Anti-Harassment, Bullying & Sexual Harassment Policy

DRAFT v0.1 — 21/06/2026 — for internal review and legal sign-off; not legal advice.

Applies to: CDOCC Limited

Policy owner: [NAME / ROLE]

Version: v0.1 (draft)

Last reviewed: 21/06/2026

Next review due: 21/06/2027 (or sooner if the law changes)

This is a master template. Replace every CDOCC Limited and other bracketed placeholder before use. Each legal entity in the group adopts its own copy, names its own responsible people, and reviews it on its own cycle.

1. Purpose

CDOCC Limited wants every person who works here, and everyone who deals with us, to be treated with dignity and respect. We do not tolerate harassment, bullying, sexual harassment or victimisation of any kind.

This policy explains:

what these behaviours are, with real examples from a bar, kitchen, hotel and lettings setting;
the active steps we take to prevent sexual harassment before it happens;
how you can raise a concern — informally or formally — and what we will do about it;
the support available to you, and our firm promise that nobody will be punished for speaking up.

We treat this as a safety issue, not just a paperwork issue. A safe team is a better team.

2. Scope

This policy applies to everyone, regardless of how long you have worked here or your contract type:

employees, workers, agency and bank staff, casual and seasonal staff;
managers, supervisors, directors and owners;
volunteers, apprentices, work-experience placements and contractors.

It covers conduct:

at work and on our premises (front of house, back of house, cellar, kitchen, hotel rooms, offices, viewings and properties);
away from the premises but connected to work — deliveries, suppliers' sites, training, conferences, off-site events, work socials and the staff Christmas party;
online and by phone — messages, social media, group chats, email and any work communication.

It protects our staff from harassment by anyone — colleagues, managers, and third parties such as customers, guests, contractors and suppliers (see Section 7).

Breaches of this policy by a member of staff are treated as a disciplinary matter and may amount to gross misconduct — see the [Disciplinary & Grievance Procedure].

3. Definitions

Plain-English summaries — the legal source is the Equality Act 2010.

Harassment. Unwanted behaviour linked to a protected characteristic that has the purpose or effect of violating someone's dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. It can be a single serious incident or a pattern of smaller ones. It does not have to be aimed directly at the person — overhearing it can be enough. It is judged partly on how it made the person feel, not only on what was intended.

The protected characteristics under the Equality Act 2010 are:

age
disability
gender reassignment
marriage and civil partnership
pregnancy and maternity
race (including colour, nationality, ethnic or national origin)
religion or belief
sex
sexual orientation

Sexual harassment. Unwanted behaviour of a sexual nature that violates someone's dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment. Examples: sexual comments or jokes, "banter", leering or staring, unwanted touching, standing too close, sexual propositions, sending or showing sexual images, comments about someone's body or sex life. It is how the behaviour lands on the person that matters — "it was only a joke" is not a defence.

Less favourable treatment for rejecting or submitting to sexual conduct. Treating someone worse because they rejected (or went along with) unwanted sexual or gender-related conduct — for example cutting a worker's shifts after they turned down a manager — is also unlawful harassment.

Bullying. Offensive, intimidating, malicious or insulting behaviour, or an abuse of power, that undermines, humiliates or injures someone. Bullying is not automatically tied to a protected characteristic, but we treat it just as seriously. Examples: persistent unfair criticism, shouting, humiliating someone in front of customers, deliberately giving someone the worst jobs, spreading malicious rumours, excluding or "freezing out" a colleague, setting someone up to fail.

Victimisation. Treating someone badly because they have made, or supported, a complaint about harassment, bullying or discrimination — or because it is believed they might. This is itself unlawful and is a serious breach of this policy (see Section 11, Non-retaliation).

Reasonable management is not bullying. Fair, constructive feedback, performance management, reasonable instructions, and proper use of the disciplinary or capability process — done respectfully — are not bullying.

4. The standard we expect

Everyone here is expected to:

treat colleagues, customers and visitors with dignity and respect;
think before they speak — what feels like harmless "banter" can be harassment to the person on the receiving end;
speak up if they see or experience unacceptable behaviour;
not retaliate against, pressure or isolate anyone who raises a concern;
co-operate honestly with any investigation.

Managers and supervisors are expected to set the tone: model respectful behaviour, never join in or laugh along with harassment, step in early when they see a problem, and act promptly on any concern raised with them.

