Sexual Harassment Policy

OUR POLICY

People First (Recruitment) Limited is committed to ensuring that all its employees and temporary workers are treated with dignity and respect and treat others in the same way. We believe that all employees and temporary workers have the right to work in an environment which is free from any form of harassment, including sexual harassment.  

People First (Recruitment) Limited has a zero-tolerance approach to sexual harassment.                       

People First (Recruitment) Limited is committed to ensuring that reasonable steps are taken to prevent sexual harassment to all employees and temporary workers. This policy will be reviewed and updated from time to time to ensure People First (Recruitment) Limited’s compliance with its duties under the Equality Act 2010 as amended by the Worker Protection (Amendment of Equality Act 2010) Act 2023 and the Employment Rights Act 2025 to ensure that all reasonable steps are taken to prevent sexual harassment.

Harassment

Under the Act, harassment is defined as unwanted conduct that relates to a protected characteristic which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual, including conduct of a sexual nature.

Sexual Harassment

In accordance with the Equality Act 2010, People First (Recruitment) Limited is committed to providing a work environment free from unlawful sexual harassment.

  • 1 Sexual harassment is unwanted behaviour of a sexual nature which has the purpose or the effect of:
    • 1.1 violating the victim’s dignity; or
    • 1.2 creating an environment that is intimidating, hostile, degrading, humiliating or offensive to the victim.

 

  • 2 An individual of any gender may be the victim of sexual harassment.
  • 3 Whilst not an exhaustive list, forms of sexual harassment can include:
    • 3.1 Slurs or unwanted sexual advances;
    • 3.2 Visual conduct such as derogatory or sexually oriented posters;
    • 3.3 Physical conduct such as assault, unwanted touching, or any interference because of sex, race, or any other protected characteristic basis;
    • 3.4 Threats and demands to submit sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment benefits in return for sexual favours;
    • 3.5 Sexual comments or jokes;
    • 3.6 Unwelcome touching, hugging, massaging, or kissing.
  • 4 If an individual believes that they have been sexually harassed by a colleague or third party not employed by People First (Recruitment) Limited they have come into contact with in the course of their work, they should make an immediate report to Ian Ward or Katie Bevan followed by a written complaint as soon as possible after the incident. The details of the complaint should include:
    • 4.1 Details of the incident
    • 4.2 Name(s) of the individual(s) involved.
    • 4.3 Name(s) of any witness(es)
  • 5 People First (Recruitment) Limited will undertake a thorough investigation of the allegations. If it is concluded that harassment has occurred, remedial action will be taken.
  • 6 Where an incident/complaint of sexual harassment relates to a temporary agency worker or a work seeker, People First (Recruitment) Limited will not carry out instructions from a hirer/and/or intermediary/and/or third party which it considers will amount to sexual harassment and victimisation.
  • 7 People First (Recruitment) Limited will take all reasonable steps to safeguard job applicants, work-seekers, temporary agency workers it supplies and internal members of staff from harassment.
  • 8 People First (Recruitment) Limited will ensure that hirers have a sexual harassment policy in place, and temporary agency workers are made aware of them.
  • 9 People First (Recruitment) Limited will take all reasonable steps to ensure that third parties members of staff come into contact within the course of their work are aware of its policies on sexual harassment.
  • 10 People First (Recruitment) Limited will ensure that all staff are given training on sexual harassment, and regular training will be provided to all staff on sexual harassment.
  • 11 People First (Recruitment) Limited will carry out due diligence checks on hirers/intermediaries who we engage in the supply of temporary agency workers to ensure that they are taking reasonable steps to carry out their duties as employers under the Equality Act 2010.
  • 2 All employees and workers and third parties they engage with in the course of their work will be expected to comply with People First (Recruitment) Limited’s policy on sexual harassment in the workplace. Any breach of such a policy will lead to appropriate disciplinary action, which may include termination of contract, and/or other sanction in the case of third parties.
  • 3 Employees who People First (Recruitment) Limited finds to be responsible for sexual harassment will be subject to disciplinary procedures and the sanction may include termination.
  • 4 Temporary agency workers who People First (Recruitment) Limited finds to be responsible for sexual harassment will be subject to appropriate disciplinary action, which may include contract termination, even where such sexual harassment involves individuals who are not engaged by People First (Recruitment) Limited.

Complaints and monitoring process

People First (Recruitment) Limited has procedures for monitoring compliance with this policy and for dealing with complaints of sexual harassment in place. These are available from the Managing Director and CEO of People First, Ian Ward and Katie Bevan, and will be made available immediately upon request.  Any discrimination complaint will be investigated fully.