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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Handling and Prevention of Bullying and Harassment Policy

1. Purpose

At {{org_field_name}}, we are committed to fostering a safe, respectful, and inclusive environment for all employees, service users, and stakeholders. Bullying and harassment in any form are unacceptable and will not be tolerated. This policy sets out how {{org_field_name}} will prevent, identify, report, investigate and respond to bullying, harassment, sexual harassment, discrimination, victimisation and any related improper treatment within our supported living services. It applies in a way that supports compliance with the Equality Act 2010, the Health and Social Care Act 2008 and the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including Regulation 10 (Dignity and Respect), Regulation 13 (Safeguarding Service Users from Abuse and Improper Treatment), Regulation 16 (Receiving and Acting on Complaints), Regulation 17 (Good Governance), Regulation 18 (Staffing) and, where applicable, Regulation 20 (Duty of Candour).

We recognise that bullying, harassment and sexual harassment can place staff, service users and others at risk of emotional harm, unsafe care, discriminatory treatment, distress, disengagement from services, and a closed or fearful culture. We are committed to a culture where people can raise concerns safely, are listened to, and do not suffer retaliation for speaking up.

Our objectives are to:

• Prevent bullying and harassment through education, training, and awareness.
• Provide a clear reporting structure for individuals to raise concerns without fear of retaliation.
• Take swift and appropriate action when incidents occur.
• Promote a positive and respectful work culture where every individual is treated with dignity.

2. Scope

This policy applies to all employees, workers, agency staff, bank staff, volunteers, students, contractors, consultants, managers, directors, visitors and any other person working for or representing {{org_field_name}}.

It also applies to service users, relatives, advocates, representatives and other third parties who interact with our staff or services.

This policy covers bullying, harassment, sexual harassment, discrimination and victimisation in any direction, including:

• staff towards staff;
• managers towards staff;
• staff towards service users;
• service users towards staff;
• relatives, visitors, advocates or professionals towards staff;
• staff towards third parties;
• conduct by third parties towards workers, including sexual harassment.

This policy applies in the workplace, in supported living settings, in service users’ homes, during visits, travel, training, meetings, supervision, work-related social events, and in online, telephone, text, email, messaging or social media communications where the conduct affects work, care, safety, dignity, wellbeing or professional relationships.

3. Definitions

3.1. Bullying

Bullying is offensive, intimidating, malicious or insulting behaviour, or an abuse or misuse of power, that has the purpose or effect of undermining, humiliating, denigrating or injuring a person. Bullying is often repeated, but a serious one-off incident may also be addressed under this policy where it has caused or could cause significant harm, distress, fear, unsafe practice or damage to dignity. It may include:

• Verbal abuse, such as insults, shouting, or belittling comments.
• Non-verbal abuse, including threatening gestures, exclusion, or intimidation.
• Undermining someone’s confidence, spreading rumours, or deliberately sabotaging work.
• Unjustified criticism or setting impossible expectations.

3.2. Harassment

Harassment is unwanted conduct that violates a person’s dignity or creates an intimidating, hostile, or degrading environment. It may be related to:

• Protected characteristics under the Equality Act 2010, including age, disability, gender reassignment, race, religion or belief, sex, sexual orientation, marriage and civil partnership, and pregnancy and maternity.
• Sexual harassment, including inappropriate comments, advances, or touching.
• Cyber harassment, such as online abuse or persistent messaging.
• Racial or cultural discrimination, including offensive remarks or exclusion.

Harassment may be a single incident or a repeated pattern of behaviour and is unlawful under the Equality Act 2010.

3.3 Sexual Harassment

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 them. It can include comments, jokes, gestures, staring, messages, images, sexual advances, touching, coercive behaviour or conduct by third parties such as service users, relatives, visitors or professionals.

3.4 Victimisation / Retaliation

Victimisation means subjecting someone to a detriment because they have made, supported or are believed to have made or supported a complaint or allegation under this policy, raised a safeguarding concern, acted as a witness, or done anything else in connection with equality, harassment, bullying, complaints or speaking-up processes. Retaliation against a person who raises a concern in good faith is prohibited.

3.5 Improper Treatment of Service Users

Improper treatment includes degrading treatment, discriminatory treatment, neglect, psychological abuse, verbal abuse, humiliating behaviour, or any care or support delivered in a way that disregards the service user’s dignity, safety, wishes or rights.

