Document control
- Version: 2.0
- Responsible: Sharon Noble
- Approver: Board of Trustees
- Approved date: November 2024
- Next review date: November 2024
1. Purpose
1.1. The Royal Academy of Engineering (the Academy) is committed to creating an inclusive and welcoming work environment which is free from harassment and bullying and where everyone can achieve their potential. The Academy will not tolerate any form of bullying or harassment under any circumstances. All employees and including any other individuals engaging in Academy activity should feel empowered to share their concerns if their experience falls below this standard.
1.2. The Academy aims to ensure that all employees and other individuals engaging in Academy activity work in an environment that respects their personal rights and dignity, and which is free from unacceptable behaviour and conduct. The Academy holds a duty of care to protect all employees and individuals within the workplace and during other work-related settings including business trips and social events.
1.3. The Academy makes it a priority to support any individual if they are experiencing bullying, harassment or sexual harassment1 from anyone connected with Academy or its activities. The Academy wants everyone to feel confident that their complaint against any other individual will be taken seriously and action will be taken as quickly as possible. The Academy encourages any individual experiencing bullying or harassment to report their experience so that an investigation can take place without delay and available support can be offered and implemented.
1.4. Bullying or harassment by a employee or Fellows is considered to be a disciplinary offence. Incidents will be investigated, as per this policy, and if proven, action will be taken in accordance with the Academy’s Disciplinary Policy and Procedure for employees (Disciplinary Policy and Procedure) and Fellows' Code of Conduct (Fellows' Code of Conduct).
2. Who does the policy apply to?
2.1. The Academy has a duty of care to protect all individuals who are engaged in activities in the name of the Academy. The policy applies to all employees at the Academy, and extends to workers, secondees, interns, Fellows, grant holders, awardees and other people who are acting on behalf of the Academy or participating in Academy activities or events. It also includes job applicants, contractors or other third parties working in, or on behalf of, the Academy. Fellows will adhere to the Fellows' Code of Conduct which expects the same standards.
2.2. The policy extends to all Academy activities (whether in person or virtual), whether during working hours or outside of normal working hours, on or off the premises, UK or international, or delivered directly by the Academy or via third party suppliers. The policy does not apply to third party events and their guests held at Prince Philip House. However, the policy will apply if employees are bullied or harassed by a guest of the third party.
3. What are bullying and harassment?
3.1. Bullying and harassment can occur in many different forms. For example, face-to- face, behind someone's back, by telephone, texts, social media, or any other form of communication.
4. Bullying
4.1. There is no statutory definition of bullying. However, ACAS, the Advisory, Conciliation and Arbitration Service, defines it as an offensive, malicious or insulting behaviour. Bullying is behaviour from a person or group that is unwanted and makes the victim feel uncomfortable.
4.2. It is an abuse or misuse of power through means intended to undermine, humiliate, denigrate or injure an individual. Bullying tactics can include hostile verbal or nonverbal communication, sabotage, exclusion, manipulation, and psychological or physical abuse. Intimidating behaviour can also be considered as bullying.
4.3. Examples of bullying include:
- Competent employees being constantly criticised, having responsibilities removed or being given trivial tasks to do.
- Shouting at an employee.
- Persistently undermining an individual in front of others or in private.
- Blocking promotion.
- Regularly and deliberately ignoring or excluding individuals from work activities.
- Cyber bullying – abuse through email or social media platforms.
- Setting a person up to fail by overloading them with work or setting impossible deadlines
- Consistently attacking an employee in terms of their professional or personal standing.
- Persistently displaying offensive, intimidating or malicious behaviour towards an individual and/or teams.
- Someone at the same or more junior level regularly overruling an employee’s authority.
4.4. This is not an exhaustive list. However, it should be noted that there are many actions that do not amount to bullying, such as:
- Fair and reasonable criticism of performance or behaviour.
- Constructive feedback.
- Not being invited to meetings where not required.
- Being placed on a performance capability procedure or not passing probation, where performance is not of an appropriate standard.
5. Harassment
5.1. Harassment is defined under the Equality Act 2010 as unwanted conduct related to an individual’s protected characteristics that has the purpose or effect of violating the claimant's dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for them.
5.2. The protected characteristics are:
- Age.
- Sex.
- Gender reassignment.
- Religion or belief.
- Disability.
- Sexual orientation.
- Race.
- Pregnancy and maternity.
- Marriage or civil partnership.
5.3. Harassment at work. Examples of harassment include:
- Verbal, which includes crude language, open hostility, offensive jokes, suggestive remarks, innuendoes, rude or vulgar comments, malicious gossip and offensive songs.
