2026 Sexual Harassment Policy
By law, all employers will need to take steps to prevent sexual harassment. There are many high profile cases which demonstrate that behaviour in the workplace falls well below an acceptable standard.
What is sexual harassment?
Sexual harassment is unwanted behaviour of a sexual nature. The law (Equality Act 2010) protects the following people against sexual harassment at work:
● employees and workers
● contractors and self-employed people hired to personally do the work
● job applicants
To be sexual harassment, the unwanted behaviour must have either:
● violated someone’s dignity
● created an intimidating, hostile, degrading, humiliating or offensive environment for someone
It can be sexual harassment if the behaviour:
● has one of these effects even if it was not intended
● intended to have one of these effects even if it did not have that effect
Who is responsible?
Carrington will take steps to prevent sexual harassment happening in the first place.
Anyone who sexually harasses someone at work is responsible for their own actions.
Carrington has a responsibility – a ‘duty of care’ – to look after the wellbeing of our employees. All complaints of sexual harassment will be taken seriously. We will handle any investigation in a way that’s fair and sensitive to:
● the person who made the complaint
● someone who witnessed it
● someone who’s been accused of sexual harassment
From 6 April 2026, sexual harassment will become a ‘qualifying disclosure’ under whistleblowing law. This means whistleblowers making a sexual harassment disclosure will be protected from detriment and unfair dismissal.
Who can experience sexual harassment?
Sexual harassment can happen to men, women and people of any gender identity or sexual orientation. It can be carried out by anyone of the same sex, a different sex or anyone of any gender identity.
You could experience sexual harassment from anyone you come into contact with because of your job, including:
● someone you work with
● a manager, supervisor or someone else in a position of authority
● someone high profile or influential
You can also experience sexual harassment from a customer, client or member of the public.
Examples of sexual harassment:
Sexual harassment can be a one-off incident or an ongoing pattern of behaviour.
It can happen in person or in other ways, for example online through things like email, social media or messaging tools.
Examples include:
● making sexual remarks about someone’s body, clothing or appearance
● asking questions about someone’s sex life
● telling sexually offensive jokes
● making sexual comments or jokes about someone’s sexual orientation or gender reassignment
● displaying or sharing pornographic or sexual images, or other sexual content
● touching someone against their will, for example hugging them
● sexual assault or rape
What some people might consider as joking, ‘banter’ or part of their workplace culture can still be sexual harassment.
Sexual harassment is usually directed at an individual, but it’s not always the case. Sometimes there can be a culture of behaviour that’s not specifically aimed at one person – such as sharing sexual images. Someone could still make a complaint of sexual harassment in this situation.
The law on harassment
The Equality Act 2010 protects people against sexual harassment and harassment related to ‘protected characteristics’, for example a person’s sex.
The law on sexual harassment is changing on 26 October 2024. By law, all employers will need to take steps to prevent sexual harassment. The new law is the Worker Protection (Amendment of Equality Act 2010) Act 2023.
Sexual harassment is different to harassment related to a person’s protected characteristic, for example sex, sexual orientation or gender reassignment. Someone could experience both types of harassment at the same time, or separately.
What to do if you experience sexual harassment
If you’ve experienced sexual harassment at work, you can make a complaint to us.
We will:
● take your complaint seriously
● handle it fairly and sensitively
Make a note of what’s happened
It’s a good idea to make a note of what’s happened. This should include dates, times and names, including any witnesses. Making a note can be especially helpful if you find talking about the experience particularly distressing.
If you recorded what happened
You should be aware of the risks of recording, or secretly recording, what’s happened – for example on your phone. This is a complicated area of the law.
A recording might not be allowed as evidence if, for example:
● your secret recording breaks data protection laws
- If your complaint leads to an employment tribunal, they might allow a recording as evidence in some circumstances, depending on your reasons for making it. A possible example might be that you made it to protect your legal rights. But the tribunal would decide on a case-by-case basis.
Getting advice on your options
You might want to talk to someone to get advice and support before deciding whether to make a sexual harassment complaint. This could be:
● someone you trust at work, for example someone you work with or a manager
● someone at work who’s been trained to advise people who are considering making this kind of complaint
specialist advice:
● Rights of Women – England and Wales
● Scottish Women’s Rights Centre
Making a complaint
If you want to try and resolve the problem informally, you can talk with Nicky Owen or John Mumford.
You can raise a grievance if either:
● talking with senior staff does not resolve the issue
● you feel the problem is too serious to deal with informally
As noted earlier, a strengthening of the current legal position is introduced from 06 April 2026, sexual harassment will become a ‘qualifying disclosure’ under whistleblowing law, this means that:
● Workers who raise concerns that sexual harassment has occurred, is occurring, or is likely to occur are likely to have made a protected disclosure for the purposes of whistleblowing law (subject to the other requirements of a protected disclosure having been met)
● Where an employee has made a protected disclosure, they are protected from detriment (adverse treatment) and unfair dismissal on the basis that they have made such a disclosure. Crucially, the protection applies regardless of when the incident took place, covering past, present or anticipated harassment
● If an employee was to be dismissed, or subject to a detriment on the grounds that they had raised a complaint of sexual harassment, they would be entitled to bring a claim before the employment tribunal
Making a complaint
We have a complaint policy that we ask you to follow, it is in the staff handbook should you need to refer to it for guidance or alternatively do ask for support in making a complaint.
If you want to make a complaint a long time after an incident took place, we will still take it seriously and it will warrant a full investigation.
When it’s a crime
If you’ve been sexually assaulted or raped at work, there are specialist helplines you can call for support and advice. They can help talk through your options.
If you choose to tell us, we will talk to you about whether you want to report it to the police, and should support you if you choose to report it.
We will not put any pressure on you to make any particular decision. If you do not want to tell the police, you do not have to.
In most cases, we will go along with your decision. However, we might feel they need to tell the police in some circumstances. For example if there’s an ongoing risk to your safety or the safety of others.
If we were going to report it to the police, we would talk with you about it before telling them, and let you know when they’ve told them.
If it’s been reported to the police or it’s going through a court
We do not have to wait for the criminal process to finish before we can:
● investigate your complaint
● carry out a disciplinary procedure
But before doing either of these things, we would check with the police and consider getting legal advice. This is to make sure there is no risk of us prejudicing the criminal process.
If the problem is not resolved
You can consider making a claim to an employment tribunal.
There are strict time limits for making a claim to an employment tribunal. In most cases, you have 3 months minus 1 day from the date of the incident.
If you take more than 3 months, your complaint may still be considered at an employment tribunal if the tribunal decides that both these things apply:
● there’s a good reason for you taking more than 3 months
● it’s fair to the employer to allow your case to go ahead
Monitoring and evaluation
We will evaluate the effectiveness of the steps you have taken by:
● reviewing informal and formal complaints data to see if there are any trends or particular issues and appropriate actions
● hold lessons-learned sessions after any complaints of sexual harassment are resolved
We also review policies, procedures and training regularly.
Find out more about:
It’s a good idea to get legal advice if either:
● your complaint involves sexual assault or rape
● you feel your employer is not dealing with your complaint because the person you’ve complained about is powerful or influential
● it’s 3 months or more since the incident and you’re considering making a claim to an employment tribunal
It’s against the law for you to be:
● victimised because you’ve made a sexual harassment complaint
● treated less favourably at work because you’ve been sexually harassed or you’ve rejected someone trying to sexually harass you
Other guidance:
EHRC provides detailed guidance
ACAS provide a broad range of workplace support
Citizen Advice is a useful port of call
| Name of reviewer | date |
| Nicola Owen | 03 2026 |