Purpose
KO is committed to a working environment free from harassment and bullying. This policy reflects KO's obligations under the Equality Act 2010 and the Worker Protection (Amendment of Equality Act 2010) Act 2023, which came into force on 26 October 2024.
Proactive Duty to Prevent Sexual Harassment
Under the Worker Protection (Amendment of Equality Act 2010) Act 2023, KO has a proactive legal duty to take reasonable steps to prevent sexual harassment of employees in the course of their employment. This includes third-party harassment (e.g. by clients, suppliers, or visitors). Failure to comply with this duty may result in the Equality and Human Rights Commission (EHRC) taking enforcement action and any Employment Tribunal award being uplifted by up to 25%.
- KO will carry out a regular risk assessment to identify situations where sexual harassment might occur.
- All employees will receive training on recognising and preventing harassment.
- Managers receive additional training on how to handle reports and implement this policy.
- The policy will be reviewed at least annually.
Definitions
- Harassment: unwanted conduct related to a protected characteristic (age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation) that has the purpose or effect of violating dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment.
- Sexual harassment: unwanted conduct of a sexual nature that has the purpose or effect described above.
- Bullying: offensive, intimidating, malicious, or insulting behaviour that involves a misuse of power and undermines, humiliates, denigrates, or injures the recipient. Bullying is not a standalone legal concept but may constitute harassment or other unlawful conduct.
Reporting
Any employee who experiences or witnesses harassment or bullying should report it as soon as possible to their line manager or, if the line manager is involved, to Panagiotis Zmpigknief Zavatzki at pazbi@kickassonline.com. All reports will be treated seriously and in confidence.
Procedure
- Reports will be investigated promptly and thoroughly by an appropriate person.
- Both the complainant and the respondent will be given the opportunity to present their account.
- Where a complaint is upheld, appropriate disciplinary action will be taken in accordance with the Disciplinary Policy.
- KO will not tolerate victimisation or retaliation against anyone making a complaint in good faith.
Policy Review
This policy will be reviewed annually, and specifically in response to any changes in EHRC guidance.
Last reviewed: May 2026.