Sexual Harassment Prevention & Protection Policy

1. Purpose

One Degree Training & Coaching Ltd is committed to providing professional services in which people are treated with dignity and respect and are protected from sexual harassment.

This commitment applies to two equally important relationships:

• Protecting One Degree's employees, workers, contractors and associates from sexual harassment by colleagues, clients, client personnel and other third parties.
• Protecting clients, their employees, coaching and training participants, delegates and others receiving One Degree's services from sexual harassment by One Degree personnel or third parties involved in those activities.

Complaints will be considered according to the behaviour reported, not the seniority, employment status, commercial importance or professional standing of the individuals involved.

The same standards apply whether the person affected or the person complained about works for One Degree, a client or another organisation.

2. Scope

This policy applies to the conduct of people working for or representing One Degree, including:

• directors;
• employees and workers;
• contractors, consultants and associates;
• temporary or agency personnel; and
• other individuals acting on One Degree's behalf.

It also establishes the standards One Degree expects in its professional interactions with:

• clients and prospective clients;
• client employees and managers;
• coaching and mentoring participants;
• training and workshop delegates;
• suppliers and subcontractors;
• event organisers and attendees; and
• other third parties involved in One Degree's activities.

Relevant activities include face-to-face meetings, consultancy assignments, individual coaching, group training, conferences, networking events, business travel, work-related social occasions, telephone calls, online meetings and digital communications.

The policy is not limited to One Degree's premises or conventional working hours.

Statutory obligations depend on the legal relationship and circumstances involved. This policy establishes One Degree's own standards without transferring another organisation's employer obligations to One Degree.

3. Legal Framework

This policy takes account of applicable law in England, including the Equality Act 2010, the Worker Protection (Amendment of Equality Act 2010) Act 2023 and the Employment Rights Act 2025.

Under section 26 of the Equality Act 2010, sexual harassment is prohibited in applicable employment-related circumstances.

Since 30 October 2026, employers have been required to take all reasonable steps to prevent sexual harassment of their workers in the course of employment.

The law also provides for employer liability for harassment by third parties in defined circumstances, where the employer failed to take all reasonable steps to prevent it.

These statutory duties operate alongside other relevant employment, health and safety, contractual and legal obligations.

One Degree recognises that the legal responsibilities owed by a client's employer to its own employees remain with that employer. One Degree will nevertheless take appropriate action where harassment involves its personnel or activities.

4. What Constitutes Sexual Harassment?

Sexual harassment involves unwanted conduct of a sexual nature which has the purpose or effect of violating someone's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.

Conduct does not have to be intended to offend to amount to sexual harassment. A single incident may be sufficient.

Examples may include:

• unwanted touching, hugging, kissing or other physical contact;
• sexual comments, jokes, gestures or remarks directed at a person;
• unwelcome sexual advances or repeated requests for personal or sexual contact;
• intrusive questions about someone's sex life or body;
• sending or displaying sexually explicit messages, images or other material;
• sexual propositions linked to work opportunities, favourable treatment or commercial decisions;
• inappropriate conduct during online meetings, messaging or social media communications; and
• retaliatory conduct following the rejection of an unwanted sexual advance.

Whether specific behaviour meets the legal definition will depend on the circumstances, including the effect on the individual and the applicable legal test.

One Degree may also take action against inappropriate sexual behaviour that breaches its professional standards, even where the legal definition of sexual harassment is not established.

5. Standards of Conduct

Everyone representing One Degree is expected to maintain appropriate professional boundaries.

Sexual comments, advances, intimidation or other inappropriate conduct will not be excused because the individuals involved know one another, are attending a social event or have previously interacted informally.

Alcohol, humour, seniority, commercial influence or assumptions about someone's willingness to participate do not excuse sexual harassment.

One Degree also expects clients and third parties interacting with its personnel to respect these standards.

Any person may raise concerns without being required to confront the person responsible directly.

6. Protecting One Degree Personnel

One Degree will take all reasonable steps required by applicable law to prevent sexual harassment of its workers, including harassment involving clients and other third parties.

Where harassment is reported or a significant risk is identified, One Degree will consider appropriate protective action.

Depending on the circumstances, this may include:

• addressing the behaviour with the client or third party concerned;
• requiring the conduct to stop immediately;
• changing meeting arrangements or avoiding isolated working;
• arranging for another person to be present;
• removing personnel from an unsafe environment without penalising them;
• requesting that an individual no longer attends sessions;
• suspending or ending an assignment where legally and contractually permitted;
• referring potentially criminal behaviour to the police where appropriate; and
• reviewing arrangements to prevent recurrence.

