Anti-Harassment and Bullying Policy


  1. Application: This policy applies to the Company’s employees and to Contractors.

Purpose of policy

  1. Purpose: The purpose of this policy is to ensure that all employees and Contractors of the Company are treated with dignity and respect and are free from harassment, intimidation or other forms of bullying at work.
  2. Breach: Any breach of this policy may lead to termination of your employment or engagement with the Company, and in the case of employees, will be dealt with under our disciplinary and dismissal procedure.

Legal framework and personnel

  1. The Company’s commitment: The Company has a duty to provide members of staff with a safe place and system of work. This includes a workplace free from harassment, intimidation and bullying. We also have responsibilities not to harass or discriminate against members of staff on the grounds of their sex, pregnancy, sexual orientation, marital or civil partnership status, gender reassignment, race, religion, colour, nationality, ethnic or national origin, disability or age. In some situations, we may also be responsible for the actions of our employees towards each other and towards third parties. In certain circumstances harassment can amount to unlawful discrimination. This policy serves to demonstrate our commitment to identifying and wherever possible eliminating such unlawful behaviour.
  2. Overall responsibility: has overall responsibility for this policy. Responsibility for monitoring and reviewing the operation of the policy and any recommendations for change to the policy also lies with the Margery Bone.
  3. Line Managers: Line Managers and heads of department have a specific responsibility to operate within the boundaries of this policy and to facilitate its operation by ensuring that staff understand the standards of behaviour expected of them and by identifying and acting upon behaviour that falls below these standards.
  4. Staff responsibility: All members of staff are responsible for treating their colleagues with dignity and should ensure that they take the time to read this policy and understand it. Staff members should disclose any instances of harassment or bullying of which they become aware to their Line Manager or head of department.

What are harassment and bullying?

  1. Definition of harassment: Harassment is any unwanted physical, verbal or non-verbal conduct which has the purpose or effect of, affecting a staff member’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment. Such conduct is commonly related to sex, pregnancy, sexual orientation, marital or civil partnership status, gender reassignment, race, religion, colour, nationality, ethnic or national origin, disability, or age.
  2. Instances: Harassment generally arises where a staff member has made it clear that they find certain behaviour unwelcome and that behaviour has continued unchanged. Harassment can also arise as a result of a single incident provided it is sufficiently serious. It is important to remember that, even though the conduct may only be unwanted or offensive to one individual, it can still amount to harassment. Staff members who believe they are being subjected to harassment should not hesitate
    to use the procedures set out below. All staff members should consider whether their actions could be offensive to others.
  3. Examples of harassment: Examples of harassment might include:
    • unwanted physical contact, ranging from touching or brushing against another staff member’s body to assault or coercing sexual relations;
    • unwelcome sexual advances, propositions or pressure for sexual activity;
    • continued suggestions for social activity within or outside the workplace after it has been made clear that such suggestions are unwelcome;
    • offensive or intimidating comments;
    • suggestions that sexual favours may further a staff member’s career or that refusal of sexual favours may hinder it;
    • the display of pictures, objects or written materials that may be considered pornographic or offensive to particular ethnic or religious groups;
    • conduct that denigrates or ridicules a staff member because of his or her sex, pregnancy, race, sexual orientation, disability, religion or age including abuse or insults about appearance or dress;
    • insensitive jokes or pranks; and
    • shunning a staff member, for example, by deliberately excluding him or her from conversation.The list is not exhaustive and other behaviour many constitute harassment.

    The list is not exhaustive and other behaviour many constitute harassment.

  4. Definition of bullying: Bullying means offensive, intimidating, malicious or insulting behaviour, an abuse or misuse of power intended to undermine, humiliate, denigrate or injure a staff member. Bullying does not include legitimate and constructive criticism of your performance or behaviour, an occasionally raised voice, or an argument. Examples of bullying include ridiculing or demeaning others, particularly junior colleagues, overbearing supervision and unjustifiably excluding colleagues from meetings/communications.
  5. Conduct outside the workplace: This policy covers harassment or bullying which occurs both in the workplace itself and in settings outside the workplace, such as business trips, events or social functions organised for or on behalf of the Company and on or off Company premises.
  6. Social Media: This policy covers any acts of harassment or bullying which occurs via any online media including, without limitation, any social media.

