Anti-Harassment and Bullying Policy

Anti-Harassment and Bullying Policy
1. Introduction
a. The company is committed to creating a harmonious working environment which is free
from harassment, including discrimination, victimisation and bullying, and which protects
the dignity of all employees irrespective of their gender, sexual orientation, marital or civil
partner status, age, racial or ethnic background, nationality, religion or belief, or disabled
status. Harassment is offensive and prejudicial to a productive working environment. It is
indicative of a lack of respect for the person harassed, undermines his or her position and
may have a negative impact upon health, job performance and sense of personal
security.
b. The company regards harassment, on any of the grounds listed above, as a most serious
matter. Such behaviour constitutes discrimination and is unlawful under the equality
legislation. Harassment may also be a civil offence and a criminal offence, and it may
contravene health and safety legislation. All staff should take the time to ensure they
understand what types of behaviour are unacceptable under this policy.
c. Everyone must comply with the policy and employees should ensure that their behaviour
at all times does not cause offence or constitute harassment. Formal complaints will be
investigated and in cases where the complaint is substantiated, appropriate disciplinary
action, including dismissal, will be taken against the person or persons responsible.
Harassers, their supervisors and their managers may all be held personally liable in the
event of any legal proceedings.
2. Definition of Harassment
a. Personal harassment takes many forms. It is unwanted conduct related to one of the
grounds set out above which has the purpose or effect of violating a person’s dignity or
creating an intimidating, hostile, degrading, or humiliating environment for him/her. It can
be an isolated act such as a wilful comment or gesture, or it can take the form of repeated
behaviour against a person.
b. A person may be harassed even if he/she is not the intended “target”. For example, a
person may be harassed by racist jokes about a different ethnic group.
c. Sexual harassment is unwanted conduct of a sexual nature which has the purpose or
effect of violating a person’s dignity or creating an intimidating, hostile, degrading, or
humiliating environment for him/her.
d. It is also harassment to treat a person less favourably because he/she has submitted to
or rejected previous unwanted conduct of a sexual nature (or conduct related to gender
reassignment or sex).
e. Appendix A at the end of this document outlines some examples of personal harassment.
Some, if occurring only once, may cause only mild irritation but if repeated become
harassing. Other examples are clearly harassment even if they occur only once. All of
them are inappropriate. The list is neither exclusive nor exhaustive and other forms of
behaviour may be regarded as harassment, discrimination, victimisation or bullying.
3. Definition of Bullying
a. Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of
power that can make a person feel vulnerable, upset, humiliated, undermined or
threatened. Power does not always mean being in a position of authority, but can include
both personal strength and power to coerce through fear or intimidation.
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. Examples of bullying and intimidation might be:
i. physical conduct ranging from the invasion of personal space to serious assault;
ii.
iii.
iv.
verbal, written and email harassment through derogatory remarks, jokes, insults,
offensive language, gossip and slander;
open aggression, threats and/or shouting;
deliberately setting objectives with unreasonable deadlines or changing
objectives unfairly;
v. intrusion by pestering, spying, following, stalking etc;
vi.
vii.
viii.
ix.
unfair allocation of work and responsibilities;
behaviour which makes direct or indirect reference to disability or impairment and
this causes discomfort, patronises, insults or offends people with a physical,
sensory or mental disability;
treating someone adversely because they have or it is suspected/believed that
they have HIV/AIDS;
repeated gibes in reference to personal traits or appearances, invasion of
privacy, or practical jokes causing physical or psychological distress;
x. persistent pressure to become involved in anti-social or unlawful behaviour;
xi.
repeated statements to an individual or third parties which demean an individual’s
professional status and performance.
4. Dealing with Harassment and Bullying
a. Anyone experiencing harassment should not wait until things become intolerable.
Sometimes the person may not realise that his or her behaviour is unwanted or
unacceptable and in such cases the misunderstandings can be resolved quickly.
b. It is helpful to make a note of the time, place and nature of any specific incidents and
attempts to discuss them. This will provide useful information in following these
procedures.
5. Informal Procedure
a. If possible, the individual experiencing harassment should state clearly to the person
concerned that his or her behaviour is unacceptable and should cease. In some
circumstances the individual might prefer to write a letter to the person concerned which
should be dated and signed, and a copy kept as this may be needed as evidence should
the harassment, victimisation or bullying continue or subsequently recur.
b. If the individual does not feel able to talk or write to the person concerned or if the
harassment does not stop, they may wish to discuss the matter with a colleague or with
their supervisor or manager and ask them to approach the person concerned on their
behalf.
6. Formal Procedure
a. At any time, whether or not informal steps have been taken, an employee who feels that
he or she or others have been harassed in a way that breaches this policy can raise the
matter with their supervisor or manager, either verbally or in writing, who will deal with it
accordingly. Thereafter, the matter will be dealt with as follows:
i. The appropriate manager will conduct an investigation into the case as soon as
possible to establish whether there is a need to take disciplinary action. The
manager will inform the person against whom the complaint is made of the nature
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ii.
iii.
iv.
of the complaint and that the matter is being investigated formally.
The appropriate manager will arrange a meeting with the employee who has
made the complaint, usually within one week, so that he/she can explain the
reasons for the complaint. The employee has the right to be accompanied by a
colleague or trade union representative of his/her choice, who must respect the
confidentiality of the investigation.
It may be necessary to interview witnesses to any of the incidents mentioned in
the complaint. If so, the importance of confidentiality will be emphasised to them.
If it is found that harassment or bullying has occurred, prompt action will be taken
to address it. Where the harasser or bully is an employee, the matter will be
dealt with as a case of possible misconduct/gross misconduct under the
company’s Disciplinary Procedure. Where the harasser or bully is a third party,
appropriate action will be taken.
v. If the complaint is not upheld, the manager will determine appropriate methods of
resolving the issue following discussion with both parties.
vi.
vii.
viii.
ix.
Both parties will be informed of the decision as soon as possible following the
conclusion of the investigation. The employee who has made the complaint may
not be provided with details of any disciplinary action taken against the individual
concerned, as this is confidential between the company and individual
employees.
Malicious allegations will be regarded as disciplinary offences.
If the employee is not satisfied with the outcome of the investigation, he/she has
the right to appeal the decision within one week of being notified of the outcome.
Written grounds of appeal should be submitted to the Directors, who may
nominate another manager to hear the appeal. Where practicable, this will be a
manager senior to the manager who originally considered the complaint.
x. The person hearing the appeal will meet the employee to discuss his/her appeal,
usually within one week. The employee may be accompanied by a colleague or
trade union official of his/her choice. The company will endeavour to notify the
employee of the outcome of the appeal within one week of the meeting.
xi.
This is the final stage of the formal procedure and there is no further right of
appeal.
7. Confidentiality
a. All complaints will be treated with due regard for confidentiality.
b. Information about a complaint by or about an employee may be placed on his/her HR file,
along with a record of the outcome and any notes or other documents compiled during
the process.
c. Breach of confidentiality may give rise to disciplinary action under the Disciplinary
Procedure.
8. Protection for those Making Complaints or Assisting with an Investigation
a. If an employee makes a complaint, or participates in good faith in any investigation
conducted under this policy, he/she will be protected from any form of intimidation or
victimisation as a result of his/her involvement.
b. If an employee consider that he/she has been subjected to any such intimidation or
victimisation, he/she should seek support from the Managing Director. He/she may also
raise a complaint in writing under this procedure or the Grievance Procedure.
Society Ltd & Society US Inc – Staff Handbook (Last updated on Wednesday, 23 September 2020) Page 17