5. Our legal duties

CDOCC Limited is committed to meeting and exceeding its legal duties, including:

the Equality Act 2010 — which makes harassment, sexual harassment and victimisation unlawful, and can make the employer liable for harassment committed by its staff;
the preventative duty on sexual harassment in force since 26/10/2024 under the Worker Protection (Amendment of Equality Act 2010) Act 2023 — a positive legal duty to take reasonable steps to prevent the sexual harassment of our workers (including by third parties such as customers);
our health and safety duties — harassment and bullying are workplace risks to health and wellbeing.

Strengthening of the duty — build to the higher bar. The Employment Rights Bill is expected to strengthen the preventative duty from "reasonable steps" to "all reasonable steps", and to introduce related protections (including on third-party harassment). (verify current commencement date.) We are not waiting for that change: this policy and our practices are deliberately built to the higher "all reasonable steps" standard now.

If an employment tribunal finds sexual harassment has occurred and the employer failed in the preventative duty, compensation can be increased by up to 25%. More importantly, getting prevention right keeps our people safe.

6. Preventing sexual harassment — reasonable steps & risk assessment

We treat prevention as an active, ongoing programme — not a one-off statement. This section is the evidence that CDOCC Limited takes all reasonable steps to prevent sexual harassment.

6.1 Sexual-harassment risk assessment

We carry out, document and review a specific risk assessment for the sexual harassment of our staff. We do not assume "it won't happen here". For each site and team we look at the risk factors that are real in hospitality and lettings, including:

Alcohol — customers (and sometimes staff at events) drinking, and the loss of inhibition that brings.
Late-night working — closing shifts, lone working, walking to cars or transport after dark, clearing a venue of reluctant customers.
Customer-facing roles — bar, waiting, reception, room service and door staff are exposed to the public and to repeat or regular customers.
Power imbalances — young, new, seasonal, casual or migrant staff; staff dependent on managers for shifts and tips; lone viewings and property visits in lettings.
Mixed teams and social culture — a "banter"-heavy culture, work socials, staff parties, shared accommodation.
Physical layout — quiet corners, cellars, stockrooms, corridors, hotel rooms, and properties where staff may be alone with a customer.
Hen/stag, sports nights and large events — predictable higher-risk occasions.

For each risk we record what we will do to reduce it (controls), who is responsible, and when we will review it. The completed assessment is held at [LOCATION OF RISK ASSESSMENT] and reviewed at least annually and after any serious incident.

6.2 The reasonable steps we take

Step	What we actually do	Evidence we keep
Policy & expectations	This policy is issued to every worker at induction and is available at [LOCATION].	Signed/acknowledged record per worker.
Risk assessment	Documented sexual-harassment risk assessment per site, reviewed annually (6.1).	Dated assessment + review log.
Training	Induction briefing for all; refresher training at least annually; extra training for managers on spotting and handling concerns (see Section 12).	Attendance records, dates, content.
Multiple reporting routes	Several named people to report to, plus an anonymous/confidential route, so nobody must report to their harasser (Section 8).	Named contacts published; report log.
Third-party protection	Clear staff-side procedures and customer-facing signals that harassment of staff is not tolerated (Section 7).	Signage, refusal/banning records, briefings.
Active monitoring	We don't wait for formal complaints — we check in with staff, review incident and near-miss logs, watch higher-risk shifts, and act on patterns.	Incident log, check-in notes, trend review.
Acting on concerns	Every concern is taken seriously, handled promptly and confidentially, and followed through to an outcome.	Case records (confidential).
Review	We review effectiveness at least annually and after any incident, and update our steps.	Review notes, policy version history.

6.3 Monitoring & continuous improvement

We keep a confidential incident and concern log (including third-party incidents and near-misses), review trends, and feed what we learn back into the risk assessment, training and shift planning. Low reporting is not assumed to mean low risk — it may mean people don't feel safe to report, which we treat as a problem to fix.

7. Third-party harassment (customers, guests, suppliers)

In a pub, hotel and lettings business our staff deal with the public every day. Harassment of our staff by a customer, guest, contractor or supplier is just as unacceptable as harassment by a colleague, and we will act on it.

