We draft diversity, equality and inclusion policy (DEQI) for Midland Cosmos ltd in Nigeria
This draft policy for Midland Cosmos Ltd is designed to comply with 2026 Nigerian labor standards and best practices, specifically aligning with the Constitution of the Federal Republic of Nigeria and the Discrimination Against Persons with Disabilities (Prohibition) Act.
Diversity and Inclusion Policy: Midland Cosmos Ltd
Effective Date: January 2026
Review Date: January 2027
1. Purpose and Scope
Midland Cosmos Ltd is committed to fostering a workplace where every employee feels respected and empowered to reach their full potential. We recognize that our strength lies in our diversity—including differences in ethnicity, gender, age, religion, and physical ability—which drives innovation and excellence in our engineering and service delivery across Nigeria.
This policy applies to all employees, contractors, and job applicants.
2. Core Commitments
Equal Opportunity: We ensure fairness in recruitment, promotion, and pay, basing decisions solely on merit and professional capability.
Inclusive Recruitment: We actively seek talent from diverse Nigerian communities, utilizing multiple channels to reach underrepresented groups.
Safe Environment: We maintain a zero-tolerance stance on harassment, bullying, and discrimination of any kind.
3. Compliance with Nigerian Law
Midland Cosmos Ltd strictly adheres to national regulations, including:
Anti-Discrimination: Prohibiting bias based on ethnicity, place of origin, gender, religion, or political opinion as per Section 42 of the Constitution.
Disability Inclusion: Providing reasonable accommodations for persons with disabilities and striving toward the statutory employment quotas.
Health Status: Protecting employees from discrimination based on actual or perceived HIV status.
Gender Rights: Ensuring at least 16 weeks of paid maternity leave and equal pay for equal work.
4. Key Actions & Accountability
Training: All managers must undergo annual training on unconscious bias and inclusive leadership.
Flexible Working: Where practical, we support flexible work arrangements to help employees balance personal and professional responsibilities.
Reporting: Employees are encouraged to report any breaches through our secure, confidential grievance channels without fear of retaliation.
5. Monitoring and Review
We will conduct annual audits of our workforce demographics and pay equity to track progress against our inclusion goals.
Approved by:
Board of Directors, Midland Cosmos Ltd
To finalize the Midland Cosmos Ltd Diversity and Inclusion (D&I) framework for 2026, the following operational sections should be added to the policy. These sections ensure the policy moves beyond a statement of intent into a functional corporate document.
6. Recruitment and Talent Acquisition
Midland Cosmos Ltd implements a "blind-review" process for initial CV screening where possible to eliminate unconscious bias.
Diverse Shortlists: We aim for gender and ethnic diversity in all final interview pools.
Accessibility: Job advertisements will be posted on platforms accessible to persons with disabilities, such as the Jobberman Accessibility Portal.
7. Employee Resource Groups (ERGs)
The company supports the formation of voluntary, employee-led groups that provide a forum for shared experiences. Supported ERGs include:
Women in Engineering/Tech: Focused on mentorship and leadership pathways for female staff.
New Professionals Forum: Supporting the integration and growth of Gen Z and early-career hires.
Cosmos Culture Club: Celebrating Nigeria’s diverse ethnic heritage through internal cultural exchange events.
8. Pay Equity and Benefits
In line with the 2026 Nigerian labor market trends, Midland Cosmos Ltd performs an annual Pay Equity Audit to ensure no wage gaps exist between employees of different genders or backgrounds performing the same role.
Parenthood Support: Beyond statutory maternity leave, we provide 2 weeks of paid paternity leave to support family inclusion.
Religious Observance: We respect all official Nigerian religious holidays and provide reasonable flexibility for personal religious practices during work hours.
9. Reasonable Accommodation
We are committed to the National Commission for Persons with Disabilities standards. This includes:
Physical Infrastructure: Ensuring our offices in Lagos and other regions have ramp access and accessible restrooms.
Digital Tools: Providing assistive technology (screen readers, etc.) for employees with visual or auditory impairments.
10. Disciplinary Measures
Any employee found to have engaged in discriminatory behavior or harassment will face disciplinary action, up to and including summary dismissal. We encourage victims or witnesses to use the NAPTIP Reporting Channels for extreme cases of workplace abuse or human trafficking concerns.
11. Policy Governance
Responsibility: The Human Resources Director is responsible for the daily implementation of this policy.
Whistleblowing: Reports of discrimination can be filed anonymously via the Midland Cosmos Integrity Hotline (internal link) or via email to integrity@midlandcosmos.com.ng.(pending)
12. Declaration of Commitment
“I, [Name of CEO], confirm that Midland Cosmos Ltd is dedicated to being a leader in corporate inclusion within Nigeria. We do not just hire for diversity; we cultivate an environment where every voice is heard.”