4. Prevention Measures

At {{org_field_name}}, we take proactive steps to prevent bullying and harassment, including:

4.1. Staff Training and Awareness

• All employees receive mandatory training on recognising, preventing, and responding to bullying and harassment. This includes understanding the impact of workplace harassment and how to create a supportive work environment.
• Regular refresher courses and workshops reinforce best practices, keeping staff informed of changes in legislation, company policies, and best practices.
• Managers receive specialist training on handling complaints, conflict resolution, and fostering a respectful workplace culture.
• Training includes real-life case studies, role-playing exercises, and interactive discussions to enhance awareness and preparedness.
• Employees are educated on bystander intervention techniques, encouraging staff to act responsibly and support colleagues facing bullying or harassment.

Training must include bullying, harassment, sexual harassment, equality, professional boundaries, dignity and respect, recognising closed cultures, bystander action, reporting options, safeguarding responsibilities, record keeping and how to escalate concerns where a manager is involved.

4.2. Sexual Harassment Prevention

{{org_field_name}} will take reasonable steps to prevent sexual harassment of workers. This includes carrying out and reviewing risk assessments, considering risks from third parties, identifying high-risk situations such as lone working, home visits, out-of-hours work, personal care, transport and digital communications, putting preventative measures in place, clearly communicating behavioural expectations, and monitoring whether those measures are effective.

4.3. Promoting a Positive Workplace Culture

• Encouraging open communication and mutual respect among staff and service users through regular team meetings and one-on-one discussions.
• Implementing zero-tolerance policies, ensuring everyone understands our stance on bullying and harassment.
• Encouraging teamwork, inclusion, and collaboration to prevent hostility, including initiatives such as peer mentoring and staff recognition programs.
• Leadership and senior management set an example of professionalism and respectful behaviour, reinforcing an inclusive workplace culture.
• Establishing a clear Code of Conduct that outlines expected behaviours and the consequences of bullying and harassment.

4.4. Speaking Up, Whistleblowing and No Detriment

{{org_field_name}} will maintain a culture in which staff can speak up about bullying, harassment, unsafe practice, discrimination, poor culture or improper treatment without fear of disadvantage. Concerns raised in good faith will be taken seriously, investigated appropriately, handled as confidentially as possible, and used to improve the service. Retaliation against anyone who speaks up or participates in an investigation is prohibited and may result in disciplinary action.

4.5. Risk Assessments and Monitoring

• Regular staff and service user surveys to identify concerns, monitor well-being, and assess workplace morale.
• Anonymous reporting mechanisms allow staff to voice concerns without fear of retaliation, providing a safe space to report issues confidentially.
• Routine evaluations of workplace dynamics to detect any patterns of conflict or potential bullying behaviours before they escalate.
• One-on-one check-ins with employees and service users to assess their experiences and address concerns proactively.
• Continuous review of policies to adapt to new risks, regulatory changes, and best practices, ensuring compliance with employment law and CQC standards.
• Implementing early intervention strategies, such as mediation services, to address issues before they escalate into serious conflicts.

Monitoring must include review of complaints, grievances, disciplinary cases, safeguarding concerns, whistleblowing, exit interviews, sickness trends, agency feedback, supervision themes and any pattern involving protected characteristics, teams, locations, service users or third parties.

5.1. Reporting Concerns

Any person who experiences, witnesses or becomes aware of bullying, harassment, sexual harassment, discrimination, victimisation or improper treatment must report it as soon as possible.

Concerns may be raised to:

1. the Registered Manager;
2. the Safeguarding Lead;
3. the Nominated Individual / senior manager / director where the concern involves the Registered Manager;
4. HR or the person responsible for employee relations, where applicable;
5. through the whistleblowing / speaking up process where the person does not feel able to use line management routes;
6. through the complaints process where the concern is raised by a service user, family member, advocate or representative; and
7. directly to external agencies where required, including the local authority safeguarding team, the police, CQC or other relevant bodies.

Where a concern indicates that a service user may be experiencing abuse, discrimination, degrading treatment or any other improper treatment, staff must treat it as a safeguarding matter and take immediate action in line with safeguarding procedures.

No person will be subjected to retaliation, disadvantage or detriment for raising a concern in good faith or participating in an investigation.

5.2. Investigation Process

All concerns raised under this policy will be risk-assessed promptly on receipt. The first consideration will be whether there is any immediate risk to a service user, worker or other person, and whether urgent safeguarding action, changes to staffing, temporary redeployment, supervision measures, medical support or police involvement are required.

The organisation will determine the correct process for the concern, which may include one or more of the following: safeguarding enquiry or referral, complaints handling, informal resolution, formal investigation, disciplinary process, capability process, grievance process, whistleblowing review, or referral to an external body.

Investigations will be fair, proportionate, timely, trauma-informed where appropriate, and carried out by a person with sufficient independence and competence.

The organisation will keep accurate, complete and contemporaneous records of the concern, actions taken, evidence considered, decisions reached, support offered, communication with the parties, and any learning or service improvements identified.

