Anti-harassment and bullying Policy
Policy
The purpose of this policy is to ensure that all staff are treated and treat others with dignity and respect, free from harassment and bullying. All staff should take the time to ensure they understand what types of behaviour are unacceptable under this policy.
This policy covers harassment or bullying which occurs both in and out of the workplace, including work-related social functions. It covers bullying and harassment by staff and by third parties such as clients, suppliers, or visitors to our premises.
Staff must treat colleagues and others with dignity and respect, and should always consider whether their words or conduct could be offensive. Even unintentional harassment or bullying is unacceptable.
We will take allegations of harassment or bullying seriously and address them promptly and confidentially where possible. Harassment or bullying by an employee will be treated as misconduct under our Disciplinary Procedure. In some cases, it may amount to gross misconduct leading to summary dismissal.
This policy does not form part of any employee’s contract of employment and we may amend it at any time or depart from it where we consider appropriate.
The Law
The Equality Act 2010 prohibits harassment related to age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation.
The Protection from Harassment Act 1997 also makes it unlawful to pursue a course of conduct which you know or ought to know would be harassment, which includes causing someone alarm or distress.
Under the Health and Safety at Work etc. Act 1974 staff are entitled to a safe place and system of work.
From 26th October 2024 following an amendment to the Worker Protection Act (2023), employers now have a legal duty to prevent sexual harassment in the workplace, including any harassment by third parties. There is already legislation in place to protect workers from harassment in general, so this is essentially being extended to include sexual harassment too.
The law requires employers to take reasonable steps to prevent sexual harassment of their workers. We take action to prevent sexual harassment from occurring and have clear reporting procedures for our staff to make a complaint about sexual harassment. If you have been sexually harassed, or you have witnessed sexual harassment, we encourage you to tell us so that we can deal with the matter swiftly.
We recognise that harassment and victimisation is unlawful under the Equality Act 2010. As such, harassment, or victimisation on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation is unacceptable and will not be tolerated.
Personal harassment takes many forms ranging from tasteless jokes and abusive remarks to pestering for sexual favours, threatening behaviour, and actual physical abuse. For the purposes of this policy, it also includes bullying.
Bullying is understood to be targeted and persistent offensive, intimidating, malicious or insulting behaviour and can include the abuse or misuse of power to undermine, humiliate, denigrate, or injure the recipient.
We deplore all forms of personal harassment and seek to ensure that the working environment is sympathetic to all our employees. The aim of this policy is to inform employees of the type of behaviour that is unacceptable and provide employees who are the victims of personal harassment with a means of redress.
Who is Covered by the Policy?
This policy covers all individuals working for us irrespective of their status, level or grade. It therefore includes managers, directors, employees, contractors, casual and agency staff (collectively referred to as staff in this policy).
Personnel Responsible for Implementation of the Policy.
All managers have a specific responsibility to operate within the boundaries of this policy, ensure that all staff understand the standards of behaviour expected of them and to take action when behaviour falls below its requirements.
All staff must take responsibility for their own behaviour, behave in line with the companies Values, respect & support their peers, and report any harassment / bullying that they either experience or witness. Staff should disclose any instances of harassment or bullying of which they become aware to their line manager or other manager if that is not appropriate.
Questions about this policy and requests for training and information on dealing with bullying or harassment should be directed to the Managing Director.
Definitions
Examples of personal harassment.
Personal harassment takes many forms and employees may not always realise that their behaviour constitutes harassment. Personal harassment is unwanted behaviour by one employee towards another and examples of harassment include:
- insensitive jokes and pranks
- lewd or abusive comments
- deliberate exclusion from conversations
- displaying abusive or offensive writing or material
- abusive, threatening or insulting words or behaviour
- name-calling
- picking on someone or setting them up to fail
- exclusion or victimisation
- undermining their contribution/position
- demanding a greater work output than is reasonably feasible
- blocking promotion or other development/advancement
These examples are not exhaustive and disciplinary action at the appropriate level will be taken against employees committing any form of personal harassment.
Examples of sexual harassment.
Sexual harassment is unwanted conduct of a sexual nature which has the purpose or effect of violating a persons dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person.
Sexual harassment may be committed by a fellow worker, an agent of an organisation, or a third party. It does not need to occur in person. It can occur via digital means, including social media sites or channels (eg WhatsApp). Someone may be sexually harassed even if they were not the target of the behaviour.