- Non-verbal, which includes wolf-whistles, obscene gestures, sexually suggestive posters/calendars, pornographic material (both paper-based and generated on a computer, including offensive screensavers), graffiti, offensive letters, offensive e-mails, text messages, offensive objects, offensive objects, flags and emblems.
- Physical, which includes unnecessary touching, patting, pinching or brushing against another employee’s body, intimidating behaviour, assault and physical coercion.
- Coercion, which includes pressure for sexual favours (e.g., to get a job or be promoted) and pressure to participate in political, religious or trade union groups.
- Isolation, which includes non-cooperation and unreasonable exclusion from meetings or exclusion from social activities.
- Intrusion, which includes following, pestering, spying as examples.
5.4. Conduct can be considered harassment whether or not it is intended to offend. For instance, what they may consider a joke may be offensive to someone else. Everyone has the right to decide what behaviour is acceptable to them and to have their feelings respected by others.
6. Sexual harassment
6.1. Sexual Harassment, by its nature and recent changes to legislation, is covered in the Academy Sexual Harassment Policy .
6.2. This policy is dedicated to preventing sexual harassment in the workplace and supporting victims. It defines what constitutes sexual harassment, sets the Academy’s stance against such behaviour, and provides guidelines for reporting incidents. The policy emphasises a culture of respect, trust, and zero tolerance for sexual harassment.
7. Academy procedure for dealing with bullying and harassment
7.1. The Academy recognises the sensitive nature of bullying and harassment. The Academy wants all individuals to feel confident that their complaint against any other individual will be taken seriously and action will be taken as quickly as possible.
7.2. Where possible and appropriate, the Academy encourages individuals to resolve concerns about bullying or harassment informally before taking the formal route. This can be done through the informal route as outlined below. If an individual (or group) experiences any form of bullying or harassment or is witness to such, they should not presume that management are aware and should raise concerns with any of the representatives listed under stage 1 below. Assuming others do not have knowledge, this will ensure that nothing is overlooked as many incidents will not be visible to those not impacted.
7.3. Stage 1 (Taking advice and guidance).
7.3.1. Employees who believe they are being bullied or harassed may wish to discuss their situation before deciding what action to take. The Academy understands that a complaint may be against a Line Manager, Head, Associate Director, Director or any other individual, and therefore employees can discuss any workplace issues with any of the following representatives:
- Member of the People Team.
- Senior Leadership Team (Associate Directors and Directors).
- Appointed Academy Trustees or Fellows ([email protected] or [email protected]).
- Authorised Trade Union representative.
7.3.2. Confidentiality, when taking advice, will be maintained as far as possible. However, the Academy has an overall legal duty of care to ensure the safety of all employees and other individuals who may be adversely affected by the alleged harasser’s/ bully’s behaviour. The Academy therefore reserves the right to investigate a situation if the circumstances are serious enough, even if the employee or individual does not wish to take the complaint further.
7.4. Stage 2 (Resolving problems through an informal route).
7.4.1. Everyone working for the Academy can use the informal process to resolve their bullying or harassment concerns. This can be done with the support of other colleagues, Line Managers, the People Team, a member of the SLT or with an authorised Trade Union representative (if the matter appears more serious given the nature of the allegation or impact, then the formal route should normally be considered in consultation with the People Team).
7.4.2. The Academy advises individuals to try to resolve their complaints as early as possible, to reduce their stress and worry and possibly with the other person involved. It is important to remember that the other person may be unaware of their behaviour and the impact it has on the person receiving such behaviour. Informal feedback from the person alleging harassment will give the alleged harasser a better understanding and opportunity to change or stop their behaviour.
7.4.3. In the first instance, it is best for the person alleging harassment to speak to the alleged harasser to explain the situation and how it has made them feel. It can be helpful to describe the day, place, meeting or event that took place, so the other person is clear about their concerns. This opportunity should be used to ask the person to change or stop their behaviour. A member from the People Team or other representatives listed in this policy can be used to do this, if the person alleging harassment feels unable to speak to the alleged harasser themselves.
7.4.4. The informal stage will not result in any formal internal investigation or disciplinary action but is intended to enable both parties to resolve the matter in a timely and satisfactory manner. All parties will be supported throughout this process.
7.5. Stage 3 (Mediation).
7.5.1. An independent third person or mediator can sometimes help resolve harassment or bullying issues. Mediation is a voluntary process where the mediator helps two (or more) people in dispute to find a solution to the issue that they can both agree to. Mediation is voluntary and all parties need to be willing to participate. The mediator is impartial and does not take sides, tell or advise those in dispute what to do.
