Democracy Spraffa

People Strategy 2021-26 - Revised HR Policies

Renfrewshire Council · 11 September 2025
Back to Finance, Resources and Customer Services Policy Board — 11 September 2025 and its agenda

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___________________________________________________________________
To: Finance, Resources and Customer Services Policy Board
On: 11 September 2025
___________________________________________________________________
Report by: Director of Finance and Resources
___________________________________________________________________
Heading: ‘People Strategy 2021-26’ - Revised HR&OD Policies
___________________________________________________________________
1. Summary 
1.1 As part of the on-going implementation of our People Strategy priorities ‘Our
People Our Future 2021-2026’, approved by Members in March 2021, key work
continues to be progressed by officers in relation to our HR&OD Policy Review
Plan. The review plan helps to improve the workplace culture and staff
experience by creating the right conditions for change, to deliver future
modernised, inclusive and sustainable services. 
1.2 These revised HR & OD policies lay strong, supportive foundations to enable
meaningful organisational development and help embed the Council’s cultural
change journey. The review has been shaped by our values and places a clear
emphasis on flexibility, health and wellbeing, and a commitment to equality,
diversity, and inclusion (EDI). 
1.3 The purpose of this report is to seek approval from members to implement the
revised HR&OD policies noted below: 
 EDI Policy at Appendix 1.
 Respect at Work Policy at Appendix 2. 
1.4 Consultation has taken place with the Trade Unions, Services, Trauma
Informed Team and Inclusive Employers and feedback has informed the
development of the policies. These policies have been modernised and
compiled in line with best practice, our values and employment legislation.

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1.5  Following approval from Members, officers will review associated EDI guidance
and training to support the implementation of these policies.  These will also be
communicated to all managers and employees within the Council via the normal
channels. 
___________________________________________________________________
2. Recommendations 
2.1 It is recommended that members: 
 Approve the revised HR&OD Policies at Appendices 1 and 2.
___________________________________________________________________
3. Background 
3.1 The Council is committed to creating a healthy, inclusive working environment
where all employees feel supported to balance their work and home
responsibilities while performing at their best.  The health, safety, wellbeing,
and development of our people remain a top priority. 
3.2 Over the past two years, we have placed greater emphasis on evolving our
workplace culture by embedding our values into everything we do.  We’ve
focused on strengthening engagement and improving communication to ensure
employees feel safe, valued, and well-informed. 
3.3 Promoting health and wellbeing, embedding EDI principles into our policies and
plans, and integrating these values into management and leadership
development programmes are all vital to driving forward the Council’s cultural
change journey. 
3.4 Through our HR & OD policies, we will continue to demonstrate care for our
people, enhancing the overall employee experience and contributing to a
healthier, more engaged, and more productive workforce.  These revised
policies will help ensure that both health and wellbeing, and EDI, are central to
our everyday practices, supported at all levels, and embedded within our
organisational culture and values. 
4. Revised HR&OD Policies 
4.1 Attached at Appendix 1 is the Council’s revised EDI Policy, which replaces the
2010 Equality and Diversity at Work Policy.  The policy reflects the Council’s
proactive approach to EDI and sets out our commitment to continuing to build
a respectful, inclusive, and diverse workplace. The policy aims to embed EDI
principles across all areas of service delivery and employment practice, while
ensuring continued compliance with the Equality Act 2010.

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4.2 The policy strengthens the Council’s commitment to inclusion by recognising
and valuing the diverse backgrounds, beliefs, and experiences of all individuals.
It explicitly covers all protected characteristics under the Equality Act 2010, and
also acknowledges additional factors such as caring responsibilities and socio-
economic status, which can influence people’s experiences and access to
opportunities. 
4.3 The Council’s commitment to learning and development is reinforced through
mandatory EDI training for all employees covered by the policy. EDI principles
are also embedded within wider learning programmes available on iLearn,
RENFO, and GLOW, ensuring they are accessible and integrated into everyday
learning. 
4.4 Attached at Appendix 2, is the Council’s revised Respect at Work Policy, which
replaces the 2010 Respect at Work Policy.  The policy sets out the Council’s
clear commitment to preventing and responding to bullying, harassment,
discrimination, and victimisation. It aims to foster a respectful, inclusive, and
safe working environment for all employees, elected members, contractors, and
partners. 
4.5 The policy emphasises respect and fairness throughout, with strong focus on
enhancing our culture of dignity, respect and support.  It acknowledges the
serious impact of unfair treatment on wellbeing and performance. 
4.6 The Council’s trauma-informed approach is woven throughout the policy, with
a strong focus on prevention, support, and repair. The policy reflects recent
legislative developments, most notably the Worker Protection (Amendment to
Equality Act 2010) Act 2023, and includes up-to-date definitions of
discrimination, bullying, and harassment. These definitions now cover cyber
harassment and harassment by third parties, ensuring the policy remains
relevant and comprehensive. 
4.7 Members are asked to note that greater emphasis is provided on inclusive tone,
language and clearer interpretation, in line with other HR&OD policies approved
at recent boards.   
__________________________________________________________________
Implications of the Report
1. Financial - None. 
2. People & Organisational Development - As outlined in the report. 
3. Community Planning – None. 
4. Legal – These plans and policy have been prepared in accordance with
current employment legislation and statutory provisions. 
5. Property/Assets – None

