SCOPE OF POLICY
The Worker Protection Act (amendment of the Equality Act 2010) which is effective from 26 October
2024 updates the Equality Act 2010 and places additional responsibilities upon employers who MUST
take proactive steps to prevent the sexual harassment of their employees in the course of their
employment. Note that the Company is committed to maintaining a workplace free from all
harassment as well as ensuring it complies fully with the current UK legislation (including the latest
changes to sexual harassment laws). This policy applies to all employees, contractors, volunteers, and
any third parties who may interact with the Company and specifically relates to unwanted conduct of
a sexual nature towards an employee. It is the responsibility of every individual within the organisation
to promote a respectful working environment, free from unwanted behaviours or actions of a sexual
nature.
Any failure to observe the principles outlined in this policy will be subject to the Company’s disciplinary
procedure which may result in disciplinary sanction up to and including summary dismissal.
SEXUAL HARASSMENT UNDER THE LAW
The Equality Act 2010 and subsequent amendments define sexual harassment as being where a person
carries out any unwanted conduct of a sexual nature that has the purpose or effect of:
• Violating an individual’s dignity; and/or
• Creating an intimidating, hostile, degrading, humiliating, or offensive environment.
The new laws also extend protections to include third-party harassment, where an employee may be
harassed by clients, customers, or contractors.
EXAMPLES OF SEXUAL HARASSMENT
Sexual harassment can take various forms, including but not limited to:
• Verbal conduct: Inappropriate comments, jokes, or conversations of a sexual nature.
• Non-verbal conduct: Displaying sexually suggestive material, unwanted gestures, or staring
(leering).
• Physical conduct: Unwelcome touching, hugging, or any other physical interactions of a sexual
nature.
• Online conduct: Sending inappropriate emails, messages, or sharing explicit content.
Even if the behaviour is not directly targeted at an individual, a workplace environment where sexual
“banter” is common can be deemed as creating an offensive environment for others.
RESPONSIBILITIES OF EMPLOYEES AND MANAGERS
All Employees:
• Employees are responsible for their conduct at all times and must ensure their behaviour does
not contribute to a hostile working environment.
• Any employee who witnesses or experiences sexual harassment should report the behaviour
immediately via the appropriate channels.
Managers:
• Managers have a duty to prevent and address any incidents of sexual harassment. They must
take all complaints seriously and respond promptly.
• Managers must set an example by modelling respectful behaviour and ensuring that
workplace culture aligns with the Company’s zero-tolerance approach to harassment.
REPORTING SEXUAL HARASSMENT
The Company encourages all employees to report any instances of sexual harassment immediately.
Complaints can be made through the following channels:
• Directly to your line manager.
• To the HR department.
• Via the confidential reporting system (if applicable).
The Company will ensure all complaints are investigated promptly, fairly, and confidentially. Any
retaliation against individuals who report harassment will not be tolerated and will result in disciplinary
action.
INVESTIGATION PROCEDURE
Upon receiving a complaint, the Company will initiate a thorough investigation, which may include:
• Interviewing the complainant, the accused, and any witnesses.
• Reviewing any relevant communications or materials.
• Maintaining confidentiality throughout the investigation process to the most extent possible.
Based on the findings, appropriate action will be taken, which may range from informal resolution to
formal disciplinary measures, including dismissal if warranted.
PROTECTION AGAINST THIRD-PARTY HARASSMENT
In line with the latest amendments to UK sexual harassment laws, the Company must take all
reasonable steps to protect employees from harassment by third parties, such as from clients or
customers. If an employee is subjected to third-party harassment, they are encouraged to report the
incident immediately, and the Company will take steps to address the situation.
Although not applicable by law, the Company may require all employees to display a footer in their
emails that includes a statement regarding zero tolerance of sexual harassment via internal or external
sources. This message is to advise third parties about the Company’s responsibility and commitment
to protecting its employees and preventing sexual harassment in the workplace, and failure to display
this message when you have been asked to may put the liability upon you as the employee rather than
the employer if an incident should occur between you and third party. This message may also be
present on the Company website.
CREATING A RESPECTFUL WORKPLACE
The Company is dedicated to fostering an environment where all employees feel safe and respected.
To support this goal, we commit to:
• Providing regular training on sexual harassment awareness and prevention.
• Ensuring all policies and procedures are easily accessible to employees.
• Encouraging open communication so that issues can be addressed before they escalate.
In addition, the Company recognises its responsibility to ensure its employees are aware of the
expectations in their conduct and how to report a case of sexual harassment in the workplace. To
support employees with this, the Company may choose to take further action, such as:
• Display posters in shared workspaces advising of responsibilities and reporting procedure.
• Require employees to sign an agreement to acknowledge they have understood the contents
of the policy after reading it.
• Share the Company’s risk assessment with its employees.
• Host a consultation meeting for employees to ask questions about the Company’s policy on
sexual harassment.
• Send out Company communications to clients and customers (third parties) advising them of
the Company’s zero-tolerance to sexual harassment.
• Provide further training and support for all employees.
Please note that this list is not exhaustive.
TRAINING
In order to ensure its employees are aware of their individual responsibilities and to support senior
management in being proactive in preventing sexual harassment in the workplace, the Company shall
provide employees (including managers, directors, employers and other staff, regardless of role in the
Company or hours worked) with training to support their understanding in this subject. This training
maybe online or in-person, and should have the intention to inform and raise awareness so that every
employee feels they are able to contribute to positive changes in workplace culture. Additional training
shall be given to managers and more senior-level employees.
After training is undertaken, records shall be kept by the Company until the employee leaves the
Company, for whatever reason. Re-training shall also be considered after a reasonable period of time,
at least annually, but may be sooner depending on the needs of the business. Additional training and
support may be necessary to ensure employees fully understand their responsibilities and the
expectations to report and manage sexual harassment in the workplace, including the use of informal
conversations, repeating the training course, attending one-to-ones and/or performance management
meetings.
Please note the company shall regard such training as mandatory and shall not treat such training as a
“tick box” exercise. ALL employees are required to attend and engage in such training.
BREACH OF POLICY
Any breach of this policy will result in disciplinary action, up to and including summary dismissal. This
applies to any acts of sexual harassment, as well as failure to report incidents or attempts to cover up
such behaviour. Breaches made via email or social media will also be investigated and addressed under
the Company’s disciplinary procedure.
SUPPORT FOR VICTIMS
The Company will provide support to any employee who has experienced sexual harassment, including
but not limited to:
• Access to counselling or support services.
• Adjustments to working arrangements where necessary.
• Guidance on legal rights and protection.
This policy will be reviewed regularly to ensure compliance with the latest legal requirements and to
reflect any changes in workplace best practices. All employees are required to comply with this policy
and are encouraged to actively contribute to a respectful and inclusive working environment
