Reporting Process:

1. Report to immediate line manager.

2. If uncomfortable, escalate to HR or a senior manager.

Reporting Process:

1. Complete an online form detailing the harassment incident.

2. HR reviews the form and schedules a follow-up interview.

3. HR contacts both the complainant and the alleged harasser to assess the situation.

Employees must report any harassment incidents to HR, who will investigate the claim after the fact. In the case of a serious incident, HR will conduct a full investigation, which includes interviewing the complainant, the accused, and any witnesses. The company will take action based on the findings.

Reporting Process:

1. Report the harassment incident to HR.

2. HR investigates the situation by interviewing all parties.

3. After the investigation, HR determines the course of action.

The company is committed to providing an environment in which all of our people treat each other with dignity and respect, and where bullying, harassment and discrimination are known to be completely unacceptable within our organisation.

Unacceptable Behaviour includes:

Workplace Bullying: Workplace Bullying is characterised as offensive, intimidating, malicious or insulting behaviour, an abuse or misuse of power through means that undermine, humiliate, denigrate or injure the recipient.

Workplace Harassment: Workplace Harassment is unwanted conduct related to a relevant 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 that individual.

The relevant protected characteristics are age, disability, gender reassignment, race, religion or belief, gender, and sexual orientation.

Examples of Bullying & Harassment:

o Unwelcome physical contact ranging from unnecessary touching to serious assault

o Intimidating. threatening behaviour, language or unreasonable demands either made directly or indirectly via email, social media or other technology platforms

o Unwelcome attention or advances of a sexual nature

o Disparaging, ridiculing or insulting behaviour, language or gestures

o Inappropriate communication or visual display of offensive material

o Isolation, non-cooperation, or deliberate exclusion of an individual from a work situation (including work-related social events)

o Undermining of an individual through unfair work allocation or persistent unjustified criticism

The examples stated in this policy are not an exhaustive list and the company reserves the right to take action against these and other inappropriate behaviours.

Grievances: Any grievances related to matters detailed in this policy should be raised in accordance with local grievance procedures that are in operation. We will ensure that all grievances are treated sensitively and responded to within the stipulated timeframes.

1. Proactive, Multichannel Reporting Mechanisms:

• Clear, Accessible Channels: Employees are encouraged to report harassment through a variety of confidential, easily accessible channels, including:

o Anonymous reporting via an online portal.

o HR hotline staffed by trained professionals.

o Direct communication with a designated independent third-party advocate or ombudsman.

o Peer support networks for informal advice and guidance.

o Reporting directly to managers or leaders, with guaranteed confidentiality and protection from retaliation.

• Why this is important: Multiple options ensure employees have access to the most comfortable and safest route for reporting, especially for those who may feel unsafe or unsupported by traditional reporting methods. Anonymous reporting ensures that individuals who fear retaliation can still come forward.

2. Immediate and Ongoing Support:

• Immediate Support: After any reported harassment incident, employees will receive immediate support from trained personnel, such as:

o HR staff trained in handling sensitive matters.

o External support professionals (e.g., counsellors, victim advocates) to ensure emotional and psychological needs are met.

• Ongoing Support: Ongoing assistance will be available throughout the reporting, investigation, and resolution processes, including:

o Access to mental health support services, legal advice, and peer support groups.

o Regular check-ins to assess the well-being of the reporting employee and ensure their safety and comfort at work.

• Why this is important: Immediate and continuous support reduces the emotional and psychological toll on employees and ensures that those who report harassment feel supported and validated throughout the process. This support helps to avoid the re-traumatisation of victims during lengthy investigations and can also aid in returning the individual to a safe work environment.

3. Clear, Culturally Sensitive Reporting Guidelines:

• Clear and Accessible Policy: The anti-harassment policy must be:

o Available in multiple formats (online, in print, in accessible formats like braille, large print, or audio) to ensure it’s accessible for all employees, including those with disabilities, non-native speakers, or neurodiverse individuals.

o Available in multiple languages to ensure all employees can understand their rights and the procedures for reporting harassment.

• Culturally Sensitive: The policy should be designed to be culturally sensitive and mindful of various religious, cultural, ethnic, and gender identities. It should explicitly outline how different protected characteristics, including transgender and non-binary identities, may experience harassment differently, and what additional steps will be taken to address these.

