Guidance

Bullying & Harassment Policy

Published 27 October 2026

Policy Statement

Nuclear Waste Services (NWS) is committed to creating an inclusive and safe working environment where people are protected from bullying and harassment, which is critical to the delivery to the NWS vision and values. 

NWS has a zero tolerance of bullying and harassment of any kind as defined in this policy, both in the workplace or outside of the workplace in a work-related context and provides an enhanced grievance process for complaints relating to bullying and harassment.

NWS commits to:	We will achieve this by:
Acting with integrity	Everyone working for NWS will take responsibility for their own behaviour, ensuring that they treat others with respect and dignity.
Bullying and harassment has no place in NWS.	Sustaining a culture where everyone feels able to call out or report behaviours they feel is unacceptable to them and to be confident that their concerns will be taken seriously. Ensuring that if employees complain they are being bullied or harassed, then they have a grievance which must be dealt with regardless of whether their complaint accords with a standard definition of bullying and harassment.
Ensuring conduct aligns to the NWS Values and the NDA Code of Conduct	Taking into account the NWS Values and NDA Code of Conduct and where relevant, raise awareness of relevant legal protections such as “harassment” related to a “protected characteristic” and “victimisation”.

This policy applies to anyone who works for NWS, whether directly employed by the organisation or not.  It also applies to anyone who is in contact with people working NWS in the course of their work including customers, external stakeholders, and visitors. 

It applies to bullying or harassment that occurs both in the workplace and outside of the  workplace such as on business trips, client or supplier events, or work-related social events.  This also includes the inappropriate use of all social media even when this originates outside of work. 

This policy does not form part of any contract, including any contract of employment and NWS may amend it at any time.

Definitions

NWS recognise that part of working life includes constructive feedback and appropriate performance management discussions which can sometimes result in differences of opinion, conflicts and tension between individuals, but NWS has a zero-tolerance approach to bullying and harassment of any kind and defines bullying as: 

Any unwanted behaviour that makes someone feel intimidated, degraded, humiliated, or offended. It is unwelcome, unwarranted behaviour that causes a detrimental effect on an individual or group through means that undermines, humiliates, excludes and/or denigrates the recipient. 

It is not necessarily always obvious or apparent to others and may happen in the workplace without an employer’s awareness. Bullying and harassment can be between two individuals, or it may involve groups of people.  It may take place over a period of time, but can also occur as a single, offensive act. 

It is important to understand that unlawful behaviour may, in some circumstances, give rise to the possibility of personal liability for those found to have acted unlawfully. There may also be circumstances in which behaviour constitutes a potential criminal offence and in such cases the NWS may consider referring concerns to the Police.

The Equality Act defines harassment as:  

Unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or of creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual.

Examples of bullying include but are not limited to: 

• behaviour causing humiliation or offence whether this is the intention or not and whether this takes place in private or in front of others 

• humiliating someone by making comments about their social background, personal appearance, or heritage  

• undermining a worker with persistent criticism  

• overbearing supervision or otherwise misuse of power or position 

• gossip or making defamatory comments 

• shouting 

• isolation / exclusion (physical or social)  

• name calling or insults 

• intimidatory or oppressive behaviour 

• excessive, unjustified monitoring of work  

• unfairly removing duties or responsibilities or withholding information or resources  

• delivering performance feedback in an inappropriate manner, time and/or place 

• intentionally blocking progression or preventing training and development opportunities

Examples of harassment include but are not limited to:

• jokes, or ‘banter’ and comments, based on race, age, disability, sexual orientation, gender, religious belief or similar belief, marital status, or trans status regardless of the intent of the person making the jokes or taking part in the ‘banter’ 

• displaying or sending inappropriate or offensive pictures, posters, or written material 

• displaying or sending offensive images or messages online 

• the impact of jokes and comments as witnessed by others

Sexual Harassment

The Equality Act also defines sexual harassment as:

Unwanted conduct or a sexual nature which has the purpose or effect of violating a person’s dignity or of creating an intimidating, hostile, degrading, humiliating or offensive environment for a person.

This includes subjecting someone to unwanted conduct of a  sexual nature, when related to sex or gender reassignment, if that unwanted conduct has the purpose or effect of violating the employee’s dignity and/or creating an intimidating, hostile, degrading, humiliating or offensive environment for the employee, and the employee is treated less favourably because they submitted to, or rejected, the unwanted conduct. 

