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Want to stay on the right side of the law? We support businesses and public authorities and help them to promote good practice.
 
 

Harassment and Bullying

Harassment and bullying in the workplace


Harassment and bullying at work continue to be an unpleasant fact of life for some employees. Employers can work to change this by putting in place policies and procedures to create and sustain inclusive workplaces.
 


What is harassment and bullying?

 
Harassment and bullying are commonly seen as being behaviours of an offensive, oppressive or intimidatory kind that, whether deliberately or not, cause their victims to feel physically and/or emotionally hurt or distressed.
 
In legal terms there are subtle differences between the terms harassment and bullying. Further information on these terms is provided in the tabs above, but in summary:
 

  • Harassment refers to offensive, oppressive or intimidatory behaviour that is connected to a protected equality ground. It is a form of discrimination that is prohibited by the anti-discrimination laws. The protected equality grounds are: sex, pregnancy and maternity, gender reassignment, marital or civil partnership status, religious or similar philosophical belief, political opinion, race, colour, ethnic or national origins, nationality, sexual orientation, disability and age. Anti-discrimination laws prohibit two forms of harassment, one of which is sexual harassment.
 
  • Bullying is similar in that it too is offensive, oppressive or intimidatory behaviour, but it is not connected to a protected equality ground. It is not deemed to be a form of unlawful discrimination under the anti-discrimination laws, although there may be legal remedies for it under other areas of employment law.

Types of misconduct

  • Physical misconduct such as assaulting a person, sexually or otherwise, or making obscene gestures
 
  • Verbal misconduct such as making racist, sexist, sectarian or homophobic remarks; making derogatory comments about a person’s age or disability; or singing songs of this nature
 
  • Visual or written material containing racist, sexist, sectarian, homophobic or other derogatory words or pictures (e.g. in posters, graffiti, letters, emails, text messages or on social media posts)
 
  • Isolating a person (e.g. “sending them to Coventry”) or refusing to co-operate or help them at work or by excluding them from work-related social activities
 
  • Forcing a person to offer sexual favours, or to take part in religious or political activities, or penalising them for rejecting such requests or pressure
 
  • Intruding on a person’s private space by pestering, stalking or spying on them whether on or off the business premises
 

Locations

Employers’ policies should be designed to protect employees from being harassed or bullied in the course of their employment. As such, it should be recognised that such policies apply to misconduct that might occur in various locations, such as, but not necessarily limited to:
 
  • on the business premises during or outside working hours
 
  • during work-related activities outside the business premises
 
  • during work-related social events (e.g. Christmas parties), whether on the business premises or outside them
 
  • on the internet or other telecommunication devices, such as social media, during or outside working hours
 

Harassment or bullying by third-parties (i.e. customers, clients, etc.)

Although employers’ policies and their associated grievance procedures are generally directed at protecting their employees from harassment and bullying of them by their employers and co-workers, it should be recognised that employees could also be exposed to the same or similar misconduct from third-parties; i.e. other people who are not employees of the organisation but who employees may encounter during the course of their work, such as customers, clients, residents or patients (or their visitors). Employers should seek to protect their employees from such third-party harassment or bullying.
 

What is an inclusive workplace?

An inclusive workplace is one where all employees feel welcome, valued and respected. In such a workplace:
 
  • Managers and supervisors are aware of their responsibilities to challenge harassment and bullying and have the skills to effectively implement relevant policies and procedures.
 
  • Appropriate measures to prevent harassment and bullying are taken in a timely and professional manner.
 
  • The employer works with staff and trade unions or employee representatives to develop an inclusive workplace.
 
  • Employees are aware of the different types of unacceptable behaviour and the potential consequences of engaging in such behaviour or allowing such behaviour to go unreported.
 
  • Employees are confident they can raise a complaint without detriment and that their complaint will be dealt with according to the policy or procedure in place.
 

Step 1: Corporate commitment

Ensure ongoing Senior Management and/or Board communication of your commitment to an inclusive workplace.
 
This will likely include a vision for an inclusive workplace, how it will be achieved and/or maintained, the corporate values which form the basis of your inclusive workplace and how these will be embedded.
 
Your policy should underpin these commitments.
 
