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1. About this policy

1.1. The purpose of this policy is to assist in developing and encouraging a working and learning environment in which harassment is known to be unacceptable and where individuals have the confidence to deal with harassment without fear of ridicule or reprisals.

1.2. All employees and students of St George’s, University of London (SGUL) are expected to work within this set of principles. Managers have a critical role in ensuring that no form of bullying, harassment or victimisation specifically that relates to a person’s protected and/or other characteristics is tolerated within our community, either between or towards; employees, students, contractors, consultants or visitors to the University.

1.3. This policy applies to the conduct of employees and students in the context of their university work or study, or other activities which affect the working, learning or social environment of the institution. It covers bullying and harassment in the workplace and in any work or study-related setting outside the workplace, eg business trips, or work/study-related social events, or locations such as placements or fieldwork. This includes bullying/harassment of students by fellow students outside of university (eg in halls of residence or in private accommodation). It also includes online bullying and harassment.

2. Our commitment

2.1. SGUL is committed to providing a second to none quality academic and work environment for its students and employees. SGUL values and celebrates its diversity and strives to create a positive working and learning environment that is free from harassment and bullying, where all people are treated with dignity and respect.

2.2. We want to enable employees and students to fulfil their personal potential and will not tolerate bullying and harassment of any kind. All allegations of bullying and harassment will be promptly and thoroughly investigated and, if appropriate, disciplinary action will be taken.

2.3. Harassment or bullying can have very serious consequences for individuals and the University and undermines SGUL’s CORE values:

  • Commitment

Working effectively and with dedication to perform to the highest standards. Being responsible and accountable for our choices and decisions.

  • Openness

Listening, treating each other fairly and honestly. Learning from experience and reflecting on our choices and decisions.

  • Respect

Shaping an inclusive environment in which diversity is valued. Communicating openly and transparently.

  • Engagement

Participating in life at St George’s and, through education and research, empowering our people to contribute to, influence and improve society and communities. Influencing effectively across the sectors in which we operate.

3. Rights and Responsibilities

3.1. SGUL has a duty of care to its employees, students and visitors; it is legally responsible for ensuring that the behaviour and conduct of employees and students in the course of their work or study is acceptable. Failure to recognise or investigate incidents of unacceptable behaviour does not excuse SGUL from liability and could have serious legal consequences under Health and Safety, employment, and anti-discrimination legislation.

3.2. All employees and students are personally responsible for their behaviour towards others and are expected to demonstrate active commitment to this policy and its aims. They may be held personally liable for any unlawful discrimination as well as, or instead of, SGUL. Employees and students who commit serious acts of bullying and harassment may be guilty of a criminal offence.

3.3. Everyone has a responsibility to acknowledge that the views and opinions held by others may not coincide with their own. Equally, employees may not always agree with decisions made by managers and supervisors. Actions or views which are not agreed with by others do not in themselves constitute bullying or harassment.

3.4. All employees as individuals and as managers with line management or supervisory duties have a responsibility to promote a culture free from unacceptable behaviour. This includes identifying unacceptable behaviour in themselves and others when it occurs, and taking reasonable corrective or preventative action. It is not acceptable for any manager to ignore unacceptable behaviour.

3.5. Senior managers have the responsibility to communicate this policy to their employees and ensure that where it is necessary to take remedial or disciplinary action against an employee or a student, this is done fairly and in accordance with SGUL’s procedures.

3.6. Students have a responsibility to acknowledge and respect the duties of members of staff and should not demean, devalue or intimidate them. The Students’ Union fully supports this policy.

3.7. There are professional as well as ethical reasons for employees to maintain an appropriate formal relationship between themselves and students. All members of the university should manage their relationships in an appropriate manner in line with the code of conduct which can be found on the website.

4. Reasonable management practices

4.1. Reasonable management and academic guidance is defined as legitimate, constructive and fair criticism of employee or student performance/conduct. This will not be considered bullying or harassment provided that those involved are treated with dignity, courtesy and respect. Firm management or academic guidance and the use of reasonable measures to improve the quality of work or study is not bullying or harassment.

4.2. Examples of reasonable management practices include:

  • setting realistic work objectives, targets and deadlines;
  • monitoring output and supporting employees to enable them to develop;
  • setting reasonable standards for work and conduct and monitoring for compliance.

4.3. Vigorous speech and comments, academic debate and legitimate management of the performance of employees or students can be distinguished from bullying behaviour. However care should be taken to ensure that neither employees nor students are made to feel intimidated. 

5. Confidentiality

5.1. SGUL’s aim is to deal with bullying and harassment complaints sensibly and with due respect for the confidentiality of those individuals involved. All employees and students must treat as confidential any information communicated to them in connection with a bully and harassment complaint.

5.2. There may be a need to disclose confidential information in circumstances where a matter is considered to involve a criminal action or breach of the University’s duty of care and in such cases the information will be divulged only to those who need to know.

