Sexual Harassment in the Workplace Policy

1. Statement of Policy

• Dyfed-Powys Police is committed to providing an inclusive and welcoming environment for all officers, staff and volunteers, free of sexual harassment and victimisation and where everyone can feel supported, safe and reach their potential.
• Dyfed-Powys Police has a zero-tolerance policy in relation to sexual harassment.
• Sexual Harassment is unlawful under the Equality Act 2010.

The aim of this policy is to:

• Advise what constitutes sexual harassment
• Make clear the professional behaviour expected of all officers, staff and police support volunteers, cadets, contractors, workers and prospective job applicants.
• Empower those to raise a complaint by setting out a clear process.
• To support those who are affected by sexual harassment.
• Make clear the responsibility on the force and managers, to remove sexual harassment from the workplace.
• Make clear the expectation of all members to be an upstander, challenging sexual harassment if observed or otherwise believed to be happening in the workplace.
• To ensure individuals know the support available in Dyfed-Powys Police.

Applies (but not limited) to: All categories of Dyfed-Powys Police officers and staff, whether full-time, part-time, permanent, fixed term, temporary (including agency staff, associates and contractors), seconded staff and volunteers. Police Officers, staff and volunteers accessing and using Force assets and property must have due regard to the contents of this policy.

 

2.     Policy Scope

This policy applies to members of Dyfed-Powys Police, which includes Police Staff, Police Offciers including Student Officers, Special Constabulary, Police Support Volunteers, Cadets, Agency Staff, Associates and Contractors and Seconded Staff. 

 

3.     Powers and Policy/Legal Requirements

Sexual Harassment:

Occurs when a person engages in unwanted conduct of a sexual nature that has the purpose or effect of:

• Violating someone’s dignity, whether intended or not.
• Creating an intimidating, hostile, degrading, humiliating or offensive environment for them, whether intended or not.

Although anyone can experience sexual harassment, women are more likely to experience sexual harassment than men and perpetrators of sexual harassment are overwhelmingly men.

Victimisation:

When you are treated poorly or unfairly because you have made a complaint related to a protected characteristic or you have helped someone else who has raised a complaint and are seen to be siding with them and are then treated badly.

4.    Options and Contingencies

This Policy must be read in conjunction with:

• Dyfed-Powys Police – Police Staff Misconduct Procedure
• Dyfed-Powys Police Dignity in the Workplace Policy 2019
• Equality Act 2010 – Section 4 ‘Public Sector Equality Duty’.
• Dyfed-Powys Police Fairness at Work Policy.
• Police Conduct Regulations 2020
• Police Staff Misconduct Policy 2022

5.     Take action and review

This policy will be reviewed initially on an annual basis then biennially thereafter by People Services. All amendments to this policy will be approved by the People, Culture and Ethics Board. For further advice regarding this policy please contact People Services.

The review and any revisions will take account of:

• The policy’s effectiveness, as assessed by the People, Culture and Ethics Board and Internal/external audit
• Any changes to legislation/Home Office guidance
• Any identified inefficiencies in relation to implementation

 

6.    Responsibilities

We all have a responsibility to create and maintain a work environment free od harassment and victimisation and to treat our colleagues with dignity and respect. 

Individuals are responsible for - 

• Being aware of how their behaviour may affect others.
• Treating colleagues with dignity and respect.
• Taking a stand if inappropriate jokes, comments or gestures are being made.
• Making it clear to others when their behaviour is unacceptable.
• Intervening to stop sexual harassment and discreditable conduct and giving support to anyone who may have been harassed.
• Reporting harassment to a manager or professional standards and co-operating as required in investigations.
• If a complaint of harassment is made, not prejudging or victimising the complainant or alleged harasser.

Please note that simply ignoring and or/walking away from such incidents or refusing to get involved is not acceptable and may even be seen as collusion with allowing it to continue within the policing culture. 