Employers commonly express these commitments in policies that are variously named: Equal Opportunities Policy; Harassment Policy; Dignity-at-Work Policy; Diversity Policy. The name itself is not particularly important, but their content is. To assist you to draft your own, we have created a number of model policies and procedures and recommend that you consult our Model Equal Opportunities and Harassment Policies.
 

Step 2: Assess the current situation

It is important to assess how you are currently performing in terms of achieving an inclusive workplace. You should firstly determine the current situation.

Determine the Current Situation


Do you…?
 
  • Commit to an inclusive workplace during induction training?
 
  • Train staff on their rights and responsibilities, that is, what are acceptable and unacceptable behaviours and what to do where these are not met?
 
  • Provide additional training to managers and supervisors on their specific responsibilities?
 
  • Ensure staff training is provided regularly and is evaluated?
 
  • Have relevant policies and procedures that are regularly reviewed and consult with staff and trade unions or employee representatives on these?
 
  • Monitor the number and type of complaints and tribunal cases, reviewing any trends and learning points?
 
  • Take opportunities to listen to staffs’ views and experiences, for example during exit interviews and through staff forums?
 
  • Ensure that any learning from grievances, exit interviews, etc., is translated into any relevant actions to promote inclusion?

A good way to involve staff and their trade unions in these processes and to ensure their “buy-in” is to jointly develop and issue a Joint Declaration of Protection, a document that declares your shared commitment to jointly creating an inclusive workplace.
 
To assist you to draft your own Joint Declaration of Protection, a Model Declaration has been published by the Northern Ireland Employment Relations Roundtable, an association of employers’ representatives and the trade unions. The model Declaration is endorsed by the Equality Commission and the Labour Relations Agency.
 

Step 3: Communicate your commitment

Clearly communicate this commitment to all staff including management, on an ongoing basis, using the most suitable methods of communication for your own workplace.
 
Detailed information and the sources of available support should be available to staff through your company intranet, from your line managers and/or human resources. Managers and those with responsibility for implementing procedures are likely to require more detailed guidance. They should be aware where they may obtain this guidance so that they may effectively challenge unacceptable behaviours and ensure harassment and bullying policies and procedures are implemented.
 

Step 4: Train staff and managers

Staff training ensures that employees and trade union or employee representatives are aware of and understand what behaviours are acceptable in the workplace, their responsibilities to adhere to workplace policies, the consequences of unacceptable behaviours, and also that employees have the confidence to make a complaint if they feel they have been harassed or bullied.
 
Training for senior managers/board members, managers and supervisors should enable them to meet their specific responsibilities of effectively challenging harassment and bullying and implementing your policies and procedures. Likewise, if appointed, harassment advisors should be trained so that they are clear with regard to their role and responsibilities and have the necessary skills to effectively support an individual.
 
Without appropriate training, other actions, such as developing new policies and procedures, are likely to be ineffective. Employment tribunals have clearly established the need not only for good policies and procedures to exist but also that employees are aware they exist, know how to use them and that they are put into visible practice.
 

Harassment Advisors

Many employers appoint harassment advisors to support an employee who feels that they have been subjected to bullying and/or harassment. It is important that the role and remit of harassment advisors are set out in your policy and procedure and that harassment advisors have received appropriate training to ensure that they can fulfil their role with sensitivity and awareness of the processes .
 

Step 5 Implement policies and procedures

Each employer should have effective procedures for dealing with harassment and bullying. You may develop stand-alone harassment and bullying procedures or you may prefer to use your grievance procedure to investigate alleged instances of harassment and bullying. Whichever approach is taken must be clearly communicated.
 
Procedures dealing with harassment and bullying should:

 
  • Outline opportunities for support internally e.g. Human Resources, trade union or employee representatives, harassment advisors.
 
  • Include informal and formal processes.
 
  • Outline roles and responsibilities of those involved in the procedure.
 
  • Outline the timeframes.
 
  • Explain possible outcomes.
 
  • Be aligned with your other policies and procedures (e.g. equality of opportunity, discipline, health and safety, safeguarding, whistleblowing, performance management), and not conflict in any way with their principles.
 
  • Make reasonable adjustments for disabled people.
 
It is not only your employees who can initiate a complaint of harassment or bullying. You, as the employer, may initiate a formal investigation where you become aware of potential bullying or harassment. This may include becoming aware of inappropriate behaviours, or any patterns/ trends from monitoring behaviours that have been dealt with through informal procedures.
 
