We are committed to promoting a working environment based on dignity, trust and respect, and one that is free from discrimination, harassment, bullying or victimisation. You have the right to be treated with dignity and respect whilst working for us.

A toxic workplace culture, where bullying or harassment is tolerated, is harmful to the wellbeing of the workforce as well as the wider Company. We maintain a zero-tolerance policy towards bullying and harassment and strongly encourage anyone who experiences or witnesses such behaviour to report it. This policy is relevant to all stages of the employment.

This policy is relevant to all stages of the employment relationship including job applicants and extends to bullying or harassment by third parties.

What we expect from you

We expect each of you to take personal responsibility for observing, upholding, promoting and applying this policy. Regardless of your role, this is an integral part of your duties.

Any dealings you have with third parties, including customers, suppliers, contractors, agency staff and consultants, must be free from discrimination, harassment, victimisation or bullying. For more information on discrimination and victimisation, please refer to our Equality, Diversity and Inclusion policy.

If any of our employees are found to have commited, authorised or condoned bullying or harassment, we will take disciplinary action against them, up to and including dismissal.

There is no justification for bullying or harassing someone. Even if you do not intend to bully or harass someone else, this does not legitimise your behaviour as it is the impact on the recipient that is important.

You should be aware that you can be personally liable for harassment.

If you experience bullying or harassment, we encourage you to speak up without delay and to ask for appropriate support.

Who is legally protected from harassment

Unlike bullying, harassment is a legal concept. Protection from harassment applies to the seven protected characteristics defined by law and outlined in our equality, diversity and inclusion policy:

  • age
  • disability
  • gender reassignment
  • race (including colour, nationality, ethnic or national origins)
  • religion or belief
  • sex
  • sexual orientation

Although pregnancy, maternity, marriage and civil partnership are not specifically protected under the legal provisions on harassment, they are protected against discrimination, and we consider unfair or inappropriate behaviour toward any individual to be unacceptable.

What is harassment?

Harassment occurs where a person engages in unwanted conduct relating to a protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them.

“Unwanted conduct” means conduct that is “unwelcome” or “uninvited”. “Unwanted” does not mean that an employee must object to the conduct before it is deemed to be unwanted.

Conduct that has one of these effects may amount to harassment even if the effect was unintentional.

In many cases, harassment is linked to discrimination, either consciously or unconsciously. Bullying can occur for many reasons but is more commonly motivated by issues linked to power or status. Harassment may occur over a period of time through a series of relatively minor incidents, or it may occur through one serious incident. An act of harassment may include an omission or a failure to act.

An employee may find conduct unwanted even if the conduct has not been directed specifically at them, or they do not share the protected characteristic to which the conduct is related.

Harassment can occur where someone behaviours in appropriately based on a misperception of their protected characteristic, for example a perception that someone is transgender even if they are not.

Harassment can also arise by association, where someone is harassed because they are associated with someone with a protected characteristic, for example having a family member of a particular religion.

Examples of harassment

Harassment can occur in many forms and can take place either at work or outside work. While this is not an exhaus􀆟ve list, examples include:

  • "banter", jokes, taunts or insults that are sexist, racist, ageist, transphobic, homophobic or derogatory against any other protected characteristic
  • unwanted physical behaviour, for example, touching, pushing or grabbing
  • derogatory comments about pregnancy, maternity leave or IVF treatment
  • derogatory or offensive comments about religion
  • unwelcome comments about someone's appearance or the way they dress that is related to a protected characteristic
  • "outing" (ie disclosing someone’s sexual orientation against their wishes), or threatening to "out" someone
  • consistently using the wrong names and pronouns following the transition of a person's gender identity
  • displaying images that are racially offensive
  • excluding or making derogatory comments about someone because of a perceived protected characteristic, or because they are associated with someone with a protected characteristic
  • excluding someone from a conversation or social event or marginalising them from the group

Understanding what may constitute harassment on a day to day basis can feel confusing for some people and can bring up emotive and complex issues. What is acceptable and not acceptable culturally has changed, and will continue to change, over time. However, this is not an acceptable justification for behaving in an unkind way to others. If you are unsure about how to deal with a particular topic in the workplace, please seek advice from your line manager or HR and we encourage you to take steps to educate yourself on these important issues.

