Introduction

This policy applies to Employees of Umbrella Company UK (“the Company”) including managers, officers, directors, staff, consultants, contractors, trainees, homeworkers, part time and fixed term employees.

All employees have a role in being aware of, preventing and dealing with sexual harassment. This policy details the expectations of all employees and how the Company will work to protect employees from sexual harassment.

What is Sexual Harassment?

Sexual harassment is unwanted behaviour of a sexual nature. It is covered under the Equality Act 2010 and the Worker Protection (Amendment of Equality Act 2010) Act 2023.

The legislation protects the following people from sexual harassment at work:

  • employees and workers
  • contractors and self-employed people hired to personally do the work
  • job applicants

in order to be considered sexual harassment, the unwanted behaviour must have either:

  • violated someone’s dignity
  • created an intimidating, hostile, degrading, humiliating or offensive environment for someone

The behaviour can be considered sexual harassment if the following applies:

  • it has one of these effects even if it was not intended
  • it intended to have one of these effects even if it did not have that effect

Sexual harassment can be a one off incident or an ongoing pattern of behaviour.

It doesn’t have to take place in person, it can also occur in other ways such as online through communication methods including email, social media or messaging tools.

Someone cannot be treated less favourably because they have either submitted a complaint of sexual harassment or have rejected such behaviour.

Anyone can be a victim of sexual harassment, regardless of their sex, sexual orientation or gender identity. Sexual harassment can also occur between people of the same sex.

Examples of Sexual Harassment

There are no specific examples of Sexual Harassment in the legislation but harassing behaviour could include but is not limited to:

  • making sexual remarks about someone’s body, clothing or appearance
  • asking questions about someone’s sex life
  • telling sexually offensive jokes or stories
  • insults based on the sex of the employee
  • making sexual comments or jokes about someone’s sexual orientation or gender reassignment
  • displaying or sharing pornographic or sexual images, or other sexual content
  • unwelcome physical contact, such as pinching, stroking or hugging
  • inappropriate touching
  • the use of job related threats or rewards to solicit sexual favours
  • sexual assault or rape

Sexual Harassment is usually directed at an individual, but it’s not always the case. Sometimes there can be a culture of behaviour that’s not specifically aimed at one person – such as sharing sexual images. Someone could still make a complaint of sexual harassment in this situation.

Sexual Harassment is different to harassment related to a person’s protected characteristic, for example sex, sexual orientation or gender reassignment. Someone could experience both types of harassment at the same time, or separately.

All employees are responsible for maintaining appropriate behaviour in the workplace. This includes:

  • taking personal responsibility to raise concerns about any sexual harassment in the workplace, whether experienced personally or witnessed
  • contributing to a respectful and productive working environment
  • being willing to help and support colleagues
  • treating any allegations or complaints of sexual harassment with appropriate confidentiality
  • ensuring that a person is not victimised for making or being involved in a complaint of sexual harassment

This policy will apply to any unwanted conduct that occurs in the course of an employee’s work and which takes place while at any location for work purposes, including working from home, related social events, business trips or external meetings.

Reporting Incidents of Sexual Harassment

Any employee who feels they have experienced sexual harassment of any kind should raise the matter as soon as reasonably practicable.

Employees can raise a complaint informally and/or formally.

They should email UCUK-HR@umbrellacompanyuk.co.uk with the details.

Any reports that are made will be treated seriously and fully investigated.

Any employee who feels that they have been subjected to Sexual Harassment may at any time decide to deal with the issue through formal procedures, regardless of whether informal steps have been taken or not.

The Company will investigate any informal or formal complaint thoroughly and fairly.

Employees who make a complaint about Sexual Harassment will be protected against any form of retaliation.