This policy was amended by NEIL RIGG on 18th March 2023, to take effect on 1st April 2023 

1. Purpose and scope

This policy provides a framework for ensuring that Juney Baby LTD meets its obligations under the General Data Protection Regulation (GDPR) and associated legislation [1] (‘data privacy legislation’).  It applies to all processing of personal data carried out for company purpose, irrespective of whether the data is processed on non-company equipment or by third parties in our company.

‘Personal data’ means any information relating to an identifiable living individual who can be identified from that data or from that data and other data. ‘Processing’ means anything that is done with personal data, including collection, storage, use, disclosure and deletion.

More stringent conditions apply to the processing of special category personal data.

‘Special category’ means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying an individual, data concerning health or data concerning an individual’s sex life or sexual orientation.

This policy does not cover the use of personal data by associates of the company when acting in a private or non-college capacity.

[1] This includes all legislation enacted in the UK in respect of the protection of personal data as well as the Privacy and Electronic Communications (EC Directive) Regulations 2003.

2. Background

The processing of personal data underpins almost everything the company does.  Without it, its clients cannot undergo business transaction ; co-workers cannot be recruited; living individuals cannot be researched; and events cannot be organised.

JuneyBaby LTD are responsible for handling people’s most personal information. By not handling personal data properly, we could put individuals at risk.

There are also legal, financial and reputational risks for the company . For example:

  • If we are not able to demonstrate that we have robust systems and processes in place to ensure we use personal data properly we might lose our ability to carry out research projects requiring access to personal data, particularly in the medical field.
  • Reputational damage from a breach may affect public confidence in our ability to handle personal information.
  • The Information Commissioners Office (ICO), which enforces data privacy legislation, has the power to fine organisations up to 4% of global annual turnover for serious breaches. The company take out annual insurance with the ICO and carry out annual adits of information.

3. Principles

The processing of personal data must comply with data privacy legislation and, in particular, the six data privacy principles.

In summary, they require that personal data is:

  • processed fairly, lawfully and in a transparent manner;
  • used only for limited, specified stated purposes and not used or disclosed in any way incompatible with those purposes;
  • adequate, relevant and limited to what is necessary;
  • accurate and, where necessary, up-to-date;
  • not kept for longer than necessary; and
  • kept safe and secure.

In addition, a new accountability principle requires us to be able to evidence compliance with these principles.

4. Aims and commitments

Juney Baby LTD  handles a medium amount of personal data and takes seriously its responsibilities under data privacy legislation. It recognises that the mishandling of an individual’s personal data may cause them distress or put them at risk of identity fraud. As a result, it is committed to:

  • complying fully with data privacy legislation;
  • where practicable, adhering to good practice, as issued by the ICO or other appropriate bodies; and
  • handling an individual’s personal data in a careful and considerate manner that recognises the importance of such information to their privacy and welfare.

Juney Baby LTD seek  to achieve these aims by:

  • ensuring that staff, students and other individuals who process data for the company  purposes are made aware of their individual responsibilities under data privacy legislation and how these apply to their areas of work. For example, employment contracts include a clause drawing the attention of the employee to data privacy legislation and the company’s data protection policy;
  • providing suitable training, guidance and advice. We investigate any suspected breach of data privacy legislation; reporting it, where necessary, to the ICO; and seeking to learn any lessons from the incident in order to reduce the risk of reoccurrence.

5. Roles and responsibilities

Data Protection Officer (DPO).

The DPO is responsible for monitoring internal compliance, advising on the company’s data protection obligations and acting as a point of contact for individuals and the ICO.

Vice Chancellor’s and Registrar’s Office: Information Compliance Team

The Director and DPO –  NEIL RIGG is ultimately responsible for:

  • establishing and maintaining policies and procedures at a central level to facilitate the company’s  compliance with data privacy legislation;
  • supporting privacy by design and privacy impact assessments;
  • responding to requests for advice from departments or organisations.
  • complying with subject access and other rights based requests made by individuals for copies of their personal data;
  • investigating and responding to complaints regarding data privacy (including requests to cease the processing of personal data); and
  • keeping records of personal data breaches, notifying the ICO of any significant breaches and responding to any requests that it may make for further information.

In fulfilling these responsibilities, the team may also involve, and draw on support from, representatives from sections, departments and divisions.

6. Breaches of data privacy legislation

The company will investigate incidents involving a possible breach of data privacy legislation in order to ensure that, where necessary, appropriate action is taken to mitigate the consequences and prevent a repetition of similar incidents in future. Depending on the nature and severity of the incident, it may also be necessary to notify the individuals affected and/or the ICO. A breach will occur where, for example, personal data is disclosed or made available to unauthorised persons or personal data is used in a way that the individual does not expect.

Incidents involving failures of IT systems or processes must be reported to the Director or DPO within 24 hours.

7. Compliance

The company regards any breach of data privacy legislation, this policy or any other policy and/or training introduced by the company from time to time to comply with data privacy legislation as a serious matter, which may result in disciplinary action.  Depending on the nature of the breach, an individual may also find that they are personally liable (for example, it can be a criminal offence for a member of the company to disclose personal information unlawfully).

8. Further information

Questions about this policy and data privacy matters in general including information security should be directed to the Data Protection Officer at: info@juneybaby.co.uk 

9. Review and development

This policy, and supporting guidance, will apply with effect from 1st April 2023.  It will be reviewed again before 1st April 2024  to take into account outstanding ICO guidance and the final form of national legislation underpinning the GDPR.

Prepared by  Director Neil Rigg 

using Oxford University as a template

At Juney baby LTD, we are committed to protecting the privacy and security of our users’ personal information. This privacy policy explains how we collect, use, and disclose personal information from users of our website that deals with real estate management, educational support services, performing art events, and recreational amusement.

Information we collect:

We may collect personal information such as name, address, phone number, email address, payment information, and any other information you choose to provide to us when you use our website, register for an account, or make a purchase. We may also collect information about your use of our website, such as your browsing history and search queries.

How we use your information:

We use your personal information to provide the services you have requested, to process transactions, to send you information about our products and services, and to communicate with you about your account. We may also use your information to improve our website and services, to conduct research and analysis, and to comply with legal requirements.

Disclosure of your information:

We may disclose your personal information to third-party service providers who help us operate our website and provide our services. We may also disclose your information to comply with legal requirements or to protect our rights and property.

Third-party links:

Our website may contain links to third-party websites that are not operated by Juney baby LTD. We are not responsible for the privacy practices of these third-party websites and encourage you to review their privacy policies before using their services.

Security:

We take the security of your personal information seriously and take appropriate measures to protect it from unauthorized access, use, or disclosure. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

Children’s privacy:

Our website is not intended for use by children under the age of 13. We do not knowingly collect personal information from children under the age of 13.

Changes to our privacy policy:

We may update our privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on our website. Your continued use of our website after any changes to the privacy policy will constitute your acceptance of the changes.

Contact us:

If you have any questions or concerns about our privacy policy or our use of your personal information, please contact us using our contact page.

Juney Baby LTD is committed to providing a safe and healthy working environment for all employees, contractors, clients, and visitors. This policy outlines our commitment to health and safety and provides guidelines for ensuring the well-being of everyone associated with our company.

  1. General Statement

1.1. Juney Baby LTD acknowledges its legal obligations under the Health and Safety at Work Act 1974 and other relevant legislation, codes of practice, and industry standards.

1.2. We strive to continually improve our health and safety performance and maintain a culture of safety throughout our operations.

  1. Responsibilities

2.1. Management: The management of Juney Baby LTD is responsible for providing leadership, resources, and support to implement effective health and safety measures. They will also ensure compliance with legal requirements and maintain a safe working environment.

2.2. Employees: All employees have a responsibility to comply with health and safety procedures, report hazards and incidents promptly, and take reasonable care to protect their own safety and that of others.

2.3. Contractors and Visitors: Contractors and visitors are required to follow health and safety guidelines, report hazards or incidents, and adhere to safety policies while on our premises.

  1. Risk Assessment and Management

3.1. Juney Baby LTD mayl conduct regular risk assessments to identify hazards, evaluate risks, and implement appropriate control measures to eliminate or reduce risks to an acceptable level.

3.2. Safe systems of work will be established for all tasks, and employees will be provided with training, information, and supervision necessary to carry out their work safely.

  1. Health and Safety Procedures

4.1. Emergency Preparedness: We will develop and maintain emergency procedures, including evacuation plans, first aid provisions, and fire safety measures. Employees will be trained in these procedures, and regular drills will be conducted to ensure preparedness.

4.2. Accident Reporting and Investigation: All accidents, near-misses, and incidents will be promptly reported, recorded, and investigated. Lessons learned will be communicated to employees to prevent recurrence.

4.3. Personal Protective Equipment (PPE): Suitable PPE will be provided to employees as necessary, and its proper use and maintenance will be ensured. Employees will receive training on PPE requirements and usage.

4.4. Health and Welfare: Juney Baby LTD is committed to promoting the health and welfare of its employees. We will provide a clean and safe working environment, access to welfare facilities, and support programs to promote well-being.

4.5. Training and Information: Juney Baby LTD will provide employees with relevant health and safety training, information, and supervision to enable them to carry out their work safely. Regular communication channels will be established to disseminate safety-related information.

  1. Review and Continuous Improvement

5.1. This health and safety policy will be reviewed regularly to ensure its ongoing suitability and effectiveness. Any necessary updates will be communicated to employees and stakeholders.

5.2. Juney Baby LTD encourages feedback and suggestions from employees and stakeholders to improve health and safety practices and systems.

By implementing and adhering to this health and safety policy, Juney Baby LTD aims to create a safe and healthy working environment for all and fulfil its legal and moral obligations towards health and safety.

Disciplinary and Grievance Policy

Effective Date: [2/6/23]

  1. Introduction
  2. This Disciplinary and Grievance Policy (“Policy”) outlines the procedures and guidelines for disciplinary actions and grievance handling within Juney Baby Ltd (referred to as “the Company”). The purpose of this Policy is to ensure fair treatment, maintain a harmonious working environment, and address disciplinary issues and grievances promptly and effectively across the sectors the Company operates in, including:
  3. Management of real estate on a fee or contract basis
  4. Educational support services
  5. Performing arts
  6. Other amusement and recreational activities not elsewhere classified.
  7. Scope and Applicability
  8. This Policy applies to all employees of Juney Baby Ltd, including permanent, temporary, full-time, part-time, and contract workers. The provisions of this Policy also extend to contractors engaged by the Company in accordance with their contracts.
  9. Disciplinary Policy
  10. (a) Principles:
    • Disciplinary actions will be undertaken in a fair, consistent, and non-discriminatory manner.
    • Employees will be informed of the nature of the allegations and provided with an opportunity to respond before any disciplinary action is taken.
    • Disciplinary measures will be proportionate to the severity of the offence.
    • Right to Appeal: Employees will have the right to appeal against any disciplinary decision.

(b) Disciplinary Procedure:

i. Informal Stage:

– Minor issues will be addressed informally through counselling or verbal warnings.

– The acting line manager/supervisor/Director will discuss concerns with the employee/contractor, clarify expectations, and provide guidance on improvement.

ii. Formal Stage:

– If informal resolution fails or for more serious offences, a formal disciplinary process will be initiated.

– The employee/contraxctor will be given a written notice of the allegations, including the specific misconduct, and be invited to attend a disciplinary hearing.

– The employee will have the opportunity to present their case and provide evidence or witnesses, if necessary.

– Following the disciplinary hearing, the Company will decide on an appropriate disciplinary action, which may include written warnings, suspension, demotion, or termination.

iii. Appeal Stage:

– If the employee/contractor disagrees with the disciplinary decision, they may lodge an appeal within a specified timeframe.

– An appeal hearing will be conducted by a different manager or a designated individual who was not involved in the original decision.

– The employee will have the opportunity to present their case, and the decision on the appeal will be communicated in writing.

  1. Grievance Policy
    • (a) Principles:
    • A grievance is any concern, problem, or complaint raised by an employee/contractor regarding their employment or working conditions.
    • Grievances will be handled promptly, impartially, and confidentially.
    • The employee has the right to be accompanied by a colleague or a trade union representative during the grievance process.
    • Right to Appeal: Employees have the right to appeal against any decision made during the grievance process.

(b) Grievance Procedure:

i. Informal Stage:

– Employees are encouraged to resolve grievances informally by discussing the matter with their immediate supervisor or manager.

– The supervisor/manager will listen to the employee’s concerns and attempt to reach a satisfactory resolution.

ii. Formal Stage:

– If the informal stage does not resolve the grievance, the employee may submit a formal, written grievance to their line manager or Human Resources (HR) department.

– The written grievance should include details of the complaint, any evidence, and the desired resolution.

– A formal grievance meeting will be arranged to discuss the matter, and the employee may be accompanied by a colleague or trade union representative.

– Following the meeting, the Company will conduct a thorough investigation. 

Equality and Corporate Social Responsibility Policy

Effective Date: [2/6/23]

  1. Introduction
  2. Juney Baby Ltd (referred to as “the Company”) is committed to promoting equality, social responsibility, and sustainable practices across all aspects of its operations. This Equality and Corporate Social Responsibility Policy outlines the Company’s approach to fostering equality, minimising environmental impact in the education and performing arts sectors, conducting ethical trading practices, and supporting charity and community initiatives.
  3. Equality and Inclusion
  4. (a) Equal Opportunities:
    • The Company is committed to providing equal opportunities for all employees, job applicants, contractors, clients, and stakeholders, regardless of their age, race, ethnicity, gender, sexual orientation, disability, religion, or other protected characteristics.
    • Employment decisions, promotions, and access to training and development opportunities will be based on merit and relevant qualifications.

(b) Diversity and Inclusion:

  • The Company recognises and values diversity in its workforce and believes that inclusion contributes to a more innovative and productive work environment.
  • Efforts will be made to create an inclusive culture that respects and values individual differences, promotes collaboration, and fosters a sense of belonging for all participants in business.
  1. Environmental Impact
  2. (a) Education and Performing Arts Sectors:
    • The Company acknowledges the environmental impact associated with its activities in the education and performing arts sectors.
    • Efforts will be made to minimise energy consumption, waste generation, and carbon emissions through the implementation of sustainable practices.
    • The use of environmentally friendly materials, recycling initiatives, and energy-efficient technologies will be prioritised wherever feasible.
    • Associates will be encouraged to adopt sustainable practices, such as reducing paper usage, conserving energy, and promoting responsible travel.
  3. Ethical Trading
  4. (a) Ethical Business Conduct:
    • The Company is committed to conducting its business in an ethical and responsible manner.
    • Suppliers and business partners will be selected based on their adherence to ethical standards, including labor rights, fair wages, and environmental sustainability.
    • Any instances of unethical conduct, such as bribery, corruption, or unfair labor practices, will not be tolerated, and appropriate action will be taken.

(b) Supply Chain Analysis:

  • The Company will conduct regular ethical trading analyses of its supply chain to ensure compliance with social and environmental standards.
  • Collaborative efforts will be made with suppliers to address any identified issues and drive continuous improvement in ethical practices.
  1. Charity and Community Support
    • (a) Charitable Initiatives:
    • The Company recognises the importance of giving back to the community and supporting charitable causes.
    • Efforts will be made to identify and support charitable initiatives aligned with the Company’s values and areas of impact.
    • Employees may be encouraged to participate in volunteering activities and fundraising events to support these initiatives.

(b) Community Engagement:

  • The Company will actively engage with local communities, educational institutions, and performing arts organisations to foster meaningful partnerships.
  • Collaboration and support will be provided to community projects, events, and initiatives that align with the Company’s values and contribute to the betterment of society.
  1. Communication and Reporting
    • (a) Communication:
    • The Company will communicate its Equality and Corporate Social Responsibility commitments and initiatives to all employees, clients, and stakeholders.
    • Clear channels of communication will be established to facilitate employee feedback, suggestions, and concerns related to equality and corporate social responsibility.

(b) Reporting:

  • Regular reports will be prepared to assess the Company’s progress in achieving its equality and corporate social responsibility objectives.
  • Key performance indicators will be established to measure and monitor the Company’s environmental impact, ethical trading practices, and charitable activities.
  1. Evaluation and Review
  2. This Equality and Corporate Social Responsibility Policy will be periodically evaluated and reviewed to ensure its effectiveness, relevance, and alignment with evolving societal expectations and industry best practices.

Expenses Policy JUNEY BABY LTD

 

Authorisation procedure

All requests for overnight accommodation and rail/air travel should be made through the appropriate Department Manager or nominated person on the relevant form, which will then be processed, and where approved, arrangements will be made through the Accounts Department.

 

Overnight accommodation

Overnight accommodation will only be approved when significant travel has to be undertaken and will only be authorised in respect of early morning client visits where it is essential that the visit should take place at 9.00am.  In all other circumstances, client visits should be arranged at a time when overnight accommodation is not necessary.

Travel

 

Travel is paid for Directors reasonable expenses.  One off payments for contractors are agreed on contract.

There will be no reimbursement of home to office mileage and return, except in the case of home based employees travelling to Head Office. The equivalent home to office mileage should be deducted from other claims.

 

Rail and Air Travel

Where such travel has been approved and it is necessary to undertake travel at extremely short notice, any travel paid direct by the employee will be reimbursed through the expense claim process, for which a receipt must be provided.  In normal circumstances, such travel is to be booked through the info@juneybaby.co.uk

Parking, Road Tolls, Underground, Taxi and Bus Fares

Parking, road tolls, underground, taxi and bus fares will be reimbursed as appropriate, but usage must be appropriate and supported by receipts.

Subsistence

 

Overnight allowance

Where overnight accommodation is authorised and booked, this will take the form of bed and breakfast accommodation only.  The reasonable cost of an evening meal will be reimbursed which must be supported by a relevant receipt.

Breakfast Allowance

Where overnight accommodation is authorised and booked, which does not include breakfast, then the reasonable cost of breakfast will be reimbursed which must be supported by a relevant receipt.

Late Evening Meal Allowance

For employees who will not return home until after 8.00pm, the reasonable cost of an evening meal will be reimbursed which must be supported by a relevant timed receipt.  This will not include “takeaways” on arrival at home, or food purchased from local supermarkets.

Lunches and Light Refreshments

There is no provision for reimbursement of lunches and light refreshments either for staff or clients, unless under special circumstances, for which prior approval from the appropriate Departmental Manager must be sought.

 

 

 

Postage, photocopying and stationary

Head Office based employees

Postage, photocopying and stationery must all be obtained through Head Office, unless in exceptional circumstances, e.g. when working away from the office. This should be claimed in the normal way on the appropriate expense claim form.

 

Home based employees

Items such as printed stationery, toners etc should be obtained from Head Office. Other expenses will be reimbursed through the expenses claim form, where these are supported by receipts.

There will be no reimbursement for personal items of stationery, for example pen refills, highlighters, etc.

THE SCHOLARS CONFLICTS OF INTEREST POLICY 

The relationship of “THE SCHOLARS” and its employees/contractors is based on mutual trust. In general, therefore, an employee should refrain from allowing their personal and/or financial activities from coming into opposition with the interests and integrity of the “THE SCHOLARS” and thus placing it at a disadvantage. 

Where this does happen is known as a conflict of interest. Conflicts of interest between an organisation and its employees can arise in many circumstances and it is not possible to provide a single definition. If, however, an employee is aware of a conflict of interest, they, as a matter of urgency, should raise the issue with their immediate manager so that corrective action may be taken before actual damage is done. 

The responsibility for resolving any conflict of interest lies with the immediate manager — although it may later involve senior management. 

THE SCHOLARS will attempt to resolve any conflicts of interest as fairly and as reasonably as possible. If no resolution can be found, the final action to be taken will rest with senior management. If a conflict of interest is deliberately concealed by an employee or if no solution to one can be found, then THE SCHOLARS may invoke disciplinary action that could lead to the employee’s/contactors dismissal. 

Bullying and Harassment Policy 

Purpose

Our aim is to provide a working environment that respects the rights of each individual employee/contractor and where colleagues treat each other with the utmost respect. Any behaviour that undermines this aim is totally unacceptable.

Juney Baby LTD therefore deplores all forms of harassment and bullying. It will not be tolerated under any circumstances and may lead to disciplinary action up to and including dismissal.

While implementing and upholding the policy is the duty of all of our managers and supervisors,Directors, all employees/contractors have a responsibility to ensure that bullying and harassment have no place in the workplace.

Principles and Procedure

The following procedure has been designed to inform employees/contractors about the type of behaviour that is unacceptable and provides employees who are the victims of harassment and bullying with a means of redress. Juney Baby LTD will not tolerate harassment or bullying of any person.

As already indicated, harassment or victimisation may lead to disciplinary action up to and including dismissal if it is committed:

  • in a work situation
  • during any situation related to work such as at a social event with colleagues.
  • against a colleague or other person connected to the employer outside of a work situation, including on social media
  • against anyone outside of a work situation where the incident is relevant to their suitability to carry out the role.

Aggravating factors such as the abuse of power over a more junior colleague will be taken into account when deciding what disciplinary action to take.

Juney Baby LTD will also not tolerate harassment of staff by third parties, eg clients or customers, and will take appropriate action to deal with all instances which are reported.

Definition of Harassment

Harassment is unwanted conduct that intentionally or unintentionally violates a person’s dignity, or creates an intimidating, hostile, degrading, humiliating, or offensive working environment for them. Harassment at work is not only despicable and demeaning, but may also be unlawful under the Equality Act 2010.

Each person has the right to decide what behaviour is either acceptable or unacceptable; if an individual finds certain behaviour unacceptable and they feel damaged by it, then that individual has every right to say so, and their right to do so will be respected. It is irrelevant whether the person who perpetrated the behaviour intended to cause offence.

People can be subjected to harassment on a wide variety of grounds.

These include:

  • sex or gender — see the next section on sexual harassment
  • sexual orientation
  • transgender status
  • marital or civil partnership status
  • pregnancy or maternity leave
  • race, nationality, ethnic origin, national origin or skin colour
  • disability
  • age
  • employment status, eg part-time, fixed-term, permanent, self-employed, agency worker, contractor, subcontractor, etc
  • membership or non-membership of a trade union
  • the carrying out of health and safety duties
  • religious or political beliefs
  • deeply held personal beliefs
  • criminal record
  • health, eg AIDS/HIV sufferers, etc
  • physical characteristics
  • willingness to challenge harassment — being ridiculed or victimised for raising a complaint.

As harassment can occur on a variety of grounds, anyone perceived to be different from the majority is at particular risk.

Harassment is normally characterised by more than one incident of unacceptable behaviour, particularly if it recurs once it has been made clear that it is regarded by the victim as offensive. However, a single incident may constitute harassment if it is sufficiently serious.

Juney Baby LTD together with any managers or supervisors who fail to take steps to prevent harassment or investigate complaints, may be held liable for their unlawful actions and be required to pay compensation to the victim, as may the employee who has committed the act of harassment. This does not include associate companies, public bodies or charities. 

There is no limit to the compensation that can be awarded in employment tribunals for acts of harassment.

Harassment on any grounds may also be a criminal offence under the:

  • Criminal Justice and Public Order Act 1994
  • Protection from Harassment Act 1997
  • Crime and Disorder Act 1998
  • Criminal Justice and Police Act 2001

Anti-terrorism, Crime and Security Act 2001 (which cites religiously aggravated harassment as a criminal offence).

These Acts mean that employees who are harassed by fellow employees or third parties may call in the police. Those found guilty face fines and/or periods of imprisonment of up to two years.

Examples of Harassment

Harassment takes many forms — from relatively mild banter to physical violence. Employees may not always realise that their behaviour constitutes harassment, but they must recognise that what is acceptable to one employee may not be acceptable to another; determining what is acceptable is an individual right that must be respected.

Examples of harassment include (but are not restricted to):

  • verbal harassment — examples include crude language, offensive jokes, suggestive or offensive remarks, innuendoes, rude or vulgar comments, malicious gossip and offensive songs related to any of the protected characteristics (eg sex, race, religion, etc)
  • non-verbal harassment — examples include 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 on mobile phones and offensive objects
  • physical harassment — examples include unnecessary and unwanted touching, patting, pinching, or brushing against another employee’s body, assault and physical coercion
  • pressure for sexual favours (eg to get a job or promotion) or victimisation on account of the rejection of such pressure
  • isolation or non-co-operation and exclusion from social activities for a reason related to sex, race, religion, etc.

Sexual Harassment

Sexual harassment occurs when a worker is subjected to unwanted conduct as defined in paragraphs 2.8 to 2.14 and which is of a sexual nature. The conduct need not be sexually motivated, only sexual in nature (s.26(2) of the Equality Act 2010).

Conduct “of a sexual nature” includes a wide range of behaviour, such as:

  • sexual comments or jokes
  • displaying sexually graphic pictures, posters or photos
  • suggestive looks, staring or leering
  • propositions and sexual advances
  • making promises in return for sexual favours
  • sexual gestures
  • intrusive questions about a person’s private or sex life or a person discussing their own sex life
  • sexual posts or contact on social media
  • spreading sexual rumours about a person
  • sending sexually explicit emails or text messages
  • unwelcome touching, hugging, massaging or kissing.

An individual can experience unwanted conduct from someone of the same or a different sex. Sexual interaction that is invited, mutual or consensual is not sexual harassment because it is not unwanted. However, sexual conduct that has been welcomed in the past can become unwanted.

Sexual harassment is unlawful and will not be tolerated by [the organisation].

Definition of Bullying

Bullying is a sustained form of psychological abuse that aims to make the victim feel demeaned and inadequate. Bullying is defined as:

“offensive, intimidating, malicious or insulting behaviour, or an abuse or misuse of power, which has the purpose, or effect of, intimidating, belittling and humiliating the recipient, leading to loss of self-esteem for the victim and ultimately the self-questioning of their worth, both in the workplace and society as a whole”.

Examples of bullying

Examples of bullying include:

  • shouting or swearing at someone
  • ignoring or deliberately excluding a person
  • persecution through threats and instilling fear
  • spreading malicious rumours
  • constantly undervaluing effort
  • dispensing disciplinary action which is totally unjustified
  • spontaneous rages, often over trivial matters.

Examples of less obvious bullying include:

  • deliberately withholding information or supplying incorrect information
  • deliberately sabotaging or impeding work performance
  • constantly changing targets without good reason
  • setting an individual up to fail by imposing impossible deadlines
  • removing areas of responsibility and imposing menial tasks
  • blocking applications for holiday, promotion, or training.

These examples listed are not exhaustive. As with harassment, it is the perception of the recipient that determines whether any particular behaviour can reasonably be viewed as bullying.

Cyberbullying

Cyberbullying can be defined as the use of information and communication technologies to support deliberate, repeated and hostile behaviour by an individual or group that is intended to harm others.

Typically cyberbullying involves the use of the Internet, email or mobile phones to send or post text or images intended to hurt or embarrass another person. In many cases, the spreading of offensive jokes or shocking or sexual material through phone or email may also constitute cyber-harassment.

Anyone found to be using technology to bully or harass a colleague or third party will be subject to the disciplinary procedure.

The Impact of Harassment and Bullying

Harassment and bullying can extract a high price on employees and [the organisation] alike. Employees can be subject to fear, stress, and anxiety, which can put great strains on personal and family life. Harassment and bullying can lead to illness, absenteeism, an apparent lack of commitment, poor performance, reduced productivity and resignation.

Enforcement

The examples of harassment and bullying provided in this policy are not exhaustive. Any harassment or bullying will be classed as gross misconduct, for which employees may be summarily dismissed.

All complaints of harassment will be treated very seriously.

The organisation expects all managers and supervisors to ensure that this policy and procedure is adhered to at all times and expects all employees to respect the dignity of their colleagues. The policy will be regularly monitored by the [Human Resources Director/other] to ensure that it is achieving its aims, and that managers and employees are confident about its application.

Procedure for Dealing with Bullying and Harassment

Advice.

The organisation recognises the sensitive nature of bullying and harassment. Employees who believe they are being bullied or harassed may wish to discuss their particular situation before deciding what action to take. [The organisation] operates an open-door policy to discuss workplace problems and employees can fully discuss the matter with their manager on an informal basis. However, the organisation recognises that this may not be appropriate in all circumstances. If this is the case, employees can discuss the situation with the next higher level of management or with a member of the Human Resources department.

Anyone giving advice will:

  • ensure the conversation remains confidential as far as possible
  • listen sympathetically
  • help individuals consider objectively what has happened
  • discuss what outcome the individual would wish to see
  • draw attention to available procedures and options
  • inform the individual of the legal liabilities involved
  • help weigh up the alternatives, but without pressure to adopt any particular course
  • assist the individual in dealing with the situation (if the individual asks for help).

Confidentiality will be maintained as far as possible. However, if an employee decides not to take any action to deal with the problem and the circumstances described are very serious, the organisation reserves the right to investigate the situation — as it has an overall duty of care to ensure the safety of all employees who may be adversely affected by the alleged harasser’s/bully’s behaviour.

Solutions

Just as it is for the individual to decide what behaviour is either acceptable or unacceptable, then it is also for the individual to decide which route to take in addressing any problem that has occurred. There are two types of solutions available: informal and formal.

Informal solutions

Employees can choose to solve the matter themselves by simply approaching the harasser/bully, telling them that their behaviour is unwelcome and that it must stop, otherwise a formal complaint will be made.

If an individual would find it difficult or embarrassing to raise the issue directly with the person creating the problem, support can be sought from a [colleague/union representative (where a union is recognised)] who can accompany the victim when speaking to the harasser/bully.

A third option is that the victim can put their views in writing to the harasser/bully, telling them that their behaviour is unacceptable and that it must stop.

Mediation (Optional Clauses)

Independent and impartial mediation conducted by a qualified mediator will be made available to assist in the resolution of the dispute between the person who is being bullied or harassed and the perpetrator.

If either party wishes to request third party mediation, they may do so by speaking to ___. However mediation will only be considered where both parties agree to enter in to the process.

Formal solutions

Where informal solutions fail, or serious harassment or bullying occurs, employees can bring a formal complaint in the form of a grievance, with the procedure adapted to take account of the sensitivities of such situations.

Each step and action under the formal grievance procedure will be taken without unreasonable delay. Complaints will be investigated swiftly and confidentially while ensuring that the rights of both the alleged victim and the alleged harasser are protected.

Employees and witnesses can be assured that they will not be ridiculed or victimised for making, or assisting in making a complaint, even if it is not upheld, as long as it is made in good faith.

Everyone involved in the investigation, including witnesses, will be required to maintain confidentiality — a failure to do so will be a disciplinary matter.

The procedure is as follows.

Step 1 — Lodging a grievance and conducting an investigation

The complaint should be put in writing, outlining the alleged incidents — when and where they occurred, the harm caused, the names of any witnesses and the name of the alleged harasser or bully.

If the victim would find it distressing to set out their complaint in writing, then they should contact the Human Resources department, which will provide assistance.

The written grievance should initially be lodged with the employee/contractor  manager. However, if this would not be appropriate in the circumstances, it should be lodged with [the Human Resources department.

The complaint will then be passed to the Director who will be responsible for progressing the complaint.

An independent investigator will be appointed by Neil Rigg or a appointee who has had no previous involvement in the situation and who will conduct investigatory interviews with the complainant, the individual against whom the complaint has been lodged, and any relevant witnesses. The right to accompaniment will be provided to all those interviewed.

The investigator will submit a full report to the Director or external verifier.

Step 2 — Grievance meeting

The employee/contractor will be invited to a meeting with Neil Rigg or external verifier to discuss the grievance and the result of the independent investigator’s report.

The employee/contractor has the right to be accompanied by a colleague or trade union official of their choice at the meeting.

The timing and location of the meeting must be reasonable.

The employee must take all reasonable steps to attend the meeting.

The meeting will be conducted in a manner that enables the employee/contractor to explain their case and Neil Rigg or appropriate verifier  to set out the results of the investigation.

Within [five working days] of the meeting, Neil Rigg or external verifier will inform the employee of their decision and notify the employee of their right to appeal against that decision if they are not satisfied with it.

Step 3 — Hearing the appeal

If the employee/contractor does wish to appeal, they must inform New Rigg to appeal to, who will be senior to the person who heard the Step 2 grievance.

The employee/contractor will be invited to attend an appeal meeting.

The employee has the right to be accompanied by a colleague or trade union official of their choice to the appeal meeting.

The timing and location of the meeting must be reasonable.

The employee/contractor must take all reasonable steps to attend the meeting.

The meeting will be conducted in a manner that enables both sides to explain their cases.

Within five working days] of the appeal meeting, Neil Rigg or body hearing the appeal will inform the employee in writing of the final decision.

Full records will be kept of the grievance proceedings and copies of meeting records will be given to the complainant.

If at the end of Step 1, the complaint is upheld, the matter will be passed to the appropriate line manager to instigate disciplinary proceedings against the person who perpetrated the bullying or harassment.

Continuing to Work Together

Whether a complaint is upheld or not, Juney Baby LTD recognises that it may be difficult for the employees/contractors concerned to continue to work in close proximity to one another during the investigation or following the outcome of the proceedings. If this is the case, Juney Baby LTD will consider a voluntary request from either party to transfer to another job or work location. However, a transfer cannot always be guaranteed.

Monitoring and Review

Where harassment or bullying has been found to have occurred, and the perpetrator remains in employment, regular checks will be made to ensure that harassment has stopped and that there has been no victimisation or retaliation against the victim. Juney Baby LTD will also ensure that the employee who committed the act of harassment or bullying is not victimised in any way.

The policy will be reviewed at regular intervals.

Malicious Complaints

Where a complaint is blatantly untrue and has been brought out of spite, or for some other unacceptable motive, the complainant will be subject to Juney Baby LTDs disciplinary procedure, as will any witnesses who have deliberately misled Juney Baby LTD during its investigations.

 

Dealing with Harassment by a Third Party

Third- party harassment can lead to legal liability and will not be tolerated by Juney Baby LTD.

A worker who is bullied or harassed by a third party is not expected to enter into any confrontation with the third party that may put their personal safety at risk.

If, however, a worker decides to tackle the matter themselves, they should take the following steps.

Politely ask the third party to stop the bullying or harassment and inform them that bullying or harassment of the company’s workers by a third party will not be tolerated.

If the third party does not stop the bullying or harassment — repeat step 1 and warn them that action will be taken against them if the bullying or harassment continues.

If the third party still does not stop the bullying or harassment — report the incident to their line manager.

The complaint will be investigated immediately and in some cases the bully or harasser may be asked to leave the employer’s premises and not return. In all instances of such third-party harassment Juney Baby LTD will take effective remedial action, including reporting any criminal act to the police.

A worker should report any incident of bullying or harassment by a third party to their line manager whether or not they have managed to resolve it. The report will be used for the purpose of monitoring the effectiveness of Juney Baby LTDs bullying and harassment policy.

Signed:

Neil Rigg

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Date: Tuesday, 15 August 2023

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Policy review date:

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25th August 2024

22 – 24 Financial Info