or harassed because of another person with whom the individual is connected or associated, for example if his/her child is disabled, wife is pregnant or friend is a devout Christian.

A single incident can be harassment if it is sufficiently serious.

Bullying or harassment will constitute unlawful discrimination where it relates to one of the protected characteristics, which are sex, gender reassignment, race (which includes colour, nationality and ethnic or national origins), disability, sexual orientation, religion or belief and age. Serious bullying or harassment may amount to other civil or criminal offences, eg a civil offence under the Protection from Harassment Act 1997 and criminal offences of assault.

Examples of bullying or harassment

Bullying and harassment may be misconduct that is physical, verbal or non-verbal, eg by letter or e-mail (so-called "flame-mail").

Examples of unacceptable behaviour that are covered by this policy are below, but specific examples which might occur in venture capital and fundraising include:

Other examples include (but are not limited to):

What is victimisation?

Victimisation is subjecting a person to a detriment because he/she has, in good faith, complained (whether formally or otherwise) that someone has been bullying or harassing him/her or someone else, or supported someone to make a complaint or given evidence in relation to a complaint.

Provided that you act in good faith, i.e. you genuinely believe that what you are saying is true, you have a right not to be victimised for making a complaint or doing anything in relation to a complaint of bullying or harassment and MMC will take appropriate action to deal with any alleged victimisation, which may include disciplinary action against anyone found to have victimised you.

Employee responsibilities

Every employee is required to assist the Company to meet its commitment to provide equal opportunities in employment and avoid unlawful discrimination. Employees are encouraged to raise concerns about behaviour which might escalate into discrimination or harassment at an early stage to their line manager, any director or the general counsel.

Employees can be held personally liable as well as, or instead of, the Company for any act of unlawful discrimination. Employees who commit serious acts of harassment may be guilty of a criminal offence.

Acts of discrimination, harassment, bullying or victimisation against third parties are disciplinary offences and will be dealt with under the Company's disciplinary procedure. Discrimination, harassment, bullying or victimisation may constitute gross misconduct and could lead to dismissal without notice.

Line managers and senior team are required to lead by example in ensure that inclusive behaviour is demonstrated to all and in noticing and responding to inappropriate behaviour.