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Prevention of Bullying, Harassment and Sexual Misconduct Policy

This policy is designed to ensure a safe, welcoming and inclusive working and learning environment for all members of the UCL community, where all staff and students are equally valued and respected.

Contents 

 

Purpose and Scope

1. Bullying, harassment and sexual misconduct are contrary to UCL’s ethos, values and mission and are never acceptable. No member of the UCL community is expected to tolerate such behaviour.

The purpose of this policy is to:

  • a) Promote a positive environment in which people are treated fairly and with respect;
  • b) Make it clear that bullying, harassment and sexual misconduct are unacceptable;
  • c) Ensure all members of UCL’s community play an active role in creating an environment free from bullying, harassment and sexual misconduct;
  • d) Provide a framework of support for staff and students who feel they have been subject to or have witnessed bullying, harassment or sexual misconduct; and
  • e) Signpost to reporting mechanisms so that complaints can, wherever possible, be addressed in a timely way.

2. This policy applies to allegations of bullying, harassment and sexual misconduct against members of UCL’s community, including students, staff, appointees[1], and third parties.

3. All staff and students have a right to complain if they believe that they are being, or have been, subjected to or have witnessed unacceptable behaviour in the course of their work or study at UCL. 
 

Definitions 

Abuse of power

4. Abuse of power is where someone uses their position of power or authority in an unacceptable manner. Abuse of power can take various forms and may include, but is not limited to, grooming, manipulation, coercion, putting pressure on others to engage in conduct they do not feel comfortable with. Please read more about this in the Personal Relationships Policy.

Bullying

5. Bullying may be offensive, intimidating, malicious or insulting behaviour that can make a person feel vulnerable, upset, humiliated, undermined or threatened. Bullying may be a pattern of behaviour or a one-off incident.

6. Bullying may include overbearing and intimidating levels of supervision or inappropriate derogatory remarks. Legitimate and constructive feedback related to academic or work-related performance is unlikely to amount to bullying.

Discrimination

7. The Equality Act 2010 prohibits less favourable treatment which is linked to one of the nine protected characteristics: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including ethnic origin, nationality and colour), religion or belief, sex and sexual orientation.

[1] An appointee is someone engaged by UCL such as a volunteer, honorary staff, agency worker or contractor.

Grooming

8. When a person in a position of power or authority builds a relationship with someone so they can abuse them and/or manipulate them into doing things they may not be comfortable with and may also make it less likely that the abusive behaviour is reported or rejected.

Harassment under the Equality Act 2010

9. Harassment includes unwanted behaviour or conduct which has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment because of, or connected to, one or more of the following protected characteristics: age; disability; gender reassignment; race; religion or belief; sex; and sexual orientation.

Harassment under the Protection from Harassment Act 1997 

10. Harassment is defined as a course of conduct conducted on at least two occasions that harasses one other person, or a course of conduct that harasses two or more persons at least once each. References to harassing a person include alarming the person or causing the person distress.

11. When the term ‘harassment’ is used in this policy it can mean harassment under the Equality Act 2010 and / or under the Protection from Harassment Act 1997.

Reporting

12. Reporting is the sharing of information with a staff member of the University regarding an incident of bullying, harassment or sexual misconduct experienced by that individual.

Reported Party

13. The Reported Party is the person(s) who is alleged to have behaved in a way that constitutes bullying, harassment or sexual misconduct.

Reporting Party

14. The Reporting Party is the person(s) who witnessed or is the subject of the alleged incident of bullying, harassment or sexual misconduct.

Sexual Harassment 

15. Sexual harassment occurs when someone is subjected to unwanted conduct of a sexual nature or which is related to sex which has the purpose or effect of either violating that person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them.  A person can be sexually harassed by someone of the same or different sex. 

Sexual misconduct

16. Sexual misconduct means any unwanted or attempted unwanted conduct of a sexual nature and includes, but is not limited to sexual harassment, sexual assault and rape.

Safeguarding

17. Protecting the health, wellbeing and human rights of a child or an adult at risk, and enabling them to live free from harm, abuse and neglect.

Stalking

18. Stalking can include physically following a person, watching or spying on them or forcing unwanted contact with them through any means, including social media.

Third-party harassment 

19. This occurs where a person is harassed or sexually harassed by someone who does not work for, and who is not an agent of, UCL, but with whom that person has come into contact during their employment or studies. Third-party harassment could include, for example, unwelcome sexual advances from a supplier visiting UCL’s premises, or where a person is visiting a supplier's premises or other location in the course of their employment or studies.

Victimisation

20. Victimisation is when someone is treated less favourably as a result of being involved with a discrimination or harassment complaint

Roles and Responsibilities

21. UCL is committed to preventing and responding to incidents of bullying, harassment or sexual misconduct. This will be done through educational and preventative training programmes, and via the effective implementation and operation of this policy and linked processes. 

