Operated by: Nudge Education Ltd · Version: Nov 2025 · Owner: HR / People
Sexual Harassment Policy November 2025 Review Date: November 2026
Introduction
We are committed to providing a workplace where everyone is treated with dignity and respect, and where sexual harassment is not tolerated under any circumstances. Sexual harassment is unlawful under the Equality Act 2010 and can take many forms, but whatever the form, it undermines a safe and supportive working environment.
We take all reasonable steps to prevent harassment and have clear procedures in place for reporting concerns. Staff who experience or witness harassment are encouraged to come forward so that issues can be addressed swiftly and fairly. The HR Lead has overall responsibility for this policy, supported by managers who operate an open door approach.
All staff share responsibility for upholding this policy, and breaches may result in disciplinary action, up to and including dismissal. This policy will be reviewed regularly to ensure it remains effective and reflects best practice. Scope
We deplore all forms of sexual harassment and seek to ensure that the working environment is safe and supportive to all those who work for us. This includes employees, workers, agency workers and contractors in all areas of our Organisation.
Definitions
Sexual harassment is unwanted conduct of a sexual nature that violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating, or offensive environment. It also includes treating someone unfairly because they submitted to, or refused, such conduct.
It may be carried out by colleagues, agents, or third parties, and can occur in person or online (e.g. social media, messaging apps). Even those not directly targeted can be affected.
Examples include:
-
sexual comments, jokes, or “banter”
-
displaying sexual images or materials
-
staring, leering, or suggestive looks
-
propositions, advances, or promises of favours
-
intrusive questions about sex life
-
sexual rumours or online posts
-
explicit messages (email, text, social media)
-
unwelcome touching, hugging, or kissing
Victimisation
Victimisation means treating someone unfairly because they have raised, or are thought to have raised, a concern under discrimination or harassment laws.
.Protected acts include:
-
making a complaint or claim under the Equality Act (e.g. discrimination or harassment)
-
supporting someone else’s claim by providing evidence or information
-
alleging that someone has breached the Equality Act
-
carrying out any other action connected to the Equality Act
Examples of victimisation include overlooking someone for promotion because they previously made a sexual harassment complaint, dismissing someone because they supported a colleague at a meeting about such a complaint, or excluding someone from work meetings because they acted as a witness in an employment tribunal claim.
This policy covers behaviour which occurs in the following situations:
This policy applies to behaviour that occurs in the workplace, outside normal working hours where it is work-related (such as business trips, working lunches, or social functions), and in situations involving individuals outside of work where the incident raises concerns about your suitability to carry out your role.
What to do if you are subject to sexual harassment or victimisation
We are committed to ensuring that there is no sexual harassment or victimisation in our workplace. Allegations of sexual harassment and victimisation will be treated as a disciplinary matter, although every situation will be considered on an individual basis and in accordance with the principles of our disciplinary policy.
Informal complaint
We understand complaints of sexual harassment or victimisation can be sensitive. If you feel able, you may first tell the harasser that their behaviour is unwelcome and must stop. If you’re not comfortable doing this, you can ask for support in writing the request.
In the first instance, you can speak to the HR team or your line manager. If you don’t feel able to do this, you may approach a trusted senior colleague who can escalate the matter on your behalf.
Formal complaint
If the informal approach fails or if the harassment is serious, you should report it to hr@nudgeeducation.co.uk or your line manager. Keep notes where possible (e.g. who was involved, what happened, dates/times, witnesses, and any steps you’ve taken).
On receipt of a complaint, we will separate you from the alleged harasser to allow an uninterrupted investigation. You’ll be invited to a meeting (normally within ten working days) and you may bring a colleague for support. A written outcome will normally follow within 14 working days.
You have the right to appeal within five working days of the outcome. A senior manager will review the case, and a final decision will be confirmed in writing.
We are committed to supporting you throughout, which may include mediation or other steps to manage working relationships. You will not be victimised for raising a complaint.
If you witness harassment
If safe, intervene or offer support to the person affected. Otherwise, encourage them to report it or raise it yourself by contacting a senior manager, emailing hr@nudgeeducation.co.uk, or using the online reporting system. Reports will be handled sensitively and promptly.
Contextual Consideration of Young People’s Behaviour
At Nudge Education, we work with children and young people who may have complex needs, including developmental, emotional, social, or psychological vulnerabilities. As part of their individual profiles, some young people may display sexualised behaviours which, while potentially inappropriate, are not always intended to cause harm or distress. These behaviours may stem from previous trauma, unmet needs, or difficulties in understanding social boundaries.
Where such behaviours are identified as part of a young person’s profile, they will be documented within their Pen Portrait and taken into account when planning and delivering support. This ensures our workforce is aware of and prepared for any such behaviours, and can respond appropriately, professionally, and in line with safeguarding principles.
This context does not excuse harmful or inappropriate behaviour, but it does support a trauma-informed, proportionate, and educational approach to managing it. Staff will receive guidance and support on how to safely respond, record, and report any incidents, including when a behaviour may also meet the threshold for sexual harassment. We remain committed to protecting our workforce from all forms of sexual harassment, including when it may arise from the children and young people we support, while also recognising the need for a compassionate, informed response to their individual circumstances.
Third-Party Sexual Harassment
Third-party sexual harassment occurs when a member of our workforce is sexually harassed by someone outside the organisation, such as service users, their friends or family, contractors, or delegates at events.
This behaviour is unlawful and will not be tolerated. Employers have a legal duty to take reasonable steps to prevent it, and Nudge Education is fully committed to doing so.
While the law does not allow individuals to bring standalone claims for third-party harassment, failure to act may lead to legal consequences under other claims.
Disciplinary action
Where an allegation of sexual harassment or victimisation is found to be substantiated, appropriate disciplinary action will be taken in line with Nudge Education’s disciplinary procedures. This may include formal warnings or, in serious cases, summary dismissal. Employees have the right to appeal any disciplinary outcome through the organisation’s disciplinary appeal process.
When determining the level of disciplinary action, relevant factors will be considered, including any aggravating circumstances such as abuse of a position of authority.
In cases where a complaint is found to be both untrue and made with malicious intent, this may also result in disciplinary action.
Training
We provide training to all our staff on sexual harassment to ensure there is a clear understanding of:
- what sexual harassment is, how it may occur and that it will not be tolerated
- expected levels of behaviour · how they can report any incidents of having been sexually harassed or having witnessed it
· how acts of harassment will be dealt with under the disciplinary procedure, which can potentially result in dismissal.
We ensure that all levels of management are trained on implementing this policy, including preventing and managing sexual harassment in the workplace and the procedure to follow if an allegation is reported.
We will regularly review the effectiveness of our training.
We provide refresher training as appropriate.
Employee Assistance Programme
We would like to remind you that further support is available by contacting our Employee Assistance Programme (EAP), More details of this service are available from peoplehub@nudgeeducation.co.uk
Document control
| Field | Value |
|---|---|
| Version | Nov 2025 |
| Owner | HR / People |
| Status | live |
| Source file | 2. HR and Employee Relations/Sexual Harassment Policy - Nov 2025.pdf |