Harassment and bullying

This policy applies to anybody we place on an assignment, anybody who uses this board, and anybody who deals with HIRINGUK LTD at all. It sits alongside our equality policy, which covers discrimination in adverts and in hiring. This one is about how people are treated once they are at work.

1. What harassment is, in law

Section 26(1) of the Equality Act 2010: unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating somebody's dignity, or of creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Section 26(2) covers unwanted conduct of a sexual nature. Section 26(3) covers being treated worse because you rejected it, or because you put up with it.

It has to be unwanted. Not unreasonable, not deliberate, not repeated. Unwanted. One incident can be enough, and nobody has to have objected the first time before it counts.

It has to be related to a characteristic, or sexual in nature. Related to is wider than because of. Conduct aimed at somebody else, or at nobody, can still be related to a characteristic of the person who has to stand in it.

Purpose OR effect. Section 26(1) says purpose or effect. Meaning nothing by it is not an answer. It is a thing people say, and it has never been a defence.

And on effect, three things are weighed. Section 26(4): the perception of the person on the receiving end, the other circumstances of the case, and whether it is reasonable for the conduct to have had that effect. The second and third are why this is not simply whatever anybody says it is.

Harassment also covers conduct aimed at somebody because of a characteristic they are thought to have but do not, and conduct aimed at somebody because of who they are associated with, such as a family member.

2. Which characteristics, and the two that are not on the list

Section 26(5) lists seven: age, disability, gender reassignment, race, religion or belief, sex, sexual orientation.

Pregnancy and maternity, and marriage and civil partnership, are NOT in the harassment section. They are protected characteristics, and treating somebody badly because of either is unlawful in other ways, but section 26 does not list them. We say that because a policy that quietly adds them to the list has been copied rather than read, and because somebody in that position needs to know which door to use. Either way, harassment on ANY ground is unacceptable to us. That is our rule, not the statute's.

3. What it looks like on a shift

Most policies on this subject give office examples. This board is about depots, warehouses and cabs, so these are the shapes it actually takes.

• Remarks about somebody's accent or English on the transport office radio, where everybody on the channel can hear it.
• Being handed the worst runs, the coldest aisle or the longest waits after turning somebody down, or after making a complaint.
• A supervisor's comments on a night shift when there is nobody else in the building.
• Contact when squeezing past in a trailer or a cage aisle that is not an accident and both people know it.
• Photographs or messages passed round the shift's group chat. A group chat is not private and the law has never treated it as private.
• "Banter" that everybody joins in with except the person it is about.
• Being asked repeatedly to meet up after a shift once the answer has been no.
• Being left out of the handover, the lift, or the break, every time.

Bullying has no legal definition of its own. We treat it as behaviour that is offensive, intimidating, malicious or an abuse of position, usually repeated, that humiliates or undermines somebody. Where it relates to one of the seven characteristics it is also harassment and unlawful. Where it does not, it is still not happening on our watch. What it is not is a supervisor giving a lawful instruction, or telling somebody plainly that their work is not good enough.

4. The duty that changed in October 2024

What changed on 26 October 2024. Section 40A of the Equality Act 2010 now requires an employer to take REASONABLE STEPS TO PREVENT sexual harassment of its employees in the course of their employment. It was inserted by the Worker Protection (Amendment of Equality Act 2010) Act 2023. The point of it is that the duty bites BEFORE anything happens, not after.

What it costs to ignore. Section 124A lets a tribunal increase the compensation in a sexual harassment case by UP TO 25 PER CENT where that duty was contravened. It is an uplift on the award, not a separate claim.

The part that did not make it into the Act. The Bill originally made employers liable for harassment by THIRD PARTIES, customers, clients, visitors. THAT WAS REMOVED IN PARLIAMENT BEFORE IT PASSED. We are saying so because other policies in this trade state the third party duty as though it were law, and it is not. What follows in this policy about client sites is ours by choice.

Why we do it anyway. The risk in labour supply is not our office. It is somebody we sent to a depot, on a night shift, surrounded by people who do not work for us. That the statute does not reach there is a reason to write it down, not a reason to be quiet about it.

5. What we actually do

Before anybody is placed, we ask the client one question in writing. Who does a worker on your site report harassment to, and what is your policy. If a client cannot answer that, we have learned something before sending anybody rather than after.

