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Policy date: 29/10/26

Introduction

We believe that a diverse, equitable and inclusive culture is central to everything that we strive to achieve and to the organisational environment we want to create and protect.

As part of our commitment to providing a working environment in which everyone is treated with dignity and respect, we are required by law to take all reasonable steps to prevent sexual harassment of our workers, including by third parties.

This policy sets out the standards of behaviour we expect, how concerns can be raised and investigated, and the support available to anyone affected by sexual harassment.

This policy should be read alongside our:

  • • Dignity at Work policy (which covers discrimination, harassment, victimisation and bullying more broadly); and
  • • Equality and Diversity policy, which sets out our wider approach to equality, diversity and inclusion.

This policy does not form part of your contract of employment and we reserve the right to amend or withdraw it at any time.

Scope

This policy applies to anyone working for us. This includes employees, workers, contractors, volunteers, interns and apprentices. It also applies to job applicants.

The policy applies to conduct:

  • in the workplace;
  • at work-related events;
  • during work-related travel;
  • online or through digital communication; and
  • in any other circumstances where an individual is working, representing us or otherwise connected to work.

This policy also applies to sexual harassment by third parties, such as customers, clients, suppliers and contractors.

Our commitment to you

We are committed to taking proactive measures to prevent sexual harassment of our workers by:

  • ensuring all new starters attend training on sexual harassment, as part of their onboarding programme;
  • requiring all employees to attend regular training on sexual harassment on at least an annual basis;
  • monitoring our workplace culture through, exit interviews, one-to-one conversations, return-to-work meetings and review meetings to identify and address any issues;
  • undertaking risk assessments to determine all reasonable measures that can be implemented to minimise the risk of exposure to sexual harassment in the workplace, including by third parties;
  • implementing appropriate measures to reduce identified risks, taking into account factors such as, lone working, customer-facing roles, social events, and the use of alcohol; and
  • ensuring that our zero-tolerance approach to sexual harassment is communicated clearly to all workers and third parties.

We recognise our legal obligations in relation to sexual harassment, including our duty to take all reasonable steps to prevent it (the preventative duty). The measures set out in this policy are designed to help us meet this obligation and will be kept under regular review.

We want everyone who works with us to be treated with dignity and respect. Consistent with this commitment, we take a zero-tolerance approach to sexual harassment.

What we expect from you

We expect you, and everyone working for us, to take personal responsibility for observing, upholding, promoting and applying this policy. This applies to everyone, regardless of your role.

You should treat colleagues, clients and other third parties with dignity and respect at all times. You must not engage in behaviour that could reasonably be perceived as unwanted, inappropriate or offensive, or that creates an intimidating, hostile, degrading, humiliating or offensive environment. All interactions with colleagues, clients and other third parties must be free from sexual harassment, discrimination, harassment, victimisation or bullying. (For more information on discrimination and victimisation, please refer to our Dignity at Work and Equality and diversity policies.

If any individual is found to have committed, authorised or condoned an act of sexual harassment, we will take action against them (for those to whom it applies) under our Disciplinary procedure, up to and including dismissal.

There is no justifiable reason to sexually harass someone else. Even if you do not intend to sexually harass someone, this does not make your behaviour acceptable as it is the impact on the recipient that matters.

You should be aware that you can be personally liable for sexual harassment.

If you experience sexual harassment, we encourage you to speak up without delay and to ask for appropriate support (see What to do if you experience sexual harassment).

If you witness sexual harassment, we also encourage you to raise concerns or support others in doing so, even if you are unsure whether it meets the legal definition. We will take all concerns seriously.

Meaning of sexual harassment

The law defines sexual harassment as:

  • conduct of a sexual nature that has the purpose or effect of:
    • violating someone’s dignity; or
    • creating an intimidating, hostile, degrading, humiliating or offensive environment; and
  • less favourable treatment related to sex or gender reassignment (or transitioning) that occurs because of a rejection of, or submission to, sexual conduct.

A single incident can amount to sexual harassment.

