Alex is Sprintlaw’s co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.
- What Is A Bullying And Harassment Policy, And Why Does Your Business Need One?
What Should A UK Bullying And Harassment Policy Template Include?
- 1) Purpose, Scope And Definitions
- 2) Zero-Tolerance Statement And Standards Of Behaviour
- 3) Reporting Options And Confidentiality
- 4) Informal Resolution Path
- 5) Formal Investigation Procedure
- 6) Outcomes, Sanctions And Appeals
- 7) Support, Adjustments And Anti-Victimisation
- 8) Third Parties And Public-Facing Work
- 9) Digital Conduct, Social Media And Remote Work
- 10) Data Handling And Record-Keeping
- 11) Training, Communication And Monitoring
- 12) Links To Related Policies And Contracts
- Common Mistakes Small Employers Make (And How To Avoid Them)
- Should You Use A Free Template Or Get A Tailored Policy?
- Key Takeaways
Workplace culture is make-or-break for small businesses. A clear, well-communicated Bullying and Harassment Policy helps you set standards, prevent issues, and handle complaints lawfully if something does go wrong.
If you’re looking for a practical bullying and harassment policy template, this guide walks you through exactly what to include under UK law, how to adapt and implement it, and common mistakes to avoid as a growing employer.
What Is A Bullying And Harassment Policy, And Why Does Your Business Need One?
In simple terms, your Bullying and Harassment Policy sets out your business’ zero-tolerance stance, explains what conduct is unacceptable, and provides a fair, transparent procedure for raising and investigating concerns.
From a legal perspective, it does a lot of heavy lifting for you:
- Equality Act 2010: Harassment related to a protected characteristic (for example, sex, race, disability, religion or belief, sexual orientation, age) is unlawful. Employers can be vicariously liable for acts by employees unless they took “all reasonable steps” to prevent them. A live, enforced policy is a key “reasonable step”.
- Worker Protection (Amendment of Equality Act 2010) Act 2023: Introduces a proactive duty on employers to take reasonable steps to prevent sexual harassment at work (in force from October 2024). A robust policy, training and monitoring will be central to compliance.
- Health and Safety at Work etc. Act 1974: You must ensure, so far as is reasonably practicable, employees’ health and safety, including psychosocial risks like stress arising from bullying.
- Management of Health and Safety at Work Regulations 1999: Requires suitable and sufficient risk assessments and preventive measures-your policy forms part of that system.
- Protection from Harassment Act 1997: Certain behaviour may also amount to criminal harassment.
- ACAS Code of Practice on Disciplinary and Grievance Procedures: While not law, tribunals take it into account. Following a fair and transparent process (as your policy should provide) reduces risk of uplifts in compensation.
Beyond compliance, a good policy protects your team and your brand, and gives managers a consistent roadmap when concerns are raised.
What Should A UK Bullying And Harassment Policy Template Include?
Use the following structure as your starting point, then tailor it to your size, structure and sector. Generic downloads rarely match how a small business actually works-keep it practical, clear and enforceable.
1) Purpose, Scope And Definitions
- Purpose: A brief statement that your business is committed to a workplace free from bullying, harassment and victimisation.
- Scope: Who the policy applies to (employees, workers, contractors, interns, volunteers, agency staff) and where it applies (in the workplace, offsite events, business travel, remote work, and online interactions).
- Definitions: Explain “bullying” (repeated or persistent offensive, intimidating, malicious or insulting behaviour) and “harassment” (as defined under the Equality Act 2010) with clear examples relevant to your workplace.
2) Zero-Tolerance Statement And Standards Of Behaviour
- Set expectations for professional conduct, dignity and respect.
- Make clear that breaches may be treated as misconduct or gross misconduct, up to and including dismissal, depending on severity.
3) Reporting Options And Confidentiality
- Multiple channels: Line manager, HR/owner, confidential email, or named contacts. Permit third-party reports and anonymous reports where practical.
- Confidentiality: Explain how information will be handled and stored, balanced against the need to investigate fairly and protect all parties.
