Anti-Harassment Policy

Anti-Harassment Policy for Financial Year 2021/2022

Policy Statement

At instaENG we strive diligently to offer a work environment in which all employees are treated with respect and dignity. This means a workplace free from harassment and bullying based on an employee's race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation, gender reassignment, age, marital or civil partnership status or disability. instaENG has a zero-tolerance approach to harassment, bullying, or intimidation on these grounds.

We pride ourselves on policies that strictly uphold existing legal protections against unlawful discrimination. We treat this behaviour as potentially gross misconduct and have in place a robust disciplinary procedure under which such violations could render employees liable to summary dismissal, personal liability, and guilt of a criminal offence.

All our employees are responsible for upholding this policy, and instaENG will not condone or tolerate any form of harassment, bullying or intimidation, whether by employees or by outside third parties with whom we do business. In return we fiercely protect our employees. We will not hesitate to take action should any third parties commit an act of improper or unlawful harassment against any member of our team.

It is a priority at instaENG that employees should feel safe and welcome when coming forward with harassment allegations or complaints. So we offer strict and explicit protections: an employee’s line manager is directly and expressly available to receive such allegations or complaints; victimisation or retaliation against employees making allegations or providing evidence will be treated as potential gross misconduct; and if an employee is subjected to this treatment following a complaint, employees are expected to offer their full support. 


Work environments have always been fluidly defined, and this is only getting truer with time - for example, with the inclusion of remote workforces, flexible hours, work-related social events, and business trips. A policy can only claim to provide effective and consistent protection if it reflects this. That is why our policy applies wherever our team operates. This includes any work-related setting outside the workplace.



Bullying and Harassment

Bullying and harassment have no place at instaENG. This is non-negotiable, and our stance on it is both clear and indiscriminate. 

Here we define bullying as offensive or intimidating behaviour, or an abuse or misuse of power which undermines or humiliates one of our employees.

We define harassment as an incident in which a person behaves in an unwanted way towards another on grounds of an employee’s race, colour, ethnic origin, nationality, national origin, religion or belief, sexual orientation, gender reassignment, age, marital or civil partnership status or disability, or in a way related to either the employee’s sex or that of another individual. This unwanted conduct: 


  • looks to violate an employee’s dignity at work, or create an intimidating, hostile, degrading, humiliating or offensive work environment for them; or 
  • is reasonably believed by an employee to violate their dignity at work, or create an intimidating, hostile, degrading, humiliating, or offensive work environment for them, even if this was not intended by the person responsible.


Sexual harassment occurs where one of the above two conditions are met with respect to unwanted conduct of a sexual nature. We are clear and uncompromising on that distinction.

We are firm, also, in accounting for the fact that harassment does not always involve clearly targeted behaviour. Gender-related harassment can occur without behaviour being directed at somebody specific. For example, the behaviour could be directed at nobody in particular, or at somebody else, including someone of the opposite sex.


‘Jokes,’ for example, or ‘office banter,’ can easily offend others without meaning to - but a crucial part of identifying harassment involves recognising that it can take place whether or not a person intended to offend. We recognise that different employees find different levels of behaviour acceptable and defend the right of every one of our employees to set this limit for themselves.

Crucial to this is an implicit trust in the integrity of our employees. We will never require employees to clarify that behaviour is unacceptable in cases where a reasonable person would realise that behaviour is likely to offend. This sort of behaviour - touching someone in a sexual way, for example - will always constitute harassment. With other forms of behaviour - for example, ‘office banter’ and ‘jokes’ - it can be unclear in advance whether or not it will cause offence. However, if one of our employees has made it clear, through words or conduct, that such behaviour is unacceptable to them, we see this as constituting harassment. Moreover, if a single instance is sufficiently serious, this will be considered harassment. 


We also consider instances in which a person is treated less favourably on the grounds of rejecting or submitting to this kind of unwanted conduct to be harassment. 