Examples of sexual harassment include but are not limited to: 

• sexual comments or jokes 

• unwanted advances or propositions  

• intrusive questions about a person’s private or sex life or a person discussing their own sex life 

• unwanted touching, hugging, massaging, or kissing 

• coercion for sexual favours 

• the impact of jokes and comments as witnessed by others

Victimisation

No one who works for NWS who makes a complaint under this policy should experience victimisation for having made the complaint, regardless of whether the complaint is upheld. Similarly, a person who has supported another in making a complaint, or themselves been impacted by witnessing any form of bullying and harassment,  should experience any form of victimisation. 

Victimisation is unlawful and examples include but are not limited to:

• exclusion or isolation at work 

• unreasonable allocation of work 

• marking down a performance assessment

• oppressive management or micromanagement 

• intentionally blocking progression or preventing training and development opportunities

Third Party Harassment

When the source of inappropriate behaviour in the workplace is a person who is not employed by NWS or the NDA, this is called “third party harassment”. This can still result in an unacceptable work environment and legal liabilities for NWS and the NDA. In the same way that harassment by anyone employed by NWS will not be tolerated, NWS will apply the same standards to anyone you come in to contact with at work from outside the organisation.  

Employees and colleagues are encouraged to report third party harassment to their line manager or the contract/project manager responsible for the third party.

Investigations into Allegations of Bullying and Harassment

• The purpose of any investigation is to establish a fair and balanced view of the facts relating to an allegation of bullying and harassment. Any investigation will be given priority and completed without unreasonable delay. 

• NWS reserve the right to appoint a suitably qualified and external investigator to ensure that investigations are impartial and objective and carried out with discretion, sensitivity, and respect, both for the employee and others who are involved, including any witnesses to the bullying and harassment. 

• It is the intention of NWS to share information gathered during an investigation with the employee to whom the bullying and harassment grievance applies, but in certain circumstances, NWS and/or NDA may wish to protect individuals or confidential business interests and therefore NWS and NDA reserve the right to withhold certain information.  In such circumstances, the employee will be advised as to why the information is withheld. 

• In most cases, informal resolution will be encouraged before enacting a formal process, however where informal action fails to deliver the required outcome, or where behaviour warrants consideration of formal action, a formal disciplinary process will be implemented.

Roles and Responsibilities

It is imperative that everyone sets the tone for NWS and the wider NDA Group and acts as a role model by their own behaviour and ensuring a supportive working environment.  To always treat others with dignity and respect and to support and promote a culture and environment that is respectful and free of any negative behaviours. 

Both the line manager and the employee have a specific role in the application of the Bullying and Harassment Policy, supported by the HR Team.  It is important that everyone fully understands their role and responsibilities to aid transparency, consistency, and effective communication.

Leaders and Managers

• It is imperative that the senior leadership team and managers set the tone for NWS and the wider NDA Group. 

• Demonstrate the NWS Values and to be aware of their own behaviours on individuals in the workplace environment generally. 

• Read the policy and the NDA Code of Conduct and be aware of what constitutes bullying and harassment, and victimisation. 

• Be prepared to challenge and tackle incidents or reports of bullying and harassment in accordance with this policy and alert to resolving potential issues. 

• Be supportive of anyone bringing a claim of bullying and harassment or who is the subject of allegations, and to treat them with sensitivity and being aware of the impact on them. 

• Report incidents to HR and to also seek support and guidance from HR. 

• Complete any relevant training to meet management responsibility to uphold this policy.

Employees and Colleagues

• All individuals should be committed to high standards in delivering work and dealing with colleagues, this will not only be about the tasks people do but the effect of their words, how they interact/engage with others and tackling bullying and harassment. 

• Read the policy and the NDA Code of Conduct and be aware of what constitutes bullying and harassment, and victimisation. 

• Report their concerns about any acceptable behaviour, whether direct or witnessed to their line manager in the first instance, or HR or Trade Union Representative. 

• Be aware of the support available if needed, from Trade Union Representatives, Employee Assistance Programme, or the HR Team.

Human Resources Team

• The HR Team provide a supportive and guiding role for line managers and employees in the application of the Bullying and Harassment Policy and the procedures and processes that underpin the key principles/commitments. 

• To ensure that line managers and employee(s) are provided with legally compliant, meaningful advice, and guidance in relation to both informal and formal stages of bullying and harassment matters.

• To facilitate discussions between the line manager and employee during the formal stages of bullying and harassment matters and to ensure fair and consistent application of the policy including challenging behaviours that do not meet the NWS Values during the formal stages of a bullying and harassment grievance process. 

• To administer all documentation relating to the formal grievance process. 

• To co-ordinate the process including identifying chairs and arranging meetings and investigations.