Anti-bullying and harassment policy
This is the fourth of HALO's safeguarding policies, which cover protections against abuse, harassment, exploitation, bullying, and procedures for reporting and responding to safeguarding concerns.
1. Introduction
The HALO Trust (“HALO”) is committed to providing a safe, respectful and professional working environment for all employees and those associated with the organisation, including volunteers and communities affected by our work.
Our work depends on trust, professionalism and mutual respect across diverse cultures and countries. All individuals working with or for HALO have the right to be treated with dignity and respect and to work in an environment free from intimidation or humiliation.
Bullying and harassment have no place in HALO and will not be tolerated in any form.
This policy sets out the standards of behaviour expected of everyone who works with or represents HALO and explains how concerns can be raised and addressed. Creating and maintaining a respectful workplace is a shared responsibility.
This policy applies to all HALO employees globally, including UK, international and national staff.
2. Purpose of the Policy
This policy aims to:
Prevent bullying and harassment in HALO workplaces
Promote respectful behaviour across all programmes
Provide clear reporting routes
Ensure concerns are handled fairly and consistently
Protect employees who raise concerns in good faith
3. Policy Principles
HALO is committed to the following principles:
Dignity and Respect. All individuals must be treated with dignity and respect regardless of nationality, culture, gender, religion or role
Zero Tolerance. Bullying and harassment are unacceptable and will not be tolerated
Fairness and Due Process. Concerns will be addressed fairly and consistently
Speak-Up Culture. Employees are encouraged to raise concerns early
Protection from Retaliation. Individuals who raise concerns in good faith will be protected
4. Scope
This policy applies globally to:
International employees
UK employees
National employees
Managers and leaders
Consultants and contractors
Volunteers and interns
Agency workers
Partner organisations working with HALO
The policy applies to behaviour:
In offices and field locations
During programme operations or in communities impacted by HALO work
During work travel
At work events and training
On communication platforms
Outside work where behaviour affects the workplace
HALO also expects individuals who interact with our staff, including suppliers, community partners and external stakeholders, to behave respectfully. Where bullying or harassment involves third parties, HALO will take appropriate action to protect employees.
5. Behaviour Expectations Summary
To support understanding across HALO’s global workforce, the following summary outlines expected workplace behaviour.
All employees are expected to contribute to a respectful workplace.
5.1. Respectful Behaviour
Employees shall:
Treat colleagues with dignity and respect
Communicate professionally
Listen to others and value different perspectives
Support a positive and inclusive workplace
5.2. Unacceptable Behaviour
Employees shall not:
Intimidate or humiliate others
Shout at colleagues or behave aggressively
Spread rumours about colleagues
Deliberately exclude individuals from work activities
Misuse authority or position of power
Send offensive or inappropriate messages
5.3. Leadership Behaviour
Managers and leaders shall:
Act as role models for respectful and appropriate behaviour
Address inappropriate behaviour promptly
Support employees who raise concerns
Ensure fair and respectful treatment of all team members
Everyone at HALO shares responsibility for maintaining a respectful workplace.
6. Power Imbalance and Leadership Responsibility
HALO recognises that differences in seniority, authority, employment status or cultural context can create power imbalances in the workplace.
Managers and leaders hold positions of responsibility and must exercise their authority fairly, respectfully and professionally at all times.
Misuse of authority, including behaviour that intimidates, humiliates or undermines others, is not acceptable.
Leaders must ensure that employees feel safe to raise concerns and must never use their position to discourage or prevent employees from reporting inappropriate behaviour.
All leaders at HALO are expected to promote a respectful working environment and address concerns about bullying or harassment promptly and responsibly.
7. Legal Framework, Standards, and Application
This policy reflects:
Local employment laws will also apply where required
HALO operates across multiple countries and legal systems
This policy establishes minimum global behavioural standards which apply across all programmes. Where local laws provide greater protection, those laws will apply in addition to this Policy.
8. Cultural and Global Context
HALO recognises and respects cultural differences. However, cultural differences do not excuse behaviour that breaches this Policy or undermines dignity, respect or professionalism.
9. What is Bullying
Bullying is unwanted behaviour that intimidates, humiliates or undermines another person
Bullying may involve misuse of power, repeated behaviour or a serious single incident
Bullying can occur between colleagues, managers and employees, or between staff and third parties
10. What is Harassment
Harassment is unwanted behaviour that violates someone’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment
Harassment may relate to protected characteristics such as race, sex, religion, disability or sexual orientation
Harassment can occur even where behaviour was not intended to cause offence or harm. When assessing concerns, HALO will consider the nature of the behaviour, the context in which it occurred, and whether it was reasonable for the behaviour to have the effect described.