At instaENG we understand bullying and harassment can come in many forms: verbal, non-verbal, written, or physical. We strive to uphold a sufficiently flexible policy to protect our employees in these various instances. Examples include, but are not limited to:

  • Unwelcome sexual advances, requests for sexual favours, other conduct of a sexual nature.
  • Subjection to obscene or other sexually suggestive or racist comments or gestures.
  • The offer of rewards for going along with sexual advances or threats for rejecting sexual advances.
  • Jokes or pictures of a sexual or racial nature.
  • Demeaning comments about an employee’s appearance.
  • Questions about a person’s sex life. 
  • The use of nick names related to an employee’s sex, sexual orientation, gender reassignment, race, religion, age, or disability.
  • Picking on or ridiculing an employee.
  • Isolating an employee or excluding them from social activities or relevant work-related matters.

Reporting and Investigation of Complaints


At instaENG the only acceptable response to allegations of harassment or bullying is one that is serious, confidential, and swift. When it comes to grievances or complaints of harassment instaENG will never ignore them, or treat them lightly. 


We are sympathetic to the fact that actual or perceived power and status disparities may make real-time confrontation of unwanted conduct impractical or difficult. Whilst we encourage employees who believe they are being harassed or bullied to use words or conduct to express that this behaviour is unwelcome, we will never assume the absence of confrontation to constitute consent. 

If such informal, direct avenues are either ineffective or impractical, or the situation is too serious to be dealt with informally, we empower our employees to report complaints with a clear road map.


  1. Any employee who believes they have been, or are being, subjected to a violation of this policy, or who wishes to report an incident, may report it to their line manager. If they do not wish to do so, our employees are also able to speak to an alternative manager or to a member of the Human Resources Department.
  2. We encourage reports to be made promptly so that we can deliver swift investigation and, where appropriate, take swift action. 
  3. All allegations of harassment or bullying will be taken seriously. This means prompt investigation, and an interview of and written statement from the employee outlining the nature and basis of the complaint. The investigation will be treated with the highest degree of confidentiality that is attainable and appropriate under the circumstances. Our commitment to just and accurate investigation may, for example, require revealing the identity of a complainant to the alleged harasser so that they might have the opportunity to fairly respond. Where required, we reserve the right to arrange for a manager other than the one to whom the complaint was initially raised to conduct the investigation. 
  4. On completion of the investigation, the employee will be informed in writing of the outcome, our conclusions, and our decision as soon as possible. instaENG is committed to taking appropriate action following all complaints of harassment or bullying which are upheld by our investigations. We do not hesitate to bring disciplinary proceedings against the alleged harasser where appropriate (see below).
  5. We understand that complaint resolution is not a one-off effort. If an employee’s complaint is upheld and the harasser remains in our employment, we take every reasonable measure to ensure that the employee can choose whether to continue working alongside the harasser. Options are discussed and arranged with the employee.
  6. If, by contrast, an employee’s complaint is not upheld, we take an active role in repairing the working relationship between the two parties and arrange for the employee and the alleged harasser to continue or resume working. 
  7. We never penalise or victimise an employee who raises a complaint, even if it is not upheld. Additionally, we recognise that our protective policies work only as far as their integrity is upheld. Exceptions are therefore made for cases where the complaint was both untrue and made in bad faith. 

We are committed to creating a safe and fair environment for our employees, and this includes making sure employees have multiple avenues for lodging and resolving complaints. As such, our employees can also use our Grievance procedure. 


Disciplinary Action

Fostering a robust and fair work environment is a top instaENG priority, so we treat violations of this policy with the utmost gravity. Any employee found in violation of this policy is subject to swift and appropriate disciplinary action under our disciplinary procedure. This may include summary dismissal. 

Moreover, at instaENG we believe a community of respect must be built upon a foundation of common trust. As such, line managers with knowledge about harassment taking place in their departments who fail to take action to eliminate it are also subject to disciplinary action.



We want our employees to be proud of the roles they play in creating a respectful, safe working community. We provide training to all employees to help them understand their rights and responsibilities under this policy, and what they can do to create a work environment that is free of bullying and harassment. We also offer the proper training, supervision and instruction that empowers line managers to deal more effectively with complaints of bullying and harassment.


Approval For this Statement

This statement was approved by the Board of Directors on 27/10/2020 signed by Frano Lubura, Quality Manager/General Manager.