1. Policy Statement
We are committed to providing a safe working environment in which all employees are treated with dignity and respect.
The Company operates a zero-tolerance approach to sexual harassment and all forms of unwanted conduct of a sexual nature.
The Company will not ignore, minimise, or conceal complaints or concerns relating to sexual harassment.
We are committed to taking all reasonable steps to prevent sexual harassment in accordance with:
- The Equality Act 2010; and
- The Worker Protection (Amendment of Equality Act 2010) Act 2023.
This policy applies to all employees of the Company.
The Company’s employees carry out assignments at third-party client locations, including but not limited to schools, public sector environments, and private sector organisations. All employees are entitled to work in an environment free from sexual harassment regardless of where their assignment is undertaken.
Sexual harassment will not be tolerated:
- at Company premises
- at client or end-user sites
- during work-related travel
- during work-related training
- at work-related social events
- during remote or home working
- via electronic communications, social media, messaging platforms, telephone calls, or video conferencing
Sexual harassment may be treated as gross misconduct. Any employee found to have committed sexual harassment may be subject to disciplinary action up to and including dismissal.
The Company also expects all recruitment agencies, end-user clients, associated organisations, and individuals connected with assignments to maintain working environments free from sexual harassment and to cooperate fully with any investigation conducted under this policy.
2. Purpose of the Policy
The purpose of this policy is to:
- prevent sexual harassment in the workplace and during the course of employment
- establish clear reporting procedures
- explain how concerns will be investigated
- protect employees from victimisation or retaliation
- set out responsibilities for employees, management, and the Company
- demonstrate the Company’s commitment to complying with its legal obligations
This policy should be read alongside the Company’s:
- Grievance Policy
- Disciplinary Policy
- Whistleblowing Policy
3. Scope of the Policy
This policy applies to all employees of the Company.
This policy covers conduct occurring:
- during working hours
- outside working hours where connected to work
- at client or end-user sites
- during work-related travel
- during work-related training
- at work-related social events
- during remote or home working
- through work-related electronic communications and online platforms
This policy also covers interactions with:
- recruitment agencies
- end-user clients
- client representatives
- contractors
- visitors
- parents
- members of the public
- any other individuals connected with an employee’s assignment or work activities
This policy applies regardless of:
- seniority
- length of service
- working location
- working pattern
4. What is Sexual Harassment?
Under the Equality Act 2010, sexual harassment is unwanted conduct of a sexual nature which has the purpose or effect of:
- violating a person’s dignity
- creating an intimidating, hostile, degrading, humiliating, or offensive environment for the individual
Conduct may amount to sexual harassment even if:
- it was not intended to offend
- it was a one-off incident
- it took place outside normal working hours
- it occurred online or remotely
- the recipient did not previously object
- the conduct was described as “banter” or a “joke”
When considering whether conduct amounts to sexual harassment, consideration will be given to:
- the perception of the individual affected
- the circumstances of the case
- whether it was reasonable for the conduct to have that effect
5. Examples of Sexual Harassment
Examples of conduct which may constitute sexual harassment include, but are not limited to:
- unwanted touching, hugging, kissing, or physical contact
- sexual comments, jokes, gestures, or innuendo
- intrusive questions about a person’s private or sexual life
- staring, leering, or suggestive behaviour
- displaying or sharing sexually explicit images or material
- sending inappropriate or sexually suggestive emails, messages, images, or social media content
- repeated unwanted invitations or advances
- comments about a person’s appearance in a sexual manner
- sexually offensive comments or remarks
- inappropriate behaviour during work-related social events
- online harassment during video calls, messaging platforms, or remote working
- coercion, threats, or pressure for sexual activity
This list is not exhaustive.
6. Third-Party Harassment
The Company recognises that employees may be exposed to inappropriate conduct from third parties including:
- end-user clients
- recruitment agency representatives
- school staff
- associated organisations
- contractors
- visitors
- parents or other members of the public
The Company takes all reports of third-party sexual harassment seriously.
Where concerns are raised involving third parties, the Company may:
- contact the end-user client or agency
- require the third-party organisation to investigate
- request removal of the individual involved
- consider alternative working arrangements
- suspend assignments where appropriate
- terminate relationships with third parties where necessary
The Company expects all client organisations and recruitment agencies to cooperate fully with investigations conducted under this policy.
7. Responsibilities
7.1 Responsibilities of All Employees
All employees are responsible for:
- treating others with dignity and respect
- complying with this policy
- avoiding behaviour that could amount to sexual harassment
- reporting concerns promptly
- cooperating with investigations
Employees must not:
- engage in sexual harassment
- victimise individuals who raise concerns
- make malicious or knowingly false allegations
7.2 Responsibilities of Directors, Managers and Head Office Staff
Directors, managers and head office personnel involved in the administration of this policy are responsible for:
- promoting a respectful working environment
- taking concerns seriously
- responding promptly to reports
- maintaining confidentiality
- escalating concerns appropriately
- ensuring employees are aware of this policy
- completing annual sexual harassment prevention training
Failure to take appropriate action will be treated seriously and may result in action under the relevant internal procedures.
