Writing an Anti-harassment and Discrimination Policy

A lot of UK businesses know they should have an anti-harassment and discrimination policy, but many still rely on a few lines in a handbook, a generic template copied from overseas, or a policy that says the right things without explaining what staff should actually do. That is where problems start. Common mistakes include defining harassment too narrowly, leaving out reporting options, and failing to deal with issues that happen at work socials, on messaging apps, or through clients and suppliers.

A clear policy does more than set expectations. It helps you prevent complaints, respond consistently, support managers, and show that your business takes a safe and fair workplace seriously. It can also sit alongside your employment contracts, grievance procedures, disciplinary rules, and training in a way that makes day to day decisions easier.

This guide explains what a UK business anti-harassment and discrimination policy should cover, when you are most likely to need one, the practical drafting points founders often miss, and how to make the policy work in real workplaces rather than just on paper.

Overview

An anti-harassment and discrimination policy sets out the standards your business expects, the behaviour it prohibits, how concerns can be raised, and how reports will be handled. In the UK, a well-drafted policy can help businesses reduce legal risk, support a respectful culture, and give managers a clear framework before issues escalate.

Define harassment, sexual harassment, discrimination, victimisation and bullying in plain English
Explain who the policy covers, including employees, workers, contractors, agency staff, applicants and visitors where relevant
State where the policy applies, such as the workplace, work events, travel, remote work, messaging platforms and social media linked to work
Set out reporting options, including alternatives where the direct manager is involved
Explain investigation, confidentiality and possible disciplinary outcomes without promising a fixed result
Address third party behaviour, including customers, clients, suppliers and event attendees
Link the policy to employment contracts, staff handbooks, grievance and disciplinary procedures, and manager training
Review and update the policy as the business grows, changes structure, or starts operating in new settings

What Writing an Anti-harassment and Discrimination Policy for Your Business Means For UK Businesses

For UK businesses, writing this policy means putting your legal obligations and workplace expectations into a practical document that staff can actually use. The goal is not simply to have a policy on file. The goal is to reduce the chance of unlawful conduct, give people confidence to speak up, and help your business respond properly when concerns arise.

In legal terms, workplace discrimination and harassment are closely linked to the Equality Act 2010. Protected characteristics include age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. A business does not need to list every legal definition in technical language, but it should explain the core concepts accurately enough for staff and managers to recognise a problem early.

What the policy is there to do

A useful policy usually has four functions. It sets standards, gives examples, explains reporting, and outlines consequences.

It tells staff what behaviour is expected and what is prohibited
It gives realistic examples of unacceptable conduct, including jokes, comments, exclusion, unwanted touching, intrusive questions, repeated messaging and online conduct
It explains how someone can report a concern, formally or informally where appropriate
It shows managers what steps they should take once an issue is raised

This matters for small businesses as much as larger employers. Founders often assume that a close-knit team or informal culture means formal written rules are unnecessary. In practice, early stage businesses often face more risk because roles are blurred, managers are inexperienced, and there is no clear process when something goes wrong.

What conduct should be covered

Your policy should not stop at obvious misconduct. It should deal with the kinds of behaviour that actually arise in modern workplaces, including hybrid working and digital communication.

Examples worth addressing include:

Offensive remarks, banter or nicknames linked to a protected characteristic
Unwanted sexual comments, advances, messages or physical contact
Excluding someone from meetings, opportunities or social events for discriminatory reasons
Mocking disability, religion, accent, gender identity or family responsibilities
Sharing inappropriate content on team chats or work-related social media groups
Retaliating against someone because they raised a complaint or supported someone else who did

If your business deals directly with the public, the policy should also say what happens if harassment comes from outside the business. Staff in retail, hospitality, healthcare, events, property, and service businesses often face unacceptable conduct from customers, clients, guests or contractors. A policy should make it clear that the business will take those reports seriously and outline how managers should respond.

How this fits with your wider documents

This policy should not sit alone. It usually works best when it lines up with:

Employment contracts and staff handbooks
Grievance and disciplinary procedures
Equal opportunities or equality, diversity and inclusion policies
Whistleblowing procedures where relevant
Manager guidance and staff training materials

Founders often get caught when these documents say different things. For example, a handbook may promise one reporting route, while the grievance policy says another. Or a contract may say serious misconduct can lead to dismissal, but the anti-harassment policy softens that message in a way that creates confusion. Consistency matters before you sign new hires, before you promote a team lead, and before you spend money on training that is built on the wrong wording.