Examples of sexual harassment

Sexual harassment can occur in many forms, and can take place at work, outside work, in person, or online. While this is not an exhaustive list, examples include:

  • physical conduct of a sexual nature, unwelcome physical contact or intimidation;
  • persistent suggestions to meet up socially after a person has made clear that they do not welcome such suggestions;
  • showing or sending offensive or pornographic material by any means (e.g. by text, video clip, email or by posting on the internet or social media);
  • unwelcome sexual advances, propositions, suggestive remarks, or gender-related insults;
  • offensive comments about appearance or dress, innuendo or lewd comments;
  • leering, whistling or making sexually suggestive gestures;
  • intrusive questions about a person’s private or sex life;
  • spreading sexual rumours about a person;
  • sexual posts, messages or contact on social media; and
  • gossip and speculation about someone’s sexual orientation or transgender status, including spreading malicious rumours.

Some behaviour (for example, a microaggression of a sexual nature) may also amount to sexual harassment. See our Anti-harassment and anti-bullying policy for further examples.

What to do if you experience sexual harassment

Informal route

Harasser is a colleague

If you feel able to, you may decide to raise the issue with the individual themselves, to make clear that their behaviour is not welcome and ask them to stop.

Alternatively, if you do not feel able to speak directly to the individual, you may consider asking your line manager, a colleague, or HR for support.

You may or may not want them to speak to the individual on your behalf and, where possible, we will respect your wishes. However, if the welfare or safety of you or others is at risk, or where the allegations are particularly serious, we may have to approach the individual and initiate a formal investigation. In such a case we will, where possible, discuss this with you first.

Harasser is a third party

Sexual harassment by third parties, such as customers, clients, suppliers and/or contractors, will not be tolerated.

If you are experiencing sexual harassment by a third party, we encourage you to report this to your line manager or the HR department without delay so that they can advise and support you on the best course of action.

Formal route

If you are not happy with the outcome of an informal process, or if you feel it is not appropriate to approach the issue informally, you may decide to raise it formally.

To make a formal complaint, you should discuss this first with your line manager. If your complaint is about your line manager, you should raise this with the Managing Director of either House of Fisher or T A Fisher. If for any reason you are unable to approach your line manager or a more senior manager, you can speak to the HR department.

You can raise a formal complaint of sexual harassment under our Grievance procedure if it applies to you. However, you may prefer to do so under this policy because it is specifically aimed at dealing with such issues. You should be aware that you cannot raise a complaint under this policy if you have raised a complaint about the same issue already under the Grievance procedure.

We understand that it may take time for an individual to feel able to raise a concern. Concerns will be taken seriously, regardless of when they are brought to our attention.

Under the formal procedure within this policy, we will usually:

  • ask you to set out your complaint in writing and include as much detail as possible, such as the alleged harasser’s name, the nature of the sexual harassment, the dates of the alleged conduct, names of any witnesses, and details of any action taken to address the matter so far;
  • hold a meeting with the alleged harasser to ascertain their response to the allegations;
  • carry out further investigations where necessary, including interviewing potential witnesses who we will instruct to keep the matter confidential;
  • invite you to a meeting to discuss your complaint in full, where you will have the right to be accompanied by a colleague or trade union representative;
  • hold a further meeting with you where necessary to enable us to ask you additional questions in light of any information we have gathered from the alleged harasser and/or witnesses;
  • consider all the evidence in full and make a decision; and
  • inform you of our decision and, if we uphold the complaint, take appropriate action, which may include disciplinary action up to and including dismissal (or other appropriate action for non-employees).

We will investigate every formal complaint as fully, promptly and objectively as possible, while ensuring that we respect your rights as well as those of the alleged harasser. We will ensure that the investigation is conducted impartially and, where possible, by individuals who have not been involved in the matter.

We will keep you informed, where appropriate, of the progress of the investigation and the outcome, in line with our data protection obligations. Where appropriate, we will also explain any steps taken to address the matter and help prevent similar behaviour from occurring again.

Where the conduct may amount to a criminal offence, we will discuss with you whether you wish to report the matter to the police and support you if you choose to do so.

Where the alleged harasser is a third party, we may need to adjust the procedure under this policy to ensure we conduct an appropriate investigation. We will discuss this with you where this is the case.

Anonymous route

You can also report concerns anonymously via HRAdmin@tafisher.co.uk without giving your name or contact details. We encourage you to report concerns in a way that feels most comfortable for you.