Practical examples we take seriously:

a regular customer who repeatedly makes sexual comments to, or about, a member of bar staff;
a guest who gropes, leers at, corners or follows a waiter or receptionist;
a drunk customer at a late-night or event shift making sexual or degrading remarks;
a contractor or supplier harassing office or lettings staff, or a tenant/visitor harassing a staff member during a property visit.

What we do about third-party harassment:

You are never expected to "just put up with it" to keep a customer happy. Looking after our staff comes first.
Report it the same way as any other concern (Section 8) — including straight away to the manager or supervisor on shift.
On-shift response: the manager on duty will support the staff member, intervene, and where appropriate refuse service, remove or ban the customer, and call the police if there is a threat to safety. No member of staff will be disadvantaged for being moved away from, or refusing to serve, someone who is harassing them.
Practical safeguards for higher-risk situations: clear "harassment of our staff will not be tolerated" signage, the ability to swap a member of staff off a table or area, buddy/lone-working arrangements for closing and for property viewings, and barring repeat offenders.
We record and review third-party incidents and feed them into the risk assessment (Section 6).

8. How to raise a concern

You can raise a concern informally or formally, and you choose which route. You do not have to use the informal route first if you don't want to.

8.1 Reporting persons — you choose who to tell

So that nobody is ever forced to report to the person harassing them, you can speak to any of the following:

your line manager or supervisor;
the duty manager on shift;
a different manager you feel comfortable with;
[NAMED CONTACT 1 — name / role / contact];
[NAMED CONTACT 2 — name / role / contact] (an alternative, ideally a different gender / different site);
the business owner / director: [NAME].

A confidential / anonymous route is also available: [CONFIDENTIAL REPORTING ROUTE — e.g. dedicated email, form or external line].

If your concern is about one of the people above, simply go to one of the others.

8.2 Informal route

Sometimes the quickest fix is the informal one. If you feel safe to do so, you can:

tell the person their behaviour is unwelcome and ask them to stop; or
ask a manager or one of the contacts above to have a quiet word, or to help you resolve it.

You are never obliged to confront the person yourself, and you should not feel you have to — especially where the behaviour is serious, or involves a customer or someone more senior. If the informal route doesn't work, or isn't appropriate, use the formal route.

8.3 Formal route

To raise a formal complaint, tell any of the people in 8.1, ideally in writing, setting out:

what happened, with dates, times and places as best you can;
who was involved and any witnesses;
how it affected you;
anything you have already done about it.

Your complaint will be handled under the [Disciplinary & Grievance Procedure]. We aim to acknowledge a formal complaint within [X working days] and to deal with it promptly and fairly.

If you are unsure, or just need to talk something through first, start with an informal chat with any contact above — you can decide what to do next afterwards.

9. Investigation & confidentiality

We take every concern seriously and investigate promptly, fairly and impartially.
Wherever possible the investigation is carried out by someone not involved in the complaint and not in the reporting line of either party.
Confidentiality: information is shared only with those who genuinely need to know to investigate and resolve the matter, or where we are legally required to share it. We ask everyone involved — including witnesses — to keep matters confidential.
Both the person raising the concern and the person complained about will be treated fairly; the person complained about will be told the allegations and given a fair chance to respond.
Where it is appropriate to protect people during an investigation, we may make temporary arrangements (for example adjusting shifts or duties so the parties are not working together). Any such step is neutral and precautionary — not a punishment — and we will avoid disadvantaging the person who raised the concern.
Outcomes are dealt with under the [Disciplinary & Grievance Procedure]. Proven harassment, sexual harassment, bullying or victimisation may be treated as gross misconduct.
We will let the person who raised the concern know, so far as we properly can, that it has been dealt with.

Malicious complaints. Complaints made in good faith that are not upheld will never be held against you. Only a complaint shown to be deliberately false and malicious may itself be a disciplinary matter — an honest concern that turns out to be mistaken is not.

10. Support

Experiencing or reporting harassment can be distressing. Support available includes:

a confidential chat with any of the contacts in 8.1;
[Employee Assistance Programme / counselling — details, if available];
reasonable practical adjustments (for example temporary changes to shifts, duties or pairings);
time to attend support appointments where reasonable;
where there is any risk to safety, support to contact the police — in an emergency always call 999.

External support includes Acas (advice on workplace problems) and your trade union, if you are a member.

