1. Purpose and commitment

Adgiftdiscounts Limited is committed to a workplace where everyone is treated with dignity, fairness and respect. Bullying, harassment, sexual harassment and victimisation are not tolerated, whether they come from a colleague, director, manager, customer, client, supplier, contractor, courier, visitor or any other third party.

Complaints and concerns will be taken seriously. They will not be ignored or covered up, regardless of the seniority, commercial importance or status of anyone involved. Misuse of power, influence or authority is unacceptable.

2. Legal framework and preventative duty

This policy supports compliance with the Equality Act 2010, the Worker Protection (Amendment of Equality Act 2010) Act 2023, the Employment Rights Act 2025 and the Acas Code of Practice on disciplinary and grievance procedures.

Since 26 October 2024, employers have been required to take reasonable steps to prevent sexual harassment, including sexual harassment by third parties. From 30 October 2026, employers will be expected to take all reasonable steps to prevent sexual harassment and may also be liable for other harassment by third parties unless all reasonable steps have been taken.

Adgiftdiscounts will work to the higher standard immediately. We will identify, record and take every preventative step that is reasonable for our organisation, rather than waiting for an incident or selecting only some available measures.

3. Who and what this policy covers

This policy applies to employees, workers, directors, apprentices, interns, agency staff, job applicants, contractors, consultants, volunteers and anyone acting for or representing the company.

It covers behaviour:

• at any Adgiftdiscounts workplace, production area or office;
• while working from home or at another location;
• in person, by telephone, email, messaging, video call, CRM, social media or another digital channel;
• on a work or personal device where the conduct is connected with work;
• during customer or supplier meetings, deliveries, exhibitions, conferences, training, travel, overnight stays or work-related social events; and
• outside normal hours where the conduct affects a working relationship or workplace.

4. Definitions

Harassment is unwanted conduct related to a protected characteristic covered by the Equality Act 2010 harassment provisions — age, disability, gender reassignment, race, religion or belief, sex or sexual orientation — which has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.

When considering the effect of conduct, the person's perception, the other circumstances and whether it was reasonable for the conduct to have that effect will be considered. Conduct can be harassment even where offence was not intended.

Sexual harassment is unwanted conduct of a sexual nature which has that purpose or effect. Treating someone less favourably because they submitted to or rejected sexual conduct can also be unlawful.

Bullying includes offensive, intimidating, malicious or insulting behaviour, or an abuse or misuse of power that undermines, humiliates or harms another person. Bullying may breach this policy even if it is not unlawful harassment.

Victimisation means subjecting someone to a detriment because they raised, supported or gave evidence about an equality-related concern, or because it is believed they may do so.

5. Examples of unacceptable behaviour

The following may amount to bullying, harassment or sexual harassment depending on the circumstances:

• sexual comments, propositions, jokes, gestures, staring, intrusive questions or unwanted physical contact;
• displaying or sending sexual, discriminatory or offensive images, videos, messages or emojis;
• comments about someone's body, appearance, clothing, relationships, pregnancy, gender identity or private life;
• racist, sexist, homophobic, transphobic, ageist, ableist or religion-related remarks or conduct;
• mocking an accent, disability, belief, name, culture or personal characteristic;
• unwanted invitations or messages after a person has indicated that the attention is unwelcome;
• deliberate exclusion, humiliation, threats, shouting, spreading malicious rumours or persistent unjustified criticism;
• coercive “banter”, initiation practices or pressure to take part in sexualised or discriminatory conversation;
• online harassment, including conduct through personal accounts or devices where it is connected with work;
• retaliation, hostility or disadvantage after a concern has been raised; and
• failing to respond to a known or reasonably foreseeable risk involving a customer, supplier or other third party.

This list is illustrative. A single serious incident can be enough, and repeated lower-level conduct may become harassment or bullying through its cumulative effect.

Reasonable, fair and constructive management — including performance feedback, work allocation or lawful disciplinary action — is not bullying merely because it is unwelcome. It must nevertheless be carried out respectfully and without discrimination.

6. Responsibilities

The Directors are responsible for ensuring that prevention is properly resourced, risks are reviewed, managers are trained, concerns are handled fairly and action is recorded.

Managers must set an appropriate example, challenge unacceptable conduct, act on concerns or warning signs, protect those involved and seek guidance rather than attempting to dismiss behaviour as “banter”. A manager who sees or receives information about possible harassment must not ignore it simply because no formal complaint has been made.

Everyone covered by this policy must:

• treat others with dignity and respect;
• stop conduct when told or when it should reasonably be clear that it is unwelcome;
• cooperate with prevention, training and investigations;
• report serious incidents or risks they witness; and
• avoid victimisation, retaliation or interference with a complaint.

7. Preventing harassment and assessing risk

Adgiftdiscounts will maintain a proportionate written risk assessment and prevention plan. It will consider our actual work, including customer and supplier contact, workshop and office environments, lone meetings or calls, trade events, travel, work-related social events, alcohol, online communication, power imbalances and people who may be particularly vulnerable.

Preventative measures will include, where reasonable:

• clear behaviour standards communicated during induction and periodically afterwards;
• practical training for all workers and additional training for managers and complaint handlers;
• more than one reporting route, including a route that bypasses a person's normal manager;
• reminders and standards for customers, suppliers, contractors and visitors;
• safe arrangements for lone working, meetings, travel and events;
• prompt action on warning signs, informal reports and near misses;
• secure recording of risks, reports, decisions and corrective actions;
• monitoring patterns across teams, locations and third-party relationships; and
• review of this policy, related procedures and the effectiveness of training.

If a proposed preventative measure is not taken, the Directors will record why it was not reasonable and what alternative control, if any, has been adopted.

