Dignity at Work and Preventing Sexual Harassment

1. Purpose

Everyone who works for Care Cove has the right to be treated with dignity and respect. We ask staff to model the Respect Code for learners every day, and we hold ourselves to it as an employer. This policy explains what bullying, harassment and sexual harassment are, the steps we take to prevent them, how to report them and how we respond. We do not tolerate any of them, and we will act on every report.

2. Scope

This policy protects employees, agency staff from First Class Teachers, counsellors from My Solution Wellbeing, coaches, sessional tutors, volunteers, students on placement, members of the Social Work Management Committee (SWMC) and job applicants. It covers behaviour by colleagues, managers and the Director, and by third parties such as parents, visitors, contractors and partner staff. It applies on site, at outdoor classrooms, on home visits and journeys, at training and social events, and online, including messaging apps and social media outside working hours where it affects work.

It does not cover an adult's behaviour towards a learner: any sexual behaviour by an adult towards a learner is a safeguarding allegation under the Managing Allegations Against Staff and Low-Level Concerns policy (section 12). Learners' behaviour towards each other follows the Anti-Bullying policy.

3. Law and guidance

• Equality Act 2010: harassment, including sexual harassment and less favourable treatment for rejecting or submitting to it (section 26); victimisation (section 27); the employer's duty to prevent sexual harassment (section 40A).

• Worker Protection (Amendment of Equality Act 2010) Act 2023, which created the section 40A duty from 26 October 2024.

• Employment Rights Act 2025 (see sections 6, 14 and 15).

• Protection from Harassment Act 1997 (a course of harassing conduct is a crime and a civil wrong).

• Public Interest Disclosure Act 1998 and the Employment Rights Act 1996 (whistleblowing).

• EHRC technical guidance on sexual harassment and harassment at work (updated 2024).

• Keeping Children Safe in Education 2026.

• The equality and conduct requirements of our contracts with commissioning local authorities, including that staff are considerate and respectful.

4. Roles and responsibilities

5. What we mean

Fair, respectful management, such as clear instructions, honest feedback in supervision or a capability process, is not bullying.

6. Our legal duty

Since 26 October 2024, employers have had a legal duty to take reasonable steps to prevent sexual harassment of their workers. From 30 October 2026, the Employment Rights Act 2025 strengthens this to a duty to take all reasonable steps, and makes employers liable for harassment of their workers by third parties, such as parents, visitors and contractors, unless they took all reasonable steps to prevent it. We work to the higher standard now. Section 7 sets out the steps we take, and we review them every year.

7. The steps we take

1. Harassment risk assessment. The Director assesses where harassment could happen, with staff input, and reviews it every year and after any report. It covers one-to-one work, home visits, community settings, our shared building, contractors, parents in distress, learners' sexualised or aggressive behaviour, power imbalances in a small team (including staff who are related), staff group chats and social events. Each risk has actions, an owner and a date.

2. Training. All staff complete dignity at work and sexual harassment training at induction and every year after. Managers have an extra session on receiving reports, interim measures and avoiding victimisation. Completion is on the Connect training matrix.

3. Clear reporting routes, including one outside the management line (section 8).

4. Protection from victimisation. Victimising anyone who reports, supports a report or gives evidence is a disciplinary matter and can be gross misconduct.

5. Support for anyone who reports or is affected (section 9).

6. Fair, prompt investigation, with sanctions through the Disciplinary, Capability and Grievance policy.

7. Clear expectations of third parties (section 10).

8. Monitoring. The Director reports anonymised data to the SWMC every term (section 17).

8. How to report

If you are in danger or a crime has happened, call 999 (or 101 if it is not an emergency).

You can report to:

• your line manager or the Head of AP;

• the Director;

• the SWMC Chair, the route outside the line. Use it for any report about the Director, or if you prefer not to use the line.

A report about an SWMC member goes to the Director and the SWMC Chair (another SWMC member if it concerns the Chair). You can report in any form, and you do not need proof. Keep notes, dates and screenshots if you can. You may bring a colleague or trade union representative to any meeting. Anonymous reports are considered, but are harder to investigate. If you witness harassment, please report it too.

If you feel able and it is safe, you can tell the person their behaviour is unwelcome, or ask a manager to. You never have to do this first.

9. How we respond

1. The same day. The report goes to the Director (or the SWMC Chair) and is recorded in a restricted log on Care Cove Connect that only they can see. The person reporting is offered support, including confidential counselling from My Solution Wellbeing, or another provider if a My Solution Wellbeing worker is involved. If a learner is involved or a child may be at risk, the DSL is told at once.

2. Within 3 working days. The Director meets the person, explains the options and agrees interim measures, such as separate rotas or groups, or a no-contact instruction. The person reporting is never moved or disadvantaged without their agreement. Suspension of the person accused is considered as a neutral act under the Disciplinary, Capability and Grievance policy.

3. Investigation. Someone with no involvement investigates, using the steps and timescales in that policy. For a report about the Director, the SWMC Chair appoints an independent investigator.

4. Outcome. Both people are told the outcome in writing, as far as confidentiality allows, with the right of appeal. Harassment, sexual harassment and victimisation can be gross misconduct. Where the behaviour happened in front of learners, the Director also reports it to the commissioning local authority as its contract requires.

