Dignity at Work Policy

Seed is committed to creating a work environment free of harassment, sexual harassment, intimidation or other forms of bullying, where everyone is treated with dignity and respect.

We adopt a zero-tolerance approach to instances of bullying or harassment. 

What we expect from you

We expect you, and every one we work with, to take personal responsibility for observing, upholding, promoting and applying this policy. Whatever your job is, this is part of your role and scope.

Any dealings you have with third parties, including customers, suppliers, contractors, agency staff and consultants, must be free from discrimination, harassment, victimisation or bullying. 

If any of our people or people we work with are found to have committed, authorised or condoned an act of bullying or harassment, we will take action against them (for those to whom it applies) under our Disciplinary procedure, up to and including dismissal and/ or termination of project contract.

There is no justifiable reason to bully or harass someone else. Even if you do not intend to bully or harass someone else, this does not legitimise your behaviour as it is the impact on the recipient that is important.

You should be aware that you can be personally liable for harassment.

If you experience bullying or harassment, we encourage you to speak up without delay and to ask for appropriate support via your line manager, the People & Culture Director, or project lead.

To whom does the policy apply?

This policy covers bullying, harassment and sexual harassment of and by managers, employees and third parties, including contractors, freelancers, suppliers, agency staff and anyone else engaged to work at Seed, whether by direct contract with us or otherwise. If the complainant or alleged harasser is not employed by Seed, e.g. if the worker’s contract is with an agency, this policy will apply with any necessary modifications such as that Seed could not dismiss the worker but would instead require the agency to remove the worker, if appropriate, after investigation and disciplinary proceedings.

The policy covers any form of bullying and harassment in the workplace and in any work-related setting outside the workplace, e.g. business trips or work-related social events or online.

What constitutes bullying and harassment?

Bullying is offensive, intimidating, malicious or insulting behaviour, and/or abuse or misuse of power that is meant to undermine, humiliate or injure the person on the receiving end.

Bullying does not include legitimate and constructive criticism of performance or behaviour, an occasionally raised voice or argument. Bullying can range from extreme forms such as violence and intimidation to less obvious actions such as deliberately ignoring someone.

Harassment is unwanted physical, verbal or non-verbal behaviour that is carried out for the purpose of violating a person’s dignity or to create an intimidating, hostile, degrading, humiliating or offensive environment. It may include insults, inappropriate jokes, unnecessary contact, threatening behaviour or gossip.

Everyone has the right to decide what behaviour is acceptable to them and to have their feelings respected by others. Some employees may not understand that their behaviour is unwelcome or offensive and, in some cases, first-time conduct which unintentionally causes offence may be resolved by explaining to the person how their actions make you feel. However, if this conduct continues after you have made it clear that it is unacceptable, this may constitute harassment.

Harassment also includes circumstances where employees are subjected to unwanted conduct from third parties and vice versa and it will not be tolerated under any circumstances. All employees and third-parties are encouraged to report any instances of harassment, following the same reporting steps as internal harassment complaints. This includes reporting the incident to a manager, the People & Culture Director, or project lead,

with the assurance that all reports will be treated confidentially and investigated promptly. To prevent third-party harassment, this policy is issued to both internal and external parties to  establish clear conduct expectations. In response to an incident, appropriate actions will be taken, which may include warning or banning the individual, ceasing work with the business or individual, reporting any criminal behaviour to the police, and sharing information across other branches of the business to prevent further issues. Our commitment to maintaining a harassment-free workplace applies to all sources of harassment, whether internal or external.

Behaviour which any reasonable person would realise would be likely to offend will be harassment without the recipient having to make it clear in advance that behaviour of that type is not acceptable to them.  It may not be so clear in advance that some other forms of behaviour would be unwelcome to, or could offend, a particular person, e.g. certain “banter”, flirting or asking someone for a private drink after work. In these cases, first-time conduct which unintentionally causes offence may not be harassment but it may become harassment if the conduct continues after the recipient has made it clear, by words or conduct, that such behaviour is unacceptable to them.

Harassment also includes circumstances where an individual is subjected to unwanted conduct from a third party, such as a client or customer.  For example, it might be that a client makes a series of racist remarks to a black employee.  If an employee or third-party feels that they have been bullied or harassed, they should report any such behaviour to their manager or project lead who will take appropriate action.

Bullying or harassment of customers, suppliers, vendors or visitors or others will be dealt with through the disciplinary procedure.

A single incident can be harassment if it is sufficiently serious.

All bullying and harassment is misconduct and is a disciplinary offence, which will be dealt with under our disciplinary policy. Bullying or harassment will often be gross misconduct, which can lead to dismissal without notice.