8. Harassment by customers, suppliers and other third parties

No one is expected to tolerate harassment as part of their job or because a third party is commercially important.

A worker should report third-party conduct or a situation in which they felt at risk, even if no incident ultimately occurred. Adgiftdiscounts will assess the immediate risk and may:

• change the contact person or method of communication;
• arrange for another colleague to attend or take over a meeting, visit or call;
• warn the third party and state the behaviour expected;
• restrict, suspend or end contact or a commercial relationship;
• require a supplier, contractor or customer organisation to investigate;
• remove a person from the premises or an event; or
• support a report to the police or another authority where appropriate.

Relevant customer, supplier and contractor terms and communications should make clear that harassment of our workers is unacceptable and may result in service, access or the relationship being restricted or ended.

9. How to raise a concern

A person may raise a concern with:

• their line manager;
• any Director; or
• another manager or senior person they feel able to approach.

If the concern involves the normal reporting contact, it should be raised through one of the alternative routes. A report may be made verbally or in writing. Anonymous reports will be considered, although anonymity may limit the investigation or the action available.

Someone may explain directly that conduct is unwelcome where they feel safe and comfortable doing so, but they are never required to confront the person before reporting it. A witness or colleague may also raise a concern.

10. Informal and formal options

Where appropriate, the person raising the concern can normally choose whether they want an informal response or a formal grievance. Informal steps might include a supported conversation, a clear instruction to stop or agreed changes to working arrangements.

Informal action will not be used where the alleged conduct is serious, there may be a continuing risk, the person does not agree, or a formal investigation is otherwise necessary. The company may need to act even if the person affected does not want to make a formal complaint, but their wishes and wellbeing will be considered carefully.

11. Immediate response and support

On receiving a concern, the company will respond without unreasonable delay, check immediate safety and explain the available options and likely next steps.

Temporary measures may include separating working arrangements, changing reporting lines, preventing contact, adjusting duties or location, or suspending a worker on full pay where appropriate. Such measures are neutral and do not imply that an allegation has been proved. Wherever practicable, the person who raised the concern will not be moved or disadvantaged against their wishes.

Reasonable support may include a chosen workplace contact, adjustments, time to attend meetings or obtain specialist support, and consideration of paid time off where appropriate. Support will also be considered for witnesses, managers handling the matter and the person accused.

12. Formal investigation and fair procedure

Formal complaints will be handled under the company's grievance and, where appropriate, disciplinary procedures and in line with the Acas Code.

The company will:

• appoint an impartial investigator wherever reasonably possible;
• explain the allegation and process to the relevant people;
• allow both sides a reasonable opportunity to provide information, identify evidence and suggest witnesses;
• consider relevant documents, messages, records and surrounding circumstances;
• permit statutory accompaniment at a formal grievance or disciplinary hearing;
• reach findings on the balance of probabilities;
• communicate decisions and any right of appeal without disclosing confidential information unnecessarily; and
• keep the parties appropriately informed if the process takes longer than expected.

No conclusion will be reached simply because an allegation was made or denied. Delay in reporting will not, by itself, mean that a complaint is rejected.

13. Confidentiality and records

Information will be shared only where reasonably necessary to assess risk, investigate, support those involved, take action or comply with the law. Absolute confidentiality cannot be promised, and witnesses must not be offered secrecy that could make a fair investigation impossible.

Records will be accurate, proportionate, securely stored, accessible only to authorised people and retained in accordance with the Data Protection Policy and applicable law. Appropriate anonymised information may be used to identify patterns and improve prevention.

Nothing in this policy prevents a protected disclosure, report of a crime, report to a regulator, request for medical or legal advice or lawful participation in proceedings.

14. Outcomes and corrective action

If a complaint involving a worker is upheld, the matter may be dealt with under the disciplinary procedure. Outcomes may include management instruction, training, a formal warning, changes to duties or working arrangements, or dismissal for gross misconduct where justified.

Where a third party is responsible, the company cannot use its employee disciplinary procedure but will take proportionate protective and commercial action. Regardless of outcome, the company will consider whether wider risks, culture, controls, training or supervision need to change.

15. Protection from victimisation and retaliation

No person will be penalised, threatened, isolated, disadvantaged or treated unfavourably because they raised a concern, supported someone, acted as a witness or participated in a process. Suspected victimisation or retaliation should be reported immediately and may itself result in disciplinary action.

A complaint that is not upheld is not automatically false or malicious. Disciplinary action will be considered only where there is evidence that a person deliberately made a false or malicious allegation; being mistaken or unable to prove an allegation is not enough.

16. Training, monitoring and review

All workers will receive information about this policy during induction and refresher training appropriate to their role. Managers and anyone handling complaints will receive additional practical training.

The Directors will review:

• the harassment risk assessment and prevention plan at least annually;
• this policy and linked policies at least annually;
• training completion and effectiveness;
• reports, near misses, outcomes and recurring patterns; and
• the controls applying to customers, suppliers, events, lone working and online communications.

An immediate review will also take place after a serious concern, identified pattern, material change in working arrangements or relevant legal change.

17. Related policies and external help

This policy should be read with the Equality & Diversity Policy, Disciplinary & Grievance Policy, Whistleblowing Policy, Data Protection Policy, Health & Safety Policy and any relevant social-media, lone-working or event procedures.

Independent information is available from Acas at acas.org.uk. Anyone in immediate danger should contact emergency services. A person who believes a crime may have been committed may report it to the police, and the company will provide reasonable support.

18. Document control

Policy owner: Directors
Version: 2.0
Prepared: 3 September 2026
Effective date: On Director approval
Next scheduled review: No later than 30 October 2026, then at least annually