5. Follow-up. The Director checks in with the person who reported after 4 weeks and 3 months, to make sure the behaviour has stopped and they have not been victimised.

Nobody faces action for a report made honestly, even if it is not upheld. A report known to be false may be a disciplinary matter.

10. Third parties

Parents, carers, visitors, contractors, drivers, partner staff and others in our shared building must treat our staff with respect.

• Prevention. Our expectations are stated at visitor sign-in and in partner and contractor agreements. Visitors are signed in and escorted (Site Security, Visitors and CCTV policy). Meetings with a parent where there is a known risk take place with two staff, and home visits follow the home visit protocol.

• In the moment. You can end a call or meeting, walk away and get a colleague. Call 999 if anyone is at risk.

• Afterwards. Record it on Connect the same day and tell your manager, who makes sure you are supported. The Director may write to the person setting out our expectations, limit contact to planned meetings with two staff, restrict access to the building, raise it with their employer, end a contract, and report crimes to the police.

• The learner keeps their place. A parent's behaviour never costs a learner their place; family work continues through a named manager.

You will never be blamed for a third party's behaviour, or told it is part of the job.

11. When the behaviour comes from a learner

Some learners make sexualised or abusive comments or gestures to staff, touch them, or send messages or images. They are still children, and many have experienced harm. Our response is child-centred and supports the member of staff.

• Respond calmly using the Behaviour, Rewards and Restorative Practice policy (for a comment, usually a private Reminder), keep yourself safe and get a colleague if you need one.

• Record it on Connect the same day and tell the DSL. Sexualised behaviour can be a sign of abuse, exploitation, exposure to pornography or harmful sexual behaviour, and the DSL decides on any safeguarding action under the Safeguarding and Child Protection policy.

• Any nude, semi-nude or deepfake image, including an AI-generated image of a member of staff, goes straight to the DSL. Do not copy or forward it.

• The learner's plan is reviewed at the weekly multidisciplinary meeting, taking account of their age, SEND, history and understanding. We never exclude. The DSL decides whether to involve the police, considering the welfare of both the learner and the member of staff.

• The member of staff is never blamed. They have a same-day debrief, wellbeing support, and a change of key learners or groups for a while if they want it, which is never seen as failure.

12. Adults and learners

Any sexual behaviour by an adult towards a learner, including comments, messages, images, touching or any relationship, is a safeguarding allegation. Tell the Director the same day, or the SWMC Chair if it is about the Director. The Managing Allegations Against Staff and Low-Level Concerns policy applies, including contact with the LADO within 1 working day. It is never handled under this policy.

13. Relationships at work

We do not stop consensual relationships between colleagues. You must declare a close personal relationship with a colleague in writing to the Director (the SWMC Chair if it involves the Director) where one of you manages the other or it could affect safeguarding decisions, as the Staff Code of Conduct requires. It is recorded in the conflicts register and may lead to changes in line management, rotas or decision-making (Conflicts of Interest policy). Behaviour at work stays professional and never happens in front of learners. Continuing advances after someone has said no, or pressure from someone in a more senior role, is harassment.

14. Confidentiality and agreements

Reports are shared only with those who need to know. We cannot promise total confidentiality where safety or the law requires us to act, but we will tell you who needs to know and why.

We will never use a settlement, non-disclosure or other agreement to stop anyone reporting harassment, making a protected disclosure, going to the police or a regulator, or getting advice from a lawyer, doctor, counsellor or trade union. The Employment Rights Act 2025 will make clauses that stop workers alleging or disclosing harassment or discrimination void from a date in 2027 still to be set. We already follow that standard.

15. Whistleblowing

Since 6 April 2026, information showing that sexual harassment has happened, is happening or is likely to happen is one of the kinds of wrongdoing covered by whistleblowing law. A worker who reports it can be protected from detriment as a whistleblower. You can use the routes in this policy or in the Whistleblowing policy.

16. Help outside Care Cove

You can also seek advice from a trade union or a solicitor. Most employment tribunal claims must be started within 6 months (from 1 October 2026), after first contacting Acas for early conciliation.

17. Monitoring and review

The Director owns this policy and the Social Work Management Committee ratifies it. Each term the Director reports anonymised data to the SWMC: the number and type of reports, whether they came from a colleague, a third party or a learner, outcomes, timescales and any victimisation concerns. Small numbers are combined so nobody can be identified. The SWMC reviews the harassment risk assessment every year. The policy is reviewed every year, or sooner after a report, a change in law (including later stages of the Employment Rights Act 2025) or a contract change.

18. Related policies

• 03 Managing Allegations Against Staff and Low-Level Concerns
• 04 Whistleblowing
• 07 Behaviour, Rewards and Restorative Practice
• 18 Equality, Diversity and Inclusion
• 21 Staff Code of Conduct
• 28 Site Security, Visitors and CCTV
• 29 Anti-Bullying
• 31 Conflicts of Interest
• 32 Disciplinary, Capability and Grievance
• 33 Staff Supervision, Appraisal and Training
• 42 Lone Working

Document control and ratification

This policy is signed off by the Designated Safeguarding Lead and the Head of Alternative Provision, and ratified by the Social Work Management Committee. It is reviewed every year, or sooner after an incident or a change in law, statutory guidance or contract requirements, and it is available to any commissioning local authority on request.