Workplace Guide: Bullying

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Effective policy & procedure | Top ten steps


Improving Reporting

As noted earlier, LGB staff do not always feel able to report bullying and harassment and existing policies and procedures may not work for them. Employers should therefore identify further ways to engage with their LGB staff, offer them support and ensure that they feel able to report any bullying and harassment. Failure to do so may result in the loss of talented staff and costly legal action.

The key elements are:

Changing organisational culture

Tackling discrimination cannot be done in isolation. Organisations which prevent anti-gay bullying and harassment are not only targeting that specific problem – they are also creating a workplace where sexual orientation equality is a familiar concept and where LGB staff feel able to participate. In many cases, these organisations are workplaces where no form of discrimination is tolerated. Stonewall has found that organisations which tackle anti-gay bullying and harassment will tend to be organisations which deal with all types of bullying and harassment effectively.

Any policy designed to protect and promote the rights of LGB staff will deliver better results in coordination with other equality initiatives, such as senior support for LGB equality, comprehensive diversity training, LGB staff network activities or sexual orientation monitoring. Changing organisational culture will take time and requires commitment and consistency, but it can reap big rewards.


Until 2000, LGB people could be dismissed from the Royal Navy simply for their sexual orientation, meaning that an anti-gay culture was endemic. To overcome this problematic organisational culture, the Navy is working to ensure that its LGB staff are protected from discrimination. As a modern employer it also wants to change its outdated reputation and attract prospective LGB employees.

The Navy has become an active member of Stonewall’s Diversity Champions programme, with prominent support from senior staff. It has also implemented full equalities training and has produced a handbook which includes information on sexual orientation equality. Staff are trained to be aware of the difference between bullying or harassment, and a lawful direct order. Equal Opportunities Advisers are on board every ship and have received training in LGB issues, and additional support is available from Chaplains, a confidential support line and an LGB staff support group. As a hierarchical organisation, the Navy sees the prevention of anti-gay bullying and harassment as a leadership issue which must ultimately be tackled by those in authority.


BT’s anti-bullying campaign, Let’s Cut it Out, is aimed at tackling all types of bullying and harassment. It was launched following responses to a question about bullying in the annual employee survey in which a number of respondents reported they had either been bullied, or had witnessed bullying. Equally, a number of respondents had opted to ‘prefer not to say’ whether they had been bullied, which might indicate that staff did not feel safe reporting the problem.

Whilst the number of respondents to both questions was relatively small compared with the 110,000 people employed, BT felt that this still represented an unacceptable situation and developed the Let’s Cut it Out programme to eradicate bullying within the company. After the launch of the campaign, the following year’s employee survey generated fewer ‘prefer not to say’ responses, and while the actual incidence of bullying or witnessed bullying had not decreased, progress was definitely being made in terms of reporting – a vital step towards eradicating the problem.

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Developing structures for gay staff

There is a range of initiatives organisations can undertake in order to engage specifically with their LGB staff and ensure they are protected from, and can freely report, bullying and harassment. Preventative measures are often similar to those designed for staff with disabilities or from ethnic minority groups. These measures will indicate to staff who may be vulnerable to discrimination that they are valued and their needs are recognised.


PricewaterhouseCoopers offers an Employee Assistance Programme to all staff. This is a confidential counselling service which is run by an external agency. The counsellors are familiar with the firm’s policies and procedures and can advise and support staff who believe they are being bullied or harassed.

In order to ensure the scheme was fully accessible to LGB staff and that the counsellors were equipped to deal with sexual orientation issues, the firm’s LGB staff network held a series of meetings with the agency. They discussed the potential issues which LGB staff might face and examined how the counsellors would deal with them. Further sexual orientation training was implemented and LGB staff have the option of requesting an LGB counsellor for telephone and face to face support. An article about this aspect of the scheme was posted on the firm’s intranet portal, and continues to be publicised by the staff network.


As part of its informal conflict resolution procedure, Manchester City Council has a team of up to 16 Conciliation Officers who can mediate for and support employees who are experiencing bullying or harassment at work. Conciliation Officers receive training in mediation, which is accredited by The Law Society, and this equips them to resolve conflict in a non-judgemental, positive and supportive way. They are also briefed on the council’s dispute resolution processes.

The council has recognised that some LGB people may feel more comfortable receiving support from someone who has personal experience of sexual orientation issues, so it publicises the fact that LGB Conciliation Officers are available. This is an integral part of the council’s diversity and inclusion strategy and aims to ensure LGB employees remain at the council, helping the workforce to reflect the local community.


Part of HM Prison Service’s equalities work includes Gays and Lesbians in the Prison Service (GALIPS). GALIPS was set up following an investigation by the national LGB staff forum into the incidence and extent of discrimination across the prison service, and an estimation of the cost that the prison service would incur if cases were taken to employment tribunals. 

GALIPS is run by two full time members of staff, along with a national committee comprising National and Deputy Chairs, and two staff from each region. The committee then works with establishment contacts within each prison. These are officers who volunteer their time to act as a contact point for members and to communicate issues at a local level. As well as raising awareness of LGB issues across the prison service, GALIPS provides a confidential telephone service that enables staff to report anti-gay bullying and harassