Introduction

FPR Group is committed to ensuring a safe and respectful working environment for all. We believe that all staff and applicants have the right to work in an environment which is free from any form of harassment, including sexual harassment.

FPR Group has a zero-tolerance approach to sexual harassment.

FPR Group is committed to ensuring that reasonable steps are taken to prevent sexual harassment to all employees, workers, and applicants. This policy will be reviewed and updated from time to time to ensure FPR Group’s compliance with its duties under the Equality Act 2010 as amended by the Worker Protection (Amendment of Equality Act 2010) Act 2023 to ensure that  all reasonable steps are taken to prevent sexual harassment.

Third Party Sexual Harassment

Harassment of a sexual nature by individuals who are not directly employed by FPR Group, such as clients, customers, suppliers, or contractors, will be treated with the same seriousness as internal cases. We are committed to taking all reasonable steps to prevent such behaviour and ensure our workers are protected in every work setting.

Scope

This policy applies to all workers, including temporary, contract, agency, and permanent staff, as well as job applicants and anyone associated with FPR Group. It covers all work-related activities, including work on client sites, travel, and social events.

Roles and Responsibilities

The Directors have overall responsibility for the operation of this policy but may delegate elements of implementation or decision making to Managers. Our managers will maintain an open door policy. All of our staff have a responsibility to behave in line with the requirements of this policy.

Definitions

Sexual harassment is unwanted behavior of a sexual nature which has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person. It also covers treating someone less favorably because they have submitted to or refused to submit to unwanted conduct of a sexual nature, or that is related to gender reassignment or sex.

Sexual harassment may be committed by a fellow worker, an agent of an organisation, or a third party. It does not need to occur in person. It can occur via digital means including social media sites or channels e.g. WhatsApp.  Examples of sexual harassment include, but are not limited to: 

1. sexual comments or jokes, which may be referred to as ‘banter’
2. displaying sexually graphic pictures, posters or photos
3. suggestive looks, staring or leering
4. propositions and sexual advances
5. making promises in return for sexual favours
6. sexual gestures
7. intrusive questions about a person’s private or sex life or a person discussing their own sex life
8. sexual posts or contact in online communications including on social media
9. spreading sexual rumours about a person
10. sending sexually explicit emails, text messages or messages via other social media
11. unwelcome touching, hugging, massaging or kissing

Preventative Measures

We will provide training to all staff on sexual harassment to ensure there is a clear understanding of: 

• What sexual harassment is and how it may occur
• That it will not be tolerated
• How to report an incident
• Understanding the consequences of harassment

We will 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 take reasonable steps to safeguard temporary workers we supply and internal members of staff from harassment.

We will ensure that the hirer has a sexual harassment policy in place, and this is given to the employee or worker.

We will work with clients to ensure they understand and support our Preventing Sexual Harassment policy. Agreements with clients will include a commitment to maintaining a harassment-free work environment for our workers.

Reporting Procedure

We are committed to ensuring that there is no sexual harassment or victimisation in our workplace.  Workers who experience or witness sexual harassment should follow these steps:

Report the Incident

Report the incident to a manager or senior colleague of your choice.  This person cannot be the same person who will be responsible for investigating the matter.

 Document the Incident

If possible, you should keep notes of what happened so that the written complaint can include: 

1. the name of the alleged harasser;
2. the nature of the alleged harassment;
3. the dates and times when the alleged harassment occurred;
4. the names of any witnesses; and
5. any action already taken by you to stop the alleged harassment.

Investigation Process

Once a report is received, the following steps will be taken:

Acknowledgment:

The complaint will be acknowledged within 24 hours of receipt. Immediate support will be offered to  the complainant, including options for temporary adjustments to their working conditions if needed.

Assign an Investigator:

A neutral and trained investigator will be assigned to conduct a thorough investigation. If the complaint involves complex issues or senior staff, an external investigator may be appointed.

Conduct the Investigation:

Interviews: The investigator will interview the complainant, the alleged harasser, and any witnesses.

All parties will be treated fairly, and confidentiality will be maintained throughout the process.

 Evidence Review: Review any physical evidence (e.g., emails, messages, CCTV footage) related to the incident.

Outcome Determination:

A determination will be made based on the evidence. This may involve disciplinary action against the harasser if the complaint is substantiated, which can range from a warning to dismissal, depending on the severity of the incident.

If the complaint is not substantiated, steps will be taken to ensure that the complainant is not subjected to any form of victimisation.

 Communication of Outcome:

On conclusion of the investigation, which will normally be within ten working days of the meeting with you, the decision of the investigator, detailing the findings, will be sent in writing to you.

Both the complainant and the alleged harasser will be informed of the investigation's outcome. The complainant will be told whether the allegation was upheld and the action taken, without breaching the privacy of those involved.

You have the right to appeal against the findings of the investigator. If you wish to appeal you must inform a manager within five working days. You will then be invited to a further meeting. As far as reasonably practicable, the Company will be represented by a more Senior Manager than attended the first meeting (unless the most Senior Manager attended that meeting).

Post-Investigation Support

Regardless of the outcome of the procedure, we are committed to providing the support you may need. This may involve mediation between you and the other party or some other measure to manage the ongoing working relationship.

Disciplinary Action

All employees and workers will be expected to comply with FPR Group’s policy on sexual harassment in the workplace. Any breach of such a policy will lead to appropriate disciplinary action.

Employees who FPR Group finds to be responsible for sexual harassment will be subject to disciplinary procedures and the sanction may include termination.

Temporary workers who FPR Group finds to be responsible for sexual harassment will be subject to FPR Group’s complaints procedure even where such sexual harassment involves individuals who are not engaged by FPR Group

Protection Against Victimisation

FPR Group prohibits victimisation of anyone who reports sexual harassment or participates in an investigation. Victimisation includes any form of intimidation, reprisal, or discrimination. Such actions will result in disciplinary measures, up to and including dismissal.

 Confidentiality and Data Protection

All information related to a sexual harassment complaint will be handled in strict confidence. Records of the investigation will be kept secure and only accessible to those directly involved in the investigation. Personal data will be managed in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).