 

Managers have a responsibilty to - 

• Implement the zero-tolerance policy on sexual harassment.
• Set a good example by their own behaviour.
• Ensure that there is a proactive and supporting working environment.
• Make sure that staff know the standard of behaviour that is expected of them.
• Intervene to stop bullying or harassment.
• Report promptly to senior management or Professional Standards Department any complaint of harassment, or any incident of harassment witnessed by them and ensure that appropriate steps are taken.

The force has responsibility to ensure that sexual harassment will not be tolerated in the workplace and that all complaints will be taken seriously, will be dealt with quickly and will be treated as serious disciplinary offences and may be considered as gross misconduct.

The Worker Protection (Amendment of Equality Act 2010) Act 2023 (Oct 26th, 2024) will impose a new legal obligation on employers to take reasonable steps to prevent sexual harassment in the workplace. This new proactive duty shifts the focus from merely responding to instances of harassment to actively working to prevent them.

To comply with this legislation Dyfed-Powys Police must demonstrate we have taken reasonable steps to prevent sexual harassment in our workplace.

Employers are expected to:

• Assess the risk of sexual harassment occurring during employment.
• Identify preventive actions that could mitigate those risks.
• Evaluate which steps are reasonable to implement.
• Implement those steps into practice.

• In addition to addressing sexual harassment between employees, the   preventative duty includes a duty to prevent sexual harassment by third parties such as customers, clients, service users, patients, friends and family of colleagues, delegates at a conference and members of the public. Employers should assess the potential risks posed by third-party interactions and take reasonable steps to protect their employees in those situations of such harassment.

There are five practical steps that as a force we will carry out.

1. Conduct risk assessments - much like health and safety, as an employer we must proactively assess the risk of sexual harassment occurring in the workplace. This involves identifying high-risk areas, such as lone working environments or roles with high interaction with third parties and reviewing any existing preventive measures. Regular updates to the risk assessment are crucial as workplace dynamics change.
2. We will foster an inclusive workplace culture - prevention is better than cure. A positive, inclusive workplace culture that promotes respect and zero tolerance for harassment is essential. We will foster this by:

• Ensuring visible support from our senior leadership.
• Regularly communicating harassment policies.
• Promoting a respectful and inclusive environment.

3. We will continue to ensure effective reporting and complaint mechanisms - employees must feel safe and supported in reporting harassment. We will establish clear, accessible reporting processes and ensure all complaints are taken seriously and handled professionally.  We will ensure continued messaging on our anonymous reporting tools to encourage more workers to come forward, knowing their concerns will be treated with confidentiality.

4. We will ensure we provide regular training - regular, tailored training on sexual harassment is essential for all staff, ensuring everyone understands what constitutes harassment, how to report it, and the consequences for those who breach policy. Beyond compliance, training should foster an environment of inclusivity and mutual respect.
5. We will monitor and evaluate progress - prevention efforts are not static. We will continuously monitor and evaluate the effectiveness of their harassment prevention measures.

 

7.     General

Sexual harassment can happen regardless of the individual’s or alleged perpetrators gender identity or sexual orientation.

The force recognises, however that women are significantly more likely to experience sexual harassment than men and that there is a gender equality issue in relation to sexual harassment.  If sexualised behaviour and sexual objectification of women is perceived to be tolerated in the workplace, it is more likely that sexual harassment will occur.

The force also recognises that there is also an issue of intersecting protected characteristics in relation to sexual harassment, and that there may be additional concerns for Black or Minoritised officers and staff, LGBT+, disabled and younger police officers, staff and volunteers where the harassment may be bound up with other forms of discrimination.

Sexual harassment in the workplace may occur from:

• Someone you work with.
• A manager, supervisor or someone else in a position of authority.
• A member of the public/visitor.

