Third-Party Sexual Harassment Policy: Brandwin Digital Limited
- Policy Statement
Brandwin Digital is committed to providing a work environment that is free from harassment and where every individual is treated with dignity and respect. We have a zero-tolerance approach to sexual harassment. This policy specifically addresses harassment committed by “third parties”—individuals who are not employees of Brandwin Digital but who interact with our staff. This includes, but is not limited to, clients, vendors, contractors, and visitors.
- Definition of Sexual Harassment
Under the Equality Act 2010, sexual harassment is defined as unwanted conduct of a sexual nature which has the purpose or effect of:
- Violating an individual’s dignity; or
- Creating an intimidating, hostile, degrading, humiliating, or offensive environment for them.
Examples of third-party sexual harassment include:
- Unwelcome sexual advances, propositions, or pressure for sexual favours.
- Inappropriate touching, hugging, or brushing against a staff member.
- Sexually suggestive comments, jokes, or “banter” (including via email, Slack, or video calls).
- Displaying or sending offensive or pornographic material.
- Comments about a staff member’s appearance or body.
- Harassment facilitated by AI or digital tools (e.g., generating deepfakes or using AI-assisted messaging to send sexually explicit content).
- Scope
This policy applies to all Brandwin Digital employees, freelancers, and interns. It covers harassment occurring:
- In the office or during remote work.
- During client meetings, site visits, or industry events.
- Through any digital communication channel (Email, LinkedIn, WhatsApp, etc.).
- Our Commitment to Prevention
We take “reasonable steps” to prevent third-party harassment by:
- Clear Communication: Notifying all clients and partners that we operate a zero-tolerance policy toward harassment.
- Risk Assessment: Regularly identifying situations where staff may be at higher risk (e.g., solo meetings with new clients) and implementing safeguards.
- Training: Ensuring all team members know how to recognise harassment and how to respond safely in the moment.
- Support: Providing a “safe to speak up” culture where reporting harassment will never result in negative consequences for the employee’s career or standing within the agency.
- Reporting Procedure
If you experience or witness harassment by a third party:
- Immediate Safety: If you feel unsafe during a meeting or call, you are authorised to end the interaction immediately. You may hang up the phone, leave a video call, or walk out of a physical meeting.
- Report: Report the incident as soon as possible to a Director. You do not need to wait for a “pattern” of behaviour; a single incident is sufficient.
- Documentation: Keep a record of what happened, including dates, times, and the nature of the conduct. Save any relevant digital evidence (screenshots, emails, etc.).
- Action and Consequences
Upon receiving a report, Brandwin Digital will:
- Investigate the matter promptly and discretely.
- Support the affected staff member, including offering adjustments to their work or client assignments.
- Take direct action with the third party. This may include:
- A formal warning to the individual/company.
- Requiring that the individual no longer has contact with Brandwin staff.
- Immediate termination of the contract or business relationship, as outlined in our core conduct and AI policies.
- Non-Retaliation
No employee will be victimised or treated less favourably for reporting harassment or for exercising their right to leave an uncomfortable situation. We value your safety and wellbeing over any commercial contract.
Last Reviewed: March 2026
Approved by: Gemma Unwin, Brandwin Digital Limited