---
title: Sexual Harassment Policy - Container Solutions
description: Read the Container Solutions Sexual Harassment Policy.
---

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# Sexual Harassment Policy

**Introduction**

We are committed to providing a working environment free from sexual harassment  
and ensuring all staff are treated, and treat others, with dignity and respect. We  
recognise that sexual harassment 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.

Sexual harassment 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 the sexual harassment and victimisation of  
all staff. Anyone who is a victim of, or witness to, sexual harassment is encouraged to  
report it in accordance with this policy. This will enable us to take appropriate action  
and provide support. Sexual harassment 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. Sexual harassment may result in disciplinary action up to and including  
dismissal.

This policy does not form part of any contract of employment or contract to provide  
services, and we may amend it at any time.

**Scope and Responsibilities**

This policy applies to all employees, officers, consultants, self-employed  
contractors, casual workers, agency workers, volunteers and interns.

The CEO has overall responsibility for the effective operation of this policy but has  
delegated responsibility for overseeing its implementation to the HR Director. Suggestions for change should be reported directly to the HR Director.

This policy and its effectiveness is reviewed annually by the HR Director.

**What is sexual harassment?**

**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 because they have submitted or  
refused to submit to unwanted conduct of a sexual nature, or that is related to  
gender reassignment or sex, in the past.

Sexual harassment may include, for example:

- Unwanted physical conduct including touching, pinching, pushing and  
  grabbing;
- Continued suggestions for sexual activity after it has been made clear that such suggestions are unwelcome;
- 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);
- Unwelcome sexual advances or suggestive behaviour (which the harasser may perceive as harmless);
- Offensive emails, text messages or social media content.

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  
a colleague's computer in the workplace.

**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 sexual harassment.
- Excluding someone because they have raised a grievance about sexual  
  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.

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:

● In a work situation.  
● During any situation related to work, such as at a social event with  
colleagues.  
● 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 your suitability to carry out your role.

If any sexual harassment or victimisation of staff occurs, we will take steps to remedy  
any complaints and to prevent it happening again. These may include updating  
relevant policies, providing further staff training and taking disciplinary action against  
the perpetrator.

**Third parties and sexual harassment**

Third-party harassment occurs where a person is harassed or sexually harassed by  
someone who does not work for the same employer, but with whom they have  
come into contact during the course of their employment. Third-party harassment  
could include, for example, unwelcome sexual advances from 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 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, in accordance with this policy.**

Any sexual harassment by a member of staff against a third party may lead to  
disciplinary action up to and including dismissal.

We will take active steps to try to prevent third-party sexual harassment of staff.  
These will include publishing our policy on our website as well as including a clear  
zero tolerance clause in our customer and supplier contracts.

If any third-party harassment of staff occurs, we will take steps to remedy any  
complaints and to prevent it happening again. These may include warning the  
harasser about their behaviour, reporting them to their business and reporting any  
criminal acts to the police.

**If you are being sexually harassed: informal steps**

If you are being sexually harassed, consider whether you feel able to raise the  
problem informally with the person responsible. You should explain clearly to them  
that their behaviour is not welcome or makes you uncomfortable. If this is too  
difficult, you should speak to your line manager or the People Team, who can  
provide confidential advice and assistance in resolving the issue formally or  
informally. If you feel unable to speak to your line manager because the complaint  
concerns them, you should speak informally to the People Team. If this does not  
resolve the issue, you should follow the formal procedure below.

If you are not certain whether an incident or series of incidents amounts to sexual  
harassment, you should initially contact your line manager or the People Team  
informally for confidential advice.

If informal steps are not appropriate, or have been unsuccessful, you should follow  
the formal procedure set out below.

**Raising a formal complaint**

If you wish to make a formal complaint about sexual harassment, you should submit  
it in writing to your line manager **and **the People Team. If the matter concerns your  
line manager, you should submit it to the People Team.

Your written complaint should set out full details of the conduct in question,  
including the name of the harasser, the nature of the sexual harassment, the date(s)  
and time(s) at which it occurred, the names of any witnesses and any action that has  
been taken so far to attempt to stop it from occurring.

If you wish to make a formal complaint about victimisation, you should submit it in  
writing to your line manager and the People Team. If the matter concerns your line  
manager, you should submit it to the People Team.

Your written complaint should set out full details of the conduct in question,  
including the name of the person or persons you believe have victimised you, the reason you believe you have been victimised, the nature of the victimisation, the  
date(s) and time(s) at which it occurred, the names of any witnesses and any action  
that has been taken so far to attempt to stop it from occurring.

As a general principle, the decision whether to progress a complaint is up to you.  
However, we have a duty to protect all staff and may pursue the matter  
independently if, in all the circumstances, we consider it appropriate to do so.

**If you witness sexual harassment or victimisation**

Staff who witness sexual harassment or victimisation are encouraged to take  
appropriate steps to address it. Depending on the circumstances, this could include:

- Intervening where you feel able to do so.
- Supporting the victim to report it or reporting it on their behalf.
- Reporting the incident where you feel there may be a continuing risk if  
  you do not report it.
- Co-operating in any investigation into the incident.

All witnesses will be provided with appropriate support and will be protected from  
victimisation.