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6. Information Technology – None.
7. Equality & Human Rights 
The Recommendations contained within this report have been assessed in
relation to their impact on equalities and human rights. No negative impacts
on equality groups or potential for infringement of individuals’ human rights
have been identified arising from the recommendations contained in the
report. If required following implementation, the actual impact of the
recommendations and the mitigating actions will be reviewed and monitored,
and the results of any reassessment will be published on the Council’s
website.
8. Health & Safety - As outlined in the report.
9. Procurement – None.
10. Risk – None.
11. Privacy Impact – None.
12. Cosla Policy Position – None.
13. Children’s Rights - None
14. Climate Risk – None.
_________________________________________________________
List of Background Papers
None
_________________________________________________________________
Author: 
Eddie Simpson, Strategic Lead Partner (Organisational Development) 
eddie.simpson@renfrewshire.gov.uk

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Issue Number:  2                         
Issue Date: 09/25
Review Date:   09/27
Equality, Diversity and
Inclusion Policy
For all council employees
This document is
available in alternative
formats on request.
For all Council Employees

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CONTENTS 
1 Introduction         3         
2 Purpose and Aims         3  
3 Scope          4 
4 What is Equality, Diversity and Inclusion?    4 
5 Legal Framework        4 
6 Responsibilities        6 
7 Disciplinary Action        7 
8 Learning and Development      7 
9 Equality and Human Rights Impact Assessment   8 
10 Confidentiality        8 
11 Monitoring and Review       8

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1.  Introduction   
1.1 The Council believes that equality, diversity and inclusion (EDI) are essential to
delivering excellent public services and being a great place to work. We know that
when people feel respected, valued and included, they can thrive, and so can our
communities. As an equal opportunities’ employer, we are committed to building
a workplace where everyone can be themselves, contribute fully, and feel a sense
of belonging. A diverse workforce brings a wide range of perspectives,
experiences and strengths, helping us to better understand and meet the needs
of the people we serve. We aim to embed the principles of fairness, inclusion and
respect in everything we do, from recruitment and development to service design
and delivery.  
1.2 We actively promote a positive and inclusive working environment for everyone,
regardless of age, disability, gender identity, marital or civil partnership status,
pregnancy or maternity, race, religion or belief, sex, or sexual orientation. We also
recognise and support diversity in caring responsibilities, socio-economic
background, and trade union membership or activity. We want all employees to
feel safe, respected and empowered to succeed. 
1.3 This policy aligns with the Equality Act 2010 and other relevant legislation. All
employees are expected to follow the principles of this policy, helping to create a
culture where equality, diversity and inclusion are part of everyday working life. 
2.   Purpose and Aims 
2.1 The purpose of this policy is to set out the Council’s vision and commitment to
EDI in the workplace. It aims to promote EDI in all aspects of the Council’s work
and to foster a working environment where everyone can reach their full potential,
free from discrimination, harassment and victimisation. 
2.2 We believe that everyone deserves to feel safe, respected and included at work.
EDI shapes how we work, lead and serve, and these values have long guided our
approach. While we’ve taken important steps to embed them across the Council,
we recognise that good intentions are not enough. That’s why we are committed
to taking meaningful action, making EDI part of everyday practice, visible in our
decisions, behaviours and services. The commitments below reflect both the
actions we already take and the areas where we must continue to improve,
strengthen and hold ourselves to account. 
2.3 To achieve this, we will: 
 Provide training to all employees on equality, diversity and inclusion.
 Develop and apply policies, procedures and practices that support our
EDI responsibilities.

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 Ensure the needs of our diverse communities are reflected in service
delivery and service redesigns.
 Work towards a workforce that better reflects the people we serve.
 Foster a safe and inclusive working environment, free from bullying,
harassment, discrimination and victimisation.
 Challenge unacceptable behaviour wherever it occurs.
 Monitor and evaluate our EDI practices to ensure they meet legal
standards and reflect best practice. 
2.4 By working together, with each of us playing our part striving to meet these
commitments, we can build a Council that is stronger, fairer and more
compassionate for everyone. This is our collective mission and our opportunity to
create lasting, meaningful change. 
3.  Scope   
3.1  This policy applies to all Council employees.  It also extends to external agencies,
partners and contractors working with the Council, who are expected to uphold
and comply with its principles and requirements. 
4.  What Is Equality, Diversity and Inclusion?   
4.1  Equality is about making sure you are treated fairly and given fair chances.  It is 
about giving you an equality of opportunity to access all services and
opportunities available to help you reach your potential.     
4.2  Diversity is about recognising, respecting and valuing differences. It is not 
about treating everyone exactly the same but treating people as individuals and 
creating a working culture and practices that enables you to understand and 
appreciate differences.   
4.3 Inclusion is when you feel valued and accepted in your team and in the wider
Council, without having to conform.  Inclusive organisations support employees,
regardless of their background or circumstance, to thrive at work. This requires
practices and processes that break down barriers to inclusion and actively value
difference 
5.  Legal and Policy Framework 
5.1 The Council is committed to meeting its legal obligations under the Equality Act
2010, which consolidates and strengthens previous anti-discrimination laws. The
Act protects you from discrimination based on nine protected characteristics: 
 Age
 Disability
 Gender reassignment