When This Issue Comes Up

This issue usually comes up at moments of growth, pressure, or change. Most businesses do not think seriously about the policy until after a complaint, but the better time is much earlier.

When you hire your first staff

As soon as you move from founder-only operations to employing people, you need more than goodwill and common sense. New recruits need a clear statement of standards, reporting routes and consequences. This is particularly true where managers are also founders and may not have formal HR experience.

When your workplace becomes less informal

A business often starts with friends, freelancers or a very small team. Then it grows into shifts, departments, line management and multiple communication channels. That is the point where assumptions break down. A written policy helps create consistency as your business structure changes.

When you run hybrid, remote or client-facing work

Workplace misconduct no longer happens only in an office. It can happen on video calls, group chats, collaboration tools, social media, customer sites, conferences, taxis after a work event, and at staff drinks. Your policy should reflect where work actually happens, not where you imagine it happens.

When you are updating contracts and policies

If you are refreshing employment contracts, staff handbooks or internal procedures, this policy should be reviewed at the same time. It is easier to align definitions, reporting routes and disciplinary wording in one project than to patch things together later.

When your industry creates higher exposure

Some sectors face recurring pressure points. Hospitality teams deal with late-night customer interactions. Construction and trades businesses may have mixed workforces across sites. Tech startups often rely on online messaging and informal communication. Professional services firms host networking events and client entertainment. In each case, the policy should match the way people actually work.

The issue also comes up during investment, tendering and larger commercial discussions. A prospective investor, enterprise customer or public sector client may ask about workplace policies and governance. Even when not legally required in a specific format, a well-written policy helps show that your business takes staff welfare and compliance seriously.

Practical Steps And Common Mistakes

The best anti-harassment and discrimination policies are specific, readable and usable in real situations. A short, clear policy that managers understand is far better than a long document no one follows.

Start with the scope

Say who the policy applies to and where it applies. This sounds basic, but it is one of the most common drafting gaps.

Your scope may include:

Employees, workers, agency staff and interns
Contractors and consultants where appropriate
Job applicants during recruitment
Directors and senior managers
Visitors, customers, clients and suppliers in terms of expected behaviour on your premises or in work interactions

It should also say the policy covers work-related settings, including remote work, travel, conferences, social events, and digital platforms used for work. If you leave this vague, people may assume the rules stop outside the office door.

Use plain English, not legal copy-paste

A UK policy should reflect UK law and UK workplace language. Imported templates often refer to foreign legislation, odd terminology, or complaint processes that do not fit your business. Staff should be able to read your policy and understand what it means without legal translation.

That does not mean oversimplifying. It means explaining concepts clearly. For example, harassment can be described as unwanted conduct related to a protected characteristic that violates someone’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment. Then give workplace examples so the meaning is real.

Give examples that match your business

Generic examples make staff switch off. Use examples tied to the way your team works.

A sales team example might involve inappropriate comments at a client dinner
A remote team example might involve repeated messages, memes or comments on video calls
A retail or hospitality example might involve a customer behaving in a sexual or racist way toward staff
A construction or fieldwork example might involve conduct on site, in shared transport or accommodation

This is where founders often get caught. They adopt a policy with office-based examples only, then struggle when a complaint relates to a WhatsApp group, a work trip or a customer interaction.

Set out more than one reporting route

If a policy tells staff to report concerns only to their line manager, it will fail in some of the most serious cases. A person may not feel safe reporting to that manager, especially if the manager is involved or close to the person complained about.

Good policies usually provide several options, such as:

The line manager
Another manager
A founder or director
An HR contact, if the business has one
A named alternative route for confidential concerns

You should also avoid wording that forces a person into informal resolution where that is not suitable. Informal action can help in some lower-level situations, but serious conduct may need a formal process straight away.

Be careful with confidentiality promises

You can say concerns will be handled sensitively and information will be shared only where necessary. You should not promise absolute confidentiality in every case. An investigation often requires some disclosure to the people involved and to decision-makers.