- Right to be accompanied: Inform employees they may be accompanied at formal meetings (consistent with the ACAS Code).
4) Informal Resolution Path
- Encourage early, informal steps where appropriate-e.g. a facilitated conversation or manager intervention-while never pressuring a complainant to confront the alleged perpetrator.
- Make clear that serious allegations may go straight to formal investigation.
5) Formal Investigation Procedure
- How to raise a formal complaint and what information to provide.
- Initial assessment for urgency or safeguarding needs (including whether temporary measures or employee suspension is appropriate and proportionate).
- Investigation steps: appointing an impartial investigator, gathering evidence, interviewing parties and witnesses, and timelines for each stage. Link this to your wider approach to workplace investigations.
- Natural justice: the respondent sees the allegations and has a chance to respond.
6) Outcomes, Sanctions And Appeals
- Possible outcomes: not upheld, partially upheld, upheld.
- Actions: training, management action, warnings (including final written warnings), transfer, dismissal where appropriate.
- Appeal rights: how and when to appeal, plus the appeal decision-maker.
7) Support, Adjustments And Anti-Victimisation
- Support options: EAP/helplines, reasonable adjustments, temporary changes to reporting lines or shifts if needed.
- Anti-victimisation: Clear prohibition on retaliation against anyone who raises or participates in a complaint.
8) Third Parties And Public-Facing Work
- How your business will respond to bullying/harassment by customers, suppliers or contractors, including escalation to the third party and steps to protect your staff.
9) Digital Conduct, Social Media And Remote Work
- Standards for emails, messaging apps, video calls, and social media.
- Clarify that bullying and harassment can occur outside working hours if connected to work or impacts colleagues.
10) Data Handling And Record-Keeping
- Keep investigation records secure, access-limited and retained for an appropriate period in line with UK GDPR/Data Protection Act 2018 and your broader workplace confidentiality policies.
11) Training, Communication And Monitoring
- Regular training for managers and staff, with additional training on harassment prevention (including sexual harassment) to meet the new proactive duty.
- Periodic audits to check the policy is working and to identify hotspots.
12) Links To Related Policies And Contracts
- Cross-reference your Disciplinary, Grievance, Whistleblowing, Equal Opportunities and Social Media Policies, and ensure your Employment Contract supports these standards and sanctions.
Step-By-Step: How To Tailor And Roll Out Your Policy
Templates are a starting point. Here’s a practical process to make sure the policy fits your business and actually works in practice.
Step 1: Consult And Assess Risk
- Gather input from managers and, where feasible, staff representatives. Consider where risks are highest-frontline customer interactions, lone working, late shifts, or remote teams.
- Document your reasoning-this helps demonstrate “reasonable steps” later.
Step 2: Draft And Align With Your Other Documents
- Align definitions and procedures with your Disciplinary and Grievance Policies and ensure contractual clauses (conduct, confidentiality, disciplinary rules) in your Employment Contract are consistent.
- If you’re refreshing multiple policies, consider implementing them together via a Staff Handbook Package so everything is in one place.
Step 3: Put The Policy Where People Will See It
- Publish on your intranet or shared drive and give all staff a copy on induction.
- Make sure reporting routes are visible (e.g. on noticeboards or internal chat pins).
Step 4: Train Your Team
- Run short training sessions for all staff on what the policy covers and how to report. Managers need additional training on how to respond, preserve evidence and avoid bias.
- Refresh training annually or after any incident or policy update.
Step 5: Appoint Contacts And Set Up Reporting Channels
- Nominate trained contact people. Provide a dedicated email inbox for reports and consider a backup route if the complaint involves a line manager.
Step 6: Keep Records And Review Annually
- Track complaints, outcomes and lessons learned (with privacy safeguards). Review the policy annually to ensure it remains effective and legally up to date.
Handling Complaints Fairly: From Report To Resolution
When a concern is raised, act promptly and follow a fair process. Tribunals scrutinise process-your policy should give managers a clear roadmap.
Early Triage And Safeguarding
- Acknowledge the complaint quickly and explain next steps.