7.5.2. Depending upon the nature of the allegations, mediation can be a good way of dealing with bullying, discrimination or harassment situations. Advice on mediation should be sought from the People Team.
7.5.3. Counselling and mental health support is available through the employee assistance programme details of which can be found on our Wellbeing page.
7.6. Stage 4 (Formal Stage for employees).
7.6.1. Many concerns can be dealt with through the various stages listed in this policy before moving to the formal stage. Where informal resolution is not appropriate or where the outcome has been unsatisfactory, employees may raise the matter formally using the Academy’s Grievance Policy and Procedure (Grievance Policy & Procedure). The grievance process will be undertaken swiftly and confidentially while ensuring individual rights are upheld and protecting the identities of the person alleging harassment and the alleged harasser or bully.
7.6.2. The People Team will act on serious matters raised with all parties concerned and agree on the appropriate course of action. This will be conducted confidentially and whilst ensuring rights and protecting the identities of the person alleging harassment and the alleged harasser or bully.
7.7. Stage 4 (Formal Stage for non-employees).
7.7.1. Some complaints may involve non-employees of either the person alleging harassment or alleged harasser or bully. For employees experiencing bullying or harassment, they should report the matter immediately to their Line Manager (who can seek support or guidance from the People Team). Alternatively, reports of bullying and harassment can be submitted in an email to [email protected] which will be picked up by the People Team.
7.7.2. Where the alleged harasser or bully is an employee or Fellow, but the person alleging harassment is not, the alleged behaviours will be investigated as below. Following the outcome of the investigation, the investigating manager and the People Team will decide whether it is necessary to address the matter more formally in accordance with the Academy’s Disciplinary Policy and Procedure for employees (Disciplinary Policy and Procedure) or the Code of Conduct for Fellows (Fellows' Code of Conduct).
7.7.3. Where the person alleging harassment is an employee, but the alleged harasser or bully is not, the Academy will act in accordance with this policy. Sanctions will depend on the relationship of the individual to the Academy. The response may involve such measures as exclusion from future Academy activities. In other cases, termination of contracts and/or removal from the list of accepted suppliers may be appropriate.
7.7.4. The failure of a Line Manager (or other) to inform the People Team of a complaint by an employee concerning a third party may also be grounds for a grievance using the Academy’s Grievance Policy and Procedures (Grievance Policy & Procedure). Some complaints will not involve employees or Fellows as either the person alleging harassment or alleged harasser or bully. For instance, there may be incidents involving two participants at an Academy event, witnessed by or reported to employees. The appropriate sanction will be applied (such as barring from future events) where a complaint is upheld following investigation.
7.7.5. Bullying and harassment are already covered by our grant conditions as instances of misconduct that should be notified to the Academy as funder. The Academy will be adding extra conditions to underline our expectations of grant receiving organisations (or individuals) around bullying and harassment and to highlight routes for failures to live up to these expectations to be reported to the Academy. Confirmed offences will be sufficient grounds to terminate awards, and failure to suitably investigate alleged offences may lead to an organisation’s eligibility being suspended.
7.8. Stage 5 (Investigations).
7.8.1. The People Team will appoint someone (from a different team or directorate and ideally agreed by both parties) unconnected with the allegations to investigate them in an independent and objective manner (guidance and support will be provided to the nominated investigator from the People Team). Investigations will be carried out in accordance with confidentiality rules with sensitivity and with due respect for the rights of both the person alleging harassment and the alleged harasser. Everyone involved in the investigation, including witnesses, will be informed that the interview is confidential and that they must not discuss the complaint with colleagues or friends. Breach of confidentiality will result in disciplinary action or other sanctions if the individual is external to the Academy.
7.8.2. The investigation will focus on the facts of the complaint. Notes and meeting minutes will be kept of all stages of the investigation and those interviewed will receive notes of the interview to agree. Parties will not be required to repeat distressing or sensitive details any more than is necessary. Consideration will be given to ensuring that the person alleging harassment and the alleged harasser are not required to work together whilst the complaint is under investigation.
7.8.3. The Academy will take all reasonable steps to ensure that every employee and witnesses involved in the process will not be ridiculed or victimised. Victimisation is illegal under the Equality Act 2010 and no employee will be victimised for making, or assisting a colleague in making a complaint, even if it is not upheld, as long as it is made in good faith. All parties will be supported throughout this process.
