Prevention of Sexual Harassment Policy

Reviewed: 27.10.26

PURPOSE

Wilson Vale Catering is committed to providing a working environment in which everyone is treated with dignity and respect and is free from sexual harassment, harassment, bullying and victimisation. We will not tolerate such behaviour by our employees or by third parties encountered through work.

We recognise our legal duty under the Equality Act 2010, as amended by the Employment Rights Act 2025, to take all reasonable steps to prevent sexual harassment of our employees in the course of their employment. From 30 October 2026, the law also requires employers not to permit harassment by third parties where all reasonable steps to prevent it have not been taken.

This policy applies to all employees and, where relevant, workers engaged by Wilson Vale Catering. It does not form part of any contract of employment and may be amended following review.

INTRODUCTION

This policy applies wherever work-related contact takes place, including kitchens, restaurants, client premises, offices, work travel, training, conferences, work-related social events, online meetings, email, messaging platforms and social media where connected with work.

As Wilson Vale employees work on client sites, this policy expressly covers conduct by third parties, including clients, customers, guests, visitors, pupils or service users, suppliers, contractors, consultants and members of the public. A third party is someone other than Wilson Vale Catering or one of its employees.

The policy applies whether conduct occurs during or outside normal working hours where there is a sufficient connection with work. It applies to incidents reported by the person affected and to incidents witnessed or otherwise brought to our attention.

What is sexual harassment?

Sexual harassment is unwanted attention that violates a person’s dignity or creates an offensive or degrading environment. Sexual harassment makes the person, or persons, affected feel uncomfortable, threatened or offended. It is the effect that matters regardless of whether or not the effect was intended.

A range of behaviours recognised to be forms of sexual harassment are listed below. However, this list is not exhaustive. It is important to bear in mind that sexual harassment covers a very broad spectrum of behaviour, and may not always appear to be overtly sexual in nature, but can include:

sexual images displayed or shared.
offensive words or comments.
demeaning or humiliating behaviour or language.
references to someone’s body.
intrusive questions about someone’s private life.
stalking, including online stalking.
sexual gestures, such as simulating sexual acts.
unwanted touching, such as putting hand on someone’s knee or hugging them.
unwanted sexual attention whether verbal or physical.
coercing someone into sexual relations through pressure, manipulation or threats, or offering rewards in exchange for sex.
sexual violence, including rape, or threatening to carry out sexual violence or unwanted sexual acts.

Sexual harassment is often considered a disciplinary offence and, in some cases may also be a criminal offence.

A single incident may amount to sexual harassment. Behaviour does not need to be directed at a particular person to contribute to an offensive environment.

Although, statistically, women are more likely to experience or report sexual harassment, it can happen to anyone. Sexual harassment does not always occur in plain sight. It can happen in-person and online, and outside of as well as during working hours. Regardless of when and how it occurs, Wilson Vale Catering will consider any sexual harassment involving employees as a workplace issue and will take action in line with our disciplinary policy accordingly.

Harassment related to protected characteristics:

Harassment under the Equality Act 2010 can also involve unwanted conduct related to a relevant protected characteristic which has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. Relevant characteristics include age, disability, gender reassignment, race, religion or belief, sex and sexual orientation. The statutory third-party harassment provision also covers relevant harassment related to protected characteristics, subject to the statutory exclusions for pregnancy and maternity, and marriage and civil partnership.

This policy focuses on sexual harassment and related prevention arrangements. Concerns about other harassment, discrimination or bullying may also be addressed under the relevant company policy.

Our commitment:

Preventing harassment is an ongoing responsibility. Wilson Vale Catering will take all reasonable steps to prevent sexual harassment, and reasonable steps to prevent third-party harassment, taking account of the nature of our operations, the risks at each site and the resources available. Measures will be reviewed and updated where risks or incidents indicate that further action is needed.

Wilson Vale Catering will deliver training sessions for all employees so that you have a comprehensive understanding of what sexual harassment is and your role in preventing and addressing it.

We will also ensure that additional training, education and guidance to the Leadership Team and all line managers to give them the confidence to tackle sexual harassment.

We recognise the need for regular risk assessments and audits to identify and mitigate risks of sexual harassment. We will actively consider the risks of sexual harassment occurring in the course of employment and devise and implement reasonable steps we can actively take to reduce those risks and proactively prevent sexual harassment occurring.

We will follow a clear, fair and supportive procedure to encourage the reporting of potential or alleged sexual harassment in the course of employment which is described below.

We will review relevant client contracts, site protocols and supplier arrangements to support prevention, reporting, cooperation and appropriate action where third-party harassment occurs.

Where appropriate, we will communicate expected standards to clients, customers, visitors and other third parties, including that harassment of our employees will not be accepted.