The name goes on the assignment confirmation. The worker gets it before the first shift, in the same document as the pay rate and the hours, so it is in their hand at three in the morning when they need it and not in a folder in an office.

Our number is on it too, and it is the one that answers. A worker on a client's site should never have to choose between reporting to the person's own supervisor and saying nothing.

A report about a client is written down the day it is made. What was said, by whom, when, and what we did. Not because of a rule about records, but because the second report about the same site is only meaningful if the first one was written down.

We will pull workers off a site. If a client will not deal with it, we stop supplying them. That costs us money and it is the only sanction a supplier actually has. Saying it here, in advance and in public, is what makes it a policy rather than an intention.

Nobody loses shifts for reporting. Section 27 of the Equality Act calls that victimisation and it is separately unlawful. In this trade the punishment is rarely a sacking. It is the phone not ringing next week. We count shifts offered before and after a report, so that if it ever happened here it would show.

6. What we do not claim

This list is here on purpose. A policy is only worth reading if you can tell which parts of it are real.

• We have no training department, no annual training programme and no Head of Inclusion. There is one person here.
• There is no confidential reporting portal. There is an email address and a person who reads it.
• We do not publish diversity statistics, because we have not collected any and inventing them would be worse than having none.
• We have never handled a harassment complaint, because we have not placed anybody yet. This policy is written before it is needed, which is the only honest time to write one.

7. Reporting it, and what happens then

Email hello@hiringuk.co.uk, or use our complaints procedure if you would rather it went through that. You can also ring the number on your assignment confirmation.

• Same day. We acknowledge it and ask nothing except whether the person is safe right now, and whether they want to be moved off that site immediately. Moving is not an admission and it costs them nothing.
• Within two working days. We write down what was reported and put it in writing back to the person, so they can tell us if we have it wrong before anybody else sees it.
• Within five working days. We raise it with the client, unless the person asks us not to, and we tell them before we do it.
• Always. We tell them what happened as a result, even when the answer is that nothing did. A report that disappears is how somebody learns never to make another one.

Confidentiality, and its honest limit. We will keep it as confidential as we can, and we will not promise more than that. Raising it with a client means telling them enough to act, and there are situations where somebody is at risk and we would have to act whatever they preferred. We would tell the person first. What we will never do is use a confidentiality clause to stop somebody talking to ACAS, the EHRC, a tribunal, a union or the police.

8. Nobody is punished for raising it

Section 27 of the Equality Act calls it victimisation, and it is unlawful separately from the harassment itself. It covers making a complaint, giving evidence about somebody else's, and being thought to be about to do either.

In this trade the punishment is rarely a dismissal. It is the phone not ringing next week. That is why we count shifts offered to a worker before and after a report: so that if it ever happened here, it would show in our own figures rather than depending on somebody's word.

9. When the complaint is about us

If the complaint is about the owner of this company, there is nobody inside it who can investigate that impartially, and we are not going to pretend otherwise. A one person business promising an independent internal inquiry into itself is telling its first lie at the moment it matters most.

So here is what we do instead. We will still write down what was reported, on the day, and we will still answer it. But we will tell the person, in the same message, that they do not have to accept our answer and that these routes exist and do not depend on us.

• ACAS, 0300 123 1100. Free, independent, and the first step for a tribunal claim anyway. Early conciliation through ACAS is how almost every claim starts.
• The Equality and Human Rights Commission. Publishes the technical guidance on sexual harassment at work that the tribunals read, and can act on the section 40A duty itself.
• An employment tribunal. Three months less one day from the act complained of, and the clock does not stop while somebody waits for us to reply.
• The Fair Work Agency. For anything about how an employment business behaved. It took over this work from the Employment Agency Standards Inspectorate on 7 April 2026. It can inspect us, and we would rather that than be the only judge of ourselves.

Three months less one day. That is the time limit for a discrimination claim, counted from the act complained of, and it does not pause while somebody waits for us to reply. If you are near it, start ACAS early conciliation and carry on talking to us at the same time. We would rather lose a claim on the merits than win one because somebody ran out of time waiting for our email.

10. Review

This policy was written before it was needed, which is the only honest time to write one. It is reviewed when the law changes, when a complaint shows it did not work, and otherwise once a year. Every version is in our document register with the date it applied from.