Signed: __________________________
Managing Director/CEO
Date: January 18, 2026
To further operationalize the Midland Cosmos Ltd Diversity and Inclusion (D&I) policy for 2026, the following advanced sections on training, community impact, and performance measurement should be integrated.
13. Training and Professional Development
Midland Cosmos Ltd recognizes that awareness is the foundation of an inclusive culture. We commit to the following structured training programs:
Unconscious Bias Workshops: Interactive, scenario-based sessions for all staff to identify and mitigate biases in daily decision-making.
Inclusive Leadership Training: Mandatory modules for all managers (Grade 4 and above) on building psychological safety and managing multigenerational teams.
Cultural Competency: Education on Nigeria’s diverse ethnic traditions and communication styles to enhance teamwork and empathy.
Digital Accessibility Training: Specialized workshops for IT and communications teams to ensure all company platforms meet international accessibility standards.
14. Community Engagement and External Impact
Our commitment to diversity extends beyond our office walls to the Nigerian communities we serve:
STEM Outreach: Active partnership with Nigerian universities to provide internships and apprenticeships for underrepresented students in engineering.
Supplier Diversity: Prioritizing partnerships with local, minority-owned, and women-led businesses through an inclusive procurement process.
Public Advocacy: Engaging with civil society organizations (CSOs) to promote disability rights and gender equality in the broader Nigerian workforce.
15. Measuring Progress (KPIs)
To ensure accountability, Midland Cosmos Ltd tracks the following Key Performance Indicators (KPIs) on a quarterly basis:
Workforce Representation: Monitoring gender and ethnic distribution across all organizational levels, with a target of 35% female representation in leadership by 2027.
Pay Equity Index: Annual review of compensation data to ensure a 0% wage gap for identical roles.
Inclusion Sentiment: Annual "Inclusion and Belonging" surveys to gauge employee satisfaction and psychological safety.
Retention Rates: Tracking turnover specifically among underrepresented groups to identify and address systemic barriers.
16. Integration of Emerging Technologies
As of 2026, we utilize AI-driven tools to enhance our D&I efforts:
Bias Detection: AI auditing of job descriptions to remove gendered or exclusionary language before publication.
Data Analytics: Using privacy-compliant platforms to analyze workforce trends and predict areas where additional support or training may be needed.
Policy Oversight:
This document will be audited annually by an independent third-party D&I consultant to ensure Midland Cosmos Ltd remains a benchmark for inclusive excellence in the Nigerian engineering sector.
To conclude the Midland Cosmos Ltd Diversity and Inclusion (D&I) policy for 2026, the final sections focus on corporate governance, the legal framework for review, and a glossary of terms for clarity.
17. Board Diversity and Governance
In alignment with Principle 2.2 of the Nigerian Code of Corporate Governance (NCCG), the Board of Directors at Midland Cosmos Ltd oversees the D&I strategy.
Board Composition: The Board strives for a minimum of 30% female representation, matching Central Bank of Nigeria (CBN) guidelines for equitable decision-making.
Executive Accountability: The CEO and HR Director are jointly responsible for meeting D&I targets, with annual performance reviews tied to these metrics.
18. Policy Review and Amendment
This policy is a living document, reviewed annually to reflect emerging global trends and 2026 Nigerian labor reforms.
Trigger for Review: Amendments may be triggered by changes in national legislation, such as the National Gender Policy (2021-2026) or new tax incentives for disability hiring expected in 2026.
Staff Feedback: Changes will incorporate feedback from employee surveys and Employee Resource Groups to ensure the policy remains relevant to the workforce's lived experiences.
19. Glossary of Terms
To ensure a shared understanding across the organization:
Diversity: The range of human differences, including but not limited to ethnicity, gender, age, religion, and physical ability.
Inclusion: The active state of being valued, respected, and supported, ensuring every employee has an equal voice in decision-making.
Equity: Proactive measures and "reasonable adjustments" taken to address barriers faced by specific groups to ensure equal access to opportunities.
Unconscious Bias: Social stereotypes about certain groups of people that individuals form outside their own conscious awareness.
Reasonable Accommodation: Modifications to the work environment or job processes that enable a person with a disability to perform their duties effectively.
20. Final Declaration
Midland Cosmos Ltd believes that a culture of belonging is a strategic business decision, not just a moral obligation. By embracing the unique talents of all Nigerians, we drive the innovation necessary for our continued success.
Document Control:
Version: 2026.1
Custodian: Department of Human Resources
Legal Advisor: [Seyi Oso from Gelias/Midland Cosmos], Specialist in Nigerian Labor Law.
To further solidify the Midland Cosmos Ltd Diversity and Inclusion (D&I) policy for 2026, the following final operational annexes should be included. These ensure that the engineering-focused firm remains compliant with the most recent Nigerian regulatory developments.
