We aim to ensure that Wholegrain is a happy place to work. As such bullying, discrimination and harassment will not be tolerated to any degree. We want our team members to feel safe, respected and valued.  We expect our team members’ behaviour and interactions with others, whilst doing business on behalf of Wholegrain, to maintain these standards. 

This policy applies to all employees and contractors at Wholegrain.  It also relates to any misconduct and/or inappropriate behaviours towards our team members from visitors, clients, suppliers or indeed anybody else that you come into contact with as part of your work with us.  It does not form part of your contract of employment or contract for services and may be amended from time to time.  Any, and all, personal data used in conjunction with this policy shall be collected, held, and processed in accordance with our ‘Data Protection Policy.’

What Is Discrimination?

Harassment is defined as unwanted conduct that has the purpose of, or is reasonably considered by an individual to be, violating their dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment for them, even if this effect was not intended by the person responsible for the conduct. It can take many forms, whether or not the person behaving in that way intends for it to offend.  Everyone has the right to decide what behaviour is acceptable to them and to have their feelings respected by others.

Harassment is related to the nine ‘protected characteristics’ as defined by the Equality Act 2010:

  • Age;
  • Disability;
  • Gender reassignment;
  • Marriage or civil partnership;
  • Pregnancy and maternity;
  • Race;
  • Religion or belief;
  • Sex;
  • Sexual orientation

Harassment may occur where a person engages in unwanted conduct towards another individual because they perceive that the recipient has a ‘protected characteristic’ (whether or not they actually do have that characteristic), or on the basis of association, for example if their child is disabled, their wife/partner is pregnant or their friend is a devout Christian.

In some cases, it may not be clear in advance that such behaviour could be considered as harassment by the recipient (for example jokes and banter). In these cases, first time conduct which unintentionally causes offence may not automatically be considered as harassment, but would become harassment if the conduct continues after the recipient has made it clear, by words or conduct, that the behaviour is unwelcome and unwanted.  

Although harassment is normally continuing, a single incident can be harassment if it is sufficiently serious.  In addition, some bullying and harassment will constitute unlawful discrimination if the conduct relates to any of the ‘protected characteristics.’

What Is Discrimination?

Discrimination is any action or attitude directed at another person due to a ‘protected characteristic.’ Discrimination may be either direct; when someone is put at a disadvantage or treated less favourably because of a ‘protected characteristic’.  It could also be indirect discrimination, when a working practice, policy or rule is the same for a group of individuals but has a worse effect on one or more individuals because of a ‘protected characteristic’.

Like with harassment, direct discrimination can either be on the basis of an actual or perceived ‘protected characteristic,’ or due to an association with someone who has the ‘protected characteristic.’ 

What is Bullying?

Bullying has crossovers with harassment and can be defined as an abuse or misuse of power, which is meant to, or has the effect of, undermining, humiliating, or injuring the recipient of that behaviour.

Examples of harassment and bullying

Harassment and bullying may be conduct, which is physical, verbal, or non-verbal in its nature.  Examples include, but are not limited to:

  • physical conduct from unwelcome touching, sexual advances and/or serious assault;
  • unwelcome comments about a person’s appearance;
  • unwelcome comments or remarks, jokes, innuendo, speculation, teasing about personal appearance or characteristics such as their gender, race, age etc;
  • visual displays of images, objects, computer screensavers, graffiti, obscene gestures, flags, bunting or emblems, or any other offensive material;
  • isolation/exclusion or non-co-operation at work or from social activities;
  • intrusion by pestering, spying, following; etc;
  • excluding an individual because they are associated or connected with someone with a ‘protected characteristic’;
  • ignoring an individual because they are perceived to have a ‘protected characteristic’ or because they do have a ‘protected characteristic’;
  • spreading malicious rumours or insulting someone;

Your Working Environment

We’re committed to maintaining a working environment that’s free from harassment, discrimination and bullying. We promote dignity and respect for all, and recognise and value all individual differences and contributions to our team. This includes our virtual workspaces such as Slack, Redbooth, Skype, and Hangouts, as well as telephone and in-person conversations.

All team members are responsible for helping us achieve our aims. Specifically, you must not discriminate against, bully or harass other people, including current and former employees, job applicants, clients, suppliers, contractors, visitors, or colleagues at our offices.

This applies both in and out of the workplace, for example on work-related trips, company social events, conferences, workshops, etc.

Addressing Harassment,  Discrimination or Bullying

If you’re the victim of harassment, discriminatory behaviour or bullying, or you suspect that others are being targeted, please discuss your concerns in private with your Line Manager or another Manager if you prefer. We take any complaints of this nature extremely seriously.

Complaints can be raised, and will be managed, in accordance with our ‘Grievance Policy and Procedure’. We will thoroughly investigate the matter, and determine the appropriate sanction and/or recommendation. 

Breaches of this policy are dealt with under our ‘Disciplinary Policy and Procedure’ and could amount to gross misconduct, potentially leading to dismissal without notice.

Please note that some forms of discrimination and harassment are also a criminal offence, and could render the perpetrator to prosecution under the Protection from Harassment Act 1997.


Victimisation is defined as treating someone less favourably than others because they have, in good faith, complained or given evidence about the behaviour of someone who has been bullying, harassing, or discriminating against them or someone else.  Providing a team member has acted in good faith, i.e. genuinely believes what they are saying is true, they have a right not to be victimised.   Team members must not victimise or retaliate against another individual who has made, or is thought to have made, allegations or complaints of harassment, discrimination, or bullying, nor against anyone who has or is thought to have assisted that individual.  Such behaviour will be investigated and if found to be true, would be treated as gross misconduct in accordance with our disciplinary procedure.

Sensitive complaints

Wholegrain recognises that some issues and complaints can be very sensitive and encourages team members to speak to another Manager,  the Managing Director or the HR Consultant in the event that they do not wish to discuss the matter with their Line Manager.  All discussions will be dealt with sensitively and in confidence.

Vexatious complaints

If upon investigation, a complaint has been found to be untrue and brought about in bad faith (i.e. spite) then it would be referred for further action under the ‘Disciplinary Policy and Procedure.’


We recognise that matters relating to harassment, discrimination and bullying can be complex and we want to ensure that our employees can access the appropriate training to ensure that they are clear on our expectations relating to their conduct. In addition, that they have the skills to identify any situations that do not support Wholegrain’s values and the best method in which to escalate such.   Training on this policy is therefore available to all employees and may be requested via your Line Manager.