You may still be asked to provide details about the concern (such as what happened, when and where), but you do not need to disclose your identity if you do not wish to.

Although we will investigate any anonymous report as far as possible, this may limit our ability to follow up with you or gather further information.

Appeals

If you are not satisfied with the outcome of the formal investigation, you have the right to appeal. Should you wish to appeal, you should write to your line manager setting out the aspects of the decision you are unhappy with and why. Appeals should be submitted without unreasonable delay and usually no longer than five working days after we inform you of the decision.

The line manager or more senior manager will arrange a meeting with you to discuss your appeal in full and to try and reach a satisfactory solution. You must take all reasonable steps to attend this meeting and you may be accompanied by a colleague or trade union representative.

The HR manager will write to you to confirm the outcome of the appeal, which will be final.

Support for those affected or involved

We understand that anyone affected by, or involved in, a complaint of sexual harassment may feel anxious or upset, and we will do what we can to support you.

We will take appropriate steps during any investigation to minimise the risk of further sexual harassment or victimisation, including, where appropriate, making temporary changes to working arrangements. If you feel unable to continue working in close contact with the individual concerned, we will give careful consideration to any requested changes. We will also take measures to protect witnesses from harassment or victimisation.

Anyone who raises a concern or takes part in good faith in an investigation must not suffer any form of detrimental treatment or victimisation. If you believe this has occurred, you should inform your line manager or the HR department as soon as possible.

Regardless of the outcome of your complaint, we will consider carefully how to manage any ongoing working relationship between you and the individual concerned, including any third party. For example, depending on the specific circumstances, we may consider amending duties, location or reporting lines, or using workplace mediation or counselling where appropriate.

Sensitivity and confidentiality

Anyone involved in an informal or formal complaint of sexual harassment, including witnesses, must keep the matter strictly confidential and act with appropriate sensitivity to all parties.

Information must be shared only where necessary to investigate and address the matter.

If you are found to have breached confidentiality or acted without due care or sensitivity in a case of sexual harassment we may take disciplinary action against you up to and including dismissal (or other appropriate action for non-employees).

Consequences of breaching this policy

If, following a formal investigation, we find that you have committed, authorised or condoned sexual harassment, we will treat this as a possible case of misconduct or gross misconduct.

We may take disciplinary action against you, up to and including dismissal (or other appropriate action for non-employees). You should be aware that any aggravating factors, such as abuse of power over a more junior colleague, will be taken into account in deciding what disciplinary action to take.

We take sexual harassment by third parties as seriously as harassment by colleagues. Where the individual responsible is a third party, such as a customer, client or supplier, we will take appropriate steps to address the situation and prevent it from happening again. This may include warning the individual about their behaviour, refusing or withdrawing services, removing them from our premises, restricting future contact, or reporting the matter to the police where appropriate, and taking any other reasonable steps necessary to protect our workers.

Anyone who complains or takes part in good faith in a sexual harassment investigation must not suffer any form of detrimental treatment or victimisation. If we find that you have victimised anyone in this way, we will take disciplinary action, up to and including dismissal (or other appropriate action for non-employees).

If you are an employee, please refer to our Disciplinary procedure for further information.

Record-keeping

We may keep appropriate records of concerns and complaints (including informal concerns) to help us respond to issues effectively, identify trends and improve our approach, in line with our data protection obligations.

Any inappropriate access or disclosure of personal data should be reported immediately in accordance with our data protection policy. This may also constitute a disciplinary offence.

Data protection

When implementing this policy, we will process any personal data collected in accordance with our data protection policy. In particular, we will record only the personal information required and keep the information only for as long as necessary.

Monitoring and review

This policy is reviewed in line with any legal updates and, if necessary, amended to ensure that it remains effective.

We may use anonymised information from complaints (including informal concerns, where possible) to help us identify trends or patterns, assess the effectiveness of this policy, and determine any further steps needed to prevent sexual harassment and improve our approach.

We may also assess the effectiveness of this policy through:

  • employee surveys and feedback;
  • exit interviews; and
  • other relevant data.

We may carry out lessons-learned reviews following complaints to improve our approach and prevent similar issues arising in the future.

We recognise that the number of formal complaints may not reflect the true level of sexual harassment in the workplace and will take this into account when evaluating the effectiveness of this policy.