21. Compliance with the 2026 Nigerian Tax and Labor Reform
In anticipation of new 2026 tax incentives, Midland Cosmos Ltd will leverage government-backed rebates for inclusive hiring.
Disability Tax Incentives: The Finance Department is mandated to track and claim tax rebates or incentives offered for employing and providing reasonable accommodations to persons with disabilities (PWDs).
National Directorate of Employment (NDE) Partnership: We will collaborate with the National Directorate of Employment to participate in outreach programs that connect our engineering teams with youth from vulnerable groups across Nigeria’s six geopolitical zones.
22. Enhanced Recruitment Protocols for 2026
To move beyond "who you know" and prioritize "what you know," we are implementing the following:
Anonymized Screening: Identifying details such as names, specific home addresses, and university names will be redacted from initial CV reviews to eliminate regional or institutional bias.
Diverse Interview Panels: Every interview panel must include at least one member from an underrepresented group (e.g., gender, ethnicity, or disability) to ensure a balanced evaluation.
Inclusive Job Adverts: Descriptions will avoid gender-coded language or ageist phrases (e.g., "young go-getter") and instead focus on specific tasks, such as "ability to manage multiple deadlines across diverse projects".
23. Conflict Resolution and Psychologically Safe Reporting
Midland Cosmos Ltd maintains a culture where employees can voice concerns without fear of retaliation.
Mediation Services: For internal D&I-related disputes, we provide access to neutral third-party mediators specialized in intercultural conflict resolution.
Legal Recourse: While we aim for internal resolution, we respect the rights of employees to approach the National Industrial Court of Nigeria (NICN) for matters involving workplace discrimination or unfair termination.
Confidential Integrity Hotline: All reports of harassment or bias are investigated within 14 working days, ensuring administrative action is taken to uphold our duty of care.
24. Supplier and Partner Diversity
We extend our D&I values to our business ecosystem:
Inclusive Procurement: We actively seek to partner with Original Equipment Manufacturers (OEMs) and local vendors who demonstrate a similar commitment to inclusive practices.
Public Commitments: Midland Cosmos Ltd will participate in national platforms like the Solar & Storage Live Nigeria and Nigeria Energy exhibitions to advocate for gender and disability inclusion in the engineering and power sectors.
Final Document Review:
Authorized by: Human Resources Director
Effective Date: January 18, 2026
Next Review Date: January 18, 2027
To conclude the Midland Cosmos Ltd Diversity and Inclusion (D&I) policy for 2026, the final operational chapters focus on technical compliance for engineering firms and integration with 2026 labor mandates.
25. Engineering Sector-Specific Inclusivity
As a multi-discipline engineering firm, Midland Cosmos Ltd recognizes that specific barriers exist in technical fields.
On-Site Accessibility: We mandate that all active project sites in the Oil, Gas, and Power sectors include inclusive facilities (e.g., gender-segregated mobile toilets and safe rest areas).
PPE for All: We provide Personal Protective Equipment (PPE) tailored for diverse body types, ensuring that female engineers and staff with physical impairments have access to gear that ensures both safety and dignity.
Technical Mentorship: 20% of senior engineering leads' performance reviews will be tied to the successful mentorship of junior staff from underrepresented backgrounds.
26. 2026 Regulatory Alignment
In 2026, Midland Cosmos Ltd adheres to the latest revalidated national standards:
National Gender Policy (2021-2026): We aim to achieve the 35% representation target for women in corporate leadership and boardrooms by the 2027 review cycle.
Disability Quotas: We strictly follow the Discrimination Against Persons with Disabilities (Prohibition) Act, reserving at least 5% of new employment opportunities for qualified persons with disabilities (PWDs).
ILO Convention 190: We implement a 2026 "Zero-Harassment" framework, providing mandatory training to all staff on preventing workplace violence and harassment, in line with Nigeria's ratification of international labor standards.
27. Monitoring and Transparency
D&I Dashboard: Our HR department will maintain a quarterly internal dashboard tracking progress on recruitment, pay equity, and retention rates across diverse groups.
External Audits: As of 2026, we will undergo voluntary annual reviews by authorized D&I consultants to ensure our practices remain a benchmark for the Council for the Regulation of Engineering in Nigeria (COREN).
Annual Reporting: While not legally required to publish data, we will include a summary of our D&I achievements in our annual Corporate Social Responsibility (CSR) report to showcase our commitment to stakeholders and OEM partners.
28. Conclusion and Call to Action
Midland Cosmos Ltd believes that our diversity is our greatest asset. This policy is not merely a set of rules but a commitment to building a resilient, innovative, and competitive organization that reflects the true spirit of Nigeria. We call on every employee to champion these values daily.
Document Final Approval:
Board of Directors, Midland Cosmos Ltd
Date: January 18, 2026
Version: 2026.
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