Similarly, avoid guaranteeing a particular outcome. A policy can explain that proven misconduct may lead to disciplinary action, up to and including dismissal where legally appropriate, without promising that every complaint will result in the same sanction.

Explain the process briefly but clearly

Staff need to know what happens after a report is made. Keep this practical.

A concern is raised, formally or informally depending on the circumstances
The business considers any immediate protective steps, such as changing reporting lines or work arrangements on a temporary basis
An appropriate person reviews the concern and decides whether a formal investigation is needed
Relevant evidence is gathered and the people involved are spoken to
The business decides what action to take and communicates the outcome as far as appropriate
Support and follow-up steps are considered

You do not need to turn the policy into a full investigation manual, but you should remove uncertainty about the basic path.

Address victimisation and retaliation

Many businesses define harassment and discrimination but forget to deal properly with retaliation. Your policy should clearly state that no one will be treated badly for raising a concern in good faith, participating in an investigation, or supporting a colleague’s complaint.

This is especially important in small teams where fear of social fallout can stop people speaking up.

Train managers and communicate the policy

A policy hidden in a shared drive will not do much. Managers need to know how to respond when someone discloses a problem, even informally. Staff need to know where to find the policy and who to speak to.

Useful implementation steps include:

Giving the policy to new starters during onboarding
Asking staff to confirm they have read it
Training managers on reporting, escalation and record keeping
Refreshing the policy after restructures, office moves, or changes to working practices
Reviewing incidents and feedback to see whether the policy is working in practice

Common mistakes to avoid

Most policy problems are not dramatic drafting errors. They are practical omissions that make the document hard to use when pressure hits.

Using a template that does not reflect UK law or your actual workplace
Leaving out third party harassment risks
Failing to cover remote work, messaging apps and work socials
Offering only one reporting route
Promising strict confidentiality or fixed outcomes
Not linking the policy to grievance and disciplinary procedures
Not reviewing the policy after growth, acquisitions or management changes
Assuming culture alone will prevent problems

If your business is scaling quickly, this policy should be treated like any other key operational document. It belongs in the same conversation as contracts, privacy notices, trade mark planning, and internal governance, because all of those documents shape how the business behaves as it grows.

FAQs

Is an anti-harassment and discrimination policy legally required in the UK?

There is no single rule that every business must have the policy in exactly the same format, but having one is a sensible and often expected step for UK employers. It helps show that the business has set standards, communicated them, and taken reasonable steps to prevent unlawful conduct.

Does a small business with only a few employees need one?

Yes, in most cases it is still a good idea. Small teams are not immune from complaints, and informal culture can make problems harder to raise and resolve consistently.

Should bullying be included even if it is not unlawful discrimination?

Yes. Bullying may not always fall within equality law, but it can still cause serious workplace issues and overlap with harassment. Many businesses cover it in the same policy so expectations are clear.

Can the policy apply to customers, clients and contractors?

Yes, the policy can state that your business will not tolerate harassment or discriminatory behaviour from third parties and explain how staff should report it. You can also set expectations for visitors and suppliers when they interact with your team.

How often should the policy be reviewed?

Review it regularly and whenever your business changes in a meaningful way, such as hiring managers, moving to hybrid work, opening new sites, or updating employment contracts and procedures.

Key Takeaways

A UK anti-harassment and discrimination policy should explain prohibited conduct, reporting routes, investigation steps and possible outcomes in clear language
The policy should reflect UK law, especially Equality Act concepts, but still be practical and easy for staff and managers to use
It should cover real working environments, including remote work, social events, client sites and digital communications
Multiple reporting options are essential, particularly where a line manager may be involved in the concern
The policy should align with employment contracts, staff handbooks, grievance procedures and disciplinary rules
Training, communication and regular review matter just as much as the written wording

If your business is dealing with writing an anti-harassment and discrimination policy for your business and wants help with employment contracts, staff handbooks, grievance and disciplinary procedures, and workplace policy drafting, you can reach us on 08081347754 or team@sprintlaw.co.uk for a free, no-obligations chat.

Writing an Anti-harassment and Discrimination Policy for Your Business