Model Procedures - To assist you to draft your own procedures, we have developed model procedures that contain our recommendations for appropriate content. We recommend that you consult our
model Joint Grievance and Harassment Procedure (Word doc) or our model standalone Harassment and Bullying Procedure (Word doc).
 
The following points from our model procedures are worth noting:
 

Informal Stage

 
  • Will enable an individual to take appropriate actions to resolve their complaint outside the formal procedures and
 
  • Can be extremely valuable, in resolving disputes before attitudes and behaviours become entrenched and established.
 
      But:

 
  • The informal procedure will not result in an investigation or disciplinary action and may not be appropriate to use in all circumstances.
 

Formal Stage:

 
  • Will provide details of the investigation process, including arrangements for meetings and hearings.
 
  • Will provide outcome and appeal provisions, and ensure that there is a reference to the disciplinary procedure as a potential outcome.
 
  • Will ensure protection of complainant from further harassment and victimisation.
 

Step 6: Monitor and review progress

Your policies, practices and procedures for dealing with harassment and bullying should be monitored and evaluated on a regular basis to ensure that they are effective.
 
You can assess the effectiveness of your current policies, practices and procedures by engaging with your staff and trade union or employee representatives to establish how confident employees are about raising issues and making complaints. Are they listened to and taken seriously? Will their complaints be dealt with subject to the procedure and in a timely manner?
 
In addition, you should examine the number and types of harassment and bullying complaints made by your employees both in respect of internal grievances and cases to tribunals.

 

A Quick Checklist

 

  • Anti-discrimination legislation affords protection on grounds of sex, pregnancy and maternity, marital or civil partnership status, gender reassignment, religious or similar philosophical belief, political opinion, disability, race, colour, ethnic or national origins, nationality, sexual orientation and age.
 
  • Be aware of other relevant legislation, in particular with regard to bullying (see the Appendix).
 
  • Commit to an inclusive workplace with a no-tolerance approach to bullying and harassment.
 
  • Develop and implement a workplace policy and procedure to address complaints of harassment and bullying.
 
  • Legal liability, including awards for damages can fall not only on the organisation but also on named individuals.
 
  • The burden of proof in harassment cases is likely to be on the balance of probabilities – i.e. is it more likely than not that it happened.
 
  • The employer’s duty of care extends to everyone, including the alleged victim, perpetrator and others.
 
 
 

Definitions


The terms harassment, bullying and victimisation are terms that are often used interchangeably. Their dictionary definitions provide a flavour of what commonly connects these forms of behaviour and why they are deemed to be so hurtful to those who are on the receiving end.

 

Definitions given in the Concise Oxford English Dictionary

Harassment - To torment by subjecting to constant interference or intimidation.

Bullying - To deliberately intimidate or persecute those who are weaker.

Victimisation - To single someone out for cruel or unjust treatment.
 

Nevertheless, it is important to note that in equality and employment law there are legal differences between the definitions that are used in that context: harassment is different to bullying, although they have some similarities too, and both are different again to victimisation.


In short, the main legal differences are:

 

 

  • Harassment

Under the anti-discrimination statutes, behaviour that is offensive, oppressive or intimidating and, crucially, which is connected to a protected equality ground (such as sex, religious belief, race, sexual orientation) is called harassment and is deemed to be a form of unlawful discrimination. Consequently, those laws provide legal remedies for those who are victims of it.[1]
 

 

  • Bullying

Bullying is usually deemed to be behaviour that is offensive, oppressive or intimidating and repetitive but which is not connected to a protected equality ground. Consequently, it is not deemed to be a form of unlawful discrimination under the anti-discrimination laws and those laws provide no legal remedies for it; although there may be remedies for victims under other areas of employment law.
 

 

  • Victimisation

Victimisation is a form of discrimination prohibited by the anti-discrimination laws and occurs where an employer treats an employee or job applicant less favourably than they treat or, would treat, others because the victim has previously exercised their rights under the anti-discrimination laws, or has assisted another person to do so.
 
Victimisation is essentially a form of retaliation, e.g. an employer is retaliating against a person who previously made a discrimination allegation by refusing, on that account, to offer them, for example, a promotion or other benefit. Victimisation can take many forms such as refusing to offer the victim a job, a promotion or a pay rise, or by dismissing them. It can also take the form of harassing a person; i.e. subjecting the victim to offensive, oppressive or intimidating behaviour.