22. All members of UCL’s community are expected to behave in a way that fosters a safe, welcoming and inclusive working and learning environment, where everyone is treated with respect and dignity. Staff and students are expected to contribute to preventing unacceptable behaviours, including harassment, bullying or sexual misconduct (including sexual harassment) through self-awareness; by modelling positive behaviour for others, and raising any concerns about negative behaviours.

23. Those in positions of responsibility have a duty to implement this policy fairly and to make every effort to ensure that bullying, harassment and sexual misconduct do not occur in the areas of work for which they are responsible and that, if they do occur, any concerns are investigated promptly and effectively. 

Unacceptable Behaviours

24. Bullying, harassment and sexual misconduct are unacceptable and, if found, disciplinary action may follow, up to and including dismissal or expulsion as applicable. These behaviours can take a wide variety of forms. Unacceptable behaviours may occur in person, online, via electronic means (including social media) and may take place on or off campus (including overseas), and in or out of working hours.

Appendix 1 contains non-exhaustive examples of behaviours that may be considered unacceptable and contrary to this policy.

25. Students may be exposed to course material, statements and views as part of their learning experience that they find offensive or unacceptable. The content of higher education course materials, including books, videos, sound recordings, and pictures, as well as lawful statements or views expressed as part of teaching, research, or discussions about the content of a higher education course are likely to be protected by academic freedom and are unlikely to breach this policy. 

Reporting unacceptable behaviour 

26. Allegations of unacceptable behaviour, whether by a UCL employee or worker, a student, a third party such as a supplier, or a member of the public, should always be taken seriously. Action should be taken to stop any inappropriate behaviour identified as quickly as possible, and consideration should be given to the use of disciplinary processes where necessary.

Informal Resolution 

27. A person affected by alleged bullying, harassment or sexual misconduct may wish to explore informal resolution in the first instance. This could include speaking directly to the person responsible for the unwanted behaviour, if the person affected prefers this approach and feels it is safe to do so, or requesting mediation.

28. Members of staff can seek advice on informally resolving issues of bullying, harassment and sexual misconduct from:

29. Students can seek advice on informally resolving issues of bullying, harassment and sexual misconduct from:

30. Where there are several reports (informal or formal) concerning unacceptable behaviours in the same area, UCL may take steps to understand the behaviours and culture in a department/faculty in more detail and to identify and target appropriate support and interventions. UCL may commission an environmental investigation into the behaviours and/or culture in these circumstances. 

Formal Complaints

31. All complaints should be made in writing and should set out full details of the conduct in question, including references to specific details such as dates, times, and potential witnesses where possible.

32. All reports of bullying, harassment or sexual misconduct will be investigated fairly and impartially under the relevant procedure. This includes providing both the Reporting Party and the Reported Parties the opportunity to present their accounts and any supporting evidence. During any investigation consideration will be given to whether any interim measures are required to protect the interests of all parties.

33. Confidentiality is very important in dealing with cases of alleged unacceptable behaviour. The Reporting Party, the Reported Party and senior staff handling the report should only divulge information to relevant people on a 'need-to-know' basis to ensure the safety and wellbeing of the individuals involved.

34. UCL understands there may sometimes be situations where there are overlapping internal UCL investigations and police proceedings relating to an allegation of harassment or sexual misconduct. For further details on this, please refer to the UCL Staff Disciplinary Procedure and/or Student Disciplinary Code.

35. If a complaint is found to be false, misleading or in bad faith, action may be taken in accordance with the Staff Disciplinary Procedure and/or Student Disciplinary Procedure as applicable.  However, the fact that a complaint is not upheld of itself is not an indicator of any wrongdoing on the part of the Reporting Party. 

Complaints from Students 

36. Students who feel they have experienced or witnessed bullying, harassment or sexual misconduct by another student may make a formal report to the Student Casework Team by emailing them on casework@ucl.ac.uk . This process may also be initiated through Report + Support.

37. Students who feel they have experienced or witnessed bullying, harassment or sexual misconduct by a member of staff may make a formal report through Report + Support.

38. Students who feel they have experienced or witnessed bullying, harassment or sexual misconduct by a third party / member of the public in the course of their studies should report this via Report + Support, or directly to a member of UCL staff, such as their personal tutor or supervisor. 

Complaints from Staff 

39. Employees who feel they have experienced or witnessed bullying, harassment or sexual misconduct may make a formal complaint against a staff member by using the Staff Grievance Policy[2] or by using Report + Support.

[2] Concerns raised by staff who remain in their probationary period are dealt with under UCL’s Induction and Probation Policy. Concerns that relate to the operation or management of another formal procedure will usually be deal with as part of that procedure.

40. Staff members may make a formal complaint against a student by contacting the Student Casework Team by emailing them on casework@ucl.ac.uk . They may also use Report + Support.

41. Staff who feel they have experienced or witnessed bullying, harassment or sexual misconduct by a third party / member of the public in the course of their employment should report this via Report + Support or to their HR Business Partner or local HR Manager. 

Complaints from Third Parties

42. Third parties or members of the public who feel they have experienced or witnessed bullying, harassment or sexual misconduct by an employee or student while at UCL or participating in a UCL activity, may make a formal complaint using the Public Complaints procedure.  