What to do if you have been bullied or harassed: informal procedure

  1. Stage 1: If you consider that you are being bullied or harassed, you should initially attempt to resolve the problem informally, explaining clearly to the person responsible that the behaviour in question is not welcome and that it offends you or makes you uncomfortable.
  2. Stage 2: If Stage 1 is too difficult or embarrassing for you to do on your own, you should seek support from your Line Manager/head of department and/or Margery Bone who will provide confidential
    advice and assistance to members of staff who have been bullied or harassed and will assist in the resolution of any problems, whether through formal or informal means. If the person concerned is your Line Manager or head of department, you should speak to the person at the next level of management.
  3. Stage 3: If the conduct continues or if it is not appropriate to resolve it informally, you should keep a record of any relevant incidents and follow the formal procedure set out below.
  4. Guidance: If you are in any doubt as to whether an incident or series of incidents which have occurred constitute bullying or harassment, then in the first instance you should approach your Line Manager/head of department and/or Margery Bone confidentially, on an informal basis. They will be able to advise you as to how the matter should be dealt with.

What to do if you have been bullied or harassed: formal procedure

  1. Formal procedure: The informal procedure may not be appropriate due to the nature of the harassment or bullying or because you do not feel able to talk directly to the person creating the problem. In these cases, or where the informal procedure has been unsuccessful, you should raise your complaint in writing with Margery Bone, whose role is to achieve a solution wherever possible and to respect the confidentiality of all concerned.
  2. Pursuing a complaint: As a general principle, the decision to progress a complaint rests with you. However, we have a duty to protect all staff members and we may pursue a complaint independently if we consider it is appropriate to do so in all the circumstances.
  3. Necessary details: If you wish to make a formal complaint, you should set out full details of the unwanted conduct in writing. These details should include the name of the harasser or bully, the nature of the harassment or bullying, the date(s) and time(s) when the harassment or bullying occurred, the names of any witnesses and any action taken so far to attempt to stop the harassment or bullying.

Formal procedure: investigation

  1. Conduct of investigation: Complaints will be managed in a timely and confidential manner via an independent investigation to establish the details of what happened. Your name and the name of the alleged harasser will not be divulged other than on a “need to know” basis to those individuals involved in the investigation. At the outset, Joanne Crowther will either investigate the complaint or will ask an individual with no prior involvement in the complaint to carry out an investigation. The investigation will be impartial and objective, and will be carried out with sensitivity and with due respect for the rights of all parties concerned.
  2. Arrangements during the investigation: Consideration will be given to whether the alleged harasser or bully should be redeployed temporarily, suspended on full pay or whether reporting lines should be altered pending the outcome of the investigation.
  3. Meeting: As part of the investigation, the person investigating the complaint will meet with you to hear your account of the events leading to your complaint. You may be accompanied by a colleague or a trade union official of your choice. The person investigating will also meet with the alleged harasser or bully who may also be accompanied by a colleague or trade union official of his/her choice. It may also be necessary to interview witnesses to any of the incidents mentioned in your complaint. Where it is necessary to interview witnesses, the importance of confidentiality will be emphasised to them.
  4. Conclusion: At the conclusion of the investigation, the person investigating will prepare a report. You and the alleged harasser will be provided with a copy of the report together with any findings. You will be informed of your rights of appeal.
  5. Disciplinary sanctions: If it is found that harassment or bullying has occurred, prompt action will be taken to stop the harassment or bullying immediately and prevent its recurrence. The findings (where appropriate) will be dealt with under the Company’s disciplinary procedure. Consideration will be given to whether the harasser or bully should have their engagement/employment terminated and, if not, whether he or she should remain in their current post or be transferred to another post. Even where a complaint is not upheld, (for example, where evidence is inconclusive), consideration will be given to how the ongoing working relationship between you and the alleged harasser or bully should be managed. This may involve, for example, arranging some form of mediation or counselling or a change in the duties or reporting lines of either person.

Formal procedure: appeal

  1. Appeal procedure: If you are not satisfied with the outcome of the investigation, you have the right to appeal the decision within five days of being notified of the outcome. If you need more time to appeal, you should notify the Company within the five day period. You should submit your full written grounds of appeal to the Company. Arrangements will then be made for your appeal to be heard by a member of senior management at an appeal meeting. You may be accompanied by a colleague or a trade union official of your choice. You will usually be notified of the outcome of the appeal within seven days of this meeting. This is the final stage of the formal procedure.


  1. Protection from victimisation: Staff members who, in good faith, make complaints under this policy will be protected from intimidation or victimisation in connection with their involvement. If you have been subjected to any such intimidation or victimisation you may raise a complaint in writing under this procedure or the grievance procedure. Staff members who, after investigation, are found to have given information falsely and in bad faith will however be subject to action under the disciplinary procedure (where appropriate).
  2. Confidentiality: Confidentiality is very important throughout all parts of this procedure. It is the responsibility of everyone involved in the procedure to respect the high level of confidentiality that is required. Breach of confidentiality may give rise to disciplinary action under our disciplinary procedure.

Monitoring and review of Policy

  1. Review: Margery Bone will be responsible for reviewing this policy from a legislative and operational
  2. Comments: Staff members are invited to comment on this policy and suggest ways in which it might be improved by contacting Margery Bone .