11. Examples of Bullying and Harassment
Shouting or aggressive behaviour
Humiliating someone in meetings
Spreading malicious rumours
Deliberately excluding someone
Persistent unfair criticism
Offensive messages or emails
Abuse of managerial authority
Cyber-bullying through messaging platforms or social media (including, but not limited to, humiliating, offensive or threatening comments or photos)
Undermining someone by deliberately withholding information needed to do their job
12. What is not Bullying or Harassment
Legitimate management actions are not bullying or harassment where they are carried out reasonably, professionally and fairly. Concerns relating to management action may instead be addressed under the appropriate HR process depending on the circumstances.
Examples include:
Providing constructive feedback
Managing poor performance
Addressing misconduct
Setting work objectives
Professional disagreement
Reasonable management decisions about workload or organisational change
13. Roles and Responsibilities
All Employees. All employees are responsible for:
Treating colleagues with dignity and respect
Behaving professionally at all times
Not engaging in bullying or harassment
Raising concerns if they experience or witness inappropriate behaviour
Cooperating with investigations where required
Everyone at HALO has a responsibility to contribute to a respectful working environment.
Managers and Leaders. Managers and leaders have additional responsibilities to:
Promote a respectful and inclusive working environment
Address inappropriate behaviour promptly
Ensure employees understand this policy
Respond appropriately when concerns are raised
Seek advice from Human Resources where necessary
Ensure employees feel safe to raise concerns
Managers should never ignore or minimise reports of bullying or harassment.
Human Resources. HQ HR, with input from Safeguarding where appropriate, is responsible for:
Providing advice and guidance on this policy
Supporting managers and employees when concerns arise
Ensuring fair and consistent application of the policy
Overseeing investigations where necessary
Ensuring compliance with employment law and organisational standards.
14. Reporting Concerns
Employees are encouraged to raise concerns as early as possible.
Concerns can be reported through the mechanisms outlined in HALO’s Whistleblowing Policy.
Employees may raise concerns confidentially and will be supported throughout the process wherever possible.
All concerns will be treated seriously and handled sensitively.
15. Informal or Formal Resolution
Where appropriate, concerns may be addressed informally.
Informal resolution may include:
Speaking directly with the person involved
Facilitated discussions
Mediation
Support from a manager or HR
Informal resolution may help resolve issues quickly and maintain positive working relationships.
However, informal resolution may not be appropriate where:
Allegations are serious
Behaviour is repeated, despite previous attempts at resolving informally
There is a significant imbalance of power
There are safeguarding concerns
If a concern cannot be resolved informally, or where informal resolution is not appropriate, a formal complaint may be raised. Typically, formal investigations will follow HALO’s Grievance and/or Disciplinary Policies and procedures.
16. Confidentiality
HALO recognises that complaints of bullying and harassment can be sensitive.
Information will be shared only with those who need to know in order to:
Investigate the concern
Protect individuals involved
Comply with legal obligations
Absolute confidentiality cannot always be guaranteed, but every effort will be made to protect the privacy of those involved
17. Protection from Retaliation
Retaliation against anyone who raises a concern or participates in an investigation is strictly prohibited.
Retaliation may include:
Unfair treatment
Intimidation
Threats
Negative changes to working conditions
Anyone found to have engaged in retaliation may face disciplinary action.
18. Malicious or False Complaints
HALO encourages employees to raise concerns in good faith.
If a complaint is made honestly but is not upheld, no action will be taken against the person who raised it.
However, deliberately making false or malicious allegations may result in disciplinary action.
19. Support for Employees
HALO recognises that bullying or harassment concerns can be distressing.
Support may include:
Line Manager support
Advice from Human Resources and / or Safeguarding
Access to Employee Assistance Programme (EAP) / counselling services where available
Temporary adjustments to working arrangements
Managerial support
Support may be provided to both the complainant and the respondent during the process.
20. Consequences of Breaching this Policy
Bullying or harassment is considered unacceptable behaviour and may be treated as misconduct or gross misconduct.
Behaviour involving harassment related to protected characteristics may also breach equality legislation and could result in more serious disciplinary action.
Possible outcomes following investigation may include:
Informal guidance or mediation
Training or behavioural expectations
Formal written warning
Final written warning
Dismissal, including summary dismissal where appropriate
Termination of contract or assignment
The outcome will depend on the seriousness of the behaviour and the findings of the investigation.
For breaches of this policy by external partners / organisations and / or contractors, this may result in the termination of contract with HALO.
21. Policy Accessibility
HALO recognises that many employees work in multilingual environments.
This policy is written in clear language to support understanding.
Where appropriate, programmes may provide translated summaries or briefings to ensure employees understand the policy.
22. Monitoring and Review
HQ HR, Employee Relations and Safeguarding will review this policy annually and monitor trends relating to bullying and harassment concerns in order to improve workplace culture and prevention measures.
23. Policy and Procedure Relationship
This policy sets out HALO’s behavioural standards.
Operational processes for handling complaints are contained in separate procedures which may be updated by HR when necessary.
24. Related Policies
Prevention of Sexual Exploitaton Abuse and Harrassment Policy
Prevention of Modern Slavery and the Trafficking in People Policy
Last updated: 12 August