Outcome of a formal complaint

43. Once a formal complaint has been investigated and, if appropriate, action has been taken under UCL’s disciplinary procedures, the reporting party will be told whether their complaint has been upheld or not, and whether the Reported Party has been dismissed or expelled.  The Reporting Party will also be informed of the reason/s for the decision. 

44. If the complaint is not upheld or the Reported Party is not dismissed or expelled, there may be limits to the information that can be shared with the Reporting Party. The level of information that can be shared with a Reporting Party will need to be carefully considered on a case-by-case basis.

45. UCL has to balance the need to provide information to a Reporting Party related to the outcome of their complaint, with the need to maintain confidentiality around disciplinary processes and its obligations to staff and students under GDPR. The Reporting Party will be asked to respect confidentiality with regards to the outcome.

46. Whether or not a complaint is upheld, it may be useful to refer to mediation to help repair the ongoing relationship between the Reporting Party and the Reported Party. 

Support Available 

47. UCL is committed to providing support for members of its community affected by bullying, harassment and sexual misconduct. Available support includes the Employee Assistance Scheme, Student Wellbeing Support Team, Dignity Advisors, Independent Sexual Violence Advisors and Safeguarding Leads. Full support information is outlined on the Report + Support pages and includes internal and external support providers, as well as help and advice regarding online bullying and harassment.

48. It is acknowledged that cases involving allegations of bullying, harassment and sexual misconduct may be distressing for members of staff who are involved in responding to complaints and any associated processes. HR Business Partners and local HR staff can provide advice on procedures and signpost managers and members of staff to sources of support such as the Employee Assistance Programme. 

Review of Policy

49. This policy is not contractual and may be varied from time- to- time following consultation with UCL’s recognised trade unions.

50. Equality data will be collected for the purposes of equality monitoring, and an annual equality assessment will be undertaken on the impact of this policy.

Related Procedures

Appendix 1- Example of Unacceptable Behaviours

 Examples of behaviour that may be considered unacceptable under this policy include (but are not limited to) the following:

  • Shouting at, being sarcastic towards, ridiculing or demeaning others
  • Repeatedly or deliberately ignoring people who are waiting to contribute to a meeting; continuously cutting people off whilst they are speaking; persistent aggressive questioning; wilfully being dismissive of someone and their suggestions.
  • Deliberately excluding someone from meetings, communications or a social activity without a good reason.
  • Abuse of power by blaming a team member when something has gone wrong, rather than taking personal responsibility.
  • Not giving due consideration and/or an explanation of a refusal to a reasonable request covered by UCL policy, such as flexible working, or requests for annual leave.
  • Deliberately creating an environment where a team member is side-lined or has their responsibilities limited or narrowed.
  • Overbearing and intimidating levels of supervision.
  • Inappropriate and/or derogatory remarks about someone’s performance.
  • Allocating staff unreasonable workloads with unreasonable deadlines that require an individual to work excessive hours for sustained periods, without adequate support and resource in place.
  • Physical or psychological threats.
  • “Grooming” behaviour, for example making someone feel special by buying them gifts, for example, and then gradually manipulating them to carry out duties outside of their normal remit, or which are in breach of UCL policy.
  • Continued suggestions for social activity after it has been made clear that such suggestions are unwelcome.
  • Any unwanted sexual advances, sexual comments or comments about someone’s body or appearance; innuendos; wolf whistling; groping; tugging or lifting someone’s clothing, or stalking.
  • Intentionally invading someone’s personal space; for example, by standing too close to them, blocking their path, or rubbing against them.
  • Touching someone without their consent, including kissing, grabbing, pinching, groping and stroking.
  • Sending or displaying material that is pornographic or that some people may reasonably find offensive (taking into account the specific circumstances of the case, including, where relevant, if materials are provided in an academic context) including emails, text messages, social media content, video clips and images sent by mobile phone or posted on the internet.
  • Making offensive jokes or derogatory or stereotypical remarks, or mocking, mimicking or belittling a person’s protected characteristic(s).
  • Outing or threatening to out someone as gay, lesbian, bisexual, non-binary or transgender.
  • Speculating or gossiping about someone's actual or perceived sexuality or gender identity.
  • Deliberately and persistently refusing to use someone's preferred gendered pronoun (e.g. using 'he' to refer to a trans woman) or continuing to use their former name ('dead naming').
  • Practices that are potentially discriminatory and have the effect of excluding certain people. Examples may include regularly holding a meeting at a time or on a day that a part-time worker cannot make or arranging an away day with a physical activity which a wheelchair-user cannot participate in.
  • Being discriminatory in recruitment practices or appointing staff in a non-transparent way.
  • Racist behaviour, which can include (but is not limited to) making racist jokes, name calling, making assumptions about someone based on their race or religion, racial harassment (for example, anti-Semitism or islamophobia) or racialised micro-aggressions.

HR Employment Policy Team

May 2025

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For queries on this policy visit MyServices

Policy Owner

HR Division: Employment Policy