Dignity at Work A Policy against Harassment and Bullying

Dignity at Work A Policy against Harassment and Bullying The Trust strives to ensure equality of opportunity for all, both as a major employer and as a provider of health care. This procedural document has been equality impact assessed to ensure fairness and consistency for all those covered by it regardless of their individual differences and the results are shown in Appendix D Policy Profile Policy Reference: HR 4.5 Version: 5 Author: Jacqueline McCullough, Deputy Director of Human Resources & Organisational Development Executive sponsor: Director of Human Resources & Organisational Development Executive Sponsor sign off 07.12.2012 Target audience: All Trust staff Date issued: 19 December 2012 Review date: December 2015 Consultation Key individuals and committees consulted during drafting Ratification Ratification Committee: Policy Ratification Group Date: 12 th December 2012 Staff Side Representatives Dates 03 Nov 2010 Line Managers Dates Nov/Dec 2012 HR Managers Dates Nov 2012 Staff Support Service Oct/Nov 2012 Document History Version Date Review date Reason for change 5 19December 2012 Dec 2015 NHSLA Policy 4 14 January 2011 14 January 2014 Policy ratified 3 October 2007 August 2010 Review Page 1 of 21

Contents Paragraph Page Executive Summary 3 1 Introduction 4 2 Purpose 4 3 Definitions 4 4 Scope 6 5 Roles and responsibilities 6 6 Process General Principles for raising concerns about harassment and/or bullying 7 7 Process to be followed once a concern has been raised: what you should do if you are being harassed 8 8 Malicious Complaints 10 9 Training 11 10 Dissemination and Implementation 11 11 Monitoring Compliance 14 12 Associated Documentation 14 13 References 14 Appendices A Some examples of behaviour that may constitute harassment and bullying 15 B Contact Organisations 17 C Flow chart detailing process 18 D Equality Impact Assessment 19 E Procedural Document Checklist 20 Page 2 of 21

Executive Summary The Trust aims to provide high quality health care to the local community and patients who use our specialist services. We can only achieve this aim through a dedicated workforce that is committed to providing these services. All employees deserve to be treated fairly and with respect and in recognition of this, the Trust introduced Dignity at Work, A Policy against Harassment and Bullying. The policy was developed in partnership with local staff representatives and its clear objective is to develop a culture in which harassment and bullying are known to be unacceptable whether it be harassment by colleagues, managers, patients, members of the public, volunteers, those on work placement or those from other organisations who are on site. In the past staff have often been reluctant to make a complaint, as they were concerned their complaint would not be taken seriously. Managers have a responsibility to investigate all complaints of harassment and to ensure that action is taken to stop the harassment and prevent its re-occurrence. We will be working with managers and Trade Union representatives to ensure that this policy is effective, and will regularly monitor the implementation and use of the policy. We all have a responsibility to challenge harassment in the workplace and this policy will help the Trust move towards an environment that is free from harassment. Page 3 of 21

1. Introduction The Trust is committed to the principle that the dignity of individuals is respected, and that all employees understand and accept that harassment in any form is considered wholly unacceptable and is contrary to the Trust s Equal Opportunities Policy and Disciplinary Procedure and Rules. The policy recognises that harassment in the workplace takes place and acknowledges the serious effects that harassment can have on the working lives of employees, for example, demoralisation, stress, anxiety and even potential sickness. In addition, staff may feel that management may not take their complaint of harassment seriously and that they themselves are in some way to blame. 2. Purpose The policy aims to provide a framework for handling harassment in the workplace and a clear process for how complaints of harassment will be dealt with. The policy aims to give employees confidence to raise complaints and assurance that such allegations will be dealt with promptly and efficiently. It is the Trust s position that all staff are entitled to carry out their duties without being subjected to harassment on grounds such as age, disability, race, nationality, ethnic or national origin, gender, religion beliefs, sexual orientation, domestic circumstances, social and employment status, HIV status, gender re-assignment, political affiliation or trade union membership. The Trust s objective will be to make the Trust s standards of employee behaviour clear and to develop a culture in which harassment and bullying are known to be unacceptable and everyone is responsible for challenging all forms of harassment. The policy sets out a clear process through which any complaints can be addressed. The outcome will be that all employees are aware of the Trust s expected standards of behaviour, and that employees are able to work in an environment free from harassment and bullying. 3. Definitions In the context of this policy, at work includes any place where the occasion can be identified as part of employment, for example, a work-related conference or any context in which employment duties are being carried out, and may also include social occasions linked to work. Harassment: Harassment can take many forms, but in general terms is unwanted conduct affecting the dignity of men and women in the workplace. It may be related to age, sex, race, disability, religion, sexual orientation, nationality or any personal characteristic of the individual. It may be persistent or an isolated incident. In the Equality Act 2010 harassment is defined as unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual s dignity or creating and intimidating, hostile, degrading, humiliating or offensive environment for that individual. Bullying: Bullying is not specifically defined in law, but in their advice leaflet for employees, ACAS give the following definition: Bullying may be characterised as offensive, intimidating, malicious or insulting behaviour, an abuse or misuse of power through means intended to undermine, humiliate, denigrate or injure the recipient' Page 4 of 21

Harassment and Bullying is described by ACAS as: Bullying or harassment may be by an individual against an individual (perhaps by someone in a position of authority such as a manager or supervisor) or involve groups of people. It may be obvious or it may be insidious. Harassment and bullying can range from extremes such as physical violence to less obvious forms like ignoring someone. They can be delivered in a variety of ways - with or without witnesses - and be persistent behaviour over a period of time, or a one-off act. It is not the intention of the perpetrator but the deed itself and the impact on the recipient, which determines what, constitutes harassment or bullying. Some examples of behaviour that may be regarded as harassment and bullying can be found at Appendix E) Victimisation: This is when someone is treated less favourably than another because they have brought proceedings, given evidence or information, rejected advances or complained about the behaviour of someone who has been harassing, discriminating against, or in some other way intimidating them or another person. It also applies when someone is treated less favourably than another because they have supported another person who has made a compliant or raised a grievance. Third party Harassment: This is treatment which creates an offensive environment for an employee even though it is not directed at them at all. For instance, an example where a member of staff is disabled and is claiming harassment against his line manager after she frequently teased and humiliated him about his disability. A second member of staff shares an office with the disabled member of staff and he too is claiming harassment, even though he is not disabled, as the manager s behaviour has also created an offensive environment for him. Association & Perception Associative discrimination: Associative discrimination is discrimination against a person because they have an association with someone with a particular protected characteristic under the Equality Act 2010 such as race, religion or belief, sexual orientation, age, disability, gender reassignment and sex. An example of associative discrimination might be a non-disabled employee who is discriminated against because of action she needs to take to care for a disabled dependant. Perceptive discrimination: Perceptive discrimination is discrimination against a person because the discriminator thinks the person possesses that characteristic, even if they do not in fact do so. An example might be a member of staff is 45 but looks much younger. Many people assume that he is in his mid 20s. He is not allowed to represent his company at an international meeting because the Managing Director thinks that he is too young. The member of staff has been discriminated against because of his perceived age Harassment at work is contrary to the Trust s Equal Opportunities Policy and will be treated as a disciplinary offence under the Trust s Disciplinary Procedure, for which action may be taken up to and including dismissal. Page 5 of 21