• Why this is important: This approach ensures that the policy reaches all employees, regardless of their background or identity. By considering cultural, linguistic, and disability-related needs, the policy demonstrates a clear commitment to inclusivity and equality. This also helps to create a workplace that understands and respects the diverse experiences of harassment.

4. Inclusive Investigation Process:

• Independent, Impartial Investigations: All harassment claims will be investigated by an independent and impartial team trained in:

o Trauma-informed investigation practices to ensure the well-being of the victim throughout the process.

o Cultural competency, ensuring that the investigators understand the intersectional nature of harassment and how it may affect employees from different racial, religious, sexual orientation, and gender identities.

• Accommodations for Diverse Needs: Investigators will provide necessary accommodations to employees, such as:

o Accessibility tools (e.g., sign language interpreters, captioning services, etc.).

o The option for anonymous testimony or remote participation for employees with physical or psychological limitations.

• Why this is important: Investigating harassment claims fairly and inclusively ensures that all individuals, regardless of their identity, are heard, respected, and treated with dignity. By providing accommodations, the process becomes more accessible and less intimidating for employees, particularly those who are marginalized or face barriers to communication.

5. Ongoing Evaluation and Training:

• Regular Audits: The company will conduct regular audits of its anti-harassment policies and procedures, including employee surveys, to ensure that they are effective, inclusive, and up-to-date.

• Regular, Inclusive Training: Training will be provided for all employees on:

o Unconscious bias and its impact on harassment.

o Inclusive leadership to ensure that leaders understand their responsibility in promoting an anti-harassment culture.

o Intersectionality and how harassment experiences differ across identities.

Specific training will be provided for managers and C-suite executives on how to handle harassment claims, prevent retaliation, and promote an inclusive work culture that prioritizes psychological safety for all employees.

• Why this is important: Regular evaluation ensures that the policy remains relevant and effective over time. Ongoing training creates an opportunity for employees to continuously learn, reflect, and grow in their understanding of harassment, intersectionality, and inclusivity. By embedding these values in the organization’s leadership and culture, harassment becomes less likely to be tolerated, and the company can promote a long-term change in behaviour and values.

Why This Is the Best Policy:

1. Proactive and Preventative: This policy doesn't just address harassment after it occurs but actively prevents it through education, support, and clear reporting channels.

2. Multichannel Accessibility: By offering multiple reporting mechanisms, the policy ensures that all employees can report harassment in a way that feels safe for them, whether they are reporting anonymously, directly to HR, or via a third-party.

3. Comprehensive Support: Immediate and ongoing support ensures that employees feel protected and cared for throughout the entire process, with access to mental health services, peer support, and legal resources.

4. Inclusivity at Every Stage: The policy is designed to be culturally sensitive and accessible for all employees, considering diverse backgrounds and identities. It emphasizes that harassment can look different depending on intersectional identities and requires responses tailored to the specific needs of marginalized groups.

5. Independent Oversight: Having an independent investigation process ensures fairness and transparency, reducing the risk of bias, retaliation, or organizational silencing.

6. Ongoing Commitment to Change: Regular audits and frequent training ensure that the policy remains effective, and employees continue to engage in positive behaviour change, ultimately fostering a culture of respect, inclusion, and psychological safety.

By adopting this inclusive approach, the policy not only provides a safe space for employees to report harassment but also creates a transformative environment that reduces harassment in the first place. It promotes the well-being of every employee, ensuring that diverse experiences are recognized, respected, and supported throughout the process.

Clearly define sexual harassment with examples.

Include all forms: verbal, non-verbal, physical, digital.

Outline clear and supportive reporting procedures.

Address third-party and online/remote harassment.

2. Provide Regular, High-Quality Training

Mandatory for all staff and managers.

Focus on recognising harassment, active bystander actions, and cultural competence.

Tailor content for different roles and levels of responsibility.

3. Review and Embed Safeguarding Processes

Integrate into onboarding, grievance, disciplinary, and exit processes.

Include safeguarding for victims (e.g. protection from retaliation, access to support).

4. Monitor Workplace Culture

• Use staff surveys, feedback channels, and audits.

• Consider intersectionality: how race, gender, sexuality, disability, etc., affect experiences.

• Take action on toxic behaviour, microaggressions, and unsafe norms.

5. Demonstrate Action

• Maintain evidence of steps taken (e.g., policy updates, training logs, culture review reports).

• Show leadership buy-in—executives must actively champion respectful culture.