Sexual harassment

Harassment can include inappropriate sexual behaviour, and this is unacceptable in our workplace. If any of our employees are found to have commitied sexual harassment, we will take disciplinary action against them, up to and including dismissal. We are commitied to preventing sexual harassment and there are a number of steps we take to ensure it does not happen.

The law defines sexual harassment as:

  • conduct of a sexual nature that has the purpose or effect of violating someone's dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment
  • less favourable treatment related to sex or gender reassignment that occurs because of a rejection of, or submission to, sexual conduct 

Examples of sexual harassment

Sexual harassment can occur in many forms. While this is not an exhaustive list, examples of unacceptable behaviour include:

  • persistent suggestions to meet up socially ater a person has made clear that they do not welcome such suggestions
  • showing or sending offensive or pornographic material by any means (e.g. by text, video clip, a work group WhatsApp chat, email or by posting on the internet or social media)
  • unwelcome sexual advances, propositions, suggestive remarks, or gender-related insults
  • unwanted physical behaviour, for example, touching, hugging, massaging or kissing
  • offensive comments about appearance or dress, innuendo or lewd comments
  • leering, whistling or making sexually suggestive gestures
  • making promises in return for sexual favours
  • intrusive questions about a person’s private or sex life
  • gossip and speculation about someone's sexual orientation or transgender status, including spreading malicious rumours 

Prevention of sexual harassment

Our policy is to proactively cultivate a workplace environment that is free of sexual harassment. We are commiteed to ensuring that all employees understand that any form of sexual harassment is unacceptable and will not be tolerated. We take the following steps to prevent sexual harassment occurring in our workplace:

Our anti-bullying and harassment policy is fully comprehensive and outlines clearly to employees what sexual harassment is and the consequences of this type of behaviour. It provides clear guidance on how to report and deal with incidents of sexual harassment, and the steps we take to prevent it happening.

  • We have in place our external HR Consultants who give us specialist advice and guidance on preventing and dealing with bullying and harassment and provide an additional, confidential and impartial contact for raising concerns to. All employees are supported with their wellbeing and are offered the opportunity to contact our HR consultant with any concerns, issues or worries about the workplace. 
  • We have in place our workplace culture forum Thrive Tribe which meets monthly to discuss employee issues and workplace culture. As part of this forum, they review how well we are meeting the objectives of this policy and to and implement solutions for improvement, including discussion of any concerns regarding bullying or harassment.
  • We seek feedback from our employees on the working environment through various methods including an employee survey and our 360 feedback process.
  • Our employee handbook clearly outlines the process for raising concerns and reporting incidents of sexual harassment both formally and informally. We respond to complaints of sexual harassment in a calm and appropriate way, supporting all employees involved throughout the process; allowing for an independent, impartial investigation which is confidential as far as possible to take place. Our thorough and impartial investigation will result in the appropriate action being taken where sexual harassment has occurred.
  • We carry out a sexual harassment risk assessment to assess the risk of workers being exposed to sexual harassment in the workplace and determine reasonable measures that can be taken to minimise those risks.
  • We communicate to third parties our zero tolerance approach to harassment of any nature, and we provide advice and guidance to managers to ensure employees dealing with clients and customers are safe and supported in external environments. Our policy statement can be found on our website.
  • We provide a confidential Speak-Up Service to all employees allowing you to speak confidentially to an independent HR professional about any concerns. They will listen to employees and work with them to find the right approach to reach an appropriate resolution, including: - helping them find the right words to use to take the next steps - signposting to the right company policies - giving sensible, impartial and balanced advice - discussing who might be the right person to escalate their concerns to - with their permission, raising concerns on their behalf - signposting to external resources that may provide additional support or advice 

The Anonymous Reporting & Support Service line number is 01794 874232 and is available during business hours of 9.00am to 5.00pm.

Bullying

Bullying is persistent behaviour directed against an individual or group of individuals which creates a threatening or intimidating work environment that undermines the confidence and self-esteem of the recipient(s). Bullying is unacceptable in our workplace, and we will take disciplinary action against anyone found to be bullying others, up to and including dismissal. Bullying is commonly based on the misuse of power. This power may be:

  • positional, i.e. linked to the bully's more senior role or position
  • relational, i.e. linked to the bully's relationship with certain individuals or groups
  • resource based, i.e. linked to the bully's power to withhold resources or knowledge that are essential to another person's role
  • psychological, i.e. linked to the bully's knowledge of another person's vulnerability