 

 


[1] The protected equality grounds are: sex; pregnancy and maternity; gender reassignment; marital or civil partnership status; religious or similar philosophical belief; political opinion; race, colour, ethnic or national origins, nationality; sexual orientation; disability; age.

 
 

   
< Harassment & Bullying (main page)
 

Defining Sexual Harassment


The anti-discrimination statutes prohibit two forms of harassment in workplaces, one of which includes sexual harassment. These terms are defined as follows:

 

Harassment

Harassment occurs where a job applicant or employee is subjected to unwanted conduct on a protected equality ground and where that conduct has the purpose, or the effect, of violating their dignity, or of creating for them an intimidating, hostile, degrading, humiliating or offensive environment.
 

Sexual harassment

Sexual harassment occurs where a job applicant or employee is subjected to unwanted verbal, non-verbal or physical conduct of a sexual nature and where that conduct has the purpose, or the effect, of violating their dignity, or of creating for them an intimidating, hostile, degrading, humiliating or offensive environment.
 
It also occurs where a person is treated less favourably than others for having rejected, or submitted to, unwanted conduct of the kind just described.

Many forms of misbehaviour may amount to harassment; examples include:
 
  • Physical conduct such as assaulting a person, sexually or otherwise, or making obscene gestures.
 
  • Verbal conduct such as making racist, sexist, sectarian or homophobic remarks; making derogatory comments about a person’s age or disability; or singing songs of this nature.
 
  • Visual or written material containing racist, sexist, sectarian, homophobic or other derogatory words or pictures (e.g. in posters, graffiti, letters, text messages or emails).
 
  • Isolating a person (e.g. “sending them to Coventry”) or refusing to co-operate or help them at work or by excluding them from work-related social activities.
 
  • Forcing a person to offer sexual favours, or to take part in religious or political activities.
 
  • Intruding on a person’s private space by pestering, stalking or spying on them.
 

Unwanted conduct - Banter

One of the conditions necessary for behaviour to be deemed to be harassment is that it is unwanted; or, in other words, the victim does not invite it or wish to be on the receiving end of it.
 
The kinds of behaviour illustrated in the preceding textbox are clearly of a kind that reasonable people would not want to be subjected to and it will usually be quite obvious that it is unwanted. However, sometimes it may not always be so clear.
 
This confusion is more likely to arise in relation to so-called banter, which the Concise Oxford Dictionary defines as being “the playful and friendly exchange of teasing remarks”. If the exchange of such remarks is genuinely friendly between all who participate in it then it may be appropriate to conclude that it is wanted, as opposed to unwanted.
 
But, employers should always be careful not to readily excuse poor behaviour on the grounds that it is alleged by some of its participants to be merely a form of wanted banter. A closer and objective examination of all the facts may disclose that it is actually unwanted by some and is not friendly or playful at all but is, in fact, hurtful; i.e. in other words, it is actually harassment.

 

Does It count if an employee sends jokes to work colleagues?

Tribunals recognise that workplace banter can and does occur, and where that behaviour is reciprocal, is taken in good spirit and is seen as unthreatening then it may not constitute harassment. However, it is also recognised that perceptions and circumstances must be taken into account. In the words of one tribunal ruling (in the case of Grimes –v- Unipork Limited, Fair Employment Tribunal, 1992):
 

‘What is banter for some may be intimidating and embarrassing for others. What is banter today may be dangerous tomorrow. There should be no place in the workplace for conduct which has the potential to disrupt the harmonious working environment.’


 

Purpose of the unwanted conduct

Harassment can occur even if the unwanted conduct is not intended to be offensive (see below). But, if a person intends to hurt another, then that will certainly be harassment. Recognising this can also be important for deciding what penalty it would be appropriate to impose, so it would be important to consider the question when investigating allegations of harassment. For example, intentional misconduct may justify sterner penalties, such as demotion or dismissal.

 

Unintended harassment – the effect of the unwanted conduct

Although the law states that harassment can occur even if the unwanted conduct is not intended to be offensive, oppressive or intimidating that does not mean that all incidents where offence is unintentionally given will necessarily be deemed to be harassment.
 
