Preventing sexual harassment policy

Everyone should be able to work without sexual harassment. We do not tolerate it, from anyone, and we take every report seriously.

This policy explains what sexual harassment is, how to report it, what happens after you report, and what we do to prevent it. Our code of conduct covers other harassment and bullying, including harassment related to age, disability, gender reassignment, race, religion or belief, sex or sexual orientation.

Who and where this policy covers

• Everyone who works for us: employees, workers, agency workers, contractors, interns and volunteers.
• Harassment by anyone you deal with through work: colleagues, managers, customers, clients, suppliers, visitors and members of the public.
• At work and everywhere work takes you: work events, training, travel and work social events. It also covers email, messages, video calls and social media, and conduct outside work that affects someone at work.

What sexual harassment is

Sexual harassment is unwanted conduct of a sexual nature that violates someone's dignity, or creates an intimidating, hostile, degrading, humiliating or offensive environment for them. It can be sexual harassment even if the person did not mean it that way. It can be a single incident or something that keeps happening.

Examples include:

• sexual comments, jokes or innuendo;
• questions about someone's sex life, or remarks about their body or clothes;
• unwanted touching, hugging or kissing, or standing too close;
• staring or leering;
• sharing sexual images, videos or messages, including images made with AI;
• sexual assault, which is also a crime.

It is also harassment to treat someone worse because they rejected sexual conduct, or went along with it.

The law

Sexual harassment at work is unlawful under the Equality Act 2010. Since 26 October 2024, employers in England, Wales and Scotland have had a duty to take reasonable steps to prevent sexual harassment of their employees.

From 30 October 2026, employers must take all reasonable steps. From the same date, they must also not permit harassment of their employees by third parties, such as customers and clients.

Harassment by customers and other people outside the company

You do not have to put up with harassment from customers, clients, suppliers, visitors or anyone else you meet through work. Report it in the same way as harassment by a colleague, and we will act on it.

What we do depends on what happened. We may warn the person, refuse them service, ban them from our premises, end a contract or report a crime to the police. We tell customers and suppliers what behaviour we expect of them.

How to report

You can report sexual harassment that happens to you, or that you see happen to someone else. You do not have to raise it with the person first. You can tell:

• your manager, or another manager you trust;
• HR;
• any director.

You do not have to report to the person you are complaining about, or to anyone close to them. You can report in person, by phone, by email or in writing, and you do not need a form. A colleague or trade union representative can come with you or report for you.

There is no time limit for reporting to us. Time limits do apply to employment tribunal claims, and Acas can explain them.

What happens after you report

1. We contact you within 2 working days. We listen, explain your options and agree the next steps with you.
2. You choose how to deal with it: informally, for example by someone speaking to the person for you, or as a formal complaint under our grievance procedure. If a report is serious, we may need to investigate even if you would prefer an informal approach. We will talk to you first.
3. Someone with no involvement in the matter investigates. You can bring a colleague or trade union representative to formal meetings, and we keep you updated.
4. We tell you the outcome in writing and explain how to appeal.

If we find that harassment happened, we act. This may include disciplinary action, up to and including dismissal. Abusing power over a more junior colleague makes it more serious.

Support for you

• You can get confidential support whether or not you make a report. HR can tell you what is available, such as counselling.
• While we deal with a report, we can make changes to keep you safe, such as to shifts, seating or who you report to. We will not change your work to your disadvantage because you reported.
• You can also get free, confidential advice from the Acas helpline or the Equality Advisory and Support Service.
• If you have been assaulted, you can report it to the police. We will support you if you do.

No victimisation

You will not be treated badly for reporting sexual harassment, for supporting someone who reports it, or for giving information in an investigation. Treating someone badly for any of these is victimisation. It is unlawful, and we treat it as misconduct.

You will not face disciplinary action because a report is not upheld. Only a report found to be both false and made in bad faith may lead to disciplinary action.

Since 6 April 2026, reporting sexual harassment can also count as whistleblowing, which the law protects.

Confidentiality

We keep reports as confidential as we can, and share details only with the people who need them to deal with the report or to support you. We may need to tell the person you reported, so that they can respond. We may also need to act to keep people safe, or share information when the law requires it. Where we can, we will talk to you before we share details of your report.

We do not use confidentiality agreements to stop anyone from whistleblowing or reporting a crime.

What we do to prevent it

• We assess the risk of sexual harassment in our work, including from customers and other third parties, and act to reduce it. We review these risks at least once a year and after any report.
• Everyone receives this policy when they join, and we remind everyone of it every year.
• Everyone completes training on sexual harassment when they join and every year after. It covers what sexual harassment is, how to report it and what to do if you see it. Managers and the people who handle reports get extra training.
• We check whether this policy is working, using reports and feedback from staff, and update it when the law or official guidance changes.

Find out more

• Acas: What sexual harassment is
• Acas: Harassment law changes from 30 October 2026
• GOV.UK: Employment Rights Act timeline
• legislation.gov.uk: Equality Act 2010, section 26, harassment
• legislation.gov.uk: Equality Act 2010, section 40A, employer duty to prevent sexual harassment of employees
• GOV.UK: Whistleblowing for employees
• Acas: Contact us, including the Acas helpline
• Equality Advisory and Support Service

Confirming you have read this policy

We review this policy every year, and sooner if the law, official guidance or a report shows it needs to change. Ask HR if anything in it is unclear, then confirm below that you have read it.