1. ABOUT THIS POLICY
1.1 H2O is committed to providing a working environment free from harassment and bullying
and ensuring all staff are treated, and treat others, with dignity and respect.
1.2 This policy covers harassment or bullying which occurs at work and out of the workplace,
such as on business trips or at work-related events or social functions. It covers bullying and
harassment by staff (but may also apply to Service Providers, contractors and agency workers)
and also by third parties such as customers, suppliers or visitors in working environments
controlled by H2O.
1.3 This policy does not form part of any employee’s or worker’s contract of employment or
engagement and we may amend it at any time.
2. WHAT IS HARASSMENT?
2.1 Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or
effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating
or offensive environment for them. A single incident can amount to harassment.
2.2 It also includes treating someone less favourably because they have submitted or refused to
submit to such behaviour in the past.
2.3 Unlawful harassment may involve conduct of a sexual nature (sexual harassment), or it may
be related to age, disability, gender reassignment, marital or civil partner status, pregnancy or
maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual
orientation. Harassment is unacceptable even if it does not fall within any of these categories.
2.4 Harassment may include, for example:
a) unwanted physical conduct or “horseplay”, including touching, pinching, pushing, and
grabbing;
b) unwelcome sexual advances or suggestive behaviour (which the harasser may perceive as
harmless);
c) offensive e-mails, text messages or social media content;
d) mocking, mimicking, or belittling a person’s disability.
2.5 A person may be harassed even if they were not the intended “target”. For example, a person
may be harassed by racist jokes about a different ethnic group if the jokes create an offensive
environment.
3. WHAT IS BULLYING
3.1 Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of
power that can make a person feel vulnerable, upset, humiliated, undermined or threatened.
Power does not always mean being in a position of authority, but can include both personal
strength and the power to coerce through fear or intimidation.
3.2 Bullying can take the form of physical, verbal, and non-verbal conduct. Bullying may include,
by way of example:
a) physical or psychological threats;
b) overbearing and intimidating levels of supervision;
c) inappropriate derogatory remarks about someone’s performance;
3.3 Legitimate, reasonable, and constructive criticism of a worker’s performance or behaviour, or
reasonable instructions given to workers in the course of their employment, will not amount to
bullying on their own.
4. IF YOU ARE BEING HARASSED OR BULLIED
4.1 If you are being harassed or bullied, consider whether you feel able to raise the problem
informally with the person responsible. You should explain clearly to them that their behaviour
is not welcome or makes you uncomfortable. If this is too difficult or embarrassing, you should
contact a representative of the H2O Management Team either in person, or by email to
compliance@h2ologistics.co.uk who will attempt to resolve the matter as appropriate. 4.2 We will
investigate complaints in a timely and confidential manner. The investigation will be conducted
by someone with appropriate experience and no prior involvement in the complaint, where
possible. Details of the investigation and the names of the person making the complaint and the
person accused must only be disclosed on a “need to know” basis. We will consider whether any
steps are necessary to manage any ongoing relationship between you and the person accused
during the investigation. 4.3 Once the investigation is complete, we will inform you of our
decision. If we consider you have been harassed or bullied by an employee the matter will be
dealt with under the Disciplinary Procedure as a case of possible misconduct or gross
misconduct. If the harasser or bully is a third party such as a customer or other visitor, we will
consider what action would be appropriate to deal with the problem. Whether or not your
complaint is upheld, we will consider how best to manage any ongoing working relationship
between you and the person concerned.
5. PROTECTION AND SUPPORT FOR THOSE INVOLVED
5.1 Any individual, whether an employee, contractor or service provider who makes a complaint
or who participates in good faith in any investigation must not suffer any form of retaliation or
victimisation as a result. Any individual found to have retaliated against or victimised someone
in this way will be considered in breach of this policy and subject to the provisions of clause 7.
6. RECORD-KEEPING
6.1 Information about a complaint by or about an employee may be placed on the employee’s
personnel file, along with a record of the outcome and of any notes or other documents compiled
during the process. These will be processed in accordance with our Privacy Standard.
7. BREACHES OF THIS POLICY
7.1 We take a strict approach to breaches of this policy, which will be dealt with either:
a) in accordance with our Disciplinary Procedure for employees; or
b) by terminating any contract in place with service providers or suppliers.
Serious cases of employees bullying or harassing any other person, may amount to gross
misconduct resulting in dismissal. 7.2 If you believe that you have suffered discrimination: 7.2.1
Employees can raise the matter through their line manager subject to our Grievance Procedure;
or 7.2.2 Any other Service Provider, Consultant, visitor or other affected third party can raise the
matter in writing to compliance@h2ologistics.co.uk. All complaints will be treated in confidence
and investigated as appropriate. 7.3 You must not be victimised or retaliated against for
complaining about bullying or harassment. However, making a false allegation deliberately and
in bad faith will be treated as misconduct and dealt with as appropriate.