It is the policy of VQ Solutions that employees and learners have the right to be treated with dignity and respect and to ensure that the
working environment is sympathetic to all its employees in accordance with our Equal Opportunities policy. Bullying or harassment causes
distress, and can also generate poor performance and illness or lead to accidents.

Unlawful discriminatory harassment or bullying of any type will not be condoned either at work or outside work if it has a bearing on the
working relationship.

The company welcomes the support of all staff, employers and learners in seeking to eradicate bullying and harassment from the


All employees have the right to work in an environment free from intimidation. Bullying is defined as any unwelcome or unsolicited act that
intimidates, humiliates, or undermines the individual involved.

Harassment at work on the grounds of race, sex, sexuality, religion (or belief) and age are all unlawful, as is harassment on the grounds of
gender reassignment or disability. Both the company and the harasser may be held liable for such unlawful actions, and be required to
pay damages. The effectiveness of the company is reduced by harassment and bullying creating a threatening environment, increasing
sickness absence and staff turnover.

Intentional racial or sexual harassment is also a criminal offence punishable by imprisonment or a fine.

Any manager who receives a complaint of, or is witness to, bullying or harassment, must investigate the situation and ensure that the
problem is resolved as quickly as possible.

Managers have a duty to establish and maintain a working environment free from bullying.

Employees must comply with the policy and take steps to ensure that bullying/harassment does not occur.

Any employee and learner who feels bullied should feel confident that complaints will be taken seriously and dealt with in confidence.

Examples of Bullying

  • Derogatory remarks
  • Public criticism
  • Insensitive jokes or pranks
  • Insulting or aggressive behaviour
  • Ignoring or excluding an individual
  • Withholding necessary information
  • Setting unrealistic deadlines
  • Substituting responsible tasks with menial or trivial ones
  • Constantly undervaluing effort

Examples of Harassment

  • Lewd comments about appearance
  • Unnecessary body contact
  • Displays of sexually offensive material, eg pin-ups
  • Requests for sexual favours
  • Speculation about a person’s private life and/or sexual activities
  • Threatened or actual sexual violence
  • Insensitive jokes related to race
  • Insensitive jokes relating to age
  • Deliberate exclusion from conversations
  • Abusive, threatening or insulting words and/or behaviour

The examples above are not exhaustive; some of the items will constitute gross misconduct punishable by summary dismissal, dependent
on the circumstances of the case in question. The actions listed above must be viewed in terms of the distress they cause the individual. It
is the perceptions of the recipient that determine whether any action or statement can be viewed as bullying/harassment.

The Environment

The display of sexually offensive material, eg pin-ups and posters is prohibited. Arrangements will be made for workplaces to be regularly
inspected and offending material removed.
All new employees will be informed, during induction training, of the company’s policy toward bullying and harassment and it will be
stressed that all complaints of bullying or harassment will be treated very seriously.
Managers and supervisors will ensure that this policy and procedure is applied at all times.
In recognising the sensitive nature of some of these complaints, the company has appointed the following people who will be available to
discuss potential complaints, being a source of advice and support for those employees who find it difficult to approach their immediate

Female employees should contact Annabel Gilmour

Male employees should contact Andrew Gilmour

Informal Procedure

If possible, the person who is the victim of bullying or harassment should tell the person being accused that the behaviour is offensive and
unwanted, and must stop. A colleague or personnel manager can act as a witness when this statement is made. Alternatively, an
appropriate line manager can speak to the alleged harasser.

Whenever possible, a complaint of bullying/harassment should be made in the first instance to the immediate line manager or supervisor.

Formal Procedure

Where informal methods fail, or the employee chooses not to use them or considers that the problem is sufficiently serious, a formal
a complaint can be made to a Director.

The complaint should be in writing and, and where possible, state:

  • The name of the harasser/bully
  • The nature of the incident/s, including dates and times when the alleged offence occurred
  • The names of witnesses to incidents
  • What, if any, action has already been taken by the complainant

A manager will be appointed to investigate the complaint.

Immediately a complaint of harassment has been received, action will be taken to separate the harasser from the complainant. This may
involve a temporary transfer of the harasser to another department or suspension with pay until the complaint has been resolved.

A thorough investigation will be carried out by the senior manager handling the complaint. This will be done as quickly as possible,
maintaining confidentiality at all times. All employees involved in the investigation are expected to respect the need for confidentiality.

Failure to do so will be considered a disciplinary offence.

The investigating manager will conduct confidential interviews with the person against whom the allegations are made, the complainant
and any relevant witnesses.

Copies of statements made by witnesses will be made available to the harasser and the complainant. Witnesses will be encouraged to
appear at the complaint hearing if requested by either party. It is acknowledged that some witnesses may be reluctant to attend and in
these circumstances the manager will, if necessary, adjourn the hearing to ask supplementary questions of witnesses in private.

The investigation should be concluded within four weeks of the complaint being received. If this time limit is exceeded, the complainant
should be advised of this and given a date when the investigation will end.

The investigating manager must keep a detailed written record of the investigation and the findings. Both the complainant and the
person(s) against whom the allegation has been made must be advised in writing of the findings.

If the complainant is dissatisfied with the outcome, or with the way in which the complaint was handled, then a written request for
reconsideration should be made to the next level of management within seven days of receiving the investigating manager’s decision.

Disciplinary Procedure

If disciplinary action is justified, a disciplinary hearing will be arranged within 10 working days of either the decision of the
investigating manager or if the matter was referred for reconsideration the decision of the next level manager.

Any disciplinary hearing will be conducted in line with the company disciplinary procedure.

Any disciplinary action taken will reflect the severity of the offence and may include the transfer of the employee accused of
bullying/harassment, on a temporary or permanent basis, or dismissal.

The severity of the penalty imposed upon an employee who is proved guilty of harassment will be consistent with those detailed in
the disciplinary procedure (e.g. gross sexual harassment will normally result in summary dismissal). Where a lesser penalty is
appropriate, (eg a written warning) this may be coupled with action to ensure that the victim is able to continue working without
embarrassment or anxiety. After discussion with the victim, the manager may order the transfer of the harasser to a different work
area, or arrange for the amendment of working practices; to minimise contact between the two employees. The result of the hearing
will be confirmed in writing to both employees.

The employee may appeal against the penalty in accordance with the disciplinary appeals procedure.

General Considerations

The appropriate line manager must ensure that any employee who makes a complaint of bullying is not victimised.

An employee who brings a complaint of sexual or racial harassment will not suffer victimisation for having brought the complaint.

Any complaints found to be false and malicious will result in disciplinary action being taken against the complainant.