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 Marriage and civil partnership
 Pregnancy and maternity
 Race (including ethnic or national origins, colour and nationality)
 Religion or belief
 Sex
 Sexual orientation 
5.2 In line with the Public Sector Equality Duty(PSED), the Council is committed to: 
 Eliminating unlawful discrimination, harassment and victimisation.
 Advancing equality of opportunity between people who share a protected
characteristic and those who do not.
 Fostering good relations between different groups. 
5.3 We recognise that creating a safe, respectful and inclusive workplace is both a
legal and ethical responsibility.  Under the Health and Safety at Work etc. Act
1974, we must ensure, as far as reasonably practicable, the health, safety and
welfare of all employees.  Inclusive health and safety practices, such as
accessible emergency procedures, reasonable adjustments for those with
disabilities, and training that reflects diverse needs, are essential to supporting
EDI.   
5.4 Recent changes to the Equality Act 2010 have introduced a proactive duty on the
Council to take reasonable steps to prevent sexual harassment in the workplace.
This includes harassment by colleagues, managers and third parties such as
service users or members of the public. We will continue to strengthen our
policies, training and reporting mechanisms to reflect this duty and foster a culture
where unacceptable behaviour is challenged, and you feel safe to speak up. 
5.5 We recognise the proposed changes under the Employment Rights Bill 2025,
which are expected to strengthen existing duties by the Council to take all
reasonable steps to prevent sexual harassment in the workplace.  We will monitor
the progress of this legislation and will amend this policy to ensure full compliance
once the new duty is enacted. 
5.6 Legal interpretations of protected characteristics continue to evolve through case
law, including recent judgments clarifying how terms such as “sex” are understood
within the Equality Act.  We will ensure our policies remain legally compliant,
inclusive and respectful of all protected characteristics. 
5.7 These legal duties are supported by a range of Council policies and procedures
that help embed equality, diversity and inclusion into everyday practice. This
includes how we recruit, support, develop and manage our workforce, and how
we respond to concerns. Key policies and resources include:

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 The Recruitment Policy, which promotes fair and inclusive hiring
practices.
 The Respect at Work Policy, which sets expectations for respectful
behaviour.
 The Grievance and Disciplinary Procedures, which provide clear
routes for addressing concerns.
 The Code of Conduct for Employees, which outlines standards of
behaviour aligned with EDI principles.
 Mandatory EDI training and staff induction, which ensure all
employees understand their responsibilities.
 The People, Performance and Wellbeing Policy, which promotes a
healthy, inclusive and supportive working environment. 
6 Responsibilities 
6.1 Embedding and upholding EDI is a shared responsibility across the Council.  
Everyone, managers, employees, trade unions/employee representatives, and
external partners, has a role to play in upholding the principles of this policy and
contributing to an inclusive working environment. 
6.2 This section outlines the specific responsibilities of key roles in supporting and
upholding the principles of this policy: 
6.3 The Council will:
 Promote a culture that values equality, diversity and inclusion.
 Monitor the application of this policy and take action to address
inequalities.
 Ensure all policies and procedures reflect EDI principles.
 Provide training and guidance to raise awareness and build
understanding.
 Publish statutory EDI information in line with legislation. 
6.4 Managers will:
 Undertake necessary training provided by the Council to engage and
uphold this policy and ensure their teams do the same.
 Implement this policy within their teams and lead by example.
 Promote a respectful and inclusive working environment.
 Apply policies fairly and consistently.
 Respond to concerns or complaints about discrimination promptly and
appropriately. 
6.5 Employees will:
 Undertake necessary training provided by the Council to engage and
uphold this policy.
 Understand and uphold the principles of this policy.

