Discrimination & Harassment Procedure
Intent, Scope & Context
Animal Think Tank (ATT) is committed to providing a safe working environment. This means we believe in providing and maintaining a work environment that is free from all forms of inappropriate conduct, including discrimination, bullying, intimidation, non-sexual harassment, sexual and gender-related harassment, other inappropriate conduct, and retaliation (summarised as “discrimination and harassment” throughout this procedure). This procedure contributes to ATT’s aim to be truly representative of all sections of society. In addition to complying with all non-discrimination laws in the UK, the goal of this procedure is to help create a culture where every individual is treated with fairness and respect and is able to give their best.
This procedure applies to all ATT members, contractors and contributors, specifically all those who perform work for ATT on an ongoing basis. All those who perform ongoing work for ATT are expected to abide by this procedure in relation to each other and to all those with whom they may interact for work purposes.
All allegations of discrimination or harassment will be taken seriously, and there will be no retaliation for making such allegations. Complaints will be kept as confidential as reasonably possible and records will be kept in a confidential file. If anyone covered by this procedure is found to have harassed or discriminated against another, they may face disciplinary action up to and including being asked to leave ATT.
ATT recognises that harassment, particularly sexual harassment, can be a manifestation of power relationships. And while it most often occurs by an individual who holds power over another individual, it can occur between any two or more people regardless of their sex or gender identity and whether or not they are in a position of power. No policy can prescribe what should be done on every occasion because circumstances vary. If anyone needs help or advice about a particular situation or circumstance, they are encouraged to contact People Operations or a Designated Person (as defined and specified below).
The Sharing Rooms policy is particularly relevant to this policy.
Key Definitions
Discrimination is the differential treatment on the basis of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex and sexual orientation, genetic information or any other factor that is legislatively protected in the UK referred to as “protected characteristics”.
Discrimination is illegal in work-related decisions including hiring, firing, pay, job assignments, promotions, layoff, training, fringe benefits, and any other term or condition of employment.
The workplace is any place (physical or virtual) where work-related activities are conducted, including, but not limited to, the physical work premises, work-related conferences or training sessions, work-related travel, work-related social functions, such as dinners with donors, and work-related electronic communication, such as email, chat, text, phone calls, and virtual meetings.
A Complainant is the person who allegedly experienced discrimination or harassment.
A Respondent is the person who allegedly committed the discrimination or harassment.
A Designated Person is a member of ATT or trusted external individual who ATT determines is qualified to receive and investigate discrimination and harassment complaints. Designated Persons at ATT have been trained and also have access to expert support as needed. Designated Persons in ATT sit within People Operations.
Harassment is unwelcome conduct including physical, verbal, and nonverbal behaviours, and results in a hostile environment. Harassment is illegal when unwelcome conduct is related to any of the protected characteristics, when enduring the conduct becomes a condition of continued employment, or the conduct is so severe or pervasive that a reasonable person would consider the working environment intimidating, hostile, or abusive.
Sexual harassment is unwanted conduct that is sexual in nature.
Examples of harassment and sexual harassment are listed below:
Examples of harassment include, but are not limited to:
verbal aggression or yelling
spreading malicious rumours
humiliation in front of coworkers, such as subjecting someone to practical jokes or ridicule
repeated unwelcome remarks or jokes, including bullying
exercising, attempting to exercise, or threatening to exercise physical force against an employee or staff member in the workplace that causes or could cause physical injury to the employee or staff member
work interference or sabotage that prevents work from getting done
slurs or negative stereotyping of any group, including but not limited to those groups with protected characteristics
comments related to an ATT member’s, contractor’s or contributor's ethnic, racial, or religious affiliation, or their sexual orientation, sex, gender identity, or age, that are publicly humiliating, offensive, threatening, or that undermine their role in a professional environment.
Sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence.
Formal Procedure
Step 1: Self-Help
An individual may attempt to resolve their concerns with the person(s) engaging in unwelcome conduct by direct communication or through a supported conversation (see Steps 1-4 of the Informal Conflict Transformation Procedure). If the Complainant feels comfortable doing so, they should communicate disapproval in clear terms to the person(s) whose conduct or comments are/have been offensive.
We encourage people to make use of ATT’s Informal Conflict Transformation Procedure to take ownership of the issue and express feelings, needs and requests in a productive way.
The Complainant should keep a written record of the date, time, details of the conduct, and witnesses, if any.
Step 2: Designated Person Support and Intervention
For Complainants who are not comfortable with self-help and believe they are victims of discrimination or harassment, or become aware of situations where such conduct may be occurring, they are encouraged to seek advice from and/or inform People Operations. People Ops will arrange for an appropriate Designated Person to assist the Complainant directly in carrying out the following activities:
Ensure that the Complainant is safe
Record the dates, times, and facts of the incident(s)
Collect any recorded evidence supporting the Complaint
Explore available options for resolution
Ensure that the complainant understands the procedure for resolving the complaint
Discuss the next steps with the understanding that resolving the matter in this manner will not prevent the complainant from pursuing a formal complaint if they are not satisfied with the outcome
Work with the Complainant throughout the resolution process
Keep a confidential record of all discussions
Ensure that the above is completed as promptly as possible.