Sexual harassment includes a wide range of behaviours including but not limited to:

• Sexual comments or jokes.
• Displaying sexually graphic pictures, posters or photos.
• Suggestive looks, staring or leering.
• Propositions and sexual advances.
• Making promises in return for sexual favours.
• Sexual gestures.
• Uninvited discussion of one’s sex life or inappropriate discussion of sex life.
• Sexual posts or contact on social media.
• Spreading sexual rumours about a person.
• Sending sexually explicit emails or text messages.
• Unwelcome touching, hugging, massaging or kissing.
• Predatory behaviour.
• Criminal behaviour, including sexual assault, stalking, grooming, indecent exposure and sending offensive communications.

Sexual harassment is usually directed at an individual or minority group, but it’s not always the case.  It may be perpetrated by one individual, a pair, a small group, or to permeate through a whole section of the force.

Sometimes there can be a culture of sexual harassment in a workplace that’s not specifically aimed at one person – such as sharing sexual images and leering at members of the public.  Someone could still make a complaint of sexual harassment in this situation.

An individual can experience sexual harassment from someone of the same or different sex and the recipient of the behaviour decides whether the approach was unacceptable or undignified.

Sexual harassment can be a one-off event and does not need to be directed at a person.  It can be witnessed or overheard.  Sexual conduct that has been welcomed or tolerated in the past may, over time, become unwanted and if it continues becomes harassment.

Forces will be liable for sexual harassment committed by their officers, staff or volunteers during their employment/volunteering unless they can show that they took all reasonable steps to prevent the harassment. ‘In the course of employment’ includes acts committed in any other place where work is conducted such as offsite, at a training course, conference or external meeting, as well as other circumstances in which the officer, staff or volunteer is not actually working but relate to work such as at a leaving party or other social event.

8.     Force Responsibility/Taking Action   

Dyfed-Powys Police wants to provide a professional working environment for its officers, staff and volunteers and has a ‘duty of care’ to do so. 

Dyfed-Powys Police will ensure reasonable action is taken to prevent sexual harassment in the workplace and ensure that there is support available for anyone who feels they have had their dignity violated or where an individual(s) has/have created an intimidating, hostile, degrading, humiliating or offensive environment, whether intended or not.

Reasonable action includes:

• Setting standards and a culture so all are made aware that such behaviour will not be tolerated.
• Providing opportunities for teams to discuss sexual harassment and the importance of tackling unlawful and discriminatory practices.
• Ensuring there is a clear reporting process in place.
• Ensuring accusations are fully investigated and appropriate action taken.
• Ensuring support is available to individuals affected by sexual harassment.

9.     Setting Standards

Standards of professional behaviours are set by the Police Conduct Regulations 2020 the Police Staff Council Joint Circular 54 and the Codes of Ethics.

The Code of Ethics is a first for everyone who works in policing in England and Wales and sets out the principles and standards of behaviour we expect to see from police professionals.  It applies to every individual who works in policing, whether a warranted officer, member of police staff, volunteer or someone contracted to work in a police force.

For the purpose of this policy the following standards are highlighted:

• Members are expected to act with self-control and tolerance, treating members of the public and colleagues with respect and courtesy.
• Members should not abuse their powers or authority and respect the rights of all individuals.
• All members are to challenge and report improper conduct.

 

Everyone has the right to a working environment free of harassment, from others within the service and members of the public. Dyfed-Powys Police will proactivly support such a working environment. 

A breach of such standards could damage public confidence in the police service.

Any breach of any of the standards could potentially lead to disciplinary action, which in serious cases may result in dismissal without notice.

10. Training

Training and information is crucial to the success of policies on sexual harassment and in changing the workplace environment.

Training programmes should include:

• Details on the policy, its implementation and promotion.
• What misogyny, sexism and sexual harassment mean, their effects and consequences.
• What victimisation means.
• How to report incidents and unacceptable behaviour.
• How to address issues of third harassment if applicable.
• How to get support.
• The help available to those being harassed.

Records should be kept ensuring that everyone is trained and that they regularly receive refresher training.  Officers and staff should also be encouraged to help each other, either by lending support or informing management of their concerns through the appropriate channels.  The procedure should also make it clear that staff have the right to be accompanied by a staff association/trade union representative at all stages.

