The Pathway Group Harassment Policy. Please feel free to have a read through and if you would like further information on this policy or on Pathway Group please feel free to give us a call.

1. Harassment Policy
Pathway Groupputting you first

2. 3.
1. INTRODUCTION
Pathway Group is an equal opportunities employer which fully supports equality for
all, irrespective of a person’s race, religion, sex, marital status or disability.
As part of the company’s equal opportunities policy, harassment will not be tolerated.
Any such behavior will be dealt with as a disciplinary offence, which could lead
to dismissal. Individual employees should also be aware that they could be held
responsible for harassment and face prosecution.
Harassment in the workplace can have long term effects on the morale and well
being of individuals and be damaging to the overall efficiency and productivity of
the company.
Pathway Group has two main reasons for its positive stance on harassment.
The company has:
a. A responsibility to ensure that all employees feel that they are protected from
harassment and discrimination. All Pathway Group employees have a right to be
treated with dignity and respect by their colleagues, in accordance with Pathway
Group values.
b. A legal requirement to remove the threat of harassment and understanding that
failure to do so will lead to direct contravention of the Employment Acts.
Signed
Safaraz Ali
Director
30 January 2014

3. 4.
2. LEGISLATION
The Equality Act 2010 defines harassment as“unwanted conduct which has the
purpose or effect of violating an individual’s dignity or creating an intimidating,
hostile, degrading or offensive environment for the individual”in the context of
• Age
• Sex
• Disability
• Gender (including Gender Reassignment)
• Marriage and Civil Partnership
• Pregnancy and Maternity
• Race
• Religion or Belief
• Sexual Orientation
The Equality Act 2010 reinforces and extends legislation contained in the Prevention
of Harassment Act 1997.
3. DEFINITION OF HARASSMENT
All of the following in this list which is not exhaustive are forms of harassment:
bad gestures, inappropriate language, pestering, leering, bullying, assault (verbal or
physical), bribery, jokes, racial abuse, isolation, mimicking, insults, threats, gossiping,
inappropriate posters/calendars, graffiti, obscene gestures, touching, slander.
There is not a single, simple definition because harassment takes many forms,
occurs on a variety of grounds and may be directed against a group or individuals.
For the purposes of this policy and the conduct we expect within the company, the
following definition will apply:
Harassment is conduct and behavior which the receiver perceives to be offensive or
hostile; cause of discomfort, distress or exclusion; unwanted or unreasonable. All
these constitute an infringement of the rights of any employee of Pathway Group.
NOTE: Harassment does not simply depend on the intention of the offender, but
rather, the impact of the behavior on others. What one individual may be able
to accept could cause distress to another. What is important, therefore, are the
perceptions and feelings of the injured person(s)

4. 5.
Frequently, harassment is unseen and only occurs when the offender and the victim
are alone. This means that frequently it is one person’s word against another’s.
Investigations, in such a complex and sensitive area, may not be straightforward
and the company may have to make decisions on whether harassment has occurred
without correlative evidence, taking into account the individual’s character and
credibility.
4. FORMS OF HARASSMENT
The following list is a guide; and is not exhaustive:
• Physical contact ranging from touching to serious assault
• Verbal and written harassment, through sectarian jokes/songs, offensive
language, gossip or slander
• Visual display of inappropriate or offensive posters, graffiti, obscene gestures,
flags, bunting and emblems
• Isolation of an individual and non co-operation at work, exclusion from social
activities
• Coercion, ranging from pressure for sexual favours to pressure to participate (or
cease to participate) in political or religious groups
• Intrusion by pestering, spying, following. - (including the obtaining of
unauthorized personal information from Pathway Group sources)
5. REASONS FOR HARASSMENT
Reasons for which individuals may be subjected to harassment in the workplace are
wide ranging, including an individual’s:
• Race, Ethnic Origin or Nationality
• Gender
• Sexual Orientation
• Religious or Political Convictions
• Membership or Non-membership of a Trade Union
• Disability, Sensory Impairment or Learning Difficulty
• Physical Appearance
• Status as an Ex-offender
• Age
• Willingness and/or Ability to Challenge Harassment
• Lack of Company Position/Power