6. Making a complaint

6.1. SGUL encourages the resolution of all complaints on an informal basis wherever possible. In some cases, it may be possible for matters to be resolved informally. Employees and students have the right to access the policy and procedures for dealing with breaches and complaints, and be supported in a sensitive manner by a member of the university who has been given relevant training.

6.2. If it is not possible to resolve concerns informally, a formal complaint may be lodged through the relevant university procedure. If employees raise concerns around bullying and harassment they should do so in accordance with SGUL’s grievance procedure, which can be found on the website. If students wish to raise concerns about an infringement of their dignity they may implement the student complaints procedure, also available on the website. 

7. Test of reasonableness

7.1. The university will apply a ‘test of reasonableness’ in responding to reports of harassment consistent with the Protection from Harassment Act 1997. This Act states that it is not necessary to prove an intention to harass, rather a court would have to be satisfied that the harasser had pursued a course of conduct which amounted to harassment of another and which the harasser “knows or ought to know amounts to harassment of the other.”

7.2. SGUL has an equal duty of care to both the individual alleging harassment and the alleged harasser and an allegation cannot be presumed proven until properly investigated and tested against this principle of reasonableness. There may be occasions where there are no witnesses to an incident of alleged harassment and it is one individual’s word against another. Where this is the case the balance of probability can be taken into account.

8. Vexatious complaints

8.1. If it is established during the investigation that an individual has knowingly raised a mischievous or malicious accusation against another person, they may be the subject of disciplinary action. The deliberately false defamation of another person’s character is equally unacceptable to the university. This covers both employees and students being found to be making vexatious complaints.

9. Criminal offences

9.1. SGUL expects employees and students to exercise their legal rights so as to protect themselves in cases where a criminal offence may have been committed. If a criminal offence such as harassing phone calls, physical assault, indecent exposure or rape takes place, nothing in any of SGUL’s polices or procedures is intended to prevent or dissuade an individual from contacting the police. It is for the employee or student to determine if they wish to report a crime to the police. SGUL will provide assistance, including signposting the individual to relevant support groups and reporting mechanisms. 

10. Victimisation

10.1. Victimisation occurs when a person is put at a disadvantage or suffers reprisal for making, in good faith, a complaint of bullying or harassment, or for supporting someone else who has made a complaint. Victimisation could result in disciplinary action, regardless of the outcome of the original complaint.

11. Monitoring

11.1. All formal complaints of bullying and harassment will be reported to the Principal.

11.2. Human Resources or Registry will record demographic data such as race, gender, age, sexual orientation, gender identity, religion & belief/non-belief and disability of all individuals raising a claim of bullying and/or harassment irrespective of whether the disciplinary process was subsequently invoked as a result of the claim. This information will be kept confidentially by Human Resources or Registry and will be used for no other purpose than to enable the university to fulfil its obligations for monitoring and analysis to ensure that no one is afforded unfair treatment because of their protected characteristic.

11.3. This data as well as the number and type of cases (anonymised), level of action and outcomes will be reported to key Committees:

  • Council.
  • Executive Board.
  • Diversity and Inclusion Steering Group.

11.4. Positive action will be taken in departments which have high levels of complaints about bullying or harassment. This will be discussed with management with a view to ensuring there is an improved inclusive environment. Individual cases will not be highlighted within this process.

12. Training and awareness

12.1. SGUL offers training and support to assist employees and managers to comply with this policy. All employees should ensure they receive SGUL’s equality, diversity and inclusion training. Further information is available on the website.

  • sex
  • race, ethnic origin, nationality or skin colour
  • disability
  • sexual orientation
  • age
  • religion or belief/non-belief
  • gender Identity
  • pregnancy and maternity
  • remarks or innuendoes which ridicule, embarrassing or insulting jokes of a derogatory nature, leering or whistling,
  • unwanted physical contact ranging from unnecessary touching, pinching and brushing against another's body to sexual assault and rape
  • unwelcome sexual advances, propositions or pressure for sexual activity; suggestive remarks, innuendoes, lewd comments or unwanted comments about appearance
  • the display of pornographic or sexually suggestive pictures, offensive e-mails/text messages/ videos.

Appendix 1 – Examples of bullying and harassment

Bullying and harassment can occur based on the following protected characteristics (Equality Act 2010) but are not limited to:


Harassment as outlined in the Equality Act is “unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual”.

Some examples of harassment are given below. These examples are not intended to be exhaustive but to illustrate the types of behaviours which many will find unacceptable. Please note, this also includes behaviour that takes place online.

On the grounds of sex

  • remarks or innuendoes which ridicule, embarrassing or insulting jokes of a derogatory nature, leering or whistling,
  • unwanted physical contact ranging from unnecessary touching, pinching and brushing against another's body to sexual assault and rape
  • unwelcome sexual advances, propositions or pressure for sexual activity; suggestive remarks, innuendoes, lewd comments or unwanted comments about appearance
  • the display of pornographic or sexually suggestive pictures, offensive e-mails/text messages/ videos.