Types of bullying

There are many different types of bullying. A person may experience one, or a combination of, different kinds of bullying:

  • serial bullying where the bully targets people one at a time, covering their tracks and moving on when there is a danger of being held accountable
  • pressure bullying where personal or work-related stress or pressure causes a person to become short tempered, irritable or oppressive at work towards others, perhaps unwitingly, and this behaviour deteriorates into bullying
  • secondary bullying where people who are under pressure from a bully start to behave in a similar way towards others, sometimes unwitingly
  • corporate bullying where an employer uses coercive methods, for example the threat of dismissal or an inappropriate amount of surveillance, to oppress employees and impose draconian work conditions.
  • cyberbullying where there is a misuse of the internet, email or mobile phones to send aggressive messages and threats
  • predatory bullying where the bully picks on a victim to demonstrate power to others
  • dispute-related bullying where bullying develops out of a conflict that has festered and "got out of hand"
  • merry-go-round bullying where the bully chooses different people to bully on a regular basis, leaving everyone on edge wondering when it will be their turn
  • good-cop/bad-cop bullying where people work in tandem, one of them appearing friendly to elicit the person's "weak points", and then passing this information on to another person to enable them to target the bullying
  • vicarious bullying where someone is deceived and/or manipulated by another person into carrying out aggressive behaviour on their behalf
  • gang bullying which can be referred to as "mobbing", this is where the victim is bullied by a group, often with a ringleader who co-opts others through manipulaton, fear or coercion

Behaviours that may constitute bullying

Different types of behaviour can amount to bullying. Bullying can be:

  • physical, verbal or mental, or a mix of all three
  • passive, for example exclusion, silent treatment or withdrawal, or aggressive, for example intimidation, threats or humiliation;
  • obvious and public, or subtle and hidden; and
  • face to face, or via telephone, email, text or social networking.

Any accusations of bullying will be fully and fairly investigated, considering both perspectives and all available evidence including witness statements from others where appropriate.

Examples of bullying

A range of behaviours may or may not constitute as bullying, depending on the context. Examples of bullying may include (but are not limited to):

  • ignoring, excluding, isolating or marginalising someone
  • spreading rumours or gossip, or manipulating other people's opinions about the target
  • making belitiling or undermining remarks, questioning a person's judgment, mocking someone and deliberately ignoring their opinion
  • public humiliation, for example making someone look stupid or posting demeaning pictures of them online
  • ridiculing, insulting or teasing someone, or verbal or practical jokes or sarcasm
  • physical intimidation, for example shouting or yelling, finger pointing or standing too close to someone
  • physical, verbal abuse or making threats
  • deliberately tampering with a person's personal effects
  • accusations of weakness, a lack of sense of humour or oversensitivity following complaints of unfair treatment

Appropriately conducted criticism of someone’s conduct or behaviour and day to day management of their job performance would not be considered as bullying. However, examples of behaviour by a line manager or superior that could be considered bullying may include (but are not limited to):

  • deliberately and persistently setting up someone to fail by giving them unachievable tasks or impossible deadlines
  • singling out someone for meaningless tasks or unpleasant jobs
  • inappropriate monitoring of work or overbearing supervision
  • persistent criticism or nitpicking not commensurate with competence or performance
  • deliberately giving someone too little work or work that is below their competence to undermine them
  • removing or reassigning a person's responsibilities or demoting them without justification
  • deliberately withholding information, they require or deliberately supplying incorrect or unclear information
  • undervaluing a person's contributions, giving no credit where due or taking credit for someone else's work
  • sabotage of someone's work, or refusing to cooperate or accept authority
  • deliberately withholding training or resources from someone that are necessary for them to perform their role, or opportunities for advancement or promotion
  • reducing or denying opportunities for someone to express their views, consistently interrupting a person when they are speaking or shutting them down during a discussion
  • making inappropriate threats about job security
  • withdrawing or refusing reasonable support
  • unjustified disciplinary hearings

Reporting and raising concerns

We encourage employees to raise any concerns they have with us regarding inappropriate behaviour they have either been on the receiving end of or witnessed taking place. All complaints of bullying or harassment will be dealt appropriately, with sensitivity to the people involved and due consideration of the context of the situation as each situation will be different.