But, employers should always be careful not to readily excuse allegations of harassment on the grounds that the offence given is alleged by the perpetrator to be unintentional or accidental. Therefore, employers should not readily accept such excuses as: “it was just banter”, for closer investigation may show that it is more sinister than that.
 
When investigating allegations of harassment, employers should carefully examine all of the circumstances in which the incident or incidents occurred and try to decide whether, in the light of that, a reasonable person would conclude that the allegations amount to harassment (i.e. that they are offensive, oppressive, intimidating, etc.).
 
The test is an objective one, albeit that weight must be given to the victim’s subjective perception of the matter. Therefore, when considering all of the circumstances in which the incident or incidents occurred, consideration must also be given to the victim’s perception of the matter.

 

Liability for harassment

If an employee is subjected to harassment in the course of their employment, they will likely look to their employer to stop it and to provide a remedy. As a matter of good practice employers should always try their best to protect their employees.
 
That does not necessarily mean, however, that the employer will be liable under equality law to compensate the employee for any harassment that they experience; although usually the employer will be so liable. Whether the employer is held liable depends on a number of factors, such as who committed the act(s) of harassment and in what circumstances, and on whether the employer took reasonably practicable steps to prevent it occurring.
 

(a) employer’s liability for their own acts of harassment

Where the employer, such as the owner of a small firm, himself (or, herself) commits the acts of harassment, then he (or, she) will be deemed to be liable for that.
 

(b) employer’s liability for the acts of their employees

All too frequently, acts of harassment are not committed by an employer themselves, but by their employees; e.g. a manager or a co-worker harassing one of their fellow team members. Nevertheless, the law will deem the employer to be liable for that harassment if it is carried out by the employee in the course of their employment.
 
That term has a wide meaning and can include situations where the harassment occurs when the employees are working at the main business premises or at other work sites, or, even, remotely from home. In can also include harassment that occurs at work-related social events, such as at Christmas parties held in hotels or bars.
 
It is not an unlimited term, however, and the law recognises that in some cases harassment between co-workers could occur in circumstances that are wholly unconnected to the work and the workplace. In such cases, the employer would not be held liable for it.
 
In cases of doubt it would ultimately be for an industrial or fair employment tribunal to decide whether the circumstances in which the alleged harassment occurred are so closely connected to the work and the workplace that it can be said to have been done in the course of the employment.
 

(c) employee’s liability for their own acts of harassment

The law does not place liability solely on an employer for unlawful acts of harassment committed by their employees in the course of their employment. Those employees are deemed to have aided and abetted their employers in committing those unlawful acts and are deemed to be jointly liable with their employer for them.
 
It means that the employee who commits harassment against a co-worker may also have to compensate his or her victim, either jointly with the employer and, sometimes, solely.
 

(d) employer’s liability for the acts of their agents

The law also deems an employer to be liable for any acts of harassment committed against one of their employees by an agent of the employer. An agent could be someone who is performing work or other tasks on behalf of the employer, such as an agency worker, or a business or occupational health consultant, or a security guard on the premises who is employed by a separate firm engaged by the employer to provide security services there.
 
That agent is deemed to have aided and abetted the employer in committing the unlawful acts and is deemed to be jointly liable for them too, meaning they are liable to compensate the victim.
 

(e) employer’s liability for the acts of customers and clients

With one exception (see below), anti-discrimination law does not deem an employer to be liable in law for any acts of harassment committed against their staff by people who are not the employer’s own employees or agents.
 
Such people are often called “third-parties” and include customers in a shop, bar, hotel or restaurant; patients in a hospital (or their visitors); residents in a care home (or their visitors); pupils in a school (or their parents); passengers on a bus or train.
 
The exception relates to acts of harassment that are prohibited by the Sex Discrimination (NI) Order 1976; namely, sexual harassment and any other harassment that is related to sex or gender reassignment. The situations in which an employer will be held liable for such third-party harassment are-
 
  • the employee is harassed in the course of her employment by the third-party
  • the employee has been harassed by that third-party (or others) on two or more previous occasions
  • the employer knows about the previous occasions, and
  • the employer has failed to take reasonably practicable steps to prevent the employee from being harassed by the third-party
 

(f) taking reasonably practicable steps to prevent harassment

The law provides employers with a legal defence that may allow them to avoid liability for acts of harassment committed by their employees and, where relevant, third-parties where they can prove that they took reasonably practicable steps to prevent the act(s) of harassment occurring. This basically requires an employer to continually follow and apply the kinds of good practice guidelines that are set out in this publication.