We will consider site-specific measures such as staffing arrangements, access controls, security support, safe routes, escalation contacts and the ability to withdraw an employee from an unsafe situation.

The steps required will depend on the risk and circumstances. Wilson Vale Catering will document the measures taken and, where a proposed measure is not adopted, consider recording the reasons. No single policy or training session on its own will necessarily be sufficient.

Leading by example:

Senior leaders and line managers must foster a culture built on mutual respect where all employees feel safe sharing their views and raise concerns. Wilson Vale Catering expects leaders and line managers to act as role models by consistently demonstrating respectful and inclusive behaviour. This includes being aware of how their own status and actions may impact on others.

In addition to self-awareness Wilson Vale Catering expects and encourages leaders and line managers to regularly seek and act on feedback from their teams and peers in regards to an inclusive culture actively engaged in preventing sexual harassment.

Preventing sexual harassment requires leaders and line managers to communicate that any form of unfair treatment such as sexual harassment will not be tolerated. Offensive behaviour can sometimes be excused as banter or jokes, so leaders and line managers must maintain high standards, even when they may face criticism for doing so.

Wilson Vale Catering will give appropriate training, education and guidance to leadership and line managers to ensure they have the confidence and capability to be proactive and deal with unacceptable behaviour at the earliest possible stage.

As a leader or line manager, you are also well placed to pick up on any underlying tensions that could indicate potentially inappropriate behaviours or attitudes. These may include employees unwilling or reluctant to work together, heated exchanges or perceived favouritism.

Wilson Vale Catering will support and train leaders and line managers so that they are able to foster a culture of open communication and reinforce values based on dignity and respect as this will enable them to understand and resolve issues in their team proactively, quickly, effectively and impartially. Managers must take concerns seriously, act promptly, consider immediate safety and support needs, report concerns to HR and avoid promising absolute confidentiality. Managers must not dismiss conduct as banter or assume that a client’s behaviour is outside the Company’s responsibility. Where the alleged harasser is a client, customer or other third party, managers must escalate the matter to HR and the appropriate operational/client contact, without exposing the employee to unnecessary further contact or risk.

How we can all help prevent sexual harassment:

We all have a shared responsibility to help create and maintain an environment free of sexual harassment. You can do this by:

Considering how your own behaviour may affect others and amending it accordingly.
Being receptive, rather than defensive, if asked to modify your behaviour.
Treating your colleagues with dignity and respect.
Taking a stand if you think inappropriate comments, jokes or behaviour is occurring.
Making it clear to others if you find their behaviour unacceptable.
Intervening, if possible, to stop sexual harassment and giving support to others.
Reporting sexual harassment or potential sexual harassment in the appropriate manner to either your line manager, Area Manager or a member of the HR Team.

What to do if you are concerned about sexual harassment:

The following process can be followed by any employee of Wilson Vale Catering. You can follow this process if you feel you are experiencing sexual harassment or if you witness sexual harassment or have a concern that another colleague may be experiencing sexual harassment.

Wilson Vale Catering commits to treating all allegations of sexual harassment with the upmost seriousness. We will follow a fair and equitable process to ensure all concerns are investigated thoroughly to allow us to resolve matters promptly whilst ensuring all parties are treated sensitively and in a confidential manner.

Informal approach:

You may be able to sort matters out informally. The person may not know that their behaviour is unwelcome or upsetting, so an informal discussion may help them to understand the effects of their behaviour and agree to change it.

If you feel able to, tell the person what behaviour you find offensive and unwelcome and say that you would like it to stop immediately. You are encouraged to keep a note of the date and what was said and done. This will be useful if the unacceptable behaviour continues, and you wish to raise the matter formally.

If this is too difficult for you, please speak to your line manager, Area Manager or a member of the HR team for advice and assistance. They may, with your agreement, speak to the person concerned on your behalf or accompany you when you speak to the other person.

If the informal approach is not appropriate, or has not been successful, you should raise the matter formally through our grievance procedure.

Formal procedure

When any employee feels that they need to deal with an issue of sexual harassment formally, you should make a formal complaint in accordance with our grievance policy.

Your written complaint should set out full details of the conduct in question, including the name of the harasser, the nature of the sexual harassment, the date(s) and time(s) at which it occurred, the names of any witnesses and any action that has been taken so far to attempt to stop it from occurring.

If you wish to make a formal complaint about victimisation, you should submit it in writing to your line manager or the HR Department.

We will investigate all complaints of this nature in a timely, confidential and sensitive manner. The investigation will be conducted by someone with appropriate seniority, training and experience and with no prior involvement in the complaint. Details of the investigation and the names of any persons involved will only be disclosed on a ‘need to know’ basis. We will consider whether any steps are necessary to manage the ongoing employment relationship between all parties involved.