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 Treat others with respect and challenge inappropriate behaviour. 
 Support efforts to promote equality and report concerns to their manager. 
6.6 Trade Unions Colleagues/Representatives and External Partners will:
 Support employees who raise or are subject to concerns. 
 Work within the principles of this policy. 
7.  Disciplinary Action   
7.1 As an employee, you have the fundamental right to be treated with dignity,
fairness, and respect at work.  We are firmly committed to fostering a safe and
inclusive working environment, where unfair treatment is not tolerated. We
recognise that such treatment can have serious and lasting impacts, and we will
take all necessary steps to address concerns promptly, sensitively, and in line
with our values and legal responsibilities. 
7.2 We will take all concerns and complaints seriously. If an issue is raised by an
employee, partner, external agency, contractor, or agency worker, it will be
investigated thoroughly and with sensitivity. Where a breach of this policy is
identified, appropriate and proportionate disciplinary action will be taken in line
with our procedures. 
7.3 Where an employee of a partner organisation, external agency, or contractor is
found to have breached this policy, we will report the matter to their employer for
appropriate action under their own disciplinary procedures.  In severe cases, this
may result in the Council reviewing or ending its working relationship with the
individual or organisation. 
8.  Learning and Development   
8.1 EDI principles are embedded across all Council training programmes. In addition,
EDI is a mandatory training module for all employees.  You will be supported and
encouraged to complete this training in a format that suits your role and learning
style, whether online, face-to-face, or through toolbox talks. Completion of this
training is a vital step in ensuring that everyone understands their responsibilities
and can contribute to a respectful and inclusive working environment. 
8.2 A wide range of additional EDI training modules is available through the Council’s
learning platforms, including iLearn, RENFO, and GLOW (the national intranet for
education). These resources support deeper learning on specific topics such as
unconscious bias, inclusive leadership, cultural competency, and trauma-
informed practice. 
8.3 We will continue to review and enhance our training offer to reflect emerging best
practice, legislative changes, and feedback from employees and service users.
Managers are expected to actively promote EDI learning within their teams and

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ensure that training is not only completed but meaningfully applied in day-to-day
practice.  
9. Equality and Human Rights Impact Assessment 
9.1  This policy has been impact assessed in line with the Council’s obligation to 
comply with the Equality Act 2010 and the Public Sector Equality Duty. 
10.  Confidentiality 
10.1  All information relating to Equality, Diversity and Inclusion (EDI) is handled with
the utmost care. It is recorded, maintained, and processed confidentially and
securely by the Council.  This ensures compliance with data protection legislation
and reflects the Council’s commitment to safeguarding sensitive information and
promoting trust across the workforce. 
10.2  Information processed may include paper or electronic records and will be done
so in line with Data Protection Laws, including the UK General Data Protection
Regulation  (“UK GDPR”), the Data Protection Act 2018 and any enactment
thereunder or amendment thereto. 
11.  Monitoring and Review 
11.1 This policy will be reviewed regularly to ensure it remains aligned with current
legislation, best practice, and organisational priorities relating to equality, diversity
and inclusion in the workplace.  Reviews will take into account feedback from
trade unions, service users, and stakeholders to ensure the policy continues to
reflect lived experience and evolving needs. 
11.2 We will continue to meet our obligations under the Public Sector Equality Duty
(PSED), ensuring due regard is given to eliminating discrimination, advancing
equality of opportunity, and fostering good relations. Equality Impact
Assessments will be conducted for all relevant policies and service changes, and
statutory EDI data will be published in line with legal requirements

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Issue Number:   2                         
Issue Date: 09/25
Review Date:   09/27
Respect at Work Policy
For all Council employees 
This document is
available in alternative
formats on request.

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CONTENTS 
1 Introduction         3         
2 Purpose and Aims         3   
3 Scope          4 
4 Legal framework        4 
5 Definitions         5 
6 Responsibilities        5 
7 Recognising Bullying, Harassment, Discrimination   6 
and Victimisation 
8 Supporting Employees Who Have Experienced Bullying,                  7
Harassment, Discrimination, or Victimisation 
9 Dealing with a Malicious or Vexatious Complaint   8 
10  Mediation         9 
11  Counselling         9 
12 Bullying, Harassment, Discrimination or Victimisation   10 
Outside the Workplace or Out with Normal Working Hours      
13 Equality and Human Rights Impact Assessment   10 
14 Confidentiality        10    
15 Monitoring and Review       11 
Appendix 1         12 
VERSION CONTROL
Version  Date Details of Review/Revisals made Next Review date
2 09/2025 This revised Respect at Work Policy
replaces the current Respect at Work
Policy, referencing the Sexual
Harassment legislation and recognising
intersectionality.
(September 2027)

