Skip to content STRAT7 is committed to developing, maintaining and supporting a culture of equality in employment in which staff are treated equitably and with respect and can work in an environment where they can realise their potential whatever their age, race, colour, nationality, ethnic origin, creed, disability, sexual orientation, sex, gender identity, marital or civil partnership status, parental status, religion, belief or non-belief, social or economic class, employment status, or any other criteria that cannot be shown to be properly justifiable.
We also believe that the working environment should always be supportive of the dignity and respect of individuals. STRAT7 is committed to creating a work environment free of harassment and bullying, where everyone is treated with dignity and respect.
Some harassment is unlawful discrimination and serious harassment may be a criminal offence.
Our staff members for the purposes of this Policy will include our employees, consultants, contractors, and temporary personnel. You are required to comply with this Policy at all times. This Policy does not form part of your contract of employment and we reserve the right to change this Policy at any time.
This policy covers discrimination, bullying and harassment of and by managers, employees, contractors, agency staff and anyone else engaged to work at the organisation, whether by direct contract with the organisation or otherwise.
The policy covers discrimination, bullying and harassment in the workplace and in any work-related setting outside the workplace, e.g. business trips and work-related social events.
It is unlawful, under the Equality Act 2010, to discriminate directly or indirectly in recruitment or employment because of age, disability, sex, gender reassignment, pregnancy, maternity, race (which includes colour, nationality and ethnic or national origins), sexual orientation, religion or belief, or because someone is married or in a civil partnership. These are known as “protected characteristics”.
Discrimination after employment may also be unlawful, e.g. refusing to give a reference for a reason related to one of the protected characteristics.
It is generally unlawful to discriminate directly or indirectly, harass or victimise a member of the public based on any of the protected characteristics in the provision of services or goods. It is unlawful to fail to make reasonable adjustments to overcome barriers to using services caused by disability. The duty to make reasonable adjustments includes the removal, adaptation or alteration of physical features, if the physical features make it impossible or unreasonably difficult for disabled people to make use of services.
STRAT7 will not tolerate direct or indirect discrimination against any person on grounds of age, race, colour, nationality, ethnic origin, creed, disability, sexual orientation, sex, gender identity, marital or civil partnership status, parental status, religion, belief or non-belief, social or economic class, whether in the field of recruitment, terms and conditions of employment, career progression, training, transfer or dismissal.
It is the responsibility of all staff in their daily actions, decisions and behaviour to endeavour to promote these concepts, to comply with all relevant legislation and to ensure that they do not discriminate against colleagues, customers, suppliers or any other person associated with the Company.
Our commitment to eradicating modern slavery is emphasised in our employee training and company policies, which promote ethical behaviours. Our employees are required to abide by our codes and ethics which are set out in our Company Handbook. This includes the expectation that employees will familiarise themselves with the Modern Slavery Act Statement, remain alert to potential violations, and report instances swiftly and appropriately. The Company Handbook brings together all our policies stated above, is regularly reviewed and published internally. All staff are directed to it upon commencing employment at STRAT7.
Additionally, Modern slavery awareness training is now a required new starter training module at STRAT7, and our HR Department ensures all new staff complete the training by tracking progress via our online training portal. By Autumn 2024 this will also be one of our required annual refresher training modules too.
STRAT7 is committed to creating a work environment free of harassment and bullying, where everyone is treated with dignity and respect.
Harassment and bullying can have very serious consequences for individuals and STRAT7.
Harassment or bullying may make people unhappy, may cause them stress and affect their health and family and social relationships, may affect their work performance and could cause them to leave their job. Severe cases of harassment and bullying can even lead to mental illness and suicide. Effects on STRAT7 can include loss of morale, poor work performance, increased turnover of staff, legal claims and damage to the organisation’s reputation.
Employees found guilty of harassment or bullying may face disciplinary penalties, up to and including dismissal, could be personally liable to pay compensation in legal claims, and may find their own family and social relationships are adversely affected. Serious harassment may be a criminal offence.