4. Scope This policy applies to all staff (temporary or permanent) working in all the locations registered by St George s Healthcare NHS Trust with the Care Quality Commission, to provide its regulated activities. This also includes volunteers, contractors, students and/or trainees. Harassment by patients and members of the public is dealt with under the Management of Violence and Aggression Policy. Contractor, agency staff and employees from other organisations working on site will be required to adhere to this policy, and this requirement shall be made clear in any contractual arrangements with the Trust. 5. Roles and Responsibilities 5.1 The Chief Executive and Executive Directors The Chief Executive has overall responsibility for the implementation and monitoring of this policy, and has nominated the Director of Human Resources and Organisational Development to take responsibility for the implementation of the Dignity at Work Policy and monitoring the cases of harassment and bullying reported to the Human Resources Department. The Human Resources Department has responsibility for advising line managers on the policy and how to manage complaints of harassment. 5.2 Responsibilities of Managers Managers have a responsibility to create a work environment where it is clear that harassment is not acceptable. Managers must be fully conversant with the Dignity at Work, A Policy against Harassment and Bullying and how it operates and: Ensure that any allegation of harassment is investigated and, if the investigation into the alleged harassment finds that an employee has been harassed that action is taken to immediately stop the harassment and prevent its reoccurrence. Provide support to any member of staff who experiences harassment Use their judgement to correct standards of conduct or behaviour that could be seen as harassment, and to remind staff of theses standards. Not dissuade employees from making a complaint or assume that those making complaints are over sensitive or troublemakers. 5.3 Work Performance Managers have a responsibility to ensure that poor performance standards from staff are addressed. This must be achieved by good management practice with the emphasis on assisting the employee to improve performance with appropriate support and guidance: 5.4 Organisational Risk Committee The Committee is responsible for ensuring the Trust creates a work environment where it is clear that harassment is not acceptable and that all Managers are fully conversant with the Dignity at Work, A Policy against Harassment and Bullying and how it operates. Page 6 of 21

The Committee oversees incidents/allegations of harassment and bullying to ensure that all such incidents/ allegations are thoroughly investigated and actions taken to immediately stop the harassment and prevent its re-occurrence. 5.5 Employee Responsibilities Every employee has responsibility for his or her own behaviour under the policy. In particular, individuals shall: Co-operate with measures introduced by the Trust to ensure harassment does not occur in any form at work. Not harass employees of the Trust and display behaviours that are consistent with the Trust s values. Not victimise or attempt to victimise any employee making a complaint. Draw the attention of management to suspected incidents of harassment. Not make malicious or unfounded allegations against fellow colleagues, managers, or other staff 5.6 Trade Union Representatives The Trust recognises that Trade Union representatives will have a vital role to play in supporting staff throughout this process and that in the majority of cases staff will be accompanied by a Trade Union representative. In addition to representation, they will be able to: Provide advice and guidance on the process. Provide information on external sources of advice. Set a good example by challenging harassment. Participate in joint training. Publicise the policy amongst Trade Union members. Participate in the monitoring and effectiveness of the policy. Trade Unions/Professional Organisations should consider appropriate mechanisms for supporting someone alleging harassment by a fellow Trade Union member. 6. Process - General Principles: for raising concerns about harassment and/or bullying 6.1 Right to Be Accompanied Throughout the process the complainant and the employee accused of harassment may be accompanied at any meetings with management held under this Procedure by a Trade Union representative or work colleague from the Trust Employees with a disability may require additional or alternative support at meetings, and all reasonable requests will be accommodated. On some occasions, an employee will raise a complaint of harassment and bullying when their manager is managing their conduct, attendance or performance under one of the Trust s employment policies. In circumstances where the complaint is against a manager, the manager will be asked to respond to the allegations and would not normally be accompanied in these circumstances. However, if their actions are investigated under the Trust s Disciplinary Procedure, they would be have the right to be accompanied at any meeting held under the Trust s Disciplinary Procedure that may result in a warning being issued. Page 7 of 21

