1. Purpose

At Coinford Ltd, we are committed to providing a workplace where everyone feels safe, respected, and valued.

We believe in leading by example — our leaders, managers, and employees are all expected to uphold a culture of dignity, inclusion, and professionalism.

We are committed to a workplace that is free from racism, discrimination, harassment, and bullying of any kind. Everyone at Coinford has a role in maintaining this standard. This policy aims to:

• Define what constitutes harassment and bullying, including sexual and racial harassment.

• Clarify that any form of unwanted behaviour—not just that related to protected characteristics—is unacceptable.

• Outline employees’ rights, responsibilities, and reporting routes.

• Guarantee that those who raise concerns will be protected and never retaliated against.

2. Scope

This policy applies to:

• All employees, agency workers, contractors, clients, and third parties working with Coinford.

• All work-related settings — including sites, offices, client premises, events, and online platforms.

• Conduct during travel, training, or social functions.

• Behaviour outside of work may be addressed under this policy only where it has a demonstrable impact on working relationships, breaches company standards, or could reasonably be expected to bring Coinford into disrepute.

• This includes remote working environments such as home working, video calls, messaging platforms, and any digital communication used for work purposes.

3. Definitions

Harassment

Harassment is any unwanted behaviour—verbal, physical, written, or digital—that has the purpose or effect of:

• Violating someone’s dignity, or

• Creating an intimidating, hostile, degrading, humiliating, or offensive environment.

Under the Equality Act 2010, harassment has a specific legal definition applying to unwanted behaviour related to a protected characteristic or of a sexual nature.

Coinford’s standards extend further: any unwanted or inappropriate behaviour, even if not linked to a protected characteristic, may be treated as misconduct under this policy.

Racial Harassment

Racial harassment includes any unwanted behaviour related to a person’s race, colour, nationality, ethnic or national origin. Examples include:

• Racist remarks, jokes, slurs, or stereotyping

• Offensive comments, gestures, or symbols

• Exclusion or isolation due to race or ethnicity

• Mocking accents or cultural differences

Coinford has a zero-tolerance approach to racism in any form, whether overt or subtle.

Bullying

While bullying is not defined in UK law, Coinford adopts the definition used by ACAS and industry best practice. Bullying is repeated, unreasonable, or offensive behaviour that:

• Intimidates, undermines, or humiliates someone,

• Damages confidence or wellbeing, or

• Interferes with work performance.

Sexual Harassment

Sexual harassment is any unwanted behaviour of a sexual nature, including but not limited to:

• Unwelcome advances, comments, or jokes

• Sharing sexual images or content without consent

• Inappropriate touching or gestures

• Requests for sexual favours or behaviour implying rewards or consequences

Examples of Unacceptable Behaviour

• Racist or discriminatory remarks, jokes, or stereotyping

• Spreading rumours or malicious gossip

• Excluding individuals from work activities

• Verbal abuse, insults, or threats

• Offensive or intimidating gestures

• Inappropriate or persistent messages online

• Micromanagement, over-criticism, or humiliation in front of others

4. Responsibilities

All Employees

• Treat everyone with respect, dignity, and fairness.
• Discriminatory behaviour, including racism, will not be tolerated.
• Take responsibility for personal conduct and challenge or report unacceptable behaviour.
• Support colleagues who raise concerns.

Managers and Supervisors

• Lead by example and set high behavioural standards.

• Act immediately when witnessing or informed of inappropriate behaviour.

• Treat all complaints seriously, confidentially, and fairly.

• Managers must document any actions taken in response to concerns or incidents to ensure transparency and accountability.

• Support and protect those who raise concerns.

HR Department

• Provide guidance, training, and impartial investigations.
• Ensure consistent handling of cases and compliance with legislation.
• Monitor and review incidents to identify patterns and areas for improvement.

Bystander Intervention

Coinford encourages employees to speak up if they witness harassment, bullying or discrimination. You are not expected to put yourself at risk, but there are safe ways to intervene:

• Direct: Calmly challenge the behaviour if it feels safe.

• Delegate: Report concerns to a manager or HR.

• Delay: Check in with the person affected afterwards.

• Document: Make a brief note of what you witnessed if needed.

Employees should not ignore inappropriate behaviour. Managers must take all reports seriously and ensure anyone who raises a concern is supported and not treated unfavourably.

5. Reporting Concerns

Anyone who experiences or witnesses harassment or bullying should:

1. Raise the issue informally, if appropriate, with the person involved, their line manager, or HR.
2. Submit a formal complaint under the Grievance Procedure if informal steps are not suitable or effective.
3. Report directly to HR or use Whistleblowing channels if the issue involves a senior manager or serious misconduct.

All concerns will be acknowledged within 2 working days. Anonymous reports will be reviewed, although the ability to investigate may be limited.

If You’re Unsure

If you are uncertain whether behaviour amounts to harassment or bullying, speak confidentially with your line manager or HR. 

Support

• You may be accompanied by a colleague or union representative at any formal meeting.
• HR can provide confidential advice and wellbeing support.

6. Investigation Process

• All reports will be handled promptly, fairly, and confidentially.

• Investigations will follow the Grievance or Disciplinary procedure, as appropriate.

• The process may include interviews, evidence review, and witness statements.

• Coinford aims to conclude investigations within 14 working days, updating all parties if delays occur.

• Informal resolution may only be used when both parties agree and the behaviour is minor or unintended.

• Investigations will be conducted by an impartial manager or HR representative who has not been involved in the incident.

• Both the complainant and the respondent may be accompanied by a colleague or trade union representative at any formal meeting.

7. Confidentiality

All information will be handled in strict confidence and only shared with those directly involved. Any breach of confidentiality may result in disciplinary action. Confidentiality cannot be guaranteed in circumstances where there is a safeguarding concern, risk of harm, or legal obligation to disclose information.

8. Protection from Retaliation

Coinford will not tolerate any form of retaliation or victimisation against anyone who:

• Raises a concern in good faith,

• Participates in an investigation, or

• Supports another person in making a complaint.

• A concern is raised in good faith when the individual believes the information is true, even if it is later found to be mistaken.

Any employee found to have retaliated will face disciplinary action, up to and including dismissal. We will take all reasonable steps to protect and support individuals who come forward.

9. Outcomes and Disciplinary Action

Where harassment, bullying, or discrimination (including racism) is substantiated:

• Appropriate action will be taken under the Disciplinary Policy, which may include training, counselling, formal warnings, or dismissal.

• Complaints made in good faith will never result in disciplinary action.

• Malicious or knowingly false allegations may lead to disciplinary proceedings.

• Outcomes will be proportionate to the nature, severity, and frequency of the behaviour, the evidence available, and any mitigating circumstances.

10. Monitoring and Review

• HR will monitor incidents and outcomes to identify trends and areas for improvement.

• Training and awareness initiatives will be reviewed regularly.

• This policy will be reviewed annually or following changes in legislation or company practice.

11. Related Policies

• Equality, Diversity & Inclusion Policy

• Grievance Policy

• Disciplinary Policy

• Behaviour at Work Policy

• Sexual Harassment Policy

• Whistleblowing Policy