- Consider immediate measures to protect parties-changed shifts, separate reporting lines or a neutral work location. Only consider employee suspension where necessary and proportionate, and keep it under review.
Investigation Best Practice
- Nominate a suitably senior and impartial investigator (external support may be needed for smaller teams).
- Plan interviews, gather documents, and preserve messages/CCTV in line with your evidence policy.
- Share a written record of allegations with the respondent and invite a response. Ensure they know their right to be accompanied.
- Follow the ACAS Code and your own documented procedure. For complex cases, get advice on workplace investigations to reduce procedural risk.
Decisions, Sanctions And Appeals
- Decide on the balance of probabilities based on evidence gathered.
- Explain outcomes to both parties (as appropriate), including any management action, training, warnings or dismissal.
- Use the full range of sanctions proportionately-up to and including dismissal in cases of gross misconduct. Follow your disciplinary policy for issuing warnings, including final written warnings.
- Offer an appeal route with a different decision-maker where possible.
Aftercare And Culture
- Provide support to those involved-signpost EAPs, offer reasonable adjustments and check in after closure.
- Review what happened and update training, supervision or staffing where needed.
Common Mistakes Small Employers Make (And How To Avoid Them)
- Policy Is Too Generic: A download that doesn’t reflect your size, structure or reporting lines is hard to follow. Tailor it to your operations or have it drafted as part of a bespoke Workplace Policy.
- No Clear Reporting Routes: If people don’t know who to approach-or the only route is their manager who may be involved-issues won’t be raised. Provide at least two options and a confidential email.
- Not Training Managers: Most claims escalate because early reports weren’t handled properly. Train managers annually and keep a manager’s checklist handy.
- Ignoring “Low-Level” Conduct: Patterns matter. A single “joke” can become a hostile environment if not addressed. Encourage early, informal action where appropriate, with a clear record.
- Skipping Process Under Pressure: Even with serious allegations, you must follow a fair procedure. That means sharing allegations, giving time to respond, and keeping an open mind.
- Policy Misaligned With Contracts: If your disciplinary rules or sanctions in the handbook clash with your Employment Contract, it creates risk. Keep documents aligned and updated together.
- Poor Record-Keeping: If it’s not documented, it’s hard to evidence your “reasonable steps.” Keep investigation notes, decisions and training records secure.
Should You Use A Free Template Or Get A Tailored Policy?
A good template helps you see the structure and essential clauses. However, the risk with off-the-shelf policies is that they don’t match your reporting lines, sector risks, or internal processes-so managers don’t follow them, and you can’t show you took “reasonable steps.”
It’s usually more efficient to have a lawyer prepare a short, practical policy that fits your business, together with companion documents like Disciplinary and Grievance Policies, all collated in a Staff Handbook Package. Pair this with manager training and a short, internal guide on running a fair process end-to-end, drawing on best practice for workplace investigations.
If you’re building your HR foundations from scratch, we can also help align policies with your Workplace Policy framework and your core Employment Contract, so everything works together in daily practice.
Key Takeaways
- A Bullying and Harassment Policy is a legal and cultural essential-helping demonstrate “reasonable steps” under the Equality Act and supporting your duty to prevent sexual harassment.
- Cover the basics: clear definitions, multiple reporting routes, confidentiality, informal options, a fair investigation process, outcomes and appeals, anti-victimisation, third-party conduct, digital behaviour, data handling, training and monitoring.
- Roll it out properly: consult, align with related policies and contracts, communicate widely, train managers and staff, document everything, and review annually.
- Handle complaints with a fair, ACAS-compliant process-consider safeguarding measures, run impartial investigations, and apply proportionate outcomes (from management action to gross misconduct dismissal where justified).
- Avoid common pitfalls: generic documents, unclear reporting routes, untrained managers, misalignment with contracts, and weak record-keeping.
- Templates are a start, but a tailored policy-implemented with training and consistent practice-offers stronger protection and real-world usability.
If you’d like help drafting a practical Bullying and Harassment Policy tailored to your business-or rolling it into a complete HR pack-reach us on 08081347754 or team@sprintlaw.co.uk for a free, no-obligations chat.