Dealing with the matter informally

If you believe you are experiencing bullying or harassment, it may be possible to resolve the issue by speaking directly with the individual involved. This will very much depend on the nature and seriousness of the behaviour and your confidence in doing so. It is possible the persons behaviour is unintentional, and they may be unaware of its impact on you. If you feel comfortable to do so, you are encouraged to provide constructive feedback to the individual. If you take this route, we suggest you seek support from a trusted colleague, our external HR consultant or your line manager in how best to deliver the feedback.

You are also encouraged, where appropriate, to provide feedback to another employee if you witness inappropriate behaviour or language being used. We suggest you seek support with this and only broach the subject if you feel it is appropriate and constructive to do so.

Informal resolu􀆟on would not be appropriate in the case of serious or persistent harassment or sexual harassment which should be reported to us as a complaint, the process of which is outlined below.

Grievance process

If you have not been able to resolve the matter informally you can make a formal complaint using our grievance procedure.

Our full grievance process is detailed separately in this handbook.

When raising a complaint through the formal grievance procedure, you will need to provide the following details in wri􀆟ng:

  • the name of the alleged perpetrator
  •  the nature of the bullying or harassment
  • when the bullying and/or harassment occurred
  • the names of any witnesses
  • and any actions taken to attempt to resolve the matter informally
  • what action you believe should be taken to resolve the grievance 

Any complaint will be investigated promptly, impartially, and as confidentially as possible. If you and the alleged perpetrator work closely or in proximity, it may be necessary to suspend one or both of you on full pay or ask either of you to work from a different location during the investigation and any subsequent disciplinary proceeding.

Complaints of sexual harassment

If you have experienced sexual harassment, you do not necessarily need to raise a grievance for us to take action. You should bring the incident or incidents to the attention of your manager, another appropriate member management and / or HR and the matter will be dealt with appropriately.

You can also raise your concerns via our confidential Speak Up Service.

We understand talking through an incident of this nature may be emotional and upsettng and we will ensure you have appropriate support to feel able to share with us the details of what has happened. Whilst with cases of sexual harassment it is not necessary to raise a grievance, we will still need you to provide certain information, so we are able to investigate and take the appropriate action.

We will need to know the name of the alleged perpetrator, as much detail as possible about what happened, when it occurred and the names of any witnesses. Depending on the nature of what you have raised, we may decide it is more appropriate to deal with it through the grievance process and we will discuss this with you at the time and share with you the details how to do this.

If you receive a complaint of sexual harassment from another employee, you should capture as much information as possible and provide support to the affected employee. Following this, the information should be shared with your line manager and / or our HR consultant so appropriate action can be taken.

Where the evidence from an investigation into bullying or harassment suggests a disciplinary offence has been committed, a meeting will be convened in accordance with our disciplinary procedure

False or malicious accusations

False accusations of bullying or harassment can have a serious effect on innocent individuals. All investigations will be thorough and impartial. Whilst it is unusual for this to happen, should an investigation show a false accusation has been made knowingly or in bad faith, appropriate disciplinary action will be taken against the complainant and witnesses who have provided false information. Third party bullying or harassment If you have a complaint of harassment or bullying at work by a person not employed by us, we will investigate as far as possible, and then take appropriate action with the appropriate third party with a request they take action to stop the bullying or harassment. We will also consider what, if any, action to take in respect of the alleged perpetrator and/or their employer. This will may involve making changes to ensure you are no longer in contact with the perpetrator.

If a complaint of bullying or harassment by you is received from a third party, we will carry out as much investigation as is practicable and, if it appears a disciplinary offence has been committed, will start disciplinary proceedings.

Support for those affected or involved

We understand that anyone affected by or involved in a complaint of bullying or harassment may feel anxious or upset, and we are committed to supporttng you through this process.

If you feel unable to continue working closely with the alleged bully or harasser, we will take any requests to change your working arrangements seriously during our investigation.

Anyone who makes a complaint or participates in a bullying or harassment investigation in good faith must not suffer any form of detrimental treatment or victimisation. If you feel you have experienced such victimisation, please inform your line manager, Director, or our HR consultant as soon as possible.

Regardless of the outcome of your complaint, we will carefully consider how to manage any ongoing working relationship between you and the individual concerned. Depending on the specific circumstances, we may amend job duties, location, or reportng lines for either party. Alternatively, workplace mediation, wellbeing support or counselling may be considered appropriate.

Continuous policy development

This policy is reviewed on an annual basis to ensure it is up-to-date and relevant. If you have any questions about the contents of this policy, please contact our HR consultant.