Bullying or harassment can amount to unlawful discrimination where it relates to one of the protected characteristics. Serious bullying or harassment may amount to other civil or criminal offences e.g. a civil offence under the Protection from Harassment Act 1997 and criminal offences of assault.

What is victimisation?

Victimisation is subjecting a person to a detriment because they have, in good faith, complained (whether formally or otherwise) that someone has been bullying or harassing them or someone else, or supported someone to make a complaint or given evidence in relation to a complaint.  This would include isolating someone because they have made a complaint or giving them a heavier or more difficult workload.

Provided that you act in good faith, i.e. you genuinely believe that what you are saying is true, you have a right not to be victimised for making a complaint or doing anything in relation to a complaint of bullying or harassment and we will take appropriate action to deal with any alleged victimisation, which may include disciplinary action being taken against you.

Sexual Harassment

At Seed, we maintain a zero-tolerance policy towards sexual harassment and are committed to creating a safe and respectful workplace. We have implemented proactive measures to help prevent incidents from occurring. While the following is not an exhaustive list, these examples reflect key initiatives that we have taken to proactively prevent sexual harassment.

• Checks – We carry out reference checks for all workers & employees.
• Ensure access to leadership – We have an open-door policy for employees to access leadership outside of their direct reporting line.
• Policy Publicity – We regularly publicise our “Dignity at Work policy” through onboarding, internal communications, and training sessions to ensure all employees are aware.
• Training & Bystander Training- We incorporate anti-sexual harassment & bystander intervention training into our ED&I training programme to empower employees to address inappropriate behaviour.
• Leadership Accountability – Our managers and senior leaders are responsible for upholding and promoting a respectful work environment. They are trained to identify and address inappropriate behaviour proactively.
• Clear Reporting Procedures – We make reporting procedures visible and straightforward, ensuring employees know both informal and formal processes, and offer easy access to reporting channels for all staff, including temporary and freelance workers.
• Anonymous Feedback and Engagement surveys – We regularly conduct anonymous surveys to gauge the workplace climate regarding respect and inclusion. These surveys help us proactively identify areas for improvement.
• Third-Party Interaction – We provide clear guidelines on appropriate behaviour when interacting with third parties and establish reporting mechanisms for incidents involving contractors or the public.
• External workforces embedded in our business – We include external workers in workplace training and policies on this subject, and ensure they have access to the same reporting and support systems. This helps establish clear conduct expectations for external workers.

Meaning of sexual harassment

Harassment may be sexual in nature. The law defines sexual harassment as:

• conduct of a sexual nature that has the purpose or effect of violating someone's dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment; and
• less favourable treatment related to sex or gender reassignment that occurs because of a rejection of, or submission to, sexual conduct.

Examples of sexual harassment

Sexual harassment can occur in many forms. While this is not an exhaustive list, examples include:

• physical conduct of a sexual nature, unwelcome physical contact or intimidation;
• persistent suggestions to meet up socially after a person has made clear that they do not welcome such suggestions;
• showing or sending offensive or pornographic material by any means (for example, by text, video clip, email or by posting on the internet or social media);
• unwelcome sexual advances, propositions, suggestive remarks, or gender-related insults;
• offensive comments about appearance or dress, innuendo or lewd comments;
• leering, whistling or making sexually suggestive gestures; and gossip and speculation about someone's sexual orientation or transgender status, including spreading malicious rumours.

What should I do if I think I am being bullied or harassed?

We understand that not everyone will want to, or be ready to, go down a formal route when reporting an issue. Therefore, we’ve highlighted some informal options for you.

Informal:

The person may not know that their behaviour is unwelcome or upsetting.  An informal discussion may help them to understand the effects of their behaviour and agree to change it. You may feel able to approach the person yourself, or with the help of a manager or another employee.

Alternatively, an initial approach could be made on your behalf by one of those people.  You should tell the person what behaviour you find offensive and unwelcome, and say that you would like it to stop immediately.  You may want to add that, if the behaviour continues, you intend to make a formal complaint to your manager, the senior team or project lead. You should keep a note of the date and what was said and done, as this will be useful if the unacceptable behaviour continues and you wish to make a formal complaint.

Seeking support:

• If you don’t feel comfortable speaking to the individual directly, consider asking your manager, a colleague, project lead, or the People & Culture Director or People & Culture Manager for support.
• You can choose whether you want them to speak to the individual on your behalf.
• We will respect your wishes where possible.

Serious concerns:

• If your safety or the safety of others is at risk, or if the matter is serious, we may need to approach the individual and initiate a formal investigation.
• Where possible, we will discuss this with you first.

 Employee Assistance Programme (EAP):

• If you prefer not to discuss the issue with anyone at work, help is available for Seed employees through our Employee Assistance Programme (EAP).
• The EAP offers confidential support from an independent adviser for any issue troubling you.