6.2. Advice and counselling If a member of staff believes they are being harassed they may find it helpful to speak to someone else and this may be a manager, trade union representative (see above) or one of the Staff Support Counsellors. The role of the person approached is to offer support, discuss the options open to the employee, and help the employee determine, if and how they wish to progress matters. This will take place in total confidence and without pressure as to the course of action to be taken. The counsellor will have no role in formal investigations of a harassment complaint. There is also the Trust s confidential telephone advice line, the Harassment and Bullying Listening Service. This dedicated confidential and informal support can be reached on 020 8725 1595 and is staffed by trained volunteers and staff support counsellors. The information discussed with volunteers will not be passed on to managers. In some cases, staff may wish to speak to someone of the same sex or ethnic background from an external organisation and some contact addresses are given at Appendix B. Both the member of staff alleging harassment and the alleged harasser will have access to staff counsellors and/or may choose to contact their Trade Union representative or someone external to the Trust. If the member of staff being harassed cannot speak to their manager because they are unavailable, they should consider speaking to a member of the Human Resources Department. 7. Process to be followed once a concern has been raised- What you should do if you are being Harassed Please refer to Appendix C Flowchart 7.1 Informal Action Individuals are not always aware of the impact of their behaviour on others and that it may be perceived as harassment. The majority of staff who experience harassment want it to stop and want the issue to be resolved informally. However, some staff may find it difficult to challenge the behaviour of others. If possible, the employee should ask the person harassing them to stop, making it clear that their conduct is unwelcome, offensive and/or interfering with work. ou might find it helpful to plan what to say to the harasser, where to say it and an appropriate time to do it. Actions you can take yourself: Keep a diary of all incidents records of dates, times, any witnesses, your feelings etc. Keep copies of any correspondence that may be relevant, for example reports, letters, memos, notes of any meetings that relate to you. Inform the harasser that you find their behaviour distressing and offensive Give examples of when and how the behaviour occurred Inform the harasser that you want their behaviour to cease Inform the harasser that you may consider making a formal complaint to your manager if the behaviour does not stop. Keep a copy of the record for yourself and one copy for your Trade Union representative. Page 8 of 21

ou are encouraged to raise your concerns with your manager as soon as possible who will discuss with you what should happen next. Alternatively, you may wish to speak to a Human Resources Advisor, work colleague or Trade Union Representative, however, responsibility for addressing your concerns will rest with your manager. ou may wish to use an external organisation as a source of support: Some examples of external sources of support are given at Appendix A. If you approach a colleague for support, it is important that you ask your colleague to treat this issue with due regard for confidentiality to avoid the risk of the accused member of staff being subjected to gossip in the department. If your complaint is about your line manager or a more senior manager and you do not wish to raise your concerns with them directly you should discuss this with their line manager. Once a resolution has been reached and agreed by the complainant, alleged harasser and manager, the dignity at work procedure will end at this point and no formal action will be taken. Further action may be taken for example, training, mediation, team building sessions or other action the manager may feel suitable. 7.2 What to do if you are accused of Harassment If it is alleged that you have harassed a member of staff you will be asked by your manager to respond to the allegation. Prior to this, the member of staff may have approached you without involving their manager and you should reflect on your behaviour and consider if it could be regarded as harassment. Usually the member of staff making the allegation simply wants the harassment to stop and for the harasser to alter their behaviour. If you believe the allegations are unfounded, you will be given the opportunity to see details of the complaint against you and will be able to respond to the allegations. ou may wish to consult your Trade Union representative for advice and support or to contact the Trust s Staff Counsellors. ou should not confront the person making the allegations or discuss the matter openly with your colleagues as this may in itself may be construed as a form of harassment. 7.3 When Informal Action is Unsuccessful or is Inappropriate If informal action has not resulted in the unacceptable behaviour ceasing, or the incidents of harassment are so serious informal action may be inappropriate or you do not wish to raise the complaint in this way, you may wish to make a formal complaint under this procedure. ou should set out your complaint in writing giving details of when the harassment occurred, the nature of the behaviour, how this made you feel and the names of any witnesses who were present. The alleged harasser will be entitled to see a copy of your statement. ou are encouraged to discuss this course of action with your Trade Union representative. 7.4 The Investigation Process On receipt of a formal written complaint, a manager will be appointed to carry out an investigation into the complaint. Where reasonable and as far as Page 9 of 21

