1. Policy statement
Friam Limited (“we”, “us”, “our”) is the company behind AgentGuard, Ready Vet Staff (VetGuard), HotelGuard, FirmGuard, CareGuard and the EveryGuard family of UK compliance products. We are committed to promoting equality of opportunity. We aim to ensure that no team member, customer, end-customer, or supplier receives less favourable treatment on the grounds of any protected characteristic.
2. Legal framework
This policy is designed to comply with current legislation including:
- Equality Act 2010
- Human Rights Act 1998
- UK GDPR and Data Protection Act 2018 (in particular, fairness and accountability principles applied to automated processing)
3. Protected characteristics
We will not discriminate against any person on the basis of:
- Age
- Disability
- Gender reassignment
- Marriage and civil partnership
- Pregnancy and maternity
- Race (including colour, nationality, ethnic or national origin)
- Religion or belief
- Sex
- Sexual orientation
4. Our commitments
4.1 For our team
- Recruit, promote, and retain on the basis of skill and suitability for the role
- Provide equal access to training and development
- Make reasonable adjustments for team members with disabilities
- Maintain a workplace free from harassment
4.2 For our customers (agents and their teams)
- Make the agent app, public Trust pages, and trainee surface accessible to a wide range of users, including assistive-technology users
- Provide reasonable adjustments for users who request them — for example, alternative formats for training content
- Apply pricing, support, and feature access on equal terms across customers
4.3 For end-customers we screen on the agent’s behalf
- Screen sanctions and PEP lists using deterministic name-matching rules; do not score people on protected characteristics
- Use only one-to-one face matching to confirm the document holder — no one-to-many facial identification, no demographic classification (gender, age, ethnicity), and no emotion detection
- Provide an appeal route via the agent (the controller) for any automated finding
4.4 In our operations
- Treat all enquiries fairly
- Design our AI systems not to assess people on protected characteristics, and review them for fairness
- Regularly review our processes for potential discrimination
- Train our team on equality and diversity
5. AI and fair processing
Our use of AI is described in detail in our AI Ethics & Transparency Policy. In summary:
- Our compliance scanner reads website text; it does not assess people
- Our agency-type classifier categorises firms, not individuals
- Our sanctions / PEP screening uses authoritative public lists with deterministic matching, not AI scoring
- Our customer-verify flow checks document validity and liveness, with no demographic scoring
- Human review is built in for every consequential output, with a documented right to appeal
6. Reasonable adjustments
We will make reasonable adjustments for users with disabilities, including:
- Alternative formats for training and policy materials
- Adjusted timeouts on the customer-verify flow on request
- Support with onboarding and document-signing for users who need it
Customers and end-customers requiring adjustments should contact us at legal@everyguard.uk.
7. Discrimination by customers
If an agent customer requests that we operate the screening or compliance tools in a way that would unlawfully discriminate against end-customers (for example, selectively running CDD only on end-customers of a particular nationality), we will:
- Decline to act on such requests
- Explain our legal and ethical obligations and the customer’s own MLR 2017 obligations
- If necessary, terminate the customer relationship
8. Complaints
Any team member, customer, or end-customer who believes they have been discriminated against may raise a complaint by:
- Emailing us at legal@everyguard.uk
- Writing to us at 164–170 High Street, Crowthorne, England, RG45 7AT
All complaints will be investigated promptly and thoroughly. We will respond within 14 days of receiving a complaint.
9. Monitoring and review
- Monitor team diversity (where data is voluntarily provided)
- Review our AI outputs for fairness
- Regularly review this policy and update as required
- Seek feedback from customers and end-customers on our practices
10. Responsibility
All Friam team members are responsible for implementing this policy. The directors of Friam Limited have overall responsibility for ensuring compliance and will address any breaches appropriately.
Friam Limited
164–170 High Street, Crowthorne, England, RG45 7AT
Company No. 14219476 · VAT No. GB419765755
Email: legal@everyguard.uk