Harassment of a sexual nature is one of the most common forms of harassment and is specifically outlawed by the Equality Act 2010 as is harassment related to relevant protected characteristics.

On the grounds of race

  • racially derogatory remarks or jokes, banter, ridicule or taunts
  • graffiti or slogans or the display of pictures, posters or web-sites with racial overtones, even if not directed at a particular person
  • using a disparaging or offensive tone when communicating with people from certain racial groups

On the grounds of disability

  • jokes about disability, disabled people or people with HIV/AIDS
  • mimicking the effect of a disability or speech impairment
  • use of offensive inappropriate terms
  • excluding individuals with disabilities from professional and social events by act of commission or omission

On the grounds of sexual orientation

  • homophobic or biphobic remarks or jokes
  • threats to disclose sexual orientation
  • asking intimate questions about sexual activity
  • outing someone as lesbian, gay or bisexual without their permission

On the ground of trans status

  • refusing to associate with or ignoring someone because they are trans
  • refusing to address the person using their new name and gender pronoun
  • failure to keep confidential information about that person’s trans status
  • refusal to allow use of sanitary facilities appropriate to the gender in which the person is living

On the grounds of age

  • use of ageist stereotypes
  • making assumptions about abilities or fitness on grounds of age
  • basing selection for training or development on the grounds of age (e.g. excluding those approaching retirement)
  • correlating career progression with age (e.g. the assumption that someone should have reached a certain career point by age 40)

On the grounds of religion or belief

  • offensive remarks or jokes about religion or belief
  • refusal to work with a person because of their religion or belief (or lack of religion or belief).
  • attempts to persuade an individual to change their religious or political beliefs or their way of living to your own
  • praying over an individual without their consent.

On the grounds of association with someone with a protected characteristic

  • making assumptions about an individual’s commitment to their work because they care for a disabled person.

On the grounds of pregnancy or maternity

  • criticising an individual because they need to take a break to express breast milk.

On the grounds of marriage or civil partnership status

  • treating an individual differently because they have a same sex or opposite sex partner.


Bullying can be defined as offensive, intimidating, malicious or insulting behaviour, an abuse of misuse of power that undermines, humiliates, denigrates or injures the recipient (emotionally or physically) - but it doesn't have a legal definition in the Equality Act. The above definition is supplied by ACAS.

Examples of actions or behaviours which may constitute bullying are set out below. These examples are not intended to be exhaustive but to illustrate the types of behaviours which the institution finds unacceptable. Please note, this also includes behaviour that occurs online.

  • sending e-mails or hard copy documents that are critical of someone to others who do not need to know
  • repeatedly shouting or swearing or humiliating at an individual in public or private
  • persistent criticism or constantly undervaluing effort
  • ridiculing or demeaning someone
  • derogatory or belittling remarks in front of others as regards appearance, work or personal attributes
  • overbearing supervision or other misuse of power or position
  • making threats or comments about job security without foundation
  • increasing responsibility whilst decreasing authority
  • overruling, ignoring, marginalising, or excluding an individual
  • removing areas of responsibility and imposing menial tasks
  • deliberately sabotaging or impeding work performance
  • preventing individuals progressing by intentionally blocking promotion or training opportunities or withholding work related information
  • excluding individuals from work or team events or isolating an individual by refusing to speak to them.

Appendix 2 – Useful Contacts

Employees can contact human resources by emailing or speak directly to any member of HR who will be able to advise of next steps.

Employees can also speak with the Diversity and Inclusion Adviser, Liz Grand.

Students can seek advice from a Personal Tutor, Student Union Vice-President (Education and Welfare) or Student Union Welfare Advisor.

UCU members can contact the St George’s UCU rep – Iain Crinson or St George’s UNITE rep – Jill Edwards.

British Medical Association – If you are a member, the BMA provide confidential counselling which is available 24 hours a day, 7 days a week on 0330 123 1245.

If employees or students would like to talk confidentially to someone, SGUL has a counselling service that can be contacted by email or 020 8725 3625.

Employees can also contact Confidential Care (an independent service) for counselling and emotional support on 0800 085 1376 or

Samaritans offer a safe place for you to talk any time you like, in your own way – about whatever’s getting to you – call 116 123.

Mind provides information on a range of topics including: 

  • types of mental health problems
  • where to get help
  • medication and alternative treatments
  • advocacy.

Lines are open 9am to 6pm, Monday to Friday (except for bank holidays) 0300 123 3393,, Text: 86463

For guidance and advice on bullying and harassment in employment, employees can contact ACAS (Advisory, Conciliation and Arbitration Service) helpline - 0300 123 1100. 


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