possible, the investigating manager will not be a manager in the same department as the member of staff who has made the complaint. The length of time it takes to complete an investigation will vary from case to case but as far as possible the investigation should be completed within 4 weeks of receipt of the formal written complaint. Where this has not been possible, the investigating manager will contact the complainant to explain the reason for the delay. The investigating manager will meet with the complainant to discuss their concerns and explain how the investigation will be conducted. The investigation process may include collecting witness statements if relevant and meeting with the alleged harasser to hear their response to the allegations. On completion of the process if the investigating manager believes there is a case for the alleged harasser to answer at a disciplinary hearing, the matter will be dealt with in line with the Trust's Disciplinary Procedure. It should be noted that harassment is a breach of the Trust s Equal Opportunities policy. Serious cases may be considered gross misconduct and may lead to dismissal. If the investigating manager believes that the allegation of bullying and harassment is unfounded and malicious, he / she may recommend that the complainant s conduct is dealt with under the Trust s Disciplinary Procedure. The investigating office may recommend that rather than dealing the matter under the disciplinary procedure, support should be given to ensure the harasser modifies their behaviour. The investigating manager may consider that the issue would best be resolved between the two parties and may recommend mediation. 7.5 Appeal If the Investigating Officer does not believe there is a case to answer under the disciplinary procedure and the member of staff alleging harassment is not satisfied with the outcome of the investigation, s/he will have the right to appeal to the final stage of the Trust s Grievance Procedure. However, the complainant will not be allowed to appeal against the perceived severity or leniency of any disciplinary action taken. Any employee who is issued with a disciplinary warning or dismissed as a result of harassing another employee will have the right to appeal under the Trust s Appeals Procedure. Following resolution of informal or formal complaints, a record should be kept of the incident. Where harassment did occur, it is important to check that the harassment has stopped and that there has been no subsequent victimisation. Monitoring may be carried out on a regular basis. 8. Malicious Complaints It is recognised that it is for the recipient to determine what constitutes harassment; however, the purpose of an investigation into the complaint is to determine whether the employee had good reason to feel they were being harassed. If a complaint turns out not to be made in good faith, and/or with malicious intent this will be treated as a disciplinary offence which may result in disciplinary action being taken, up to and including dismissal. Page 10 of 21

. 9. Training All staff will receive training in dignity at work as per the Trust s Training Needs Analysis (TNA). Monitoring of attendance and follow up of non attendance please see the Corporate Induction Policy. 10. Dissemination and implementation 10.1 Dissemination Both managers and the Trade Unions recognised by the Trust will make every effort to promote this policy. Managers are responsible for ensuring that all staff are aware of how the policy operates, how to raise a complaint both informally and formally and how such a complaint will be handled, and the responsibilities of both staff and managers under the policy. New staff will be informed of the policy, as part of their induction into the Trust and a summary of the policy is contained in the staff handbook distributed at induction. The Trust will display the policy statement in all its premises and publish the policy on the Trust s intranet system 10.2. Implementation Managers will receive training on how this policy operates through the Trust s Effective People Management training for Managers course and their responsibilities under it to ensure that the policy is consistently and fairly operated. 11. Monitoring compliance See table below Page 11 of 21

Monitoring compliance and effectiveness table Element/ Activity being monitored Process for raising concerns about harassment and/or bullying Process to be followed once a concern has been raised Lead/role HR Managers with support from Deputy Director of HR Human Resources Department Chief Executive will be the lead on the monitoring of this policy. He / she will be assisted in this role by the Human Resources Department Methodology to be used for monitoring -Ongoing raising awareness by Line Managers -Corporate Induction -Training to Managers at Effective People Management training The Trust will use the annual NHS National Staff Survey to monitor compliance Frequency of monitoring and Reporting arrangements Annual report to Trust Board and Staff side representatives at the Partnership Forum. The report will also be submitted to the Organisation Risk/Health and Safety Committee The Human Resources Department will keep a record of all reported incidents of harassment and bullying, including the outcome of the investigation, whether it was dealt with informally or formally, and how long it took to complete the investigation. The record will include biographic details on the complainants and alleged harassers with particular reference to sex, race and disability and any trends that might emerge. Acting on recommendations and Leads The required actions will be identified through these meetings and led by the HR Managers If the monitoring or HR Director s report reveals a greater incidence of harassment complaints in certain departments, this will be investigated with the relevant General Manager or Director. Change in practice and lessons to be shared Required changes to practice will be identified and actioned within twelve months. The General Manager will take each change forward. Lessons will be cascaded from the General Manager to all staff affected.. Required changes to practice will be identified and actioned within twelve months. The General Manager will take each change forward. Lessons will be cascaded from the General Manager to all staff affected.. Page 12 of 21

The Director of Human Resources will report on the operation of this policy on an annual basis at the Trust Board, and will also discuss this report with staff side representatives at the Partnership Forum. The report will also be submitted to the Organisation Risk/Health and Safety Committee Page 13 of 21

