1. Policy Statement
   • IWA wishes to provide a safe and supportive working environment for everyone that works for us. Such an environment cannot exist where any employee or volunteer is subjected to harassment, intimidation, aggression, victimisation or coercion.
   • We recognise that sexual harassment is unlawful under the Equality Act 2010. It is unacceptable and will not be tolerated.
   • The law requires employers to take reasonable steps to prevent sexual harassment of their employees and volunteers. IWA will be responsible for ensuring everyone understands the rules and policies relating to the prevention of harassing behaviour at work and during work-related social events.
   • IWA recognises that sexual harassment can exist in the workplace, and this can seriously affect employees and volunteers’ working lives by interfering with their job performance or by creating a stressful, intimidating and unpleasant working environment. IWA trustees, committee chairs and employee managers operate an open-door policy, and our employees and volunteers should feel empowered to raise any complaints or concerns if they see or experience inappropriate behaviour.
   • IWA will treat all complaints of sexual harassment seriously and will investigate them promptly and in confidence. We recognise that we have a duty to implement this policy, and all employees and volunteers are expected to comply with it.
   • IWA undertakes to review this policy at regular intervals so that it can monitor its effectiveness.
   • Instances of sexual harassment or victimisation may lead to disciplinary action up to, and including, termination of employment or position.

2. Definitions of Sexual Harassment and Victimisation
   • Sexual harassment is unwanted conduct 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.
   • Sexual harassment also covers treating someone less favourably because they have submitted to, or refused to submit to, unwanted conduct of a sexual nature or in relation to gender reassignment or sex.
   • Sexual harassment may be persistent or an isolated incident, obvious or subtle, face-to-face or indirect.
   • Examples of behaviour which may constitute sexual harassment include (but are not limited to):
     • unwelcome sexual advances or physical contact;
     • sexual comments, intrusive questions or offensive or embarrassing jokes;
     • physical assault;
     • abusing a position of power, e.g. by making promises in exchange for sexual favours;
     • blocking promotion or leadership roles, or access to development or training opportunities;
     • cyber-bullying, e.g. sending offensive and/or sexually explicit emails, texts or visual images, or posting embarrassing images on social media;
     • displaying sexually graphic pictures or photos;
     • suggestive looks, staring or leering; or
     • spreading sexual rumours about an individual.
   • Victimisation is subjecting an individual to detriment because they have done, are suspected of doing, or intend to do, an act which is protected under discrimination and harassment laws. These are:
     • making a claim or complaint under the Equality Act;
     • helping another individual to make a claim by giving evidence or information in connection with proceedings under the Equality Act; and
     • alleging that someone has breached the Equality Act.
   • Examples of victimisation may include:
     • not considering an individual for promotion or leadership roles, or access to development or training opportunities because they have previously made a complaint of sexual harassment;
     • dismissing an individual because they accompanied a colleague to a meeting about a sexual harassment complaint; or
     • excluding an individual from meetings because they gave evidence as a witness for another employee as part of a sexual harassment employment tribunal claim.

3. Unlawful Grounds of Sexual Harassment
   • IWA reiterates that it will not tolerate any instance of sexual harassment, regardless of the grounds. This Policy will equally apply to work related events, even if they occur away from the normal workplace.
   • Harassment may be committed by a fellow employee, volunteer or a third party and it does not need to occur in person, e.g. it can occur digitally (WhatsApp, social media sites, etc).

4. Reporting Harassment
   • Employees and volunteers have the right to complain if they are treated in a way that they believe constitutes sexual harassment or victimisation. The informal and formal procedures to follow are set out below.
   • Employees and volunteers who make a genuine complaint under this policy will not be subjected to any unfavourable treatment or victimisation because of making the complaint.

5. Witnessing Harassment or Victimisation
   • If an employee or volunteer sees sexual harassment or victimisation taking place, they should take appropriate action to address it. If the employee or volunteer is unable to intervene to prevent the action, they should encourage the persopn who is being harassed or victimised to report the incident, or they should report the incident themselves.
   • Reports of incidents should be made in writing to any trustee or senior employee.

6. Third party harassment
   • IWA operates a zero-tolerance policy in relation to sexual harassment of its employees and volunteers by a third party, such as a member, supplier or visitor. The law requires employers to take steps to prevent sexual harassment by third parties and we are committed to doing so.
   • All employees and volunteers are encouraged to report any instances of harassment involving a third party in line with the reporting procedure set out below.
   • In order to prevent third-party sexual harassment from occurring, IWA will draw it to the attention of third parties where appropriate to do so.
   • If an allegation of harassment by a third party proves to be well-founded, steps taken by IWA may include:
     • warning the individual and/or any organisation they represent about the inappropriate nature of their behaviour;
     • banning the individual from IWA’s premises and activities; and
     • reporting the individual’s actions to the police.

7. Procedure for Complaints

IWA is committed to ensuring that there is no sexual harassment or victimisation in our workplace.

