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Scope
1.1 This policy applies to all employees, including those who work part-time, or on fixed term contracts. It covers conduct:
• At work, in any capacity
• Whilst at any RW Armstrong office or construction sites
• Whilst using any of RW Armstrong’s IT systems
• In any non-working situation, including outside office hours work events (e.g. Christmas party) where a person is identifiable as an employee of RW Armstrong or its subsidiaries
1.2 This policy covers actions:
• Committed by an employee of RW Armstrong (and its subsidiaries), during the course of their employment
• Experienced by any employee of RW Armstrong (and its subsidiaries) during the course of their employment
• Committed in person and/or online
2. Aims
2.1 RW Armstrong is committed to creating a safe, constructive working environment in which all employees are treated with dignity and respect and we aim to create a culture of equality and respect between all employees. Therefore, sexual harassment in the workplace will not be tolerated.
2.2 This policy sets out:
• What we mean by sexual harassment
• How employees can report sexual harassment
• How the company will handle reports of sexual harassment
• The actions the company will take against an employee who breaches this policy
• How the company will support those who experience sexual harassment
3. Roles and Responsibilities
3.1 Senior Leadership Team (SLT) and Human Resources
SLT and HR have overall responsibility for this policy and will make sure:
• This policy is included in the Company Induction
• This policy is regularly reviewed and shared with employees
• It is known that the Company has a zero tolerance approach to sexual harassment
• Employees receive relevant training
3.2 Line Managers
Line Managers will:
• Support and encourage employees to report instances of sexual harassment
• Foster a safe working environment
• Understand how to handle reports of sexual harassment
• Provide employees with confidential support and sign post to relevant support
3.3 Employees
All employees are responsible for:
• Taking responsibility for their own behaviour
• Behaving in line with the Company’s values
• Respecting and supporting their peers
• Reporting any sexual harassment they witness or experience
4. What is sexual harassment?
4.1 Sexual harassment is unwanted conduct of a sexual nature that has the purpose or effect of:
• Violating someone’s dignity, and/or
• Creating an intimidating, hostile, degrading, humiliating or offensive environment for that person
Sexual harassment is unlawful under the Equality Act 2010
4.2 Examples of unwanted conduct of a sexual nature, could include, but are not limited to:
• Sexual comments or jokes
• Sexist jokes
• Displaying or sharing sexually graphic pictures
• Suggestive looks, staring or leering
• Propositions and sexual advances
• Making promises in return for sexual favours
• Sexual gestures
• Intrusive questions about a person’s sex life or discussing your own sex life
• Sexual posts or contact on social media
• Spreading sexual rumours about someone
• Sending sexually explicit emails, texts or messages
• Unwelcome touching, hugging or kissing
• Demeaning language related to a persons sex or gender reassignment
• Criminal behaviour, including sexual assault, stalking, indecent exposure and offensive communications
5. Reporting instances of sexual harassment
5.1 Anyone experiencing or witnessing sexual harassment is encouraged to report and keep a record of the incident. Ideally this will include the date/time, details of what happened and details of any witnesses. Record keeping will help with investigations if the matter is formally reported.
5.2 Informal process
If you feel comfortable, you may wish to try to resolve the matter informally. This could be by:
• Arranging an informal, confidential, meeting with your line manager and ask for advice and support
• Speaking to the person responsible for the harassment for them to understand the effect of their actions
• Speaking to the person responsible for the harassment, in the presence of a manager, for them to understand the effect of their actions
5.3 Formal process
If the informal process does not achieve the required outcome, or you feel unable to try to resolve the matter informally, or if the incident is of a more serious nature, you can move to the next stage which is the formal process.
5.4 You should raise the issue as a formal written complaint, using the Grievance Procedure, to either a member of the Senior Leadership Team or the HR department. On receipt of a formal complaint, a confidential investigation will commence.
6. Investigation, record keeping and data protection
6.1 Investigating allegations
Where a confidential investigation into allegations is necessary, the Company will:
• Interview everyone involved
• Consider the circumstances surrounding the allegations
• Consider the reporting person’s feelings and perception of the conduct
• Establish if the conduct can be defined as sexual harassment
If the allegations are upheld, the Company will decide what action will be taken next. This could be disciplinary action, reporting to the Police, or an informal resolution.
Where appropriate, the victim (or reporter, if different) will be updated.
6.2 Record keeping and data protection
The Company will keep a record of all reports of sexual harassment.
The information regarding the complaint will be kept on the HR files of those involved, including the victim and the perpetrator.
Information on a reported act of sexual harassment will be kept confidential and only discussed and share with those who need to know and/or involved in the reporting of the incident.
In some cases it might be appropriate to report the incident to the Police. This would normally be done in consultation with the victim, but in some cases it may be necessary to do so even if the victim does not want the report to be made. A report to the Police would normally only take place where there was a hate crime, physical violence or sexual assault.
All information gathered, recorded and stored will comply with the Data Protection Act 2018 and the General Data Protection Regulation GDPR.
7. Breaches of policy
7.1 If an employee breaches this policy, and sufficient evidence is available, we will take action in accordance with the Disciplinary Policy.
7.2 Disciplinary action will also be taken if false allegations are made, or allegations made in bad faith where they are known to not be true.
8. Third-Party breaches
8.1
If an employee experiences sexual harassment from a third-party (e.g. contractor, supplier, etc), the Company will take appropriate steps, which could include, but are not limited to:
• Making sure that the victim does not come into contact with the perpetrator
• Ceasing to use the contractor, supplier etc
• Formally reporting the incident to the perpetrator’s manager/company
• Formally reporting the incident to the Police, where appropriate
9. Support
9.1 The Company is committed to making sure victims are supported through the reporting/investigation process.
9.2 Additional external support is available through the Company’s Employee Assistance Programme. Further details can be found on the Hub or from the HR Department.