**Formal investigations**

We will investigate complaints in a timely, respectful and confidential manner.  
Individuals not involved in the complaint or the investigation should not be told  
about it.

We will arrange a meeting with you, usually within one week of receiving your  
complaint, so that you can give your account of events. You have the right to be  
accompanied by a colleague of your choice, who must respect the confidentiality of  
the investigation.

Where your complaint is about an employee, we may consider suspending them on  
full pay or making other temporary changes to working arrangements pending the  
outcome of the investigation, if circumstances require. The investigator will also  
meet with the alleged harasser, who may also be accompanied by a colleague of  
their choice, to hear their account of events. They have a right to be told the details  
of the allegations against them, so that they can respond.

Where your complaint is about someone other than an employee, such as a  
customer, supplier or visitor, we will consider what action may be appropriate to  
protect you and anyone involved pending the outcome of the investigation, bearing  
in mind the reasonable needs of the business and the rights of that person. Where  
appropriate, we will attempt to discuss the matter with the third party.

We will also consider any request that you make for changes to your own working  
arrangements during the investigation. For example, you may ask for changes to  
your duties or working hours to avoid or minimise contact with the alleged harasser.

It may be necessary to interview witnesses to any of the incidents mentioned in your  
complaint. If so, the importance of confidentiality will be emphasised to them.

At the end of the investigation, which will normally be within 10 working days of the  
meeting with you, the decision of the investigator, detailing the findings, will be sent  
in writing to you.

You have the right to appeal against the findings of the investigator. If you wish to  
appeal, you must inform any member of the Senior Leadership Team (SLT) within  
five working days of receiving the outcome. You will then be invited to a further  
meeting, you have the right to be accompanied to this meeting. Where practicable,  
the appeal hearing will be conducted by a member of the SLT who has not been  
previously involved in the case.

Following the appeal meeting, you will be informed of the final decision, normally  
within 10 working days, which will be confirmed in writing.

Regardless of the outcome of the procedure, we are committed to providing the  
support you may need. This may involve mediation between you and the other party  
or some other measure to manage the ongoing working relationship.

You will not be victimised for having brought a complaint.

**Action following the investigation**

If the decision is that the allegation of sexual harassment or victimisation is well  
founded, the harasser/victimiser will be liable to disciplinary action in accordance  
with our disciplinary procedure up to, and including, summary dismissal. An  
employee who receives a formal warning or who is dismissed for sexual  
harassment/victimisation may appeal by using our disciplinary appeal procedure.

When deciding on the level of disciplinary sanction to be applied, we will take into  
consideration any aggravating factors affecting the case. One example of  
aggravating factors is an abuse of power over a more junior colleague.

If, due to the investigation, it is concluded that your complaint is both untrue and has  
been brought with malicious intent, disciplinary action will be taken against you.

**Training**

We provide training to all our staff on sexual harassment to ensure there is a clear  
understanding of:

- What sexual harassment is, how it may occur and that it will not be tolerated
- Expected levels of behaviour

We will regularly review the effectiveness of our training.

**Protection and support for those involved**

Staff who make complaints, report that they have witnessed wrongdoing, or who  
participate in good faith in any investigation must not suffer any form of retaliation or  
victimisation as a result. Anyone found to have retaliated against or victimised  
someone in this way will be subject to disciplinary action under our Disciplinary  
Procedure.

If you believe you have suffered any such treatment you should inform the People  
Team. If the matter is not remedied, you should raise it formally using our Grievance  
Procedure or this procedure if appropriate.

We offer access to confidential counselling via our **Employee Assistance Program**  
with AXA.

Support and guidance can also be obtained from the following external services:

1. The Equality Advisory and Support Service  
   ([http://www.equalityadvisoryservice.com](http://www.equalityadvisoryservice.com)).
2. Protect ([http://www.protect-advice.org.uk](http://www.protect-advice.org.uk)).
3. Victim support ([http://www.victimsupport.org.uk](http://www.victimsupport.org.uk)).
4. Rape crisis ([http://www.rapecrisis.org.uk](http://www.rapecrisis.org.uk)).
5. Rights of women (England and Wales) ([http://www.rightsofwomen.org.uk](http://www.rightsofwomen.org.uk)).
6. Scottish Women's Rights Centre (Scotland)  
   ([http://www.scottishwomensrightscentre.org.uk](http://www.scottishwomensrightscentre.org.uk)).

**Reporting outcomes, confidentiality and record-keeping**

Confidentiality is an important part of the procedures provided under this policy.  
Details of the investigation and the names of the person making the complaint and  
the person accused must only be disclosed on a "need to know" basis. Breach of  
confidentiality may give rise to disciplinary action under our Disciplinary Procedure.

When appropriate and possible, where a complaint is upheld, we will advise the  
complainant of the action that has been taken to address their specific complaint  
and any measures put in place to prevent a similar event happening again.

Information about a complaint by or about a staff member may be placed on their  
personnel file, along with a record of the outcome and of any notes or other  
documents compiled during the process.

**Contacts**

People Team: [hr@container-solutions.com](mailto:hr@container-solutions.com)

SLT: James O’Donavan, Sarah Bennett, David Perks, Ian Miell, Ivana Scott

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