7. Protecting Clients and Participants

One Degree is equally committed to protecting people receiving its services from sexual harassment involving One Degree personnel.

This includes employees, directors and representatives of client organisations, individual coaching participants, training delegates and other service users.

One Degree will not tolerate sexual harassment by its directors, employees, contractors, associates or others acting on its behalf.

Where a concern is raised about a person representing One Degree, the matter will be taken seriously and assessed fairly.

Appropriate action may include:

• making immediate arrangements to prevent further unwanted contact;
• appointing an independent investigator where appropriate;
• replacing or withdrawing the individual delivering services;
• suspending the individual's involvement while a serious allegation is investigated;
• taking disciplinary or contractual action where justified; and
• working with the client organisation to establish appropriate protective measures.

One Degree will also act on concerns involving harassment of a client or participant by a third party where the situation arises within an activity that One Degree organises or controls.

Where the alleged perpetrator is employed or controlled by another organisation, One Degree will work with that organisation as appropriate. One Degree cannot impose employment disciplinary sanctions on another organisation's staff.

If a client reports harassment within its wider workplace that is unrelated to One Degree's personnel or activities, responsibility for dealing with that workplace matter normally rests with the client employer.

8. Prevention and Risk Management

One Degree will consider foreseeable sexual harassment risks arising from its professional activities and take the preventative measures appropriate to those risks.

Risk assessments will be proportionate to the scale, nature and working arrangements of the organisation.

Particular consideration will be given to:

• individual coaching, mentoring and consultancy meetings;
• working alone with clients or delegates;
• activities carried out on client premises;
• business travel and overnight accommodation;
• conferences, networking events and business-related social activities;
• situations involving alcohol;
• telephone calls, messaging and digital communication;
• the use of subcontractors, consultants and associates; and
• circumstances in which professional or commercial relationships could make reporting difficult.

Preventative measures may include communicating standards before engagements, establishing reporting arrangements, providing appropriate training, adjusting working practices and reviewing concerns or incidents.

Where a client controls the workplace or event, One Degree may seek to agree suitable arrangements for preventing and responding to harassment involving its personnel or services.

Assessments and preventative measures will be reviewed when working arrangements, risks or relevant circumstances change.

9. Reporting Sexual Harassment

Anyone who experiences or witnesses sexual harassment involving One Degree personnel or activities is encouraged to report the matter as soon as reasonably possible.

A report may be made by the affected person, a witness or someone who becomes aware of concerning behaviour.

Normal Reporting Route

Reports should normally be made to:

Where the Concern Involves the Managing Director

No person will be required to submit a detailed allegation directly to the individual complained about.

Where the Managing Director is implicated, One Degree will arrange for the matter to be received and assessed by a suitably qualified independent external HR professional, employment adviser or other appropriate independent person.

A person working for a client organisation may instead report their concern to their own designated HR contact, safeguarding contact or senior manager and request that the matter be raised through an independent process.

One Degree personnel and other affected persons may seek independent advice from ACAS, an appropriate professional adviser or another relevant authority.

A permanent independent reporting contact will be provided where one has been formally appointed. Reports concerning the Managing Director must not be investigated or decided by the person accused.

What Information to Include

Where reasonably possible, a report should explain:

• what happened or what behaviour caused concern;
• when and where it occurred;
• the people involved;
• whether there were witnesses or relevant messages or records;
• whether there is any immediate safety concern; and
• any outcome or protective measure the person wishes to request.

An incomplete account will not automatically prevent a concern from being considered.

10. Responding to Reports

Reports of sexual harassment will be taken seriously and assessed promptly.

The initial response will consider the nature of the allegation, whether anyone is at immediate risk and what action may be necessary before an investigation is completed.

Where appropriate, One Degree will:

• acknowledge the concern;
• consider immediate protective measures;
• identify who should assess or investigate the matter;
• consider whether a client or another organisation needs to be involved;
• establish suitable arrangements for communication with those concerned; and
• determine whether any external authority should be contacted.

Serious concerns will not be left without initial consideration merely because the general Complaints Procedure allows a longer period for a substantive response.

A person raising a serious allegation will not be required to confront the person accused or attempt an informal resolution.

Where immediate danger exists, emergency services should be contacted using 999.

11. Investigating Allegations

Where an investigation is appropriate, it will be conducted fairly, sensitively and impartially.

The arrangements will be proportionate to the seriousness and complexity of the matter.

The investigation may include:

• speaking separately with the complainant, person accused and relevant witnesses;
• reviewing emails, messages, documents and other evidence;
• considering the circumstances and impact of the conduct;
• identifying whether preventative measures were appropriate and followed; and
• making findings supported by the available evidence.

