Effective Date: January 2026
Review Date: January 2027
Owner: HR Department
1. Purpose
NSEMM, as a Charitable Incorporated Organisation (CIO), is committed to creating a working environment free from harassment, bullying and victimisation. This policy sets out our zero-tolerance approach and our commitment to equality, diversity and inclusion (EDI) across all areas of our work.
2. Scope
This policy applies to all NSEMM staff, volunteers, trustees, contractors and anyone acting on behalf of the organisation. It covers behaviour in the workplace, at external events, during online communications and in any context connected to NSEMM duties.
3. Zero Tolerance Statement
NSEMM operates a zero-tolerance policy towards:
- Harassment – unwanted conduct related to a protected characteristic that violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment
- Bullying – offensive, intimidating, malicious or insulting behaviour, or an abuse or misuse of power that undermines, humiliates or causes physical or emotional harm
- Victimisation – treating someone unfavourably because they have made or supported a complaint, or raised a grievance under the Equality Act 2010
4. Protected Characteristics
Under the Equality Act 2010, the following characteristics are protected:
- Age
- Disability
- Gender reassignment
- Marriage and civil partnership
- Pregnancy and maternity
- Race (including colour, nationality, ethnic and national origin)
- Religion or belief
- Sex
- Sexual orientation
NSEMM extends its protection beyond these statutory characteristics to include caring responsibilities, socio-economic background and any other factor that may lead to unfair treatment.
5. EDI Commitment
NSEMM is committed to:
- Building an inclusive environment where every individual feels valued and respected
- Ensuring equal access to opportunities, development and progression
- Celebrating diversity and recognising the strength it brings to our organisation
- Removing barriers to participation and engagement
- Embedding EDI principles into all policies, procedures and decision-making
- Providing reasonable adjustments for disabled staff and volunteers in line with our legal obligations
6. Reasonable Adjustments
Staff and volunteers who require reasonable adjustments should discuss their needs with their line manager or HR. Adjustments may include changes to working hours, equipment, duties or the physical environment. Requests are handled confidentially and reviewed regularly to ensure they remain appropriate.
7. Reporting Harassment or Discrimination
Anyone who experiences or witnesses harassment, bullying or discrimination should report it through one of the following channels:
- Protect App – submit a concern at protect.nsemm.org.uk for confidential reporting and investigation tracking
- Line Manager – raise the matter directly with your line manager
- HR Department – contact HR via the HR App or in person
- Safeguarding Lead – where the behaviour involves safeguarding concerns
All reports are treated seriously and investigated promptly. Anonymous reporting is available through the Protect App.
8. Investigation Process
- All complaints are acknowledged within two working days
- A trained investigator is appointed who is independent of the parties involved
- Both the complainant and the respondent are interviewed separately
- Witnesses may be interviewed and evidence gathered
- Findings are documented and shared with relevant parties
- Outcomes may include mediation, formal warnings, disciplinary action or dismissal
- Both parties have the right to appeal the outcome
Harassment, bullying, and discriminatory behaviour constitute gross misconduct under the Staff Code of Conduct and will be dealt with under the Disciplinary and Grievance Policy.
Investigations are conducted with discretion and all parties are reminded of their confidentiality obligations.
9. Support Available
NSEMM provides support to all parties during and after an investigation:
- Access to the Employee Assistance Programme (EAP)
- Time off for counselling appointments where needed
- Mediation services for workplace relationship breakdowns
- Regular welfare check-ins with HR
10. Training Requirements
All staff and volunteers must complete mandatory EDI training through NSEMM Moodle. This includes:
- Equality and diversity awareness (on induction)
- Unconscious bias training (annual refresher)
- Bystander intervention training (annual refresher)
Managers receive additional training on handling complaints and supporting diverse teams. Training completion is tracked and forms part of performance reviews.
11. Monitoring and Review
This policy is reviewed annually by the HR Department and the Board of Trustees. Monitoring includes:
- Analysis of complaints data (anonymised) to identify trends
- Staff survey feedback on workplace culture
- EDI audit of recruitment, retention and progression data
- Review of reasonable adjustment provisions
NSEMM publishes an annual EDI report summarising progress and setting objectives for the coming year.