   
< Harassment and Bullying (main page)
< Definitions
 

Defining Bullying


Bullying is usually deemed to be behaviour that is offensive, oppressive or intimidating but which is not connected to a protected equality ground.
 
Thus, the types of behaviour that illustrate bullying may include acts like assaulting an employee, making derogatory, overcritical or other unfair comments (verbal or written) to or about them, isolating them, intruding on their personal space; albeit that the behaviour will not be motivated by or otherwise related to a protected equality ground, but may be associated with other reasons such a jealousy or personal dislike or revenge or insecurity.

Unlike harassment, there is no statutory definition of bullying for the purposes of employment law.

Addressing Bullying in Schools Act (NI) 2016
Interestingly, the only statutory definition of bullying that exists comes from this education law which applies for the protection of pupils in schools.


‘[Bullying] includes...the repeated use of any verbal, written or electronic communication, or any other act or omission, or any combination of these by a pupil…against another pupil…, with the intention of causing physical or emotional harm to that pupil…’


Another useful, but non-legal, definition (drafted by the former trade union MSF) that has stood the test of time is:

Persistent, offensive, abusive, intimidating, malicious or insulting behaviour, abuse of power or unfair penal sanctions, which makes the recipient feel upset, threatened, humiliated or vulnerable, which undermines their self-confidence and which may cause them to suffer stress.
 

Repetition and persistence

As these definitions indicate, one of the hallmarks of bullying behaviour is that it is usually repetitious and persistent. Another area in which it may differ from equality-related harassment is that the latter an sometimes occur in relation to a single one-off act.

 

Motive or intent

The law affords intent a low priority. It is less interested in the why than the “what” and, in particular, the outcome or how the person has been affected.

 

Reasonableness

While the law recognises that we are all different, that we each perceive the world uniquely, and that circumstances change, ultimately the test of what ‘counts’ has to rest on the construct of reasonableness.
 
This is not to deny our individuality, nor that many people feel deeply upset and aggrieved by how they may have been treated, but without the application of a test of reasonableness then the effective management of bullying would be almost impossible.


Does it count If a staff member is monitored and supervised more closely because of poor performance?
In legal claims relating to bullying, the tribunals or courts are likely to apply a test of reasonableness. If the alleged victim is complaining that his manager is bullying him by criticising his work performance standards, yet where he has consistently underperformed and that performance is not connected with being harassed or bullied, and it has been dealt with fairly and recorded appropriately, then it is unlikely to constitute the basis for a claim.

 

Legal remedies for bullying

Given the features of bullying that are outlined above, a victim would not, by definition, be able to bring a complaint to an industrial tribunal under the anti-discrimination laws.
 
There may, however, be remedies available to them under other laws which may be enforceable in industrial tribunals and/or the civil courts. Examples may include:
 
  • a claim for unfair (constructive) dismissal – but only if they have left their employment as a result of their treatment and have sufficient length-of-service to bring such a claim
 
  • a claim for breach of contract – based on alleging that the employer has breached the implied term of mutual trust and confidence that all employment contracts contain
 
  • a claim for compensation for personal injury under common law (negligence) or for breach of statutory health and safety at work law
 
  • a claim for compensation under the Protection from Harassment (NI) Order 1997 – this is a law developed to combat stalking but which is wide enough to protect people from any persistent conduct that causes them distress or alarm.[1]
 
These causes of action each have their own peculiarities and conditions. Further information may be obtained from the Labour Relations Agency.
 
By following the good practice guidance outlined here employers will significantly reduce the likelihood that any member of their staff will be subjected bullying behaviour. If, despite that, such behaviour does occur, employers will still be in a much better position to defend any legal claims brought against them than if they had not followed these steps.

 
 
[1] The name of the Protection from Harassment (NI) Order 1997 is somewhat confusing. Its definition of harassment is different to that which applies under the anti-discrimination laws. For example, the conduct does not need to be related to a protected equality ground but it does require the conduct to have occurred on two or more occasions. The latter is not a requirement for an act to be deemed to be harassment under the equality laws, for single, one-off acts may be enough in that context.
 
 
< Harassment and Bullying (main page)
< Definitions
< Defining Sexual Harassment
 
 
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