12. Associated documentation The Trust s policies and procedures: Disciplinary Procedure Grievance Procedure Policy on the Employment of Disabled People Equality and Diversity in Employment Policy Zero Tolerance, Prevention and Management of Intimidation, Violence & Aggression, Policy & Procedures Corporate Induction Policy 13. References Equality Act 2010 www.equalityhumanrights.com NHS Terms and Conditions of Service Handbook Section 32 Dignity at Work (Amendment umber 25) British Medical Association (BMA) (2006) Bullying and Harassment of Doctors in the Workplace Chartered Institute of Personnel and Development (CIPD) (2005) Bullying at Work: Beyond Policies to a Culture of Respect Department of Health (2000) Improving Working Lives Standard Department of Health (2010) The NHS Constitution: The NHS belongs to us all Department of Health (2002) Code of Conduct for NHS Managers NHS Employers (2010) Health and Safety essential guide NHS Employers website NHS Employers website provides further information and resources on bullying and harassment: www.nhsemployers.org Royal College of Nursing (2005) Bullying & Harassment at Work: A Good Practice Guide for RCN Negotiators and Healthcare Managers Page 14 of 21

APPENDIX A Some examples of behaviour that may constitute harassment and bullying are Physical contact ranging from touching to serious assault. Verbal and written harassment (including e-mail) including jokes, offensive language, insulting or abusive behaviour, gossip, slander, sectarian songs, and letters. Exclusion from social or workplace events Visual display of posters, graffiti, obscene gestures, flags and emblems, calendars and slogans on clothing. Jokes aimed at certain groups for example, sexually or racially offensive jokes, jokes aimed at people with disabilities. Coercion ranging from pressure for sexual favours, including implied or overt promises of preferential treatment or threats concerning present or future employment status, to pressure to participate in political/religious groups. Intrusion by pestering, spying and/or following. Bullying, for example, criticising one person for a common fault, criticising in a public and humiliating way, exerting excessive and unnecessary pressure, and unwarranted use of authority or power. Failure to safeguard confidential information Shouting at staff Setting impossible deadlines Persistent criticism Personal insults. Cyber bullying, for instance, detrimental texts sent via mobile telephones or images of work colleagues posted on external websites following work events could amount to bullying It should be noted that this is not an exhaustive list, but one, which aims to indicate area of potential harassment, discrimination, victimisation or bullying. Harassment of Disabled People Harassment of disabled people can include the following types of behaviour: Staring and/or uninvited touching. Speaking to others rather than directly to the disabled person. Asking intimate questions about a person s impairment. Questioning a disabled person s work capacity and/or ability by making inappropriate demands or requirements e.g. over zealous scrutiny of sickness records. Making assumptions or speculating about someone s impairment. Sexual Harassment Although sexual harassment may be persistent and continue even after the recipient make it clear they want it to stop, a single incident can constitute unacceptable behaviour. Page 15 of 21

Some examples of behaviour that may constitute sexual harassment Physical contact, ranging from unnecessary touching through to sexual assault. Sexual advances, propositions or demands for sexual favours; Suggestive comments, leering and innuendo; Unwanted or derogatory comments about dress and/or appearance; Displaying offensive materials for example pornographic pictures or pin ups. Racial Harassment The NHS has identified tackling racial harassment as a priority action point for NHS Trusts and St. George's Healthcare NHS Trust welcomes and supports this priority and is fully committed to tackling racism. This policy is intended to offer staff a process through which they can raise complaints of racial harassment by management, colleagues, patients and members of the public. Racial harassment can be defined as racially motivated actions and behaviour, which are directed at people because of their race, colour, ethnicity, cultural differences, creed and/or nationality and which are unwanted and/or cause offence and distress. The Macpherson Report defines a racist incident as any incident which is perceived to be racist by the victim or any other person. Some examples of behaviour that may constitute racial harassment Racist jokes, banter, insults and taunts; Racist literature and graffiti. Excluding people because of their race, colour, ethnic origin, cultural differences, creed and/or nationality; Making racist insinuations; Unfair work allocation; Physical attacks on co-workers, because of their race, colour, cultural differences, ethnic origin, creed and/or nationality. This list is not exhaustive and therefore complaints of inappropriate behaviour may be raised under this procedure regardless of whether or not they fall within the definitions outlined in policy. Page 16 of 21

