Anti-Harassment and Anti-Bullying Policy

1. Policy statement

1. The Company wishes to provide a stimulating and supportive working environment which will enable all employees to fulfil their personal potential. Such an environment cannot exist where any employee is subjected to bullying, harassment, intimidation, aggression, victimization or coercion.
2. The purpose of this policy is to ensure that all employees are treated with dignity and respect, free from harassment or other forms of bullying at work. It sets out examples of the type of conduct that may constitute harassment or bullying and our commitment to eliminating such conduct.
3. All employees are responsible for treating their colleagues with dignity and respect. For this policy to succeed, everyone should ensure that they take the time to read and understand it. Every employee should consider whether their words or conduct could be offensive to others. Even unintentional harassment or bullying is unacceptable.
4. Where harassment or bullying is shown to have taken place it will be dealt with under our Disciplinary Procedure as a form of misconduct. In some cases it may be treated as gross misconduct leading to summary dismissal of those responsible. It should also be borne in mind that an employee who harasses another person with intent is committing a criminal offence, and may (apart from internal disciplinary action) be prosecuted under applicable legislation. Additionally, the harasser may be personally liable for damages if the victim makes a complaint of sexual, racial or disability harassment to a tribunal or court.
5. This policy does not form part of any employee’s contract of employment and it may be amended at any time.

2. What the law requires

1. We have a duty in accordance with relevant legislation to provide our employees with a safe place and system of work. This includes a workplace free from harassment and bullying which may, in certain circumstances, also amount to unlawful discrimination.
2. We also recognize that harassment and victimization is unlawful and the Company is responsible for ensuring that employees are protected from unlawful harassment, bullying or discrimination in the course of their work on grounds of gender, sexual orientation, marital or civil partner status, gender reassignment, race, colour, nationality, ethnic or national origin, religion or belief, disability or age.
3. Individual employees may also in some cases be held legally liable for harassing their colleagues or third parties (including customers), and may be ordered to pay compensation by a court or employment tribunal.

3. Who is covered by the policy?

This policy covers all individuals working for us or at any of our premises irrespective of their status, level or grade. It therefore includes managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term employees, casual and agency staff (collectively referred to as “employees” in this policy).

4. Personnel responsible for implementation of the policy

1. Our Board of Directors has overall responsibility for the effective operation of this policy but has delegated day-to-day responsibility for overseeing its implementation to the CFO.
2. All managers have a specific responsibility to operate within the boundaries of this policy, ensure that all employees understand the standards of behaviour expected of them and to take action when behaviour falls below its requirements.
3. Employees should disclose any instances of harassment or bullying of which they become aware either to their line Manager or to the CFO.
4. Questions about this policy should be directed to the CFO.

5. What are harassment and bullying?

1. Harassment is any unwanted physical, verbal or non-verbal conduct which has the purpose or effect of violating the recipient’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them.
2. Harassment often (but not exclusively) targets the gender, sexual orientation, marital or civil partner status, pregnancy and maternity, gender reassignment, race, colour, nationality, ethnic or national origin, religion or belief, disability or age of the victim.
3. A single incident of unwanted or offensive behaviour to one individual can amount to harassment.
4. Examples of harassment include:
   1. unwanted physical conduct or “horseplay”. Such unwanted physical conduct may range from touching, pinching, pushing or brushing past someone or invading their personal space, to grabbing, shoving, punching and more serious forms of physical or sexual assault;
   2. unwelcome sexual behaviour, which the harasser may perceive as harmless flirting, and which may involve unwanted suggestions, advances, propositions or pressure for sexual activity;
   3. suggestions that sexual favours may further a career or that refusal of sexual favours may hinder it, or result in less favourable treatment;
   4. continued suggestions for social activity within or outside the workplace after it has been made clear that such suggestions are unwelcome;
   5. inappropriate or insulting behaviour whether in the form of offensive or intimidating comments or gestures or insensitive jokes or pranks;
   6. the sending or displaying of material that is pornographic or obscene or that some individuals or groups may find offensive (including e-mails, text messages, video clips and photographs taken or sent using mobile phones or via the internet);
   7. ignoring or shunning someone, for example, by deliberately excluding them from a conversation or a workplace social activity;
   8. spreading malicious rumours;
   9. inciting others to commit any of the above.
5. Bullying is offensive, intimidating, malicious or insulting behaviour which, through the abuse or misuse of power, makes the recipient feel vulnerable, upset, humiliated and threatened. Power includes both personal strength and the power to coerce others through fear or intimidation. Bullying is often a form of harassment and can undermine an individual’s self- confidence, competence and self-esteem. As with harassment, bullying can take the form of physical, verbal and non-verbal conduct. It can be persistent or an isolated incident, obvious or subtle, face-to-face or indirect.
6. Legitimate and constructive criticism of an employee’s performance or behaviour or reasonable requests made of employees in the course of their employment does not constitute bullying.
7. Examples of bullying may include:
   1. shouting at, being sarcastic towards, ridiculing or demeaning others;
   2. physical or psychological threats;
   3. calculated undermining of an employee’s competence, for example through a consistently unreasonable or unfair workload or overbearing supervision;
   4. inappropriate and/or derogatory remarks about someone’s performance;
   5. abuse of authority or power by those in positions of seniority;
   6. unjustifiably excluding colleagues from meetings or communications.
8. This policy covers harassment or bullying which occurs both in the workplace and in settings outside the workplace, such as business trips, events or social functions organised for or on our behalf and whether on or off our premises. The Company also operates a zero tolerance policy in relation to harassment of one of its employees by a third party, such as a customer or visitor.
9. Anyone who believes they are being subjected to harassment or that they are being bullied should not hesitate to use the procedures set out below.