Examples of sexual harassment include, but are not limited to
- sexual comments or jokes, which may be referred to as “banter”
- displaying sexually graphic pictures, posters or photos
- suggestive looks, staring or leering
- propositions and sexual advances
- making promises in return for sexual favours
- sexual gestures
- intrusive questions about a person’s private or sex life or a person discussing their own sex life
- sexual posts or contact in online communications, including on social media
- spreading sexual rumours about a person
- sending sexually explicit emails, text messages or messages via other social media
- unwelcome touching, hugging, massaging or kissing
Sexual harassment can also take place where an employee is treated less favourably because they have rejected, or submitted to, the unwanted conduct that is related to sex or is of a sexual nature. Whether less favourable treatment occurs as a result will be examined broadly and includes areas such as blocking promotion and refusal of training opportunities or other development opportunities.
Examples of victimisation.
Victimisation takes place when an employee is treated unfavourably as a direct result of raising a genuine complaint of discrimination or harassment. Furthermore, any employee who supports or assists another employee to raise a complaint is also subjected to victimisation if they are treated unfavourably.
Third party harassment
The Organisation operates a zero-tolerance policy in relation to harassment perpetrated against one of its employees by a third party, such as a client/customer or visitor to the organisation. All employees are encouraged to report any and all instances of harassment that involve a third party in line with our reporting procedure, as outlined below.
If we find that the allegation is well-founded, we will take steps we deem necessary in order to remedy this complaint. This can include, but is not limited to:
- warning the individual about the inappropriate nature of their behaviour
- banning the individual from organisation premises
- reporting the individual’s actions to the police.
In addition to this, the Organisation will endeavour to take all reasonable steps to deter and prevent any form of harassment from third parties taking place.
Responsibilities
Employee responsibilities.
The Organisation requires its employees to always behave appropriately and professionally during the working day, and this may extend to events outside of working hours which are classed as work-related such as social events. Employees should not engage in discriminatory, harassing, or aggressive behaviour towards any other person at any time.
Any form of harassment or victimisation may lead to disciplinary action up to and including dismissal if it is committed:
- in a work situation
- during any situation related to work, such as a social event
- against a colleague or other person connected to the employer outside of a work situation, including on social media
- against anyone outside of a work situation where the incident is relevant to their suitability to carry out the role.
A breach of this policy by will be treated as a disciplinary manner Employer responsibilities.
The Organisation will be responsible for ensuring all members of staff, including those within management positions, understand the rules and policies relating to the prevention of harassing and bullying behaviour at work and during work-related social events. We will promote a professional and positive workplace whereby managers are alert and proactively identify areas of risk and incidents of harassment, sexual harassment, and bullying.
We will also take into account aggravating factors, such as abuse of power over a more junior colleague, when deciding what disciplinary action to take.
Where an incident is witness, or a complaint is made under this policy, the Organisation will take prompt action to deal with this matter. All incidents will be deemed serious and dealt within in a sensitive and confidential manner.
Complaining about harassment and/or bullying
Informal method.
We recognise that complaints of personal harassment, and particularly of sexual harassment, can sometimes be of a sensitive or intimate nature and that it may not be appropriate for you to raise the issue through our normal grievance procedure. In these circumstances you are encouraged to raise such issues with a senior colleague of your choice (whether or not that person has a direct supervisory responsibility for you) as a confidential helper. This person cannot be the same person who will be responsible for investigating the matter if it becomes a formal complaint.
If you are the victim of minor harassment, you should make it clear to the harasser on an informal basis that their behaviour is unwelcome and ask the harasser to stop. If you feel unable to do this verbally then you should hand a written request to the harasser, and your confidential helper can assist you in this.
In addition, you may also choose to raise concerns during your regular communication with your manager, eg in a one-to-one meeting. Your manager will listen to you and take your concerns seriously if you do this but may encourage you to follow the reporting procedures set out below. If you don’t have a one-to-one meeting scheduled with your manager, you can ask to meet with them to discuss any concerns that you may have.
Formal method.
Where the informal approach fails or if the harassment is more serious, you should bring the matter to the attention of Tony Higgins, Managing Director as a formal written grievance and again your confidential helper can assist you in this. If possible, you should keep notes of the harassment so that the written complaint can include:
- the name of the alleged harasser
- the nature of the alleged harassment
- the dates and times when the alleged harassment occurred
- the names of any witnesses
- any action already taken by you to stop the alleged harassment.
Where it is not possible to make the formal complaint to the above-named person, for example where they are the alleged harasser, we would encourage you to raise your complaint to Robin Brown, Chairman.
On receipt of a formal complaint, we will take action to separate you from the alleged harasser to enable an uninterrupted investigation to take place. This may involve a temporary transfer of the alleged harasser to another work area or suspension with contractual pay until the matter has been resolved.
