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Two Brothers Anti-Harassment & Bullying Policy 

 Two Brothers Pictures is committed to supporting the principle of equal opportunities and opposes all forms of discrimination. Harassment is one form of unlawful discrimination which can have a detrimental effect upon health, confidence, morale and performance at work. This policy should be read in conjunction with the Equal Opportunities Policy and the Diversity and Inclusion Policy. 


Harassment is unwanted conduct whether verbal or not which is related to pregnancy or maternity, race, nationality, ethnic or national origin, age, marital or civil partner status, religion or belief, sex, gender reassignment, sexual orientation, or disability which has the purpose or effect of violating that other person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person. 

It is irrelevant that the harassment was intentional or whether the employee that suffers the harassment has the characteristic that is the reason for the harassment. 

A single incident can amount to harassment if sufficiently grave. 

Examples of harassment would include (but is not limited to) the following: 

• Banter of a sexual, racial, religious nature or based upon sexuality, disability or age or some other protected characteristic; 

• The display of material with sexual or racial overtones (even if not directed at the complainant); 

• Sarcastic personal remarks about colleagues, especially those reporting to you; 

• Over-demanding requirements; 

• Unwanted physical contact, including touching, patting, pinching, brushing against another employee’s body or indecent assault; 

• Unwelcome sexual advances; 

• Derogatory comments, ridiculing or name calling; 

• Telling jokes which are based upon sex, race, religious belief, disability, sexual orientation, age or other unlawful grounds; and 

• Offensive emails, text messages and social media content (including social media activity in and outside work). 


Bullying is also unacceptable.

Bullying is usually defined as offensive, intimidatory, malicious or insulting behaviour, an abuse or misuse of power through means that undermine, humiliate, denigrate or injure the recipient. It includes (but is not limited to) the following: 

• Direct verbal and/or physical threats; 

• Blocking access to promotion, training, overtime, etc.; 

• Setting impossible deadlines and targets; 

• Withholding information essential to do the job properly; 

• Excessively tight supervision; 

• Public humiliation including being shouted at; 

• Persistent and undue criticism including inaccurate accusations about quality of work; 

• Undermining responsibility; 

• Spreading malicious rumours; and 

• Physical isolation from other workers. 

Harassment and bullying does not have to be based on sex, race, sexual orientation, religion or belief or otherwise to be taken seriously by the Company. Any behaviour of this type, whatever the grounds, is totally unacceptable and will be dealt with appropriately. 

Please note that legitimate, reasonable and constructive criticism of a worker’s performance or behaviour or reasonable instructions given to workers in the course of their employment/engagement will not amount to bullying on their own. 

Employees shall be protected from intimidation, victimisation or discrimination for bringing a complaint or assisting in an investigation into bullying or harassment. Retaliating in any way against an employee for complaining about harassment or bullying is a serious disciplinary offence. 

Prevention of harassment and bullying 

1. Informal stage 

1.1 It is entirely in order for a recipient of unwanted conduct amounting to harassment and/or bullying to try to resolve the problem if he/she so prefers, by explaining to the individual concerned that the behaviour is not welcome, that it offends or makes the recipient uncomfortable and that it interferes with their work. 

1.2 Anyone who has been subjected to harassing or bullying behaviour may seek confidential assistance from the Group Head of HR at All3Media or such other nominated representative from another Company in the Group. 

1.3 If you prefer, where you find it too difficult or embarrassing to take up the matter yourself HR will participate in an informal meeting between you and the individual concerned or will, at your request, approach the individual on your behalf. 

1.4 The informal stage will not result in any formal internal investigation or disciplinary action but is intended to enable you to resolve the matter yourself without it going any further in the Company. 

2. Formal stage 

2.1 Where informal resolution is not appropriate, is not requested  

or where the outcome has been unsatisfactory, then you may bring a formal complaint to your Manager using the Company's grievance procedure as set out in 5.5 below. As a general principle, the decision whether to progress a complaint is up to you, but the Company has a duty to protect all staff, and may pursue the matter independently if, in all the circumstances, we consider it appropriate to do so. 

2.2 Investigations will be carried out with sensitivity and with due respect for the rights of both the complainant and the alleged harasser. All those interviewed will be permitted to be accompanied by a colleague or representative of their trade union. 

2.3 The importance of confidentiality will be stressed to all those interviewed and everyone will be strictly required not to discuss the complaint with colleagues or friends. Breach of confidentiality may give rise to disciplinary action. 

2.4 The investigation will focus on the facts of the complaint. Notes will be kept of all stages of the investigation and those interviewed will receive notes of the interview to agree. Parties will not be required to repeat distressing or embarrassing details any more than is necessary. 

2.5 Wherever possible, consideration will be given to ensuring that the complainant and the alleged harasser are not required to work together whilst the complaint is under investigation. 

2.6 The complainant will be kept informed of the general progress of the process of investigation and will be informed whether the complaint has been upheld and is to result in disciplinary action. 

2.7 Where a complaint has been upheld, consideration will be given, wherever possible, to permitting the complainant to choose whether they wish to remain in their current post or to transfer. The Company will seek to ensure that the complainant is not in any way penalised whether directly or indirectly for bringing a complaint and the situation will be monitored to ensure that the harassment has stopped. In appropriate cases a complainant may be given additional leave at the discretion of the complaint’s officer or other assistance to enable him or her to recover from the effects of harassment. 

2.8 Even where a complaint is not upheld, for example where the evidence is inconclusive, consideration will be given to effecting arrangements which will enable the parties not to continue to work together against the wishes of either party, should this be appropriate. It may also be appropriate to arrange some form of mediation. 

2.9 Any complaint made by an employee that is unfounded and not made in good faith, for example a malicious complaint, will be treated as a serious disciplinary offence. 

2.10 Details of all formal complaints of harassment will be collated by HR. These will be annually reviewed by the Group Chief Operating Officer with a view to ensuring that every effective step has been taken to prevent harassment at work and to monitor the effectiveness of the complaints procedure. 

2.11 Where the complaint is upheld and the harasser is an employee, the Company may deal with the matter in accordance with the Disciplinary Procedures in 5.4 of the Handbook (available on request). 

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