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1. Introduction
1.1 The Council is committed to fostering a safe, respectful, and inclusive working
environment where all employees are treated with fairness, dignity, and
respect. We recognise the potential impact of bullying, harassment,
discrimination or victimisation, including the emotional and psychological harm
it can cause, and are committed to preventing all forms of unfair treatment. 
1.2  Every employee has the right to be treated fairly and respectfully at work.  We
understand that experiences of unfair treatment can have serious and lasting
effects. Any concerns or complaints will be taken seriously and handled with
care, compassion and fairness, in line with our Council policies and our
trauma-informed values. 
1.3 This policy has been developed in line with relevant legislation, Council
policies and the Council’s Code of Conduct for Employees.  It also reflects our
commitment to creating psychologically safe and supportive workplaces. 
1.4 This policy should be read and applied in accordance with other related
Council policies and procedures, for example the Disciplinary Policy and
Grievance Procedures, and the Violence and Aggression policy, all of which
contribute to a culture of safety and wellbeing. 
1.5  We will provide guidance and training to managers and employees to support
the implementation of this policy. 
2.  Purpose and Aims 
2.1  The purpose of this policy is to clearly outline the Council’s commitment to
preventing and addressing all forms of bullying, harassment, discrimination
and victimisation. It sets out how we support respectful working relationships
and what we’ll do when concerns are raised. 
2.2  We want a psychologically safe and inclusive workplace which enables all
employees to participate fully, contribute meaningfully and feel valued at work. 
Our aim is to support greater job satisfaction, wellbeing and overall
performance. 
2.3 All concerns about offensive behaviour will be taken seriously. Employees will
not face any disadvantage for raising concerns in good faith, even if the issue
raised is not upheld. Allegations found to be clearly malicious or knowingly
untrue will be addressed in line with existing Council procedures. 
2.4 All employees and employee representatives have a shared role in fostering a
culture where respect and inclusion are the norm and where harmful behaviour
is recognised early and addressed quickly and supportively.

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2.5 The key aims of the policy are to:
 Raise awareness of behaviours that may cause harm, such as bullying,
harassment, discrimination, and victimisation, and promote a culture of
respect and shared responsibility across the workforce.
 Promote accountability by helping employees recognise the impact of
their behaviour and encouraging constructive responses when concerns
are raised.
 Reinforce a clear commitment to preventing and responding to
harmful behaviours, ensuring employees feel safe to speak up without
fear of judgement, blame, or retaliation.
 Provide clear and supportive procedures for raising and responding to
concerns, with an emphasis on confidentiality, fairness, and emotional
sensitivity.
 Ensure prompt and respectful handling of all complaints, using
trauma-informed approaches and aligning with Council policies and
procedures. 
3.  Scope 
3.1  This policy applies to all Local Government Employees including Chief Officers
and Teachers. 
3.2 External agencies, partners and contractors who work with or on behalf of the
Council are also expected to support the principles of this policy and act in
ways that uphold a safe, respectful working environment in line with our
Council values. 
4.  Legal Framework 
4.1 The Council is committed to upholding its legal responsibilities under
the Equality Act 2010, which consolidates and strengthens previous equality
legislation.  Under this act, employees are protected from discrimination,
harassment, and victimisation based on the following protected characteristics:
 Age
 Disability
 Gender reassignment
 Marriage and civil partnership
 Pregnancy and maternity
 Race (including ethnic or national origins, colour and nationality)
 Religion or belief
 Sex
 Sexual orientation 
4.2 In line with the Health and Safety at Work Act 1974, the Council also has a
duty to ensure, so far as is reasonably practicable, the health, safety, and

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welfare of all employees. This includes taking proactive steps to prevent and
address workplace behaviours, such as bullying and harassment, that may
cause psychological harm or contribute to a hostile or unsafe working
environment. 
4.3 By aligning our approach with both equality and health and safety legislation,
the Council aims to foster a working environment that is inclusive, respectful,
and safe for everyone. 
4.4 The Council further recognises the relevance of additional legislation in
supporting a culture of dignity and respect at work: 
 The Protection from Harassment Act 1997 offers civil remedies for
persistent and distressing behaviour, even where not linked to a
protected characteristic.
 The Human Rights Act 1998 underpins key workplace rights, including
dignity, privacy, and protection from degrading treatment, and informs our
commitment to fairness and psychological safety.
 The Worker Protection (Amendment of Equality Act 2010) Act 2023
introduced a statutory duty for employers to take reasonable steps to
prevent sexual harassment, such as training, awareness and reporting
mechanisms.   
4.5 To maintain compliance with relevant legislation, the Council will continue to
strengthen its policies, practices, and training to prevent harm, promote
inclusion, and ensure that all employees feel safe, respected, and supported in
the workplace. 
5. Definitions
5.1 Unfair treatment and inappropriate behaviour may be verbal, physical, written
or digital.  To support understanding and consistency, key definitions of
bullying, harassment, discrimination, and victimisation are provided
in Appendix 1 of this policy. These definitions are intended to help employees
identify unacceptable behaviour and understand how it may be addressed
under this policy. 
6.  Responsibilities
6.1 Creating and maintaining a respectful, inclusive, and psychologically safe
workplace is a shared responsibility across the Council.  Every employee,
regardless of role or seniority, shares responsibility for promoting a respectful,
inclusive, and psychologically safe workplace. 
6.2 This section outlines the specific responsibilities of key roles in supporting and
upholding the principles of this policy:

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6.3 The Council will:
 Promote and regularly review this policy to ensure its effectiveness.
 Provide training and accessible guidance to support understanding and
implementation.
 Foster a culture where employees feel safe to speak up without fear of
blame or retaliation. 
6.4 Managers and Supervisors will:
 Undertake necessary training provided by the Council to engage with and
uphold this policy.
 Creating psychologically safe, inclusive team environments.
 Introduce the policy through local induction, supervision and team
engagement.
 Role model respectful behaviour and be mindful of personal impact.
 Identify and address any concerns promptly and compassionately,
seeking advice from People and OD when necessary. 
6.5 Employees will: 
 Undertake necessary training provided by the Council to engage with and
uphold this policy.
 Treat colleagues with respect, empathy and fairness.
 Value diversity and individual contributions.
 Communicate with others in ways that avoid harm or distress.
 Challenge inappropriate behaviours or raise the matter with your line
manager, trade union or People and OD team to support a culture of
accountability. 
6.6 Trade Union Colleagues and Employee Representatives will 
 Support employees who raise or are subject to concerns. 
 Work within the principles of this policy. 
7. Recognising Bullying, Harassment, Discrimination and Victimisation   
7.1 Subjecting someone to bullying, harassment, discrimination, or victimisation
can have serious and lasting impacts. These behaviours are not always
obvious or intentional, but their effects, such as creating an intimidating,
unsafe, or humiliating environment, can be deeply harmful. 
7.2 What may seem like a joke or casual remark to one person can be distressing
to another.  When employees feel excluded, targeted, or unsafe at work, it can
affect their emotional wellbeing, mental and physical health, self-worth, and
ability to thrive. 
7.3 Experiences of harm are shaped by individual identity, lived experience, and
context.  Even unintentional behaviours can cause distress.  Recognising this
is essential to building a trauma-informed and psychologically safe workplace.

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The Council will listen without judgement, acknowledge harm, and respond
supportively and proportionately. Harmful behaviours must be addressed
seriously, even if not formally reported. 
7.4 We also recognise that some individuals may face increased risk due to
overlapping forms of discrimination or marginalisation, known as
intersectionality. For example, someone may experience compounded
challenges related to their race, sex, disability, or sexual orientation. Our
approach will ensure support is tailored and sensitive to each employee’s
circumstances. 
7.5 Inappropriate behaviours may also pose risks to health and safety at work.
Stress, anxiety, and other psychological impacts can lead to physical
symptoms, reduced concentration, and increased risk of accidents or illness.
The Council has a duty under the Health and Safety law to protect employees
from these risks. 
7.6 Examples of inappropriate and harmful behaviour may include, but are not
limited to: 
 Verbal and written abuse: Offensive or insulting language, malicious
rumours, derogatory names, or jokes and innuendoes that demean or
intimidate.
 Humiliation and exclusion: Ridiculing or singling someone out,
excluding individuals from work opportunities or social interactions, or
provoking hostility between colleagues.
 Discrimination and stereotyping: Making assumptions or derogatory
comments based on age, race, gender identity, disability, religion, or
other protected characteristics.
 Unwanted conduct: Inappropriate physical contact, sexualised
behaviour, or mocking someone’s beliefs, culture, or personal identity.
 Misuse of information and communication: Sharing personal or
confidential information without consent, or distributing offensive content
via email, messaging platforms, or social media.
 Unfair treatment: Denying access to training, promotion, or development
opportunities based on personal characteristics.
 Health and safety risks: Creating a hostile environment that contributes
to stress, burnout, or illness; ignoring signs of distress or failing to act
when someone feels unsafe. 
8. Supporting Employees Who Have Experienced Bullying, Harassment,
Discrimination, or Victimisation 
8.1 Experiencing or witnessing bullying, harassment, discrimination, or
victimisation at work can be deeply distressing and isolating.  If this has
happened to you, the Council wants you to know that you will be listened to,

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supported, and treated with respect.  Your wellbeing matters, and you do not
have to manage the situation alone. Whether the behaviour was recent or
ongoing, subtle or overt, support is available, and steps can be taken to
address it in a way that is fair, compassionate, and safe. 
8.2 Employees are encouraged to document incidents and, where safe and
appropriate, address the behaviour directly.  Support is available through line
managers, trusted colleagues, trade union representatives, or People
Advisers. Early reporting allows timely and appropriate action. Informal
resolution, such as a respectful conversation, may be helpful in some cases.
Where informal approaches are unsuitable or unsuccessful, employees may
access counselling or mediation or submit a formal complaint through the
Council’s Grievance Procedure. Formal investigations will be conducted
sensitively and fairly, in line with Council policy. 
8.3 If the behaviour involves a third party, for example, a member of the public,
client, or contractor, employees should report this to their line manager as
soon as possible. The Council will investigate and take appropriate action
under relevant policies, including those relating to health and safety. 
8.4 Managers play a key role in maintaining a safe and respectful workplace. They
must respond to concerns promptly   and empathetically, support informal
resolution where appropriate, and escalate to formal procedures when
necessary.  Formal complaints must be investigated in line with grievance and
disciplinary procedures, with appropriate action taken where behaviour is
found to be unacceptable. 
8.5 While the views of the complainant will be respected, serious concerns may
require formal action to protect others.  In cases of gross misconduct,
disciplinary outcomes may include dismissal. Where the individual whose
behaviour is in question is not a Council employee, managers must still take
appropriate steps to support the employee impacted and respond in line with
Council policies. 
9. Dealing with a Malicious or Vexatious complaint
9.1 Malicious complaints are rare. This section is intended to protect the integrity
of the reporting process without discouraging genuine concerns.  Concerns
about bullying, harassment, discrimination, or victimisation will be handled with
respect, fairness, and care.  Most complaints are raised in good faith and
reflect genuine experiences.  However, to protect the integrity of the process, it
is important that the policy is not misused. 
9.2 Where an investigation finds that a complaint was made with malicious or
vexatious intent, such as knowingly making false allegations, misrepresenting
events, seeking to cause distress, or retaliating against a previous complaint,
appropriate action may be taken under the Council’s Disciplinary Procedures.