5. 6.6.
6. HOW TO STOP HARASSMENT
Responsibilities
6.1 The Director
• To ensure the policies and practices on equality and harassment are continually
developed and updated
• To ensure that all employees are aware of the equal opportunities and
harassment policies
6.2 All line managers
• To fully implement Equal Opportunities and Harassment Policies, and bring them
to the attention of all employees
• To treat complaints of harassment seriously, being sensitive to personal feelings
and perceptions (just because you cannot understand why someone feels
harassed does not mean they are not)
• To ensure complainants are not victimized as a results of making a complaint;
• To ensure that proven cases are dealt with in accordance with Pathway Group
discipline procedure;
• To protect confidentiality as appropriate.
7. INVESTIGATING A COMPLAINT
Any harassment complaint must be investigated fully, the following sets out how
this should happen:
• Line Managers must carry out an investigation in a confidential manner within
the specified timescale of 15 days ;
• A written record must be maintained by managers of ALL interviews and decisions
made
• Appropriate decisions and actions must be taken by managers, as befits the
nature of the offence

6. • All employees are to be aware of the equal opportunities and harassment policies
and must comply with them.
• All employees are to be encouraged to offer support to a known victim of
harassment;
• Employees should not indirectly support the offender/harasser, by ignoring what
is happening
• Employees are required to maintain records of incidents, to enable an accurate
recall of what has happened
• Employees are required to make it clear, if practicable, to the harasser that their
behavior is unacceptable and unwelcome ( In many cases, this may be sufficient
to stop the harassment)
• The harassment should be reported by the employee, verbally and in writing to
the Director - Safaraz Ali
EMPLOYEES SHOULD NOT BE AFRAID TO COMPLAIN EVEN IF THE HARASSER IS THEIR
SENIOR.
8. DEALING WITH COMPLAINTS OF HARASSMENT
The investigation can be formal or informal depending on the needs of the
complainant, and the nature of the complaint. Often an informal approach, at an
early stage, can offer the best solution before matters escalate. However, it should
be recognized that there will be instances where but because of the nature of the
harassment that action should be taken on a formal basis. Such action can only be
taken with complainants consent.
In all cases the complaint should be handled quickly, and with the appropriate
confidentiality.
8.1 Informal Procedure
Inmanycases,aninformalinterviewwithoffender,(i.e.thepersongivingharassment),
explaining that their behavior is unwelcome, embarrassing and is interfering
with work, will resolve the situation. It is recommended that these interviews are
conducted by the line manager of the person causing offence. Although informal,
it is recommended that the line manager or the interviewer should make notes that
will be retained on the individuals file in case there are any subsequent incidents.

7. 6.6.
8.2 Formal Procedure
If informal attempts have been unsuccessful, or the behavior is deemed
inappropriate to be resolved informally, it should be dealt with under the grievance
procedure by the Director, who is responsible to ensure a full investigation is carried
out, via the line manager of the alleged harasser.
If at any time during the investigations, potential misconduct is uncovered then the
case must be handled in accordance with the general disciplinary procedure.
8.3 Subsequent Action
If a complaint is upheld:
• Disciplinary action will be taken against the harasser, including dismissal where
appropriate;
• It is the responsibility of line management to check the harassment has ceased,
and that there are no signs of victimisation occurring
• It should be recognised that the complainant may need to undergo a number of
counselling sessions, to enable them to deal with what has happened to them
• It may also be necessary for the harasser and fellow employees to receive
counselling about what has happened within the work group
If a complaint is not upheld:
• It may be sensible for the complainant and the other person (s) involved to
receive counselling. The Director may consider whether to reschedule the work of
one or more of the other employees concerned in the interest of good employee
relations
• It is not likely that the complainant deliberately misled people with the claim,
consideration will be taken whether any follow up disciplinary action
is appropriate
• All documentation pertaining to the matter should be held in confidence by the
Director for a period of 12 months and then destroyed

8. 9. CONTACTS FOR HELP AND ADVICE
The Director is responsible for the overall control and implementation of the
procedure and will:
• Offer and ensure support for complainants;
• Assist and advice
• Liaise with relevant managers’

9. Pathway Group
Fairgate house, 205 Kings Road, Tyseley, Birmingham B11 2AA
Tel: 0800 955 0870 / 0121 707 0550
Email: info@pathwaygroup.co.uk
Web: www.pathwaygroup.co.uk