Access to leadership:

• We have an open-door policy for all employees to access leadership outside their direct reporting lines.
• If you feel more comfortable talking to any member of the leadership team instead of your line manager, simply ask for a confidential or informal conversation.
• The People & Culture team is also available for support in these situations.

Formal:

If an informal approach does not resolve matters, or you think the situation is too serious to be dealt with informally, you may choose to raise it formally. To begin the formal process, you should first discuss it with your line manager or the People & Culture Director.

You can make a formal complaint by using Seed’s grievance procedure.  In the case of grievances about bullying or harassment, the normal grievance procedure is modified so that you can choose whether to raise your grievance with your manager or directly with an independent party.  Seed will ensure that you can bring your complaint in the first instance to someone of your own sex, if you so choose.

The People & Culture Director will be more than happy to guide you through the process and explain what it involves.

Complaints will be investigated promptly and, if appropriate, disciplinary proceedings will be brought against the alleged harasser.  You will have the right to be accompanied by a work colleague of your choice at any meeting dealing with your grievance.  You will be kept informed of the general progress of the process of investigation and the outcome of any disciplinary proceedings.

Seed will treat complaints of bullying and harassment sensitively and maintain confidentiality to the maximum extent possible.  Investigation of allegations will normally require limited disclosure on a “need to know” basis.  For example, your identity and the nature of the allegations must be revealed to the person you are complaining about, so they are able to respond to the allegations.   Some details may also have to be given to potential witnesses but the importance of confidentiality will be emphasised to them.  If the complaint is upheld, and a person who has been found to have harassed you is kept in our employment, managers may need to be given some information where this is necessary for them to manage the risk of further harassment by that person against you or others.

Wherever possible, we will try to ensure that you and the alleged harasser are not required to work together while the complaint is under investigation.  This could involve giving you the option of remaining at home on special leave, if you wish. In a serious case, the alleged harasser may be suspended while investigation and any disciplinary proceedings are underway.

If your complaint is not upheld, we will support you, the alleged harasser and your manager/ project lead for third-parties in making arrangements for you both to continue or resume working and to help repair working relationships.  We will consider making arrangements to avoid you and the alleged harasser having to continue to work alongside each other, if either of you do not wish to do this.  You have a right not to be victimised for making a complaint in good faith, even if the complaint is not upheld.  However, making a complaint that you know to be untrue may lead to disciplinary action taken against you.

Those responsible for the implementation of the policy

Managers and project leads have a specific responsibility to operate within the boundaries of this policy and to facilitate its operation by ensuring that workers understand the standards of behavior expected of them and by identifying and acting upon behaviour, by employees or third parties that falls below these standards.   Managers will be given training on the relevant legal and operational framework and best practice.

All employees and third-parties are responsible for treating their colleagues with dignity for the success of this policy and should ensure that they take the time to read and understand it. Employees and third-parties should disclose any instances of harassment or bullying of which they become aware of to a member of the senior team.

Support for those affected or involved

We understand that being involved in a complaint (informal or formal) of bullying, harassment or sexual harassment can be stressful. We are committed to supporting you throughout the process.

Working arrangements:

• If you find it difficult to continue working closely with the alleged bully/harasser during the investigation, please let us know. We will take any requests to adjust your working arrangements seriously.

Emotional support:

• Free and confidential counselling is available for Seed employees through our Employee Assistance Programme (EAP). 

Protection from victimisation:

• If you raise a complaint or participate in a bullying or harassment investigation in good faith, you should not face any detrimental treatment or victimisation.
• If you feel you have experienced victimisation, please inform your line manager, project lead or the People & Culture Director as soon as possible.

Ongoing working relationships:

• Regardless of the outcome of the complaint, we will carefully consider how to manage the ongoing working relationship between you and the individual involved.
• Depending on the circumstances, we may adjust job duties, location, or reporting lines for either party. Alternatively, workplace mediation or counselling may be appropriate.

Sensitivity and confidentiality

Anyone involved with an informal or formal complaint about bullying or harassment, including witnesses, must keep the matter strictly confidential and act with appropriate sensitivity to all parties.

If you are found to have breached confidentiality or acted without due care or sensitivity in a case of bullying or harassment, we may take disciplinary action against you up to and including dismissal (or other appropriate action for non-employees).

Continuous Improvement

We will regularly review and update this policy to ensure it remains in line with best practices and legal requirements. Our commitment to preventing bullying, harrassesment and sexual harassment is ongoing, and we will continue to seek new ways to promote a respectful workplace culture.

Zero Tolerance

Any confirmed incidents of bullying, harrassment or sexual harassment will be met with disciplinary action, up to and including dismissal, depending on the severity of the behaviour.

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