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The complainant’s intent and awareness are key in distinguishing such cases
from genuine but unsubstantiated concerns. 
9.3 A malicious or vexatious complaint involves deliberate misuse of the policy.
This includes knowingly making a complaint with no factual basis, intentionally
distorting events, or using the process to cause harm or disruption. It may also
include retaliatory complaints made in response to previous allegations,
regardless of whether those were upheld. 
9.4 Some complaints may not be upheld, but they were raised in good faith and
reflect genuine concerns.  A complaint may not be upheld due to insufficient
evidence or differing perspectives, but the employee may still have
experienced genuine distress.  In such cases, appropriate support will be
offered, and restorative or learning-based approaches may be considered to
address any underlying issues. 
9.5 Maintaining a psychologically safe and trusting workplace requires fair and
respectful handling of all concerns. Addressing misuse of the policy helps
ensure that all employees can engage with the process confidently, knowing it
is just, supportive, and free from reprisal. 
10. Mediation
10.1 Workplace conflict, including concerns about bullying, harassment,
victimisation, and discrimination can be distressing and disruptive to
individuals and teams. Where appropriate, and with the voluntary agreement of
all parties, mediation may offer a constructive way to address concerns,
rebuild relationships, and restore a respectful working environment. 
10.2 Mediation is facilitated by an impartial, trained mediator or independent third
party, and provides a confidential space for individuals to: 
 Share their experiences and perspectives safely and respectfully.
 Understand the impact of the situation on themselves and others.
 Collaborate on mutually acceptable solutions.
 Rebuild trust and agree on how to move forward together. 
10.3 Participation in mediation must be voluntary, and it will only proceed when both
parties feel safe and willing to engage. It is not suitable in all cases, particularly
where there is a significant power imbalance, ongoing risk, or trauma-related
concerns. 
11. Counselling 
11.1 Experiencing or witnessing bullying, harassment, discrimination or victimisation
can have a significant emotional and psychological impact, including stress,

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anxiety, and a reduced confidence.  To support employee wellbeing,
counselling is available to those impacted. 
11.2 Counselling provides a confidential, non-judgemental space for individuals to
explore their experiences, understand their feelings, and consider their
options, whether informal or formal, based on their needs and preferences. 
11.3 Managers must respond to concerns with empathy and respect, and ensure
employees are supported appropriately. All referrals must be handled
confidentially, and employees should be given time and flexibility to attend
sessions. Creating a culture of openness, trust, and care is a shared
responsibility across the Council.   
12. Bullying, Harassment, Discrimination or Victimisation Outside the
Workplace or Out with Normal Working Hours 
12.1 Harmful behaviour such as bullying, harassment, discrimination, or
victimisation may occur outside of traditional work settings or working hours,
such as at conferences, awards ceremonies, or via online platforms, and still
have a serious impact on an individual’s sense of safety and wellbeing at work.
When such behaviour is connected to work, it falls within the scope of this
policy.
12.2 Employees are expected to uphold respectful, inclusive standards of behaviour
whenever they are representing the Council, including in virtual environments
and on social media.
12.3 Any complaints about behaviour occurring outside of the workplace, but linked
to work-related contexts, will be taken seriously and may be considered under
the Council’s disciplinary procedures, where appropriate. This ensures that all
employees feel safe, supported, and protected, regardless of where or when
the incident occurs. 
13. Equality and Human Rights Impact Assessment (EqHRIA) 
13.1 The policy has been equality impact assessed in line with Council’s obligations
to comply with the Equality Act 2010 and the Worker Protection (amendment
to Equality Act 2010) Act 2023.
14.  Confidentiality 
14.1  Information processed may include paper or electronic records and will be
done so in line with Data Protection Laws, including the UK General Data
Protection Regulation  (“UK GDPR”), the Data Protection Act 2018 and any
enactment thereunder or amendment thereto.