APPENDIX B Contact Organisations St George s Healthcare NHS Trust Staff Support Service 020 8725 3368 Mediation Service, from the Staff Support Service; contact on ext 3368 or 4749 or by email Harassment and Bullying Listening Service 020 8725 1595 Equality and Human Rights Commission 0845 604 6610 Page 17 of 21

APPENDIX C Approach the harasser Harassment Occurs Keep record of dates & events Put compliant Formal in writing using Trusts grievance procedures Raise concerns with manager who will agree a course of action Appropriate manager hears grievance and will interview any relevant parties including witness If behaviour continues or has not been resolved Inform employee of the outcome of the investigation If necessary use discipline Proceed with formal action Other e.g. training, mediation If employee remains unhappy appeal to Stage 3 (Final Stage) of the Grievance Procedure Harassment Stops Page 18 of 21

Appendix D: 1. EQUALIT IMPACT ASSESSMENT FORM INITIAL SCREENING Service/Function/Policy Directorate / Department Assessor(s) New or Existing Service or Policy? Date of Assessment Dignity at Work Human Resources Jacqueline McCullough Existing 1 December 2010 1.1 Who is responsible for this service / function / policy? Human Resources 1.2 Describe the purpose of the service / function / policy? Who is it intended to benefit? What are the intended outcomes? To challenge harassment in the workplace and move towards an environment that is free from harassment from all staff. 1.3 Are there any associated objectives? E.g. National Service Frameworks, National Targets, Legislation, Trust HR strategic objectives, specifically the Trust s objective to be an exemplary employer. Agenda for Change Equality Act 2010 1.4 What factors contribute or detract from achieving intended outcomes? Management and staff engagement 1.5 Does the service / policy / function / have a positive or negative impact in terms of race, disability, gender, sexual orientation, age, religion or belief and Human Rights? Details: [see Screening Assessment Guidance] A positive impact on all groups of staff 1.6 If yes, please describe current or planned activities to address the impact. N/A 1.7 Is there any scope for new measures which would promote equality? N/A 1.8 What are your monitoring arrangements for this policy/ service NHS Annual Staff Survey HR Monitoring spreadsheet Spread equally across all staff 1.9 Equality Impact Rating [low, medium, high]- see guidance notes 3.1 above Low 2.0. Please give you reasons for this rating Low impact on equality Page 19 of 21

Appendix E: Checklist for the Review and Approval of Procedural Documents To be completed and attached to any document submitted to the Policy Approval Group for ratification. Title of document being reviewed es/no/ Unsure Comments 1. Title Is the title clear and unambiguous? Is it clear whether the document is a guideline, policy, protocol or standard? 2. Rationale Are reasons for development of the document stated? 3. Development Process Is the method described in brief? Are individuals involved in the development identified? Do you feel a reasonable attempt has been made to ensure relevant expertise has been used? Is there evidence of consultation with stakeholders and users? 4. Content Is the objective of the document clear? Is the target population clear and unambiguous? Are the intended outcomes described? Are the statements clear and unambiguous? 5. Evidence Base Is the type of evidence to support the document identified explicitly? Are key references cited? Are the references cited in full? Are local/organisational supporting documents referenced? 6. Approval Does the document identify which committee/group will approve it? Page 20 of 21

Title of document being reviewed If appropriate, have human resources/staff side committees (or equivalent) approved the document? 7. Dissemination and Implementation Is there an outline/plan to identify how this will be done? Does the plan include the necessary training/support to ensure compliance? 8. Document Control Does the document identify where it will be held? Have archiving arrangements for superseded documents been addressed? 9. Process for Monitoring Compliance Are there measurable standards or KPIs to support monitoring compliance of the document? Is there a plan to review or audit compliance with the document? 10. Review Date Is the review date identified? Is the frequency of review identified? If so, is it acceptable? 11. Overall Responsibility for the Document Is it clear who will be responsible for coordinating the dissemination, implementation and review of the documentation? es/no/ Unsure Comments Page 21 of 21