Any Respondent(s), regardless of their position within ATT, will be excluded from administering and managing the investigation and resolution process (save and except for their involvement as a Respondent).
Step 3: Formal Complaint
If the Complainant wants to make a formal complaint, or if previous attempts to resolve the matter don’t lead to a satisfactory outcome, they should inform People Operations. Their steward can support them to do this. At that time, a formal investigation will take place. This investigation will be conducted by a Designated Person or by a qualified external party (such as a Discrimination and Harassment specialist, a human resources professional, or a lawyer).
In the case that a Designated Person has a conflict of interest due to their relationship with the Complainant or Respondent, or for another reason, they will turn the investigation over to the other Designated Person or a third party.
The Designated Person overseeing the investigation will then work with the Complainant to gather as many details as possible, including the date, time, descriptions of the incident(s), and witnesses, if any. The investigation process will involve interviews with the Complainant, the Respondent, any witnesses named by either, and the review of any other materials as may be appropriate.
The Designated Person will then - in consultation with either the other Designated Person(s), People Operations or the broadest circle, or an external advisor - determine the best way to resolve the matter and implement next steps as necessary, including referral to formal disciplinary action. This consultation step is intended to provide a form of checks and balances during the decision-making process as a resolution is sought.
During the course of an investigation, ATT may implement interim measures as necessary with the express purpose of protecting all parties. Measures may include temporarily reassigning or placing the Complainant or Respondent on leave until the outcome of the investigation is determined.
Procedural Considerations
Confidentiality & Record-keeping
Discrimination and harassment complaints will be kept as confidential as reasonably possible. Some information may need to be shared with certain trusted parties during the course of an inquiry or investigation, particularly during the consultation phase with a Designated Person and/or People Operations and/or the broadest circle.
Records will be kept for reference as needed if potential legal matters are pursued by the individuals involved or the organisation. Records will be kept in a confidential file under the purview of the Designated People and People Operations (unless there is a conflict of interest with one of those parties in which case the file will be kept private for that particular claim). Records will not be filed under individual personnel records but rather in a file totalling all complaints as a method of identifying patterns of behaviour by alleged offenders.
Disciplinary Action
Disciplinary action will follow the formal procedure set out in ATT’s Disciplinary Procedure. Disciplinary action for violations of this policy will take into consideration the nature and impact of the violations, and may include a mandatory training programme, a suspension, or termination of employment for cause as determined by ATT. Similarly, deliberate false accusations are of an equally serious nature and will also result in disciplinary action up to and including termination of employment. Note, however, that an unproven allegation does not mean that the conduct did not occur or that there was a deliberate false allegation. It may simply mean that there was insufficient evidence to proceed.
Complaints Involving External Parties
If the Respondent is not subject to this policy, but rather an ATT client or another external party, ATT will address the situation with the same gravity as internal matters and proceed in the manner most reasonable and appropriate under the circumstances. Anyone who believes that they have been discriminated against or harassed by an external party is encouraged to inform a Designated Person.
Timeframe to Submit a Complaint
There is no time restriction on when to file a complaint about a discrimination or harassment incident, however early reporting and intervention are strongly encouraged so that ATT can take appropriate action to prevent further harassment.
Conclusion
ATT endeavours to grow and learn, providing room for improvement in writing and implementing this policy, in the hope that those associated with ATT will contribute to a fair and respectful culture in the Animal Freedom movement.
Responsibility and Communication
ATT will provide this procedure to all members, contractors and contributors, specifically those who perform work for ATT on an ongoing basis.
It is the responsibility of the People Operations to ensure that all members, contractors and contributors are aware of this procedure.
Members and relevant contributors will be provided with training about harassment and discrimination in the workplace.
Designated Persons will report the number of incidents, their resolutions, and any recommendations to the People Operations Circle.
The People Operations Circle will report this information to the broadest circle.
Everyone who works for ATT is responsible for contributing to a positive work environment and maintaining a respectful workplace. As such, any ATT member, contractor or contributor who becomes aware of discrimination or harassment in the workplace—even if they are not directly involved—are expected to report it to People Operations. It is then the responsibility of People Operations to address the situation and assist as necessary in finding a route to resolution.
Additional Resources
For more information on the UK Equality Act see Equality Act 2010: What do I need to know? A summary guide to your rights.
*This policy has been adapted from the Non-Discrimination and Anti-Harassment Policy from Vegan Outreach and Faunalytics.
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