External Anti-Sexual Harassment Policy

Introduction

The Worker Protection (Amendment of Equality Act 2010) Act 2023 places increased responsibility on employers to take reasonable steps to prevent sexual harassment in the workplace. This includes considering risks arising from people who interact with employees as part of their work.

CHN Financial Consultancy is committed to providing a safe, inclusive and respectful working environment. We require every external person who interacts with our staff to treat them with dignity and respect.

Purpose and scope

This policy explains the standards of behaviour expected from clients, prospective clients, suppliers, contractors, agency workers, consultants, visitors and any other third party who communicates or deals with our staff.

It applies to conduct in our offices, at external venues, during meetings and events, while travelling for work, and through telephone calls, video calls, email, messaging services and social media.

We have zero tolerance for sexual harassment. A single incident may be sufficient for action under this policy.

What is sexual harassment?

Sexual harassment is unwanted conduct of a sexual nature that has the purpose or effect of violating a person’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment.

The person receiving or witnessing the behaviour determines whether it is unwanted. Conduct does not need to be directed at a particular individual and does not need to be repeated.

Examples of unacceptable conduct:

• Non-verbal conduct, including sexual gestures, staring or leering, displaying sexual images or materials, or sending unwanted gifts of a sexual or intimate nature.
• Verbal or written conduct, including sexual comments, suggestive or explicit language, intrusive questions, unwanted propositions, sexual jokes, pet names, catcalling, whistling, or derogatory and patronising remarks.
• Physical conduct, including deliberate unwanted contact, brushing against someone, touching, pinching, groping, fondling, indecent exposure or sexual assault.
• Conduct through email, social media, messaging platforms, telephone or video calls is covered in the same way as conduct in person.

Expected standards for external people

• You must communicate professionally and respectfully with our staff at all times.
• You must stop any behaviour immediately if a member of staff indicates that it is unwanted or inappropriate.
• You must co-operate with any reasonable steps we take to protect staff or investigate a concern.
• You must not retaliate against, disadvantage or victimise anyone who raises a concern, supports a complaint or participates in an investigation.

Raising a concern

Employees are encouraged to report concerns to their line manager, the next level of management, or the HR Manager/Practice Manager. External people may also report a concern about conduct connected with their interaction with our organisation to their usual company contact or to the Practice Manager.

Concerns will be handled sensitively and, where possible, confidentially. We may need to share information with relevant individuals so that the matter can be considered fairly and appropriate action can be taken.

No person who raises a genuine concern, or assists with an investigation, should be subjected to victimisation.

How we may respond

We will consider each concern promptly, fairly and proportionately. Depending on the circumstances, we may speak to those involved, preserve relevant records, restrict contact with staff, require communications to take place through a named contact, remove an individual from our premises or suspend access while enquiries are made.

Where inappropriate conduct is established, action may include a formal warning, a request for a replacement representative, restrictions on future contact, removal from our premises, or termination or non-renewal of a commercial or professional relationship, subject to any applicable contractual terms.

Where the individual is employed or engaged by another organisation, we may report the matter to that organisation and require it to take appropriate action.

Criminal behaviour and immediate risks

Sexual harassment may overlap with criminal conduct, including sexual assault, indecent exposure, stalking and offensive communications. A person affected may choose to report suspected criminal conduct to the police.

If we believe that a criminal offence may have been committed, or that there is an ongoing risk of serious harm, we may contact the police or another appropriate authority. Where appropriate, we will inform the person affected.

Communication and contractual arrangements

This policy will be provided to clients, suppliers, contractors, agency staff, consultants and visitors. Compliance may also be included as a requirement in contracts, terms of engagement, site rules or supplier standards.

Organisations working with us are expected to make this policy known to their employees, workers and representatives who may interact with our staff.