Expected business conduct by third parties

Date: May 2025

Harassment, Bullying and Victimisation

Com Laude is committed to providing a working environment free from harassment (including sexual harassment), bullying and victimisation and ensuring all staff are treated, and treat others, with dignity and respect.
We recognise that harassment, bullying or victimisation can occur both in and outside the workplace, such as on business trips, or at work-related events or social functions, or on social media.

Harassment, bullying or victimisation of any member of staff, or anyone they come into contact with during the course of their work, is unlawful and will not be tolerated. We will take active steps to help prevent any harassment, bullying and victimisation of all staff.

Anyone who is a victim of, or witness to harassment, bullying or victimisation is encouraged to report it. This will enable us to take appropriate action and provide support. Harassment, bullying or victimisation can result in legal liability for both the business and the perpetrator, whether they work for us or are a third party outside of our control. It may result in disciplinary action of our staff up to and including dismissal.

This statement sets out our expectations to all third parties including clients and suppliers dealing with Com Laude staff (including employees, homeworkers, part-time and fixed-term employees, officers, directors, agency workers, casual workers, consultants, contractors, trainees, self-employed contractors, volunteers and interns). It also confirms to third parties the standards we expect of Com Laude staff.

What is harassment?

Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment.

It also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past.

Unlawful harassment may be related to age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. Sexual harassment is dealt with specifically below.

Harassment may include, for example:

  • derogatory or stereotypical remarks about a particular ethnic or religious group, religion or belief, or gender
  • offensive e-mails, text messages or social media content
  • mocking, mimicking or belittling a person’s disability

A person may be harassed even if they were not the intended “target”. For example, a person may be harassed by racist jokes about a different ethnic group if the jokes create an offensive environment.

What is victimisation?

Victimisation includes subjecting a person to a detriment because they have done, or are suspected of doing or intending to do, any of the following protected acts:

  • bringing proceedings under the Equality Act 2010
  • giving evidence or information in connection with proceedings under the Equality Act 2010
  • doing any other thing for the purposes of or in connection with the Equality Act 2010
  • alleging that a person has contravened the Equality Act 2010

Victimisation may include, for example:

  • denying someone an opportunity because it is suspected that they intend to make a complaint about harassment
  • excluding someone because they have raised a grievance about harassment
  • failing to promote someone because they accompanied another staff member to a grievance meeting
  • dismissing someone because they gave evidence on behalf of another staff member at an employment tribunal hearing

Harassment and victimisation are unlawful and will not be tolerated. They may lead to disciplinary action up to and including dismissal.

Third-party harassment occurs where a person is harassed by someone who does not work for, and who is not an agent of, the same employer, but with whom they have come into contact during the course of their employment.

Third-party harassment could include, for example, derogatory comments about a person’s age, disability, colour or sexual orientation by a client, customer or supplier visiting the employer’s premises, or where a person is visiting a client, customer or supplier’s premises or other location in the course of their employment. Third-party harassment could also occur online via remote meetings, social media or messaging services.

What is bullying

Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean being in a position of authority but can include both personal strength and the power to coerce through fear or intimidation.

Bullying can take the form of physical, verbal and non-verbal conduct. Bullying may include, by way of example:

  • physical or psychological threats
  • dismissive, insulting or aggressive behaviour
  • insensitive jokes or pranks
  • ignoring or excluding an individual
  • creating an intimidating environment for others

Legitimate, reasonable and constructive criticism of a worker’s performance or behaviour, or reasonable instructions given to workers in the course of their employment, will not amount to bullying on their own.

What are sexual harassment & victimisation?

Sexual harassment is any unwanted physical, verbal or non-verbal 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 for them. A single incident can amount to sexual harassment.

It also includes treating someone less favourably due to their submission to, or refusal of, unwanted conduct of a sexual nature, or that is related to gender reassignment or sex, in the past.

Sexual harassment may include, for example:

  • continued suggestions for sexual activity after it has been made clear that such suggestions are unwelcome
  • unwanted physical conduct or “horseplay”, including touching, pinching, pushing and grabbing
  • sending or displaying material that is pornographic or that some people may find offensive (including emails, text messages, video clips and images sent by mobile phone or posted on the internet). The only exception is when such content is directly relevant to a staff member’s work, such as when we need to take action related to third-party websites containing offensive material
  • unwelcome sexual advances or suggestive behaviour (which the harasser may perceive as harmless)
  • offensive emails, text messages or social media content. This applies regardless of whether work-based or personal systems are used
  • A person may be sexually harassed even if they were not the intended target. For example, a person may be sexually harassed by pornographic images displayed on another person’s computer in a setting connected to the work of the Com Laude staff.

Victimisation in the context of sexual harassment may include, for example:

  • denying someone an opportunity because it is suspected that they intend to make a complaint about sexual harassment
  • excluding someone because they have raised a grievance about sexual harassment
  • Sexual harassment and victimisation are unlawful and will not be tolerated. They may lead to disciplinary action up to and including dismissal if they are committed by a staff member and discussions with and further action if committed by a third party:
  • in a work situation
  • during any situation related to work, such as at a social event with third parties
  • against a colleague or other person connected to us outside of a work situation, including on social media
  • against anyone outside of a work situation where the incident is relevant to suitability of the Com Laude staff member to carry out their role

If any sexual harassment or victimisation of staff occurs, we will take steps to remedy any complaints and to prevent it happening again.

Third-party sexual harassment occurs where a person is sexually harassed by someone who does not work for, and who is not an agent of, Com Laude, but who comes into contact with Com Laude staff during the course of their employment.
Third-party sexual harassment could include, for example, unwelcome sexual advances from a client, customer or supplier visiting the employer’s premises, a business contact at a business-related event, or where a person is visiting a client, customer or supplier’s premises, business event or other location in the course of their employment. Third-party sexual harassment could also occur online via remote meetings, social media or messaging services.

Third-party sexual harassment can result in legal liability and will not be tolerated. All staff are encouraged to report any third-party harassment they are a victim of, or witness.

If the harasser is a third party, such as a customer or other visitor, we will consider what action would be appropriate to deal with the problem. We will take active steps to try to prevent third-party sexual harassment of staff including attempting to discuss the matter with the third party to remedy any complaints and to prevent it happening again. These may include warning the harasser about their behaviour, banning them from our premises, reporting any criminal acts to the police, and sharing information with other branches of the business.
Any sexual harassment by a member of staff against a third party may lead to disciplinary action up to and including dismissal.

Reporting incidents

If you are member of Com Laude staff, incidents can be reported anonymously via Bob – Your Voice. If you are a third party, incidents can be reported to hr@comlaude.com or in writing to:

Kevin Thain
Com Laude
28 Little Russell Street
London
WC1A 2HN