7.8.4. The Academy aims to resolve matters as quickly and thoroughly as possible and will not normally take more than one month. Where circumstances dictate that more time may be required to resolve the matter, all parties will be promptly informed as appropriate.
7.8.5. Where appropriate, consideration may be given for a short period of absence (on full pay) or time away from the workplace if an employee needs to recover from any aftereffects resulting from bullying or harassment. The People Team must be consulted about this in the first instance.
8. Examples of possible outcomes
8.1. Where a grievance is upheld, the Academy will consider the views of the person alleging harassment when deciding what appropriate action should be taken. This may involve:
- Moving the harasser to another position (if a suitable position is available).
- Moving the person alleging harassment to a different place or post should they wish (the Academy will not require the person alleging harassment to move if this is not acceptable to them).
- Offering the person alleging harassment counselling and reasonable time off to enable them to recover from the effect of the harassment.
8.2. Formal action taken using the Disciplinary Policy and Procedure(Disciplinary Policy and Procedure). All parties will be informed in writing of the outcome within ten working days (taking into account the need for confidentiality).
8.3. Thereafter, the matter will be dealt with as follows:
- The People Team will follow up in writing as soon as reasonably possible with details of the conclusion.
- Check in on the wellbeing of the person alleging harassment and any other participants involved while offering further support as appropriate.
8.4. The Academy will ensure that the person alleging harassment is not penalised whether directly or indirectly for bringing a complaint and the situation will be monitored to ensure that the harassment has stopped.
8.5. If a complaint is unfounded or not made in good faith, for example a malicious complaint, this will be treated as gross misconduct.
9. General guidance
9.1. No audio or video recordings of any kind can be made at any meetings either remotely or in the office, unless this is pre-agreed for the purpose of a workplace adjustment with clear guidance on use and disposal. Written notes can be made. Any breach of these rules may result in disciplinary action.
9.2. Risks of bullying and harassment should be considered and addressed in planning activities such as highlighting this policy.
10. Academy training and awareness
10.1. In addition to this policy, the Academy will ensure that there are appropriate and regular communication, training and awareness sessions organised by the People Team for employees to:
- Help prevent bullying and harassment occurring in the workplace and ensure employees understand their responsibilities and the Academy’s expectations.
- Understand how to seek advice and guidance, know how to raise complaints and are confident they will be handled effectively.
- Are aware of the Academy’s approach to diversity and inclusion throughout our work.
- Receive training and awareness sessions for all employees at all levels.
- Have access to the People Portal on the Academy intranet including relevant employee guides, management guides and policies.
- Attend and participate in briefing meetings such as All Staff meetings and employee inductions.
10.2. An annual review of any bullying and harassment cases at the Academy will be provided to the Executive Leadership Team by the People Team.
10.3. The Academy will also communicate its bullying and harassment policy to Fellows. Attendees at events and activities will be expected to adhere to the anti-bullying and harassment policy. This, along with other key policies, will be made available for viewing as part of the event registration process.
10.4. Risks of bullying and harassment should be considered and addressed in planning activities and events. Particular thought should be applied for international travel and for off-site, informal or residential events. Examples of risk mitigation measures might include:
- Briefing to event participants on the Academy’s policy.
- Circulation of a code of conduct to participants.
- Ensuring that large parties selected by other organisations for Academy events have a suitably briefed and responsible person appointed from that organisation.
- Planning around employee numbers and venue security
11. Resource and source of support
11.1. Employer Support Organisations
- ACAS – Bullying and Harassment at Work, Guide for Managers and Employers.
- CIPD – Bullying and Harassment, information and guidance.
- Equality and Human Rights Commission – information on Harassment.
11.2. Membership Organisations (these organisations provide information around protected characteristics and strategies and campaigns to challenge and overcome discrimination).
- Employers Network of Equality & Inclusion.
- Business in the Community – Diversity Campaigns.
- InterEngineering
- AFBE.
- WISE Campaign.
- Women's Engineering Society.
11.3. Charities that support people being bullied or harassed.
- Women’s Aid.
- Family Lives.
- Stonewall.
- Anti-Bullying Ambassadors Programme.
- Samaritans.
- Safeline.
12. Policy Monitoring and review
12.1. The Head of People Operations will monitor the ongoing suitability and review the implementation of this policy regularly and will report to the Director of People on its adequacy, and effectiveness. Any improvements identified will be made as soon as possible.
12.2. Employees and those who are acting for or on behalf of the Academy are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries should be addressed to the Head of People Operations.
12.3. This policy does not form part of any employee's contract of employment, and it may be amended at any time.