If the report does not come directly from the person being harassed, the nominated investigator will confidentially speak to the person affected and ideally encourage them to report. In cases where individuals are reluctant to report despite encouragement, the investigating manager needs to respect the wishes of the person making the complaint as far as possible.

Once the investigation is complete, Wilson Vale Catering will inform all parties (separately) of our decision. Whether or not a complaint is upheld, we will consider how best to manage any ongoing working relationships between all parties. As a general principle, the decision whether to make a complaint is up to you. However, we have a duty to protect all staff and may pursue the matter independently if, in all the circumstances, we consider it appropriate to do so.

If the manager considers that there is a case to answer and the harasser is an employee, the matter will be dealt with as a case of possible misconduct or gross misconduct under our Disciplinary Procedure. Our investigation into your complaint may be put on hold pending the outcome of the Disciplinary Procedure. Where the disciplinary outcome is that sexual harassment occurred, prompt action will be taken to address it.

Action where the alleged harasser is a third party

Where the alleged harasser is a client, customer, visitor, supplier, contractor or another third party, Wilson Vale will consider the immediate risk to the employee and the appropriate steps to prevent further harassment. Depending on the circumstances, this may include:

supporting the employee to leave the situation or temporarily changing duties, location or contact arrangements where appropriate;
reporting the incident to the relevant client or site contact and seeking prompt action;
requiring the third party to stop the behaviour, restricting access or contact, or asking that an individual be removed from the site where this is within our control or can be agreed;
reviewing the relevant risk assessment, site controls, staffing, security arrangements and reporting processes;
reviewing contractual or operational arrangements with the client or other organisation, including escalation to senior management where necessary;
considering whether the incident should be reported to the police or another relevant authority.

The Company will not treat third-party harassment as simply a client relationship issue. We will consider what steps are reasonably available to protect our employees, document the actions taken and follow up to assess whether the risk has been addressed. Where a proposed action is outside our direct control, we will consider what other reasonable steps can be taken and escalate the matter as appropriate.

Supporting the investigation

All reports of sexual harassment should be believed and protecting the person who raised the complaint or who is the recipient of sexual harassment should be paramount. Alongside this, the alleged harasser also needs to be treated fairly in line with procedure and the law.

In some cases, more immediate action may need to be taken, such as suspending or moving the alleged harasser. A member of the HR Team will be able to advise investigating managers on the appropriate course of action. Care must be taken to ensure no action is taken that could be perceived as punishing any person who raises a complaint.

If you witness sexual harassment

Staff who witness sexual harassment or victimisation are encouraged to take appropriate steps to address it. Depending on the circumstances, this could include:

Intervening where you feel able to do so.
Supporting the victim to report it or reporting it on their behalf.
Reporting the incident where you feel there may be a continuing risk if you do not report it.
Co-operating in any investigation into the incident.
All witnesses will be provided with appropriate support and will be protected from victimisation.

Providing support

Wilson Vale Catering understands that reporting sexual harassment takes courage and can be extremely stressful. We will ensure that any individuals raising a concern or complaint are given reassurance and support throughout the process. This support may also need to be extended to any employees who have witnessed sexual harassment.

As well as providing opportunities to talk, our HR team are trained to signpost employees to relevant services such as occupational health or counselling if appropriate.

Wilson Vale Catering educates leaders and line managers to be vigilant for signs of victimisation whereby an employee is treated less favourably because they have reported sexual harassment and will take appropriate action through our disciplinary policy if required.

Consequences of a breach of this policy:

If after due investigation, we consider that an incident of sexual harassment has occurred, the matter will be dealt with under the disciplinary procedure as a case of possible misconduct or gross misconduct. The person concerned may be suspended on full pay during the investigation until any eventual disciplinary proceedings have been concluded. If the complaint is upheld, a disciplinary sanction may be imposed up to and including dismissal, depending on all relevant circumstances.

Incidents of sexual harassment may constitute a criminal offence and Wilson Vale Catering may suggest that the matter is reported to the police.

In our commitment to prevent sexual harassment in the course of employment, we will fully analyse any unaddressed risks which were not recognised and could have reasonably prevented any incident of sexual harassment and put in place any reasonable measures to prevent a recurrence of a similar nature.

If someone makes a complaint which is not upheld, and Wilson Vale Catering has good grounds for believing that the complaint was not made in good faith, we make take disciplinary action against the person who made a false complaint.

Record keeping:

Information about a complaint by or about an employee may be placed on either party’s personnel file, along with a record of the outcome and any other notes or documents compiled during the process. These will be processed in accordance with our Data Protection Policy.