Anti Sexual Harassment Policy

Anti Sexual Harassment Policy

Purpose

1. This Anti-Sexual Harassment Policy outlines Omnia’s commitment to providing a workplace free from sexual harassment, discrimination, and bullying. We are committed to ensuring all employees work in an environment where they are treated with dignity and respect. This policy is in line with the latest UK legislation, including the Equality Act 2010, the Protection from Harassment Act 1997, and the amendments brought by the Worker Protection (Amendment of Equality Act 2010) Act 2024.

Scope

2. This policy applies to all employees, contractors, consultants, clients, vendors, and visitors to Omnia. It covers harassment in the workplace and in any work-related setting outside the workplace, such as business trips, events, and social functions.

Legal Framework

3. The policy is designed to comply with the following relevant legislation:

• Equality Act 2010: This Act prohibits discrimination, harassment, and victimisation on the basis of protected characteristics, including sex and gender. Sexual harassment is defined as unwanted conduct of a sexual nature that violates an individual’s dignity or creates an intimidating, hostile, degrading, humiliating, or offensive environment.
• Protection from Harassment Act 1997: This Act addresses harassment involving repeated behaviour that causes alarm or distress, including sexual harassment.
• Worker Protection (Amendment of Equality Act 2010) Act 2024: Effective from October 2024, this amendment imposes a duty on employers to prevent sexual harassment in the workplace and introduces mandatory protection measures, including obligations to take all reasonable steps to prevent harassment by third parties (e.g., clients or customers).

Definitions

• Sexual Harassment: Unwanted conduct of a sexual nature that makes an individual feel intimidated, degraded, humiliated, or offended, including but not limited to:
• Physical acts of a sexual nature, including inappropriate touching, pinching, or brushing up against someone.
• Unwelcome sexual advances or suggestive behaviour.
• Comments or jokes of a sexual nature.
• Displaying or circulating sexual or pornographic images.
• Sending or soliciting sexually explicit emails or messages.

     5. Third-Party Harassment: Harassment by someone who is not an employee of the firm, such as a client, vendor, or visitor, that affects an employee’s work environment.

     6. Workplace: can include the London office of Omnia Strategy and/or any work-related setting outside the workplace, such as business trips, events, and social functions.

Third Parties

7. In line with the 2024 amendments to the Equality Act, the firm acknowledges its duty to prevent third-party harassment. If an employee is harassed by a third party, the incident should be reported using the procedure set out in clause 10 below. The firm will take appropriate action, which may involve speaking to the third party or barring them from firm premises.

Responsibilities

Employer Responsibilities:

8. Omnia has a duty to take all reasonable steps to prevent sexual harassment and to protect employees from third-party harassment. This includes:

• Providing regular training on sexual harassment prevention.
• Implementing clear reporting procedures.
• Conducting prompt investigations into complaints.
• Taking appropriate action against perpetrators.

Employee Responsibilities:

9. All employees are responsible for:

• Complying with this policy.
• Treating colleagues with dignity and respect.
• Reporting any incidents of harassment they experience or witness.

Reporting Procedures

10. Employees should report any sexual harassment to HR either verbally or by email, or alternatively to any of the firm’s Equity Partners.

Investigation Process

11. All complaints will be taken seriously and investigated promptly. The investigation will be conducted in a fair and unbiased manner, ensuring confidentiality as much as possible and in line with the firm’s grievance procedures. Where a complaint is substantiated, appropriate disciplinary action will be taken, which may include dismissal.

Support for Victims

12. Employees affected by sexual harassment will receive support from the partners and firm. Counselling services are available through the firm’s private medical insurance.

Training and Awareness

Mandatory Training

13. All employees must complete sexual harassment training annually.

Awareness

14. Internal communication will reinforce the firm’s zero-tolerance stance on harassment.

Consequences of Breaching the Policy

15. Failure to comply with this policy may result in disciplinary action, up to and including termination of employment. For third parties, it may lead to a termination of contracts or services.

Monitoring and Review

16. This policy will be reviewed regularly to ensure compliance with the latest legislation and best practices. Updates will be made as necessary following changes in the law or case law developments.