• Any employee or volunteer who feels that they have been subjected to sexual harassment or victimisation should raise the matter as soon as reasonably practicable.
• Any employees or volunteer can raise a complaint. They should contact any trustee or senior employee. Any complaints will then be reviewed and addressed by the Management Committee or, if appropriate, by the board of trustees.
• Before raising a formal complaint, if they feel able to do so, the employee or volunteer is encouraged to talk directly and informally to the person whom they believe is harassing them, using the informal procedure below. It may be that the person whose behaviour is causing offence is genuinely unaware that their behaviour is unwelcome or causing distress and that a direct approach can resolve the matter without the need to use the formal procedure.

8. Informal Procedure
   • If the employee or volunteer feels able to do so, they should speak up at the time when they feel harassed. It is important to be direct and for the employee or volunteer to state explicitly that they feel they are being harassed and that the behaviour is unacceptable to them.  The employee or volunteer can also discuss the matter with another colleague, volunteer or their line manager and ask them to speak to the harasser on their behalf.
   • Alternatively, if the employee or volunteer feels unable to speak to the harasser directly, they could write a letter to them which clearly identifies the offending behaviour and requests that it stops immediately. The employee or volunteer should sign and date any such letter and ensure that a copy is kept for any possible future formal complaint.  It is also advisable that the employee or volunteer keep an ‘incident diary’ of any offending behaviour.
   • Where the informal procedure has not resolved an employee’s or volunteer’s complaint, a formal grievance can be raised by the employee or volunteer.

9. Formal Procedure
   • Any employee or volunteer who feels that they have been subjected to sexual harassment may at any time decide to deal with the issue through formal procedures (using IWA’s grievance procedure), regardless of whether informal steps have been taken or not.
   • When bringing a complaint of sexual harassment, the employee or volunteer should state:
     • The name of the person whose behaviour is believed to amount to sexual harassment;
     • The behaviour that is causing offence, with specific examples;
     • Dates and times when incidents of sexual harassment occurred;
     • The names of any employees and/or volunteers who witnessed any incidents;
     • Details of any action the employee or volunteer has taken to try and address the harassment.
   • IWA will investigate any complaint thoroughly and fairly.
   • An employee accused of sexual harassment will be informed of the exact nature of the complaint against them and given a full opportunity to give their version of events.
   • During the investigation, IWA reserves the right to suspend or temporarily redeploy either the employee or volunteer making the complaint of sexual harassment, or any employee or volunteer suspected of sexual harassment. For employees, suspension will be on full pay and will not be a disciplinary sanction. As soon as the investigation is complete, IWA will inform the employee or volunteer suspected of sexual harassment of the outcome and decide if it is appropriate to start disciplinary proceedings.
   • On conclusion of the investigation, a report of the findings will be submitted to a nominated trustee or member of the Management Committee who will hold a grievance meeting. The employee or volunteer who has made the complaint will be invited to attend a meeting to discuss the matter. The meeting will be held in accordance with IWA’s grievance policy.
   • If, following the hearing, it is decided that the allegation is well-founded, the harasser will be subject to disciplinary action up to, and including, dismissal in accordance with IWA’s disciplinary procedure.
   • IWA is committed to ensuring employees and volunteers are not discouraged from using this procedure and no employee or volunteer will be disadvantaged or subjected to disciplinary action for having brought a complaint, unless they have done so with clear malicious intent and – after investigation – without any basis in fact.

10. Consequences of Breach
    • Sexual harassment is a disciplinary offence and will be dealt with according to IWA’s disciplinary procedures. Sexual harassment or victimisation may constitute gross misconduct, punishable by summary dismissal without notice.
    • Employees and volunteers should bear in mind that harassment may also constitute a criminal offence punishable by a fine and/or imprisonment.

11. Responsibilities of Employees, Volunteers and Managers
    • IWA requires its employees and volunteers to always behave appropriately and professionally.
    • All employees and volunteers are responsible for their own behaviour and should ensure that they always comply with this Policy.
    • All trustees, committee chairs and managers are responsible for implementing this Policy and bringing it to the attention of employees and volunteers.
    • Any complaints under this Policy brought to the attention of a trustee or member of the Management Committee must be dealt with promptly, confidentially, fairly and consistently.
    • Any form of 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 a social event; or
      • against a colleague or other individual connected to IWA outside of a work situation, including on social media.

12. Training
    • IWA will provide written guidance to all employees and volunteers on sexual harassment and victimisation to ensure there is a clear understanding of:
      • what sexual harassment and victimisation is;
      • expected levels of behaviour;
      • how employees and volunteers can report any incidents of having been harassed or having witnessed such incidents; and
      • how acts of sexual harassment will be dealt with under the disciplinary procedure, which can potentially result in dismissal.
    • In addition, IWA will ensure that all trustees, committee chairs, members of the Management Committee and senior staff are properly briefed on implementing this policy.

13. Confidentiality
    • IWA will treat any complaint received under this Policy confidentially.
    • All employees and volunteers involved with an investigation are required to respect the need for confidentiality.
    • IWA will maintain records of investigations into alleged incidents of sexual harassment and the outcome of the investigations. These records will be maintained in confidence and in line with IWA’s Data Protection Policy.
    • Any breaches in confidentiality will be subject to disciplinary action.

This Policy was approved by trustees on 5^th February 2025

See also Risk Assessment for Prevention of Sexual Harassment, noted by trustees on 5th April 2025