Both the person raising the concern and the person whose behaviour is being questioned will be treated fairly. Each will be given appropriate information about the process, an opportunity to provide their account, and appropriate support.

At the end of the process, the organisation will confirm the outcome, any action taken, any safeguarding or quality improvements required, and whether the matter must be monitored further.

The organisation will also consider whether the matter triggers any wider duties, including duty of candour, safeguarding notifications, CQC notifications, contractual reporting or referral to professional bodies.

Where the concern is upheld, action may include apology, mediation where appropriate, support plans, supervision, additional training, risk controls, disciplinary action, safeguarding action, referral to external agencies, environmental or service changes, and wider lessons learned across the organisation.

5.3. Safeguarding and External Escalation

Any concern involving a service user that suggests abuse, discriminatory treatment, degrading treatment, neglect or other improper treatment must be considered under safeguarding procedures immediately. The organisation will refer concerns externally where required, including to the local authority safeguarding team, the police, CQC, commissioners, landlords, professional regulators or other appropriate bodies. Records must clearly show what was identified, what action was taken, who authorised decisions, and why.

5.4. Support for Those Involved

Appropriate support will be offered to those involved, including service users, staff, witnesses and managers. This may include welfare checks, advocacy, EAP or counselling signposting, supervision, debrief, temporary changes to duties, communication support, and reasonable adjustments where required.

5.5. Learning, Governance and Audit

All cases, whether upheld or not, will be reviewed to identify lessons, themes, required actions and opportunities to improve culture, dignity, safety and reporting confidence. Themes will be reported through governance arrangements and used to inform training, supervision, quality assurance and service improvement.

6. Responsibilities

6.1. Management Responsibilities

• Enforce this policy and act as role models by demonstrating respectful and professional behaviour in all interactions.
• Investigate reports impartially and promptly, ensuring all concerns are taken seriously and handled confidentially.
• Provide ongoing staff support and training, including refresher courses on preventing bullying and harassment.
• Maintain clear communication channels for employees and service users to raise concerns safely.
• Ensure appropriate disciplinary measures are in place and consistently applied when necessary.
• Monitor workplace culture through regular staff feedback and well-being assessments.
• Encourage mediation and conflict resolution before issues escalate into formal complaints.
• Ensure staff know how to raise concerns through complaints, safeguarding and speaking-up routes, including where their line manager is implicated.
• Take prompt action where any service user may be at risk of abuse, degrading treatment, discrimination or improper treatment.
• Maintain accurate records, oversight, trend analysis and evidence of learning, audit and service improvement.
• Review themes by protected characteristic, team, service location, service user group and third-party source to identify disproportionality or repeated risks.
• Consider whether external notification, referral or duty of candour obligations arise.

6.2. Employee Responsibilities

• Treat colleagues, service users, and stakeholders with respect, ensuring inclusivity and fairness in all interactions.
• Report concerns in good faith, without fear of retaliation, through designated reporting channels.
• Cooperate fully in investigations and conflict resolution efforts, ensuring honesty and transparency.
• Foster a supportive workplace culture by intervening when witnessing inappropriate behaviour and supporting colleagues who may be affected.
• Attend required training sessions on workplace respect, diversity, and bullying prevention.
• Adhere to company policies and professional codes of conduct at all times.
• Maintain professional boundaries with service users, relatives, visitors and colleagues.
• Immediately report any conduct that may amount to abuse, discriminatory treatment, degrading treatment, sexual harassment or retaliation.
• Make accurate records of incidents, disclosures, witnesses and actions taken, in line with recording requirements.

6.3. Service User Responsibilities

• Service users and their families should also treat staff with dignity and respect, recognising the professionalism and dedication of care workers.
• If concerns arise, they are encouraged to raise issues through the appropriate channels, such as formal complaints procedures, feedback forms, or direct discussions with management.
• Engage in open and respectful communication with staff members, fostering positive relationships and collaboration.
• Recognise and respect staff boundaries, understanding the importance of a professional and safe working environment.
• Participate in care discussions and decisions in a constructive and respectful manner, ensuring a person-centred approach to care delivery.

6.4 Senior Leadership / Provider Responsibilities

The Provider, Nominated Individual and senior leaders are responsible for ensuring that this policy is implemented effectively, monitored through governance systems, supported by training and supervision, reviewed against complaints and safeguarding data, and used to drive service improvement and a positive speaking-up culture.

7. Policy Review

This policy will be reviewed at least annually and sooner if required by legislative change, changes to CQC guidance, internal incidents, complaints, safeguarding concerns, whistleblowing matters, audit findings, inspection findings, case law developments or identified organisational risks. Reviews will consider whether the policy remains effective in practice, whether staff understand and use it, whether people feel safe to speak up, and whether further training, assurance or control measures are required.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.