Guidance

Sexual Harassment Prevention Policy

Published 27 October 2026

Policy Statement

Nuclear Waste Services is committed to providing an inclusive, supportive, and safe environment for everyone who works for NWS. This policy applies to all employees, agency workers, consultants, contractors, volunteers, and interns.  

The aim of the Policy is to prevent and respond to incidents that arise and take action to effect long-term change in our ways of working and to support the NWS Values in all our business activities. 

Whilst this policy does not form part of any contract of employment or contract to provide services, and may be amended at any time, all persons will be made aware of this policy and will be expected to comply with it. The policy will be communicated to all persons on a regular basis using a variety of methods including induction, specific training, information and publicity, team briefings, departmental meetings, and in-house communication channels.

NWS commits to:	We will achieve this by:
Educating all persons about sexual harassment and their role in developing a culture free from harassment	Providing appropriate educational interventions to foster a working environment that supports the dignity and respect of all and is free from any form of discrimination, bullying, harassment, and violence, including gender-based violence.
Where sexual harassment does occur, providing a procedure for dealing with it to ensure it is properly managed	A zero tolerance of any form of sexual harassment in the workplace and treating all incidents seriously and promptly by investigating all allegations of sexual harassment. There will be no time limitation around reporting an incident of sexual harassment under this policy or the NWS Grievance or Bullying & Harassment Policies.
Building continuous improvement into our culture	Capturing learning to help create an environment free from sexual harassment and monitoring our progress in achieving a workplace free from harassment by embedding our standards and expectations.

What is Sexual Harassment?

Sexual harassment is prohibited under the Equality Act 2010. It occurs when a person is subjected to unwanted conduct of a sexual nature which has the purpose or the effect of violating the person’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person.  

Sexual harassment that has one of these effects can be harassment even if the effect was not intended. A single one-off event or a series of incidents can amount to sexual harassment. A person can be affected by sexual harassment even if the conduct is not targeted at them. 

It is also unlawful to treat someone less favourably because they have either submitted a complaint of sexual harassment or have rejected such behaviour. To do so could be considered as victimisation. 

Anyone can be a victim of sexual harassment, regardless of their sex, sexual orientation, or gender identity, 

Under international law, sexual harassment constitutes a breach of a person’s human rights.  

Sexual harassment is often a manifestation of power relationships and frequently occurs within unequal relationships in the workplace, for example between a manager and a more junior colleague, or a longstanding employee and a new joiner. It frequently arises as the result of sexism and power inequalities between two parties. 

In cases where sexual harassment is found to have occurred, such abuses of power will be taken into account in deciding what disciplinary action is taken. 

NWS also recognises that certain vulnerable or minority groups may be more at risk from sexual harassment. Where a person has more than one protected characteristic, this may increase the risk of them experiencing sexual harassment. This is because multiple categories of identity such as gender, race, sexuality, trans status, religion, and disability can interact in ways that create complex systems of oppression and power which can result in harassment based on a combination of different aspects of a person’s identity. This is referred to as intersectional harassment.

What is Unwanted Conduct?

Unwanted conduct covers a wide range of behaviour which is unwanted or unwelcome. Types of behaviours which constitute sexual harassment include, but are not limited to:

• Physical conduct. Unwelcome physical contact including patting, pinching, stroking, kissing, hugging; fondling, or inappropriate touching; physical violence, including sexual assault and rape; the use of job-related threats or rewards to solicit sexual favours.

• Verbal conduct. Banter, mimicry, Comments on a worker’s appearance, age or private life; sexual comments, stories, jokes or pranks; sexual advances; repeated and unwanted social invitations for dates or physical intimacy; insults based on the sex of the worker; condescending or paternalistic remarks; sending/sharing sexually explicit messages/images (by any medium); coercion; gaslighting (a form of covert emotional abuse).

• Non-verbal conduct. Displays of sexually explicit or suggestive material or imagery; graffiti; acts affecting a person’s surroundings; posts or contact on social media; sexually suggestive gestures; facial expressions; whistling; leering; predatory behaviour, ghosting and deliberately ignoring an individual, and stalking.

The effect of such behaviour and whether it is unwanted should be considered from the point of view of the person who feels harassed (the “recipient”).  

There may be other sexual behaviour, which though not unwanted, is still inappropriate in the workplace( including in a place that may legally count as work such as at a work event or travelling to or from a place of work), a work- related social event, client or customer events, conferences, training courses, etc. 

NWS does not permit sexual contact in the workplace and any such behaviour may still be addressed as a breach of this policy. NWS recognise that if this behaviour were allowed to take place, there is a risk of one party believing that the conduct is welcome and the other considering the conduct to be unwanted, either at the time or in hindsight. This can increase the risk of sexual harassment.

Duty of Care

Legislation imposes a duty of care on NWS to provide a safe system of work for all staff. This includes a specific obligation to protect the health, safety and welfare of their staff and others who might be affected. The Equality Act 2010 and the Worker Protection Act set out the obligation on the employer to protect workers from sexual harassment in the workplace.