11. Non-retaliation — our firm promise

Nobody will be punished, disadvantaged or treated badly for raising a genuine concern about harassment, bullying or victimisation, for supporting someone else's complaint, or for taking part in an investigation.

This protection covers things like shift changes, lost hours, being overlooked for opportunities, exclusion, cold-shouldering or any other detriment. Retaliation (victimisation) is itself a serious disciplinary offence and may be treated as gross misconduct.

If you feel you are being treated badly for having spoken up, report it immediately to any contact in 8.1 — we will act on it.

12. Training

All staff receive a briefing on this policy and on recognising and reporting harassment and sexual harassment at induction, and refresher training at least annually.
Managers and supervisors receive additional training on preventing harassment, spotting warning signs, handling concerns sensitively, supporting staff, and managing third-party/customer incidents on shift.
Training is recorded (who, when, what) as part of our reasonable-steps evidence (Section 6.2).
Training is refreshed when the law changes, after any significant incident, and as part of the annual review.

13. Responsibilities

Owners / directors — set the culture, resource prevention, and ensure this policy is applied. Ultimate accountability sits here.
Managers & supervisors — model respectful behaviour, never tolerate or join in harassment or "banter" that crosses the line, act promptly and confidentially on concerns, support staff (including against customers), and keep the required records.
All staff — behave respectfully, speak up about unacceptable behaviour, support colleagues, and co-operate with investigations.
Policy owner ([NAME / ROLE]) — keeps this policy, the risk assessment and the training current, and reviews effectiveness.

14. Related policies

[Disciplinary & Grievance Procedure] — how complaints are formally investigated and how outcomes (including dismissal for gross misconduct) are decided.
[Equality, Diversity & Inclusion Policy] — our wider commitment to fair, inclusive treatment.
[Health & Safety Policy] and the sexual-harassment risk assessment (Section 6.1).
[Whistleblowing Policy], [Social Media / Communications Policy], [Lone Working Policy] (include those that exist for the entity).

15. Review date

This policy is reviewed at least annually, and additionally:

when the law changes (in particular the strengthening of the preventative duty under the Employment Rights Bill — verify current commencement date);
after any serious incident or upheld complaint;
when the risk assessment identifies a change in risk.

Next scheduled review: 21/06/2027.

Legal review checklist

For the reviewer (HR adviser / employment solicitor) before this draft is adopted. Tick, amend or query each item.

[ ] Confirm definitions align with the Equality Act 2010 (harassment, sexual harassment, victimisation, all nine protected characteristics).
[ ] Confirm the description of the preventative duty (Worker Protection Act 2023, in force 26/10/2024) is accurate.
[ ] Verify the current commencement date / status of the Employment Rights Bill changes — the move to "all reasonable steps" and any new third-party harassment liability — and update Sections 5, 7 and 15.
[ ] Confirm building the policy to the "all reasonable steps" bar is appropriate and the listed steps are genuinely deliverable and evidenced by CDOCC Limited.
[ ] Confirm the sexual-harassment risk assessment approach (6.1) meets the duty and is documented per site.
[ ] Confirm third-party harassment provisions (Section 7) are adequate for a pub / hotel / lettings setting, including service refusal and banning.
[ ] Confirm multiple reporting persons and a confidential/anonymous route satisfy the "not forced to report to your harasser" principle, and that named contacts are filled in for each entity.
[ ] Confirm non-retaliation / victimisation wording is robust and consistent with the Equality Act.
[ ] Confirm cross-references to the [Disciplinary & Grievance Procedure] and [Equality, Diversity & Inclusion Policy] match the entity's actual documents (and consider the Acas Code of Practice on disciplinary and grievance).
[ ] Confirm gross misconduct characterisation is consistent with the contracts of employment and disciplinary policy.
[ ] Confirm training cadence and record-keeping are realistic and actually happening (reasonable-steps evidence).
[ ] Confirm any data protection / confidentiality handling of complaint records complies with UK GDPR / Data Protection Act 2018.
[ ] Replace all bracketed placeholders, set the responsible people, and adopt a separate copy per legal entity (Duke of Cornwall / Bugle Inn under the one Ltd; Luv Plymouth Lettings Ltd; Chy Lowen Holidays).
[ ] Confirm acknowledgement/sign-off mechanism for issuing to every worker.
[ ] Remove the DRAFT banner and set version, owner and review dates on adoption.