STRAT7 will not tolerate bullying and harassment of any kind. All allegations of bullying and harassment will be investigated and, if appropriate, disciplinary action will be taken. We will also not tolerate victimisation of a person for making allegations of bullying or harassment in good faith or supporting someone to make such a complaint. Victimisation is a disciplinary offence.
Bullying is offensive, intimidating, malicious or insulting behaviour, and/or an abuse or misuse of power that is meant to undermine, humiliate or injure the person on the receiving end.
Harassment is unwanted conduct related to relevant protected characteristics, which are sex, gender reassignment, race (which includes colour, nationality and ethnic or national origins), disability, sexual orientation, religion or belief and age, that:
Conduct may be harassment whether or not the person behaving in that way intends to offend. Something intended as a “joke” may offend another person. Different people find different things acceptable. Everyone has the right to decide what behaviour is acceptable to him/her and to have his/her feelings respected by others. Behaviour which any reasonable person would realise would be likely to offend will be harassment without the recipient having to make it clear in advance that behaviour of that type is not acceptable to him/her, eg sexual touching.
It may not be so clear in advance that some other forms of behaviour would be unwelcome to, or could offend, a particular person, eg certain “banter”, flirting or asking someone for a private drink after work. In these cases, first-time conduct which unintentionally causes offence will not be harassment, but it will become harassment if the conduct continues after the recipient has made it clear, by words or conduct, that such behaviour is unacceptable to him/her.
Harassment may also occur where a person engages in unwanted conduct towards another because he/she perceives that the recipient has a protected characteristic (for example, a perception that he/she is gay or disabled), when the recipient does not, in fact, have that protected characteristic. For example, it would be harassment for an individual to tease repeatedly an individual because of an incorrect belief that the recipient is deaf. Similarly, harassment could take place where an individual is bullied or harassed because of another person with whom the individual is connected or associated, for example if his/her child is disabled, wife is pregnant, or friend is a devout Christian.
There may also be circumstances in which an individual is subjected to unwanted conduct from a third party, such as a client or customer. For example, it might be that a client makes a series of racist remarks to a black employee. If an employee feels that he/she has been bullied or harassed by customers, suppliers, vendors or visitors, he/she should report any such behaviour to their manager who will take appropriate action. Bullying or harassment of customers, suppliers, vendors or visitors or others will be dealt with through STRAT7 disciplinary procedure.
A single incident can be harassment if it is sufficiently serious.
You may be able to sort out matters informally. The person may not know that his/her behaviour is unwelcome or upsetting. An informal discussion may help him/her to understand the effects of his/her behaviour and agree to change it. You may feel able to approach the person yourself, or with the help of someone in human resources, a manager or another employee.
Alternatively, an initial approach could be made on your behalf by one of these people. You should tell the person what behaviour you find offensive and unwelcome and say that you would like it to stop immediately. You should keep a note of the date and what was said and done. This will be useful evidence if the unacceptable behaviour continues and you wish to make a formal complaint.
If an informal approach does not resolve matters, or you think the situation is too serious to be dealt with informally, you can make a formal complaint by using STRAT7 grievance procedure. In the case of grievances about bullying or harassment, the normal grievance procedure is modified so that you can choose whether to raise your grievance with your manager or directly with the HR department.
All complaints will be investigated promptly and, if appropriate, disciplinary proceedings will be brought against the alleged harasser. You will have the right to be accompanied by a work colleague of your choice at any meeting dealing with your grievance. You will be kept informed of the general progress of the process of investigation and the outcome of any disciplinary proceedings. At the hearing it will be decided on a balance of probabilities, after considering all available evidence, whether or not harassment or bullying has occurred.
STRAT7 will treat complaints of bullying and harassment sensitively and maintain confidentiality to the maximum extent possible. Investigation of allegations will normally require limited disclosure on a “need to know” basis. For example, your identity and the nature of the allegations must be revealed to the person you are complaining about, so he/she is able to respond to the allegations. Some details may also have to be given to potential witnesses but the importance of confidentiality will be emphasised to them. If the complaint is upheld, and a person who has been found to have harassed you is kept in STRAT7 employment, managers may need to be given some information where this is necessary for them to manage the risk of further harassment by that person against you or others.
