Group Sexual Harassment Policy
Description: Group Sexual Harassment Policy
Policy Applicable to: Greosn Group Policy Owner: Greosn Board
Last Updated: (Version 1) January 2026
Next update due: January 2027
Version: 1
Our Policy
Greosn recognises the importance of ensuring that all our working environments are safe from sexual harassment. Sexual harassment will not be tolerated in any of our businesses. Any complaints will be taken seriously and not ignored and this applies to everyone working in the group. We will take the appropriate steps to prevent sexual harassment taking place in our businesses.
Scope
This policy applies to all growing companies within the Greosn Group, their sites and locations across the UK and to permanent and temporary/seasonal employees. It does not apply to Pro-Force employees and agency workers. It does not form part of an employee’s contract of employment and may be amended at any time. Greosn may also vary the procedure at their discretion.
Responsibility
It is the responsibility of the directors of each business in the group to review, agree and implement this policy.
What is Sexual Harassment?
Sexual harassment is unwanted behaviour of a sexual nature. The law (Equality Act 2010) protects the following people against sexual harassment at work:
• employees and workers
• contractors and self-employed people hired to personally do the work
• job applicants
To be sexual harassment, the unwanted behaviour must have either:
• violated someone's dignity
• created an intimidating, hostile, degrading, humiliating or offensive environment for someone It can be sexual harassment if the behaviour: • has one of these effects even if it was not intended
• intended to have one of these effects even if it did not have that effect It can happen in person. It can also happen online, for example in meetings, email, social media or messaging tools.
Examples include:
• making sexual remarks about someone's body, clothing or appearance
• asking questions about someone's sex life
• telling sexually offensive jokes
• making sexual comments or jokes about someone's sexual orientation or gender reassignment • displaying or sharing pornographic or sexual images, or other sexual content
• touching someone against their will, for example hugging them
• sexual assault or rape
The Law
The laws that protect people against sexual harassment are:
• the Equality Act 2010
• the Worker Protection (Amendment of Equality Act 2010) Act 2023 – this law is about preventing sexual harassment
• the Employment Rights Act 2025 – this law makes sexual harassment a “protected disclosure” under the whistleblowing legislation
The Equality Act 2010 also covers other types of harassment. This includes:
• harassment related to certain 'protected characteristics' – for example sex, sexual orientation and gender reassignment
• less favourable treatment because of how someone responded to previous sexual harassment
Someone could experience more than one type of harassment at the same time.
By law, Greosn must take reasonable steps to prevent sexual harassment of our employees. This covers sexual harassment from other people at work and third parties e.g. customers and suppliers.
Risk Assessment
In order to take appropriate action to prevent sexual harassment, each Greosn business carries out an annual risk assessment to identify the risks of this happening in their business.
The risk assessment considers the following factors:
• the sector we operate in
• the type of work undertaken
• our working arrangements
• the types of roles we have in our business
• whether awareness training has taken place There is a sample risk assessment form (Appendix 1) at the end of this policy. Each businesses will complete the risk assessment spreadsheet. This is reviewed annually by the relevant business directors.
Steps taken to Prevent Sexual Harassment
Each business will review the annual risk assessment and identify any actions required to address the risks identified.
This may include but not limited to:
• Train managers to recognise and understand sexual harassment
• Train managers on handling complaints
• Communicate the policy to staff, managers and third parties
• Promote the procedure for reporting sexual harassment complaints
• Update policies and procedures to address identified risks
Reporting Procedure
If an employee believes that they have experienced or witnessed sexual harassment, they should feel able to raise this within the business. Employees can use one of the following channels to raise an issue:
• Grievance procedure
• Whistleblowing hotline
• Line manager
• Director
• Worker representatives
The complaints can be made formally or informally. Serious situations would need to be dealt with formally, as it would be unacceptable for the business to allow this to continue.
Dealing with a Sexual Harassment complaint
Sexual harassment complaints are handled through the grievance policy to establish the facts and decide if the complaint should be upheld. If the complaint is upheld, this means that the complaint is valid. If the complaint is upheld, the business will decide what is the most appropriate action to take. This may include disciplinary action in line with the disciplinary policy.
Any third-party sexual harassment complaints will also be investigated through the grievance policy and may require involvement from the third party. This may be a customer, supplier, contractor, service provider or a member of the public. If the complaint is upheld, the business will take appropriate action to ensure that this does not re-occur. This may include obtaining a signed commitment from the third party confirming the behaviour will not be repeated through to banning the person from coming onto any Greosn site.
Victim Support
Victims of sexual harassment will be directed to specialist help and support such as:
ACAS Sexual harassment – Specialist help and support
NHS - Help after rape and sexual assault
Able Futures – mental health at work support
Rights of women - Sexual harassment at work advice
Victim support
Safeline - we believe in you
Galop – LGBT+ sexual violence support