 

11.  Reporting Process

Individuals are encouraged to come forward if they believe they have been harassed.  Dyfed-Powys Police has robust procedures in place designed to take prompt action.

Wherever possible, Dyfed-Powys Police will try and ensure the individual and alleged harasser, are not required to work together whilst the complaint is under investigation.

Individuals who have been harassed should raise the issue with their Line Manager or if not appropriate then the Professional Standards Department.

If an individual becomes aware of sexual harassment between a colleague and another individual they must raise the issue with their Line Manager or if not appropriate the Professional Standards Department.

Sexual harassment can also give rise to situations where there is coercive or predatory behaviour.  If intimate relationships arise between colleagues and any person has concerns about any predatory or coercive element to such a relationship, they are encouraged to report the issue to their Line Manager or if not appropriate the Professional Standards Department.

Investigations into complaints or allegations of sexual harassment may also lead to a criminal investigation being instigated.  Where there are concerns that a criminal act has taken place, advice must be taken from the Professional Standards Department.  If a criminal act is suspected any action taken must avoid prejudicing the criminal investigation.  Appropriate action will be taken depending on the circumstances.

Any investigations into allegations of sexual harassment by police officers, police staff members, volunteers and contractors will be undertaken by the Professional Standards Department.

Confidentiality will be maintained, subject to any requirement to involve external agencies where a criminal offence may have been committed or where maintaining confidentiality would pose a risk to the person making the report or others.

 

12.  Misconduct Process

The alleged perpetrator, if a member of Dyfed-Powys Police will be fairly investigated through the appropriate process.

All complaints of sexual harassment will be taken very seriously.  Dyfed-Powys Police will handle any investigation in a way that’s fair and sensitive to:

• The person who made the complaint
• Someone who witnessed it
• Someone whose been accused of sexual harassment

An individual who sexually harasses someone at work will be held responsible for their actions and if a member of Dyfed-Powys Police, faces an investigation into their conduct at work this could result in disciplinary action up to and including summary dismissal.  In addition, they could be held personally liable to pay compensation in legal claims.

 

13. Support and advice for individuals

There are many sources of support available. These include:

• Line managers/Supervisors
• HR personnel
• Staff Association
• Police Federation
• Equality and Diversity Team
• Occupational Health Department
• TRIM
• Peer Support
• Staff Support Networks
• Dyfed-Powys Police Whistleblowing Policy

CODE OF ETHICS CERTIFICATE OF COMPLIANCE

This policy has been drafted in accordance with the Code of Ethics and has been reviewed on the basis of its content and the supporting evidence and it is deemed compliant with that Code and the principles underpinning it.

HUMAN RIGHTS ACT CERTIFICATE OF COMPLIANCE

This policy has been drafted in accordance with the Human Rights Act and has been reviewed on the basis of its content and the supporting evidence and it is deemed compliant with that Act and the principles underpinning it.

EQUALITY IMPACT ASSESSMENT

Section 4 of the Equality Act 2010 sets out the protected characteristics that qualify for protection under the Act as follows: Age; Disability; Gender Reassignment; Marriage and Civil Partnership; Pregnancy and Maternity; Race; Religion or Belief; Sex; Sexual Orientation.

The public sector equality duty places a proactive legal requirement on public bodies to have regard, in the exercise of their functions, to the need to:

• eliminate discrimination, harassment, victimisation, and any other conduct that is unlawful under the Act;
• advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;
• foster good relations between persons who share a relevant protected characteristic and persons who do not share it.

The equality duty applies to all protected characteristics with the exception of Marriage and Civil Partnership, to which only the duty to have regard to the need to eliminate discrimination applies.

Carrying out an equality impact assessment involves systematically assessing the likely or actual effects of policies on people in respect of all the protected characteristics set out above. An equality impact assessment should be carried out on any policy that is relevant to the public sector equality duty. 

EQUALITY IMPACT ASSESSMENT COMPLETED: February 2025