Anti-bullying and Harassment

What is the policy about?

Harassment is unwanted conduct which violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment. It may be on the grounds of sex, marital status, race, disability, religion or beliefs, sexual orientation, age or gender reassignment. For the purposes of this Policy this list should be considered non-exhaustive, and harassment or bullying on any grounds will not be tolerated by the Company. Harassment may be persistent or an isolated incident, obvious or subtle, face-to-face or indirect.

KnowledgeBrief (KB) wishes to provide a stimulating and supportive working environment which will enable its staff to fulfil their personal potential and creativity. Such an environment cannot exist where any member of staff is subjected to harassment, intimidation, aggression or coercion.

Also, KB wishes to ensure an open, transparent and safe working environment where all KB people feel able to speak up. Hence KB is committed to listen to the important concerns of all KP people. In instances about important concerns or knowledge of wrongdoing “blowing the whistle” the escalation route is the same as for harassment or bullying outlined in this policy.

Why is it important?

KB is fully committed to the principles of equality and diversity in the workplace and regards harassment as a form of discrimination. As such KB will not tolerate any form of bullying or harassment. The legal and moral drivers for preventing bullying and harassment are clears. Yet, there are also very positive business benefits: our research into high-performing organisations and across the services we provide, is that a working environment providing psychological safety enhances business performances. We have learnt that advanced organisations actively design safe working environments, where people can thrive and contribute more and better to the organisational objectives.

What is harassment?

Examples of behaviour which may constitute harassment or bullying include (but are not limited to):

  • spreading malicious rumours; professional or social exclusion; insulting behaviour;
  • unwelcome sexual advances or physical contact; unfounded threats relating to job security;
  • calculated undermining of an employee’s competence, for example through a consistently unreasonable or unfair workload, overbearing supervision or unnecessary circulation of critical memoranda;
  • physical assault;
  • verbal abuse, threats, derogatory name-calling, ridicule, insults and offensive or embarrassing jokes;
  • offensive emails, texts or visual images;
  • derogatory graffiti/insignia or display of derogatory or offensive material; and inciting others to commit any of the above.

What is whistleblowing?

Whistleblowing is the term used when an employee passes on information concerning wrongdoing. The wrongdoing will typically (although not necessarily) be something they have witnessed at work. To be covered by whistleblowing law, an employee who blows the whistle must reasonably believe two things: (1) They are acting in the public interest. This means in particular that personal grievances and complaints are not usually covered by whistleblowing law. (2) An employee must reasonably believe that the disclosure tends to show past, present or likely future wrongdoing falling into one or more of the following categories:

  • criminal offences (this may include, for example, types of financial impropriety such as fraud);
  • failure to comply with an obligation set out in law;
  • miscarriages of justice;
  • endangering of someone’s health and safety;
  • covering up wrongdoing in the above categories.

KB Application

This policy applies to:

  • actual and prospective learners (‘learner’ is used as a common term to also denote client and customer where appropriate),
  • employees (individuals who work for the company either on a permanent, temporary, contractual or voluntary basis),
  • employers (individual or organisations who are in receipt of KnowledgeBrief services).

We will:

  1. Provide learning and working environments that respect difference and protects the diversity of those working within them.
  2. Raise individual awareness of the importance of preventing bullying and harassment.
  3. Consider recognised act of bullying and harassment as disciplinary offence and may constitute gross misconduct.
  4. Ensure that everyone can access clear and transparent procedures to log complaints and grievances.
  5. Demonstrate, through visible leadership at all levels of the organisation, that we welcome and encourage all KB people to make disclosures.

What do I need to do?

All KB people are expected to:

  1. Be responsible for their own behaviour and should ensure that they comply with this policy at all times.
  2. Any employee who feels that they have been subjected to harassment or bullying by any other member of staff, or a third party, or have an important concern, should raise the matter as soon as reasonably practicable.
  3. Inform their manager or Director Justin Gowen in the absence of that manager or where their complaint is against that specific manager.
  4. If the complaint is against directors, inform Head of Business & Performance Management, Katherine Raleigh. Any issues should be raised internally first.
  5. As a Manager, be responsible for implementing this Policy and bringing it to the attention of employees.
  6. As a Manager, take any complaint seriously and deal with it promptly, confidentially, fairly and consistently.

Complaints / Grievances

Informal Procedure

If the employee feels able, they should speak up at the time when they feel harassed or bullied. It is important to be direct and for the employee to state explicitly that they feel they are being harassed and that the behaviour is unacceptable to them. The employee can also discuss the matter with another colleague or their supervisor and ask them to speak to the harasser on their behalf. Where the informal procedure has not resolved an employee’s complaint, a formal grievance can be raised by the employee.

Formal Procedure

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

They could write a letter which clearly identifies the offending behaviour and requests that it stops immediately. The employee should sign and date any such letter and ensure that a copy is kept for any possible future formal complaint. It is also advisable that the employee keep an ‘incident diary’ of any offending behaviour. Where employees are not happy with the outcome of the formal grievance procedure they can appeal this decision internally.

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

Consequences of Breach

Harassment is a disciplinary offence and will be dealt with according to the Company’s Disciplinary Procedures. Bullying, harassment, victimisation or discrimination may constitute gross misconduct, punishable by summary dismissal without notice.

Employees should bear in mind that harassment or bullying may also constitute a criminal offence punishable by a fine and/or imprisonment.

Customer outcomes

Third Party Harassment

Third party harassment refers to harassment of an employee by any person who is not an employee of the Company. Third party harassers may include:

  • customers or clients of the Company,
  • suppliers of the Company,
  • independent contractors.

Any employee who believes that they have been the victim of third party harassment should immediately inform their immediate line manager of the incident.

Where an employee has been harassed on more than one occasion, the Company will take such steps as are reasonably practicable to prevent any recurrence.

For the purposes of third party harassment, it is immaterial whether the third party harasser is a different person in each instance of harassment.

Induction and Anti-Bullying and Anti-Harassment Training

All individuals will receive an induction into their learning/employment and working environment. We will make everyone aware of our commitment to prevent bullying and harassment, and how to make us aware of any dissatisfaction or concern.

Learning and Working Environment

We are committed to creating open and conducive learning and working environments where everyone has the right to feel safe from bullying and harassment. We will ensure all individuals have clear routes to report incidents and/or concerns and for these to be managed fairly and fully.


Links, References & Further Reading

Equality Act 2010
Acas (Advisory, Conciliation and Arbitration Service)
Department for Business Innovation & Skills: Whistleblowing; Guidance for Employers and Code of Practice

Whistleblowing law is located in the Employment Rights Act 1996 (as amended by the Public Interest Disclosure Act 1998). It provides the right for a worker to take a case to an employment tribunal if they have been victimised at work or they have lost their job because they have ‘blown the whistle’.

Anti-bullying and Harrassment Policy, 27/02/2018, v1.3