Dignity at work policy: what to include, and how to handle bullying and harassment complaints

Harassment is unlawful, and you’re liable for your staff’s harassment

An employer must not harass its employees or job applicants (Equality Act 2010, section 40). The law treats anything an employee does in the course of their work as done by the employer as well, whether or not the employer knew about it or approved it. The employer’s defence is to show it took all reasonable steps to prevent it (section 109).

Harassment by customers and other third parties

From 30 October 2026, an employer must not permit a third party, such as a customer, client or patient, to harass its staff. An employer permits it when the harassment happens in the course of the employee’s work and the employer failed to take all reasonable steps to prevent it. The rule covers all three forms of harassment, and staff can bring a tribunal claim over it. Our third-party harassment guide covers it in full.

The duty to prevent sexual harassment

Since 26 October 2024, employers have had to take reasonable steps to prevent sexual harassment of their staff, and from 30 October 2026, all reasonable steps. The Equality and Human Rights Commission enforces the duty. Our Worker Protection Act guide covers each step.

Bullying

There’s no specific law against bullying, and staff can’t bring a tribunal claim for bullying on its own. Acas says employers have a legal duty of care to protect their workers from harm, which includes dealing with bullying. When it relates to a protected characteristic, it can be harassment, and severe bullying that makes someone resign can contribute to a constructive dismissal claim.

Victimisation

Treating someone worse because they complained of harassment or discrimination, gave evidence, or helped someone else complain is victimisation, which is unlawful too (section 27). The law doesn’t protect a false complaint made in bad faith.

Whistleblowing, and FCA-regulated firms

Since 6 April 2026, telling your employer or a prescribed body that sexual harassment has happened, is happening or is likely to happen can be a protected disclosure, as long as the worker reasonably believes it’s in the public interest. Our UK whistleblowing policy guide covers what that means for your policies. If you’re an FCA-regulated firm, our non-financial misconduct guide covers when serious bullying and harassment can breach the FCA’s conduct rules.

Regulations to come

The Employment Rights Act 2025 lets ministers list steps that count as reasonable, such as publishing policies and handling complaints. The government expects to make those regulations in 2027/28, after consultation.

Is there a Dignity at Work Act?

No. A Dignity at Work Bill was before the House of Lords in 2002, and legislation.gov.uk lists no Act of that name. A dignity at work policy is an employer’s own policy on bullying and harassment.

Many staff stay quiet. In 2024, 37% of UK employees who knew about misconduct at work didn’t speak up, and of those, 40% feared for their job and 42% doubted anything would be done (Institute of Business Ethics). Most people who do speak up go to their manager: 68% of people who report misconduct tell their direct manager (Gartner, 2019). That route doesn’t work when the concern is about the manager.

The EHRC’s guidance on harassment sets out what helps staff speak up:

• More than one route, so nobody has to report to the person harassing them, and where possible a route to someone more senior than the person involved.
• Named or anonymous: a reporting system that lets staff raise an issue anonymously or by name. You can still act on an anonymous report, for example by reminding staff of the policy or monitoring the area.
• One record of every concern, formal and informal, kept centrally and confidentially.
• Regular chances to speak, such as one-to-ones, return-to-work meetings, exit interviews and staff surveys.

Acas adds that a complaint can come from a witness, about bullying or discrimination directed at someone else, or from a trade union or employee representative. Our guide to psychological safety at work covers what helps people speak up.

Acas says to take any bullying or discrimination complaint seriously and look into it as soon as possible, even when someone raises it long after the event. If the person goes to an employment tribunal, the tribunal will take into account how you handled it.

1. Check which policy applies. You may have one for bullying and another for sexual harassment: follow the one that fits the complaint.
2. Talk to the person who raised it. Listen, keep an open mind and assume nothing. Let them bring a colleague or a trade union representative; at a formal grievance meeting, that’s their legal right.
3. Agree with them how to handle it. Resolve it informally where you can. Handle it formally if they won’t try an informal approach, your policy requires it, it’s very serious or it could lead to disciplinary action. If you’re in any doubt, handle it formally.
4. Use your grievance procedure for a formal complaint, unless you have a specific procedure for that kind of complaint, such as sexual harassment.
5. Protect the person who complained. Don’t move them unless they ask, since a move they didn’t ask for could look like a punishment, and think very carefully before suspending anyone.
6. Allow companions on both sides. Let the person complained about bring a companion to meetings that involve them, and see the evidence in time to prepare.
7. Keep it confidential, including any investigation.
8. Keep a record: the evidence, the steps you took, whether you upheld the complaint and why, and how you resolved it.
9. Watch for victimisation afterwards. Treating someone worse because they were involved in a discrimination complaint is victimisation.

If the person asks you to take no action, the EHRC says to keep a record of the complaint and weigh the risk to them and to others before you decide. The grievance meeting, the decision and the appeal follow Acas’s grievance steps.

CalmER takes each bullying or harassment complaint from the first report to its outcome, with an audit trail of every step.

• Intake, in confidence. Staff raise a case through any channel, confidential if they choose, and CalmER acknowledges it instantly, with a clear owner from the start.
• The right route. CalmER suggests the proportionate route against your policy, informal first where it fits, and a named person accepts or overrides it, on the record.
• A consistent investigation. Guided, enforced investigation steps, with templates for grievance, conduct and performance.
• Investigations, written up. Every investigation report ends with a clean summary, a balanced findings section, recommended actions and the audit trail attached.
• An evidenced outcome. Every outcome links to the policy and precedent behind it, for a tribunal-ready record at the end of every case.
• Patterns, early. Every case connects to related people, teams and prior cases, so the pattern shows before the third complaint.

Moore Kingston Smith runs CalmER across all 8 of its offices. It tracks every case from first report to resolution with a full audit trail, and early concerns doubled within six months.

Amazon ran Safe Workplace’s case and concern management across its corporate workforce in more than 40 countries, and early-stage reporting tripled within 12 months. 70% of Amazon employees surveyed said they wouldn’t have reported through any previous route.

Thiess, the world’s largest mining services provider, uses Safe Workplace to comply with Australia’s rules on workplace bullying complaints, including the powers of the NSW Industrial Relations Commission.