Introduction

Xi Training Ltd is committed to providing a working environment that is free from sexual harassment and in which everyone is treated with dignity, courtesy, and respect.

Sexual harassment is unlawful under the Equality Act 2010 and will not be tolerated under any circumstances. We are committed to taking reasonable steps to prevent sexual harassment and to deal promptly and effectively with any concerns or complaints.

Any employee found to have engaged in sexual harassment may be subject to disciplinary action, up to and including dismissal for gross misconduct.

Scope

This policy applies to:

• All employees, regardless of seniority or employment status.
• Directors and managers.
• Agency workers, contractors, consultants and temporary workers.
• Job applicants.
• Third parties, including customers, clients, suppliers, visitors and service providers.

This policy applies during:

• Working hours.
• Business travel.
• Training courses and conferences.
• Work-related social events.
• Online meetings and communications.
• Any situation where an individual is representing the company.

Definition of Sexual Harassment

Under the Equality Act 2010, sexual harassment is unwanted 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.

The conduct does not need to be intended as harassment for it to be unlawful. The effect on the recipient will be considered alongside all circumstances of the case.

Examples of Sexual Harassment

Examples include, but are not limited to:

Verbal Conduct

• Sexual comments, jokes or innuendo.
• Suggestive remarks.
• Repeated requests for dates after refusal.
• Comments about a person's appearance in a sexual manner.

Non-Verbal Conduct

• Leering or staring.
• Displaying sexually explicit materials.
• Making sexually suggestive gestures.
• Sending inappropriate memes, images or videos.

Physical Conduct

• Unwanted touching, hugging or kissing.
• Deliberately invading personal space.
• Physical assault or unwanted sexual contact.

Online Conduct

• Sending inappropriate messages, emails or social media communications.
• Sharing sexually explicit content.
• Making offensive comments during virtual meetings.

 

Third-Party Harassment

The Company will not tolerate sexual harassment by third parties such as customers, suppliers, contractors or visitors.

Employees who experience harassment from a third party should report the matter immediately. The Company will take appropriate steps to investigate and, where possible, prevent further incidents.

 

Responsibilities

All Employees Must

• Treat colleagues and others with respect.
• Refrain from any form of harassment or inappropriate behaviour.
• Report incidents of harassment where appropriate.
• Cooperate with investigations.

 

Managers

Managers are responsible for:

• Promoting a respectful workplace culture.
• Taking complaints seriously.
• Acting promptly when concerns are raised.
• Escalating complaints to HR where appropriate.
• Ensuring employees do not suffer victimisation.

Human Resources (Neathouse Partners)

HR will:

• Provide advice and guidance.
• Investigate complaints fairly and impartially.
• Maintain confidential records.
• Deliver training and awareness programmes.

Reporting a Complaint

Anyone who believes they have experienced or witnessed sexual harassment should report the matter as soon as possible.

Complaints may be made to:

• A line manager;
• A senior manager;
• The Managing Director, where appropriate.

A complaint may be made verbally or in writing.

Employees are encouraged to keep a record of incidents, including:

• Dates and times;
• Details of what occurred;
• Names of witnesses;
• Copies of relevant communications.

 

 

Investigation Procedure

The Company will:

1. Acknowledge receipt of the complaint.
2. Conduct a fair, thorough and impartial investigation.
3. Interview relevant individuals.
4. Review available evidence.
5. Maintain confidentiality as far as reasonably possible.
6. Reach a conclusion based on the evidence.

Where necessary, formal disciplinary action will be taken in accordance with the Company's Disciplinary Policy.

Confidentiality

All complaints will be handled sensitively and confidentially.

Information will be shared only with those who need to know for the purposes of investigating and resolving the matter.

Victimisation and Retaliation

No employee will suffer detriment, victimisation or retaliation because they:

• Raise a genuine complaint;
• Assist with an investigation; or
• Act as a witness.

Victimisation is a disciplinary matter and may constitute unlawful conduct under the Equality Act 2010.

Disciplinary Action

Sexual harassment may constitute gross misconduct.

Where allegations are substantiated, disciplinary action may include:

• Informal action or training;
• Written warnings;
• Final written warnings;
• Dismissal.

Where criminal conduct is alleged, the Company may refer the matter to the police.

Training

The Company will provide appropriate training to all employees and managers on:

• Sexual harassment awareness.
• Acceptable workplace behaviour.
• Reporting procedures.
• Managers' responsibilities.

Training will be refreshed periodically.

Monitoring and Review

The Company will monitor the effectiveness of this policy and review it at least annually, or sooner if required by changes in legislation or organisational requirements.

 

Signed: Glen Pearson

Name: Glen Pearson

Position: Managing Director Xi Training Ltd.          

Date: September 2026