Action Against Sexual Harassment

NWS will treat sexual harassment as a disciplinary offence. 

Appropriate disciplinary action, including warnings, suspension, and/or dismissal with or without notice in accordance with the NWS Disciplinary Policy may be taken against any person who violates this policy.  

There may also be circumstances where further training is mandated for individuals, teams, business areas or the whole organisation.  

No one will be victimised for making a complaint of sexual harassment or for helping another person to make such a complaint. This means that anyone who makes such a complaint or who helps someone to make such a complaint, for example by giving evidence or information, will not be treated badly because of their actions.  

NWS provides a range of ways for an individual who wishes to make a complaint, both in name or anonymously.  In the first instance, the person making the complaint may wish to talk to their line manager or HR to try and resolve the problem informally.   They may also raise a grievance in line with the NWS Grievance Policy, or anonymously via Safecall,  if they feel that raising the issue informally may not resolve the issue, or it is too serious to raise informally. 

A complaint may be verbal or written and may come from either the person experiencing the sexual harassment or from someone who has witnessed it and will be managed and investigated in line with the NWS Grievance Procedure.

When does this policy apply?

This policy will apply to any unwanted conduct that occurs in the course of a person’s work and which takes place at their usual place of work, including in their home while working from home, on their commute, or while travelling to a place which is not their usual place of work if they are there for any reason related to their work, including for a work-related social event, business trip, training session or conference.

What is the alleged perpetrator is not a member of staff?

The sexual harassment of staff will not be tolerated, whether caused by those that work for NWS or third parties including customers, suppliers, clients, members of the public, or visitors, whether on third party, NWS, or NDA premises or in general public areas. 

Any instance of work-related sexual harassment should be reported to an appropriate line manager, supplier contact, member of the Executive or HR, in line with this policy, regardless of who the alleged perpetrator is.

Management Responsibilities

1. All those with line management responsibility must ensure that all employees are aware of this policy and understand their own, and the organisation’s responsibilities.  

2. Managers and supervisors have a particular duty to ensure that, within their area of responsibility, everyone is treated with dignity and respect and to discharge this duty; they must always challenge any unacceptable or questionable behaviour that they become aware of even if they are not directly affected.  They should also be aware of behaviour and language that can cause offence including jokes and banter, and if necessary, remind employees of the expected standards.  

3. Managers must respond to complaints of sexual harassment promptly, sensitively, and objectively, seeking advice and guidance from HR.  

4. Where the complaint relates to third party perpetrators (such as service providers, visitors, or contractors) managers are responsible for agreeing actions which may include withdrawing service, terminating a contract, or banning an individual from the premises if the behaviour is not moderated.  

5. In terms of their own behaviour, managers and supervisors are expected to be exemplars to others. Any inappropriate behaviour, inappropriate response to such behaviour, or abuse of a manager’s positional power will serve to condone harassment and will be considered a serious breach of this policy and will be managed under the Disciplinary Policy.  

6. A line manager’s failure to actively implement this policy within their area of responsibility, or to fail to deal with sexual harassment when they become aware of it, could constitute a breach of this policy and their employment contract, and disciplinary action may be taken.

Employee Responsibilities

1. All staff have a responsibility to contribute to a respectful and productive working environment. This includes supporting and caring for their colleagues, customers, and services providers. All staff have a duty to assist in the creation of a safe working environment, where sexual harassment is not tolerated.  

2. Individual members of staff must ensure they understand what sexual harassment is and be aware of how their behaviour may affect others. 

3. Employees should challenge unacceptable behaviour wherever possible as long as it is safe to do so. Forms of intervention may include calling out behaviour that is unacceptable when it happens and addressing the person who is behaving inappropriately; taking steps to defuse the situation/redirect those involved; checking in with the recipient of the behaviour after it has taken place, assuring them that what occurred was not acceptable; reporting incidents of sexual harassment when witnessed and/or support recipients of sexual harassment in reporting it and co-operate in investigations into alleged sexual harassment.

HR Responsibilities

1. NWS recognise that it can be difficult for individuals to discuss or report sexual harassment, for example, if the individual’s manager is the perpetrator or is aware of the harassment but has not taken action to stop it, the worker is reluctant or too embarrassed to raise the matter with their line manager, or feels that their manager may lack the skills, knowledge or sensitivity to deal with complaints of sexual harassment.  

2. HR will provide empathetic assistance and support to staff with complaints of sexual harassment.  The role of HR is to explain the procedure for making a complaint and the potential outcomes; establish the main details of any complaint and help the worker to decide what they want to do.  

3. HR will also signpost Safecall and additional support for employee’s health and wellbeing.  

4. An employee who makes any disclosure to HR about sexual harassment is under no obligation to take further action. Employees who have been sexually harassed are not obliged to refer their complaints to HR and any such disclosure is made voluntarily.  

5. We will work with the disclosing employee to investigate a complaint with their agreement.  However, there may be circumstances, such as a serious health and safety risk, where without agreement it is still appropriate for NWS to investigate; in such circumstances the complaint will be handled on a confidential and need to know basis.