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15. Monitoring and Review 
15.1  The Council will continue to monitor developments in employment law,
including proposed reforms to the Human Rights Act and emerging legislation
such as the Employment Rights Bill. Any changes with implications for
workplace dignity, equality, or safety will be reflected in future revisions of this
policy.  The recognised Trade Unions will be consulted on any future changes
to this policy. 
Appendix 1

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Definitions
1.1 Bullying
1.1.1 Bullying is targeted, offensive, intimidating, malicious or insulting behaviour,
and can include the abuse or misuse of power intended to undermine,
humiliate, denigrate or injure. It may be a single incident or pattern of
behaviour and can significantly impact emotional safety and wellbeing.
1.2 Cyber Bullying
1.2.1 Cyber-bullying is a form of bullying using electronic means. It can be an
extension of face-to-face bullying, with technology providing the bully with
another route to harass their target. 
This may take place via mobile phones or online through emails, instant
messaging, blogs and social networking websites. Cyber-bullying can include
continuing to send e-mails to someone who has said they want no further
contact with the sender. It may also include threats, sexual remarks, posting
inappropriate pictures, offensive or intimidating language directed at another
employee, unauthorised publication of private information or images,
impersonation, pressure to join someone’s online circle of “friends” or work
contacts and “trolling” (abusing the internet to provoke or offend others online). 
The nature of this type of bullying means it can occur outside working hours.
However, if it is instigated by an employee against another employee, it will still
be dealt with under this policy. 
The Council can check emails and social networking sites if an employee
reports instances of cyber bullying and will seek guidance from the Head of
People & Organisational Development before doing so. 
Employees who use social networking sites, emails or other forms of social
media for example to air their grievances regarding their employment or other
employees, defame or breach the confidentiality of Renfrewshire Council,
could be seen as representing Renfrewshire Council and may lead to
disciplinary action being considered. 
1.3  Harassment
1.3.1 Harassment is unwanted conduct related to relevant “protected
characteristics”, which has the purpose or effect of violating an individual’s
dignity or creating and intimidating, hostile, degrading, humiliating or offensive
environment for that individual. 
1.4 Sexual Harassment

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1.4.1 Sexual Harassment is defined in the Equality Act 2010 as ‘unwanted conduct
of a sexual nature which has the purpose or effect of violating someone’s
dignity or creating an intimidating, hostile, degrading, humiliating or offensive
environment for them’. Conduct that has any one or more of these effects can
be harassment even if the effect was not intended. 
1.4.2 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. The Equality Act 2010
enables employees to complain of behaviour that they find offensive even if it
is not directed at them. The complainant need not possess the protected
characteristic themselves.
1.4.3 The Equality Act 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. 
Examples of sexual harassment include, but are not limited to:
 sharing sexually inappropriate images or videos, such as pornography. 
 sending suggestive letters, notes, messages or e-mails.
 displaying inappropriate sexual images or posters in the workplace.
 telling lewd jokes or sharing sexual anecdotes.
 making inappropriate sexual gestures.
 abuse of authority or power by those in positions of seniority. 
1.4.4 Any sexual action that creates a hostile work environment is considered sexual
harassment, and the victim of the harassment may not only be the target of the
offence but anyone who is negatively affected by the inappropriate behaviour.
1.5 Third Party Harassment
1.5.1 Third-party harassment refers to harassment of an employee by someone who
is not a co-worker, such as a customer or contractor. While employers are not
currently liable for all forms of third-party harassment, they now have a legal
duty to take reasonable steps to prevent sexual harassment under the Worker
Protection (Amendment of Equality Act 2010) Act 2023.
1.6 Discrimination
1.6.1 Discrimination is the singling out of a particular person or group of people for
special favour or disfavour, based on stereotypical assumptions about
characteristics or interests within certain groups of people. Discrimination may
be Direct, Indirect, Associative or Perceptive.

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1.7 Direct Discrimination
1.7.1 Direct discrimination occurs when someone is treated less favourably than
another person because of a “protected characteristic” they have or are
thought to have because they associate with someone who has a protected
characteristic.
1.8 Associative Discrimination
1.8.1 This is direct discrimination against someone because they associate with
another person who possesses a “protected characteristic”.
1.9 Perceptive Discrimination
1.9.1 This is direct discrimination against an individual because others think they
possess a particular “protected characteristic”. 
1.10 Indirect Discrimination
1.10.1 Indirect Discrimination occurs when you have a condition, rule, policy or
practice that applies to everyone, but particularly disadvantages individuals
who share a “protected characteristic”.
1.11 Victimisation
1.11.1 Victimisation occurs when an employee is treated less favourably because
they have made or supported a complaint or raised a grievance, or because
they are suspected of doing so.
1.12 Favouritism
1.12.1 Favouritism is the giving of preferential treatment to one or more employees
without a valid or justifiable business/ organisational reason. Favouritism is
considered to be inappropriate behaviour when its practice has a detrimental
effect on others and has the potential to lead to bullying, harassment,
discrimination and victimisation.
1.13  Complainant
1.13.1 The employee or group of employees raising a concern about behaviour they
believe is inappropriate.
1.13.2 Can also refer to a third party (including a witness) who reports behaviour that
they believe negatively affects them or others. In some cases, the third party
may not be treated as a complainant, but concerns may still prompt an
investigation. 
1.14 Respondent

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1.14.1 The employee or a group of employees whose behaviour is being reported
under this policy.