7.3 Responsibilities of the Company
The Company will:
- ensure appropriate Director oversight of the implementation and review of this policy
- take reasonable steps to prevent sexual harassment
- maintain appropriate reporting procedures
- investigate complaints fairly and promptly
- protect employees from victimisation
- provide appropriate training to head office staff
- monitor workplace risks where reasonably practicable
- undertake periodic assessments of workplace and assignment-related risks relating to sexual harassment where reasonably practicable
- implement appropriate preventative measures where reasonably practicable
- review this policy regularly
8. Reporting Concerns
Employees are encouraged to report any incident of sexual harassment as soon as possible.
Employees are also encouraged to report situations where they have felt at risk of sexual harassment, even where no specific incident has occurred.
Concerns may be raised whether the conduct relates to:
- another employee
- any individual connected with the end-user client
- any recruitment agency personnel
Reports can be made:
- to the Company at workplaceconcerns@keyportfolio.com
- where appropriate, to the recruitment agency responsible for the assignment
Reports may be made by:
- the individual affected
- a witness
- a colleague acting on behalf of another person
Reports are encouraged to include:
- details of the incident
- dates and locations
- names of individuals involved
- details of any witnesses
- copies of relevant communications where available
No person will suffer detriment, retaliation, or victimisation for raising a genuine concern in good faith.
9. Confidentiality
All complaints and investigations will be handled as confidentially as possible, taking into account the need to conduct a fair investigation and comply with legal obligations.
Information will only be shared with individuals who need to know in order to:
- investigate the matter
- protect individuals
- comply with legal obligations
All individuals involved in investigations are expected to maintain confidentiality.
10. Victimisation
Victimisation occurs where a person suffers a detriment because they:
- raised a complaint
- supported another person’s complaint
- participated in an investigation
- raised concerns about conduct covered by this policy
Victimisation is prohibited and may result in disciplinary action.
11. Investigation Procedure
All reports will be assessed promptly and fairly.
Depending on the circumstances, the Company may:
- conduct an internal investigation
- liaise with the recruitment agency
- liaise with the end-user client
- request documentation or witness statements
- implement temporary safeguarding measures
- suspend individuals or assignments where appropriate
Investigations will normally include:
- initial review of the complaint
- gathering evidence
- interviews with relevant individuals
- assessment of findings
- decision on appropriate action
The Company will aim to complete investigations without unreasonable delay.
Where allegations involve safeguarding-sensitive environments, including schools, the Company may also consider:
- safeguarding obligations
- client safeguarding procedures
- referral obligations where appropriate
The Company reserves the right to involve external advisors where necessary.
12. Outcomes and Disciplinary Action
Where allegations are upheld, the Company may take appropriate action including:
- informal resolution
- formal warnings
- removal from assignments
- mandatory training
- disciplinary action
- dismissal
- termination of contractual arrangements
- notification to relevant recruitment agencies or end-user clients
Where allegations involve third parties, the Company may request action from the relevant organisation.
If an allegation is found to be deliberately false or malicious, disciplinary action may also be taken.
13. Training and Prevention
The Company is committed to taking proactive steps to prevent sexual harassment.
Preventative measures may include:
- regular policy reviews
- annual training for head office staff
- communication of behavioural expectations
- reporting mechanisms
- monitoring workplace risks
- engagement with agencies and end-user clients regarding standards of conduct
- periodic assessments of workplace and assignment-related risks relating to sexual harassment
- implementation of appropriate preventative measures where reasonably practicable
- periodic reminders to employees of this policy and the available reporting procedures
Employees may also receive guidance or awareness information where appropriate.
14. Online and Remote Working Conduct
This policy applies to remote and online working environments.
Unacceptable conduct includes:
- inappropriate messages
- sharing offensive material
- sexual comments during video calls
- harassment through messaging applications or social media
- intrusive or offensive online behaviour connected to work
Employees are expected to maintain professional standards in all work-related communications.
15. Record Keeping
The Company will maintain records relating to:
- complaints
- investigations
- training
- preventative actions
- outcomes
Records will be retained in accordance with data protection obligations and the Company’s Privacy Policy.
16. Policy Review
This policy will be reviewed regularly and may be amended from time to time to reflect:
- changes in legislation
- regulatory guidance
- operational requirements
- lessons learned from investigations, employee feedback, or workplace trends
17. Further Support
Employees requiring support or guidance relating to this policy may contact the Company using the designated workplace concerns email address.
Independent information, advice, or support is available from external organisations including:
This policy is reviewed regularly and may be updated from time to time.