The person dealing with the complaint will invite you to attend a meeting, at a reasonable time and location, to discuss the matter and carry out a thorough investigation. The meeting will normally be held within five working days of receipt of your complaint. You have the right to be accompanied at such a meeting by your confidential helper or another work colleague of your choice and you must take all reasonable steps to attend. Those involved in the investigation will be expected to act in confidence and any breach of confidence may be dealt with under the disciplinary procedure.
On conclusion of the investigation, which will normally be within 10 working days of the meeting with you, the decision of the investigator, detailing the findings, will be sent in writing to you.
You will be invited to attend a meeting, at a reasonable time and location, to discuss the matter once the person hearing the grievance has had opportunity to read the report. You have the right to be accompanied at such a meeting by a colleague and you must take all reasonable steps to attend. Those involved in the investigation will be expected to act in confidence and any breach of confidence will be a disciplinary matter.
You will be able to put your case forward at the meeting and the manager will explain the outcome of the investigation. You have a right to appeal the outcome, which is to be made to Robin Brown, Chairman within 5 working days of receiving the outcome.
If the decision is that the allegation is well founded, the harasser will be liable to disciplinary action in accordance with our disciplinary procedure up to and including dismissal.
Regardless of the outcome of the procedure, we are committed to providing the support you may need. This may involve mediation between you and the other party or some other measure to manage the ongoing working relationship.
You will not be victimised for having brought a complaint.
What to do if you witness sexual harassment or victimisation
If you witness sexual harassment or victimisation, you are encouraged to take appropriate action to address it. You should not take any action that may put you at risk of sexual harassment or other harm. If you feel able, you should intervene to prevent the matter continuing. If you are not able to do this, your action may include offering support to the person who has been sexually harassed and encouraging them to report the incident or reporting the incident yourself.
If reporting the incident, you should bring the matter to the attention of with a senior colleague of your choice (whether or not that person has a direct supervisory responsibility for you).
Your concerns will be handled by one of the Leadership Team who will sensitively talk to the person subject to sexual harassment to determine how they want the matter to be handled.
Third-party sexual harassment
Third-party sexual harassment occurs when a member of our workforce is subjected to sexual harassment by someone who is not part of our workforce but who is encountered in connection with work. This includes our customers, suppliers, members of the public, delegates, self-employed contractors, etc. Third-party sexual harassment of our workforce is unlawful and will not be tolerated. The law requires employers to take steps to prevent sexual harassment by third parties and we are committed to doing so. If you have been subjected to third-party sexual harassment, you are encouraged to report this as soon as possible toa member of the Leadership Team.
Should a customer sexually harass a member of our workforce, we will take appropriate action. Any criminal acts will be reported to the police.
We will not tolerate sexual harassment by any member of our workforce against a third party. Instances of sexual harassment of this kind may lead to disciplinary action, including termination of employment.
Disciplinary action
If the decision is that the allegation of sexual harassment or victimisation is well founded, the harasser/victimiser will be liable to disciplinary action in accordance with our disciplinary procedure up to, and including, summary dismissal. An employee who receives a formal warning or who is dismissed for sexual harassment/victimisation may appeal by using our disciplinary appeal procedure.
When deciding on the level of disciplinary sanction to be applied, we will take into consideration any aggravating factors affecting the case. One example of aggravating factors is an abuse of power over a more junior colleague.
If, due to the investigation, it is concluded that your complaint is both untrue and has been brought with malicious intent, disciplinary action may be taken against you.
Confidentiality
Confidentiality is an important part of the procedures provided under this policy. Everyone involved in the operation of the policy, whether making a complaint or involved in any investigation, is responsible for observing the high level of confidentiality that is required. Details of the investigation and the names of the person making the complaint and the person accused must only be disclosed on a “need to know” basis.
Information about a complaint by or about an employee may be placed on the employee’s personnel file, along with a record of the outcome and of any notes or other documents compiled during the process.
A breach of confidentiality may give rise to disciplinary action under our Disciplinary Procedure. .
The Organisation is committed to ensuring employees are not discouraged from using this procedure and no employee will be victimised for having brought a complaint.
This policy is approved and endorsed by the System People Ltd Board and will be reviewed on a bi-annual basis.
Version: 4, October 2025
Document Control
Document approved for release: 31/10/2025 by the Managing Director
Version Control
Version 3 Effective Date: 31st October 2025
Version 2 Effective Date: 5th March 2024
Review Dates
Policy will be reviewed on a bi-annual basis.
Linked Policies
Disciplinary Policy – June 2025
Safer Recruitment Policy – June 2025 Equal Ops Policy – June 2025 Grievance Policy – June 2025
Person Responsible for the Policy
Managing Director
Name
Tony Higgins
To view a signed version of this policy document:
Anti Harrassment and Bullying Policy – October 2025