Policy Statement

  1. The Company is committed to promoted equality, diversity and inclusion, by which we mean:
    1.1 equality: providing equal opportunities and fairness for all employees, workers and job
    applicants, and eliminating unlawful discrimination;
    1.2 diversity: recognising, respecting and valuing the differences in our people’s protected
    characteristics, backgrounds, skills and experience and encouraging gender diversity, age
    diversity, ethnic diversity, diverse physical ability and neurodiversity in our workforce;
    1.3 inclusion: ensuring a workplace culture that is fair and safe for all staff, that values our
    differences and enables each person to be themselves, achieve their potential and thrive
    at work.
  2. The Company has a zero-tolerance policy on harassment of any individual because of any
    relevant ‘protected characteristic’ recognised by current legislation, namely:
    2.1 age;
    2.2 disability;
    2.3 gender reassignment;
    2.4 race;
    2.5 religion or belief;
    2.6 sex; or
    2.7 sexual orientation.
    Introduction
  3. The Policy Statement above sets out the Company’s commitment to ensuring that all staff and job
    applicants have equal opportunities and are not unlawfully harassed. The remainder of this
    document sets out the Company’s code of conduct on unlawful harassment in the workplace and
    what constitutes unlawful harassment.
  4. This code of conduct applies to any person who may enter the business for any reason, who is
    not an employee or worker of the Company. This includes but is not limited to patients, clients or
    suppliers of the Company.
    Harassment related to a protected characteristic
  5. This type of harassment arises when a worker is subject to unwanted conduct that is related to a
    protected characteristic and has the purpose or effect of:
    5.1 violating the worker’s dignity, or
    5.2 creating an intimidating, hostile, degrading, humiliating or offensive environment for that
    worker.
  6. Unwanted conduct covers a wide range of behaviour. It can include:
    6.1 spoken words;
    6.2 banter;

6.3 written words;
6.4 posts or contact on social media;
6.5 imagery;
6.6 graffiti;
6.7 physical gestures;
6.8 facial expressions;
6.9 mimicry;
6.10 jokes or pranks;
6.11 acts affecting a person’s surroundings;
6.12 aggression; and
6.13 physical behaviour towards a person or their property.

  1. Unwanted conduct ‘related to’ a protected characteristic has a broad meaning. The conduct does
    not have to be because of the protected characteristic. It can include the following situations:
    7.1 where conduct is related to the worker’s own protected characteristic; and
    7.2 when there is any connection with a protected characteristic.
    Sexual harassment
  2. Sexual harassment occurs when a worker is subjected to unwanted conducted and which is of a
    sexual nature. The conduct need not be sexually motivated, only sexual in nature.
  3. Conduct ‘of a sexual nature’ includes a wide range of behaviour, such as:
    9.1 sexual comments or jokes;
    9.2 displaying sexually graphic pictures, posters or photos;
    9.3 suggestive looks, staring or leering;
    9.4 propositions and sexual advances;
    9.5 making promises in return for sexual favours;
    9.6 sexual gestures;
    9.7 intrusive questions about a person’s private or sex life or a person discussing their own
    sex life;
    9.8 sexual posts or contact on social media;
    9.9 spreading sexual rumours about a person;
    9.10 sending sexually explicit emails or text messages; and
    9.11 unwelcome touching, hugging, massaging or kissing.
    Meaning of ‘purpose or effect’
  4. If the harasser’s purpose is to violate the worker’s dignity or to create an intimidating, hostile,
    degrading, humiliating or offensive environment for them, this will constitute harassment.
  5. Unwanted conduct will also amount to harassment if it has the effect of violating the worker’s
    dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for
    them, even if that was not the intended purpose.
    Meaning of violation of dignity or creation of an intimidating, hostile, degrading, humiliating or
    offensive environment
  6. The unwanted conduct must have had the purpose or effect of violating the worker’s dignity, or
    creating a hostile, degrading, humiliating or offensive environment for them. It is not necessary to
    show both.
  7. An environment may be created by a single act of unwanted conduct.
    Breaches if this code of conduct
  8. The Company will not tolerate behaviour that goes against the terms, spirit and/or aims of this
    code of conduct.
  9. Breaches of this code of conduct may result in the termination of the Company’s relationship with
    any of its patients, suppliers, clients or any other third party.

Review

  1. The Company will regularly monitor the effectiveness of this code of conduct to ensure that it is
    working in practice and the aims are being met. The Company reserves the right to update this
    code of conduct at any time.

Back To Top