No conclusion will be assumed before the evidence is considered.

The person accused will normally be given a fair opportunity to understand and respond to the allegations.

Where the allegation concerns the Managing Director, an appropriate independent person will conduct or oversee the investigation and its findings.

Where individuals from multiple organisations are involved, One Degree may coordinate with the relevant client or third-party employer, subject to confidentiality and applicable law.

Any decision about disciplinary or contractual consequences will follow an appropriate process and take account of the available evidence.

12. Support, Privacy and Confidentiality

One Degree will treat people affected by allegations of sexual harassment with dignity and sensitivity.

Appropriate support may include temporary changes to working arrangements, reducing contact between those involved, reasonable time away from relevant activities and signposting to independent support.

Support will be considered for both the person raising the concern and the person accused, without prejudging the outcome.

Information will be shared only where reasonably necessary for assessment, safeguarding, investigation, legal compliance or appropriate management action.

Absolute confidentiality cannot be promised where disclosure is necessary to investigate fairly, protect someone from serious harm or comply with the law.

Personal information will be handled in accordance with applicable data protection requirements.

13. Consequences of Sexual Harassment

Sexual harassment by One Degree personnel may result in disciplinary, contractual or other appropriate action.

Serious misconduct by an employee may constitute gross misconduct and could result in dismissal without notice following an appropriate procedure.

For contractors or associates, a serious breach may result in withdrawal from an assignment or termination of their engagement where contractually permitted.

Where a client, delegate or third party is responsible, One Degree may:

• issue a warning or require the conduct to stop;
• restrict contact with its personnel;
• exclude an individual from an activity;
• change service delivery arrangements;
• suspend or end a commercial relationship where legally permitted; or
• report potentially criminal behaviour to relevant authorities.

Appropriate consequences will reflect the evidence, seriousness of the conduct, contractual arrangements and legal obligations.

14. Protection from Retaliation

One Degree will not tolerate retaliation against anybody because they have raised a concern, made a complaint, supported another person, acted as a witness or participated honestly in an investigation.

Individuals making qualifying protected disclosures may also have statutory protection under whistleblowing law.

Since 6 April 2026, the statutory whistleblowing framework expressly includes qualifying disclosures concerning sexual harassment.

An allegation that is not upheld will not, merely because it was unsuccessful, be treated as having been made in bad faith.

Deliberately false allegations made knowingly and in bad faith may be addressed through an appropriate process.

Nothing in this policy prevents a person from obtaining legal advice, exercising statutory rights or contacting relevant authorities.

15. Responsibilities

Managing Director

The Managing Director is responsible for:

• maintaining this policy;
• ensuring relevant risks are assessed;
• implementing appropriate preventative measures;
• communicating conduct expectations to personnel and relevant third parties;
• arranging appropriate training or awareness;
• responding to concerns and arranging independent handling where necessary;
• considering the safety of people affected by allegations; and
• monitoring and reviewing preventative arrangements.

One Degree Personnel

Everyone representing One Degree is expected to:

• comply with this policy;
• maintain appropriate professional boundaries;
• avoid sexual harassment and inappropriate sexual conduct;
• raise serious concerns where appropriate;
• cooperate honestly with relevant investigations; and
• respect confidentiality and the rights of those involved.

Clients and Third Parties

One Degree expects clients and third parties to maintain equivalent standards of appropriate behaviour when interacting with its personnel or participating in its activities.

Clients remain responsible for their own employment arrangements, staff conduct and statutory employer duties.

Where appropriate, One Degree will seek to establish shared expectations and reporting arrangements at the start of an engagement.

16. Monitoring and Review

This policy will normally be reviewed at least annually, or earlier where circumstances require.

An earlier review may follow:

• changes to applicable legislation or authoritative guidance;
• a serious complaint or incident;
• changes to working arrangements or service delivery;
• identification of additional risks;
• recruitment of staff or engagement of new associates; or
• evidence that existing safeguards are inadequate.

One Degree will consider whether its preventative measures are effective in practice, rather than relying solely on the absence of complaints.

Appropriate records of risk assessments, preventative measures, incidents and reviews will be maintained in accordance with relevant data protection requirements.

17. Policy Status

This policy is non-contractual and may be amended when reasonably necessary.

It does not replace statutory rights, applicable employment procedures, contractual obligations or One Degree's existing Equality, Diversity & Inclusion Policy.

All individuals representing One Degree are expected to comply with its standards.

Failure to do so may result in appropriate action.

This policy is intended to apply alongside the applicable law, without claiming to exclude, limit or replace legal protections available to individuals.