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The UK presents a mixed scorecard when it comes to protecting sexual discrimination beyond the gender-defined minorities.

The UK anti-discrimination (sexual orientation) regulations of 2007 could be seen as refreshing in their apparent simplicity and true egalitarianism. Terms like hetero and gay did not occur in the regulations themselves. Instead, discrimination was described in relation to a sexual orientation which someone is thought to have. That could in theory constitute a pathbreaking way of rephrasing the whole problem: Do not use my sexuality in any way to discriminate against me. Sadly, though, in official explanatory guidelines accompanying the regulations, a more traditional gender-focused approach was used. Even transsexualism was explicitly ruled out as a sexuality, and instead only considered in relation to gender discrimination: It does not include transsexuality which is related to gender and is covered in the employment context by sex discrimination legislation. Accordingly, since transsexual attraction is denied as an acceptable basis for a discrimination complaint, one senses a more narrow conception of sexuality at work. Quite in line with this, the UK Equality Act of 2010 (which superseded the regulations of 2007) seems to reproduce a traditional gender-based focus: Sexual orientation means a persons sexual orientation towards (a) persons of the same sex, (b) persons of the opposite sex, or (c) persons of either sex. Still, the fact that heterosexuality is specifically mentioned at least offers some dynamism in that a heterosexual minority group like sadomasochists might plausibly claim protection in the UK. In many other countries, including Norway, one has to deny heterosexuality to be protected by the sexual anti-discrimination clauses of the penal code. Countries such as Belgium,Canada,France,Germany and Switzerland have more indeterminate definitions of sexual orientation or preference which might offer securityfor those individuals who see the gender variable as secondary to their sexual identity. Canada though refused to define sexual orientation might include sadomasochists as well. From 1985, France has used moeur or lifestyles in their legislation, way of life by Switzerland since 1999 in their new constitution and some German states simply refer to the sexual identity category. According to the international experts of 2006 who adopted the Yogyakarta principles, Sexual orientation is understood to refer to each persons capacity for profound emotional, affectional and sexual attraction to, and intimate and sexual relations with, individuals of a different gender or the same gender or more than one gender.

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