6. Informal steps to resolve bullying or harassment

1. If you consider that you are being bullied or harassed, you should initially attempt to resolve the problem informally with the person responsible if you feel able, and explain clearly to them that their behaviour is not welcome or makes you uncomfortable. If this is too difficult or embarrassing to do on your own, you should seek support from your line Manager or the CFO. They will provide confidential advice and assistance to those who believe they have been bullied or harassed and will offer to assist in the resolution of any problems, whether through informal or formal means.
2. If you are in any doubt as to whether an incident or series of incidents which have occurred constitute bullying or harassment, then you should initially contact your line Manager or the CFO confidentially, on an informal basis. They will be able to advise you how your concerns should be dealt with.
3. If informal steps have not been successful or would not be appropriate, you should follow the formal procedure set out below.

7. Raising a formal complaint about bullying or harassment

1. 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 the CFO, whose role is to achieve a solution wherever possible and to respect the confidentiality of all concerned. If the matter concerns that person, you should refer it to the CEO.
2. Your written complaint should set out full details of the conduct in question, including the name of the harasser or bully, the nature of the harassment or bullying, the date(s) and time(s) at which it occurred, the names of any witnesses and any action that has been taken so far to attempt to stop it from occurring.
3. As a general principle, the decision to progress a complaint rests with you. However, we have a duty to protect all employees and may decide to pursue the matter independently if, in all the circumstances, it is considered appropriate to do so.

8. Formal investigations

1. Complaints will be investigated in a timely and confidential manner to establish full details of what happened. Your name and the name of the alleged harasser or bully will not be divulged other than on a “need to know” basis to those individuals involved in the investigation. We will appoint a manager with suitable experience and with no prior involvement in the complaint to investigate and we will set out a provisional timetable for the investigation, which will be communicated to all parties. The investigation will be thorough, impartial and objective, and will be carried out with sensitivity and with due respect for the rights of all parties concerned.
2. Consideration will be given to whether the alleged harasser or bully should be redeployed temporarily, or suspended on full pay or whether reporting lines or other managerial arrangements should be altered pending the outcome of the investigation.
3. At the outset of the investigation, the investigator will meet with you to hear your account of the events leading to your complaint. You have the right to be accompanied by a colleague of your choice. We will arrange further meetings with you as appropriate throughout the investigation and/or at its conclusion.
4. The investigator will also meet with the alleged harasser or bully who may also be accompanied by a colleague of their 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.
5. At the conclusion of the investigation, the investigator will submit a report to the senior Manager nominated by us to consider the complaint. The senior Manager will usually arrange a meeting with you to report the outcome within a week of the conclusion of the investigation. A copy of the investigator’s report together with the senior Manager’s findings will be provided to you and to the alleged harasser.
6. If the senior Manager finds that harassment or bullying has occurred, prompt action will be taken to stop the harassment or bullying immediately and prevent its recurrence. The findings will be dealt with under our Disciplinary Procedure. Consideration will be given to whether the harasser or bully should be dismissed and, if not, whether they should remain in their current post or be transferred.
7. Even where a complaint is not upheld, 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 party.
8. Any employee who is, after investigation, found to have deliberately provided false information or to have acted in bad faith may be subject to action under our Disciplinary Procedure.

9. Appeals

1. If the grievance has not been resolved to your satisfaction you may appeal in writing to the CFO stating your full grounds of appeal, within one week of the date on which the decision was sent or given to you.
2. We will hold an appeal meeting, normally within one week of receiving your written appeal. This will be dealt with impartially by a more senior Manager who has not previously been involved in the case (although they may ask anyone previously involved to be present), or by a Director. You have a right to bring a colleague to the meeting.
3. We will confirm our final decision in writing, usually within one week of the appeal hearing. This is the end of the procedure and there is no further appeal.

10. Protection for those making complaints or assisting with an investigation

1. Employees who make complaints or who participate in good faith in any investigation conducted under this policy will be protected from any form of intimidation or victimisation as a result of their involvement.
2. Any employee who considers that they have been subjected to any such intimidation or victimisation should seek support from the CFO. They may alternatively or additionally raise a complaint in writing under this procedure or our Grievance Procedure.

11. Confidentiality

1. Confidentiality is an important part of the procedures provided under this policy. Everyone involved in the operation of the policy, whether making a complaint or involved in any investigation, is responsible for observing the high level of confidentiality that is required.
2. Breach of confidentiality may give rise to disciplinary action under our Disciplinary Procedure.

12. Monitoring and review of this policy

1. This policy is reviewed periodically by the CFO. Recommendations for any amendments are reported to the board.
2. The CFO has responsibility for ensuring that any person who may be involved with investigations or administrative tasks carried out under this policy receive regular and appropriate training to assist them with these duties.
3. Employees are invited to comment on this policy and suggest ways in which it might be improved by contacting the CFO.

CSAHABP 10/2025