In a serious case, the alleged harasser may be suspended while investigation and any disciplinary proceedings are underway.
If your complaint is upheld, and the person found to have bullied or harassed you remains in STRAT7 employment, every effort will be made to ensure that, if possible, you do not have to continue to work alongside the harasser, if you do not wish to do so. We will discuss the options with you.
If your complaint is not upheld, the HR department will support you, the alleged harasser and your manager(s) in making arrangements for you both to continue or resume working and to help repair working relationships. STRAT7 will consider making arrangements to avoid you and the alleged harasser having to continue to work alongside each other, if either of you do not wish to do this.
You have a right not to be victimised for making a complaint in good faith, even if the complaint is not upheld. However, making a complaint that you know to be untrue may lead to disciplinary action being taken against you.
If someone approaches you informally about your behaviour, do not dismiss the complaint out of hand because you were only joking or think the complainant is being too sensitive. Remember that different people find different things acceptable and everyone has the right to decide what behaviour is acceptable to him/her and to have his/her feelings respected by others. You may have offended someone without intending to. If that is the case, the person concerned may be content with an explanation and an apology from you and an assurance that you will be careful in future not to behave in a way that you now know may cause offence. Provided that you do not repeat the behaviour that has caused offence, that may well be the end of the matter.
If a formal complaint is made about your behaviour, this will be fully investigated and STRAT7 may bring disciplinary proceedings, if appropriate. STRAT7 will follow its disciplinary procedure and you will have the rights set out in that procedure. You will have the right to be informed of the allegations against you and to put your side of the story and to be accompanied to meetings by a work colleague of your choice. The procedure will be implemented at the appropriate stage for the seriousness of the allegation. Complaints of bullying and harassment will often be allegations of gross misconduct that, if proved, could lead to dismissal without notice.
STRAT7 will treat complaints of bullying and harassment sensitively and maintain confidentiality to the maximum extent possible. Investigation of allegations and future management of risk, if complaints are upheld, will normally require limited disclosure on a “need to know” basis. For example, some details may have to be given to potential witnesses but the importance of confidentiality will be emphasised to them.
If the allegation is of gross misconduct, you may be suspended on full pay during the investigation and, if a disciplinary hearing is to be called, until disciplinary proceedings have been concluded.
If the complaint against you is upheld, on a balance of probabilities, a disciplinary penalty may be imposed up to and including dismissal, having regard to the seriousness of the offence and all relevant circumstances. If the complaint is upheld, but you are not dismissed, STRAT7 could decide to transfer you to another post.
If a complaint is made against you that is not upheld and STRAT7 has good grounds for believing that the complaint was not made in good faith, the organisation will take disciplinary action against the person making the false complaint.
You must not victimise a person who has made a complaint in good faith against you or anyone who has supported him/her in making the complaint or given evidence in relation to such a complaint. Disciplinary action will be taken against you if STRAT7 has good reason to think that you may have victimised the complainant or someone else.
If the complaint against you is not upheld, the HR department will support you, the complainant and your manager(s) in making arrangements for you both to continue or resume working and to help repair working relationships. STRAT7 will consider making arrangements to avoid you and the complainant having to continue to work alongside each other, if either of you do not wish to do this and there is a suitable alternative role available.
Some types of bullying or harassment may constitute unlawful discrimination and allegations may give rise to the possibility of other civil claims or criminal proceedings against you, which would proceed independently of STRAT7 disciplinary proceedings.
We all have a responsibility to help create and maintain a work environment free of bullying and harassment. You can help to do this by:
Managers have a particular responsibility to:
If you fail to comply with this Policy, this may result in disciplinary action being taken against you which could result in the termination of your employment with us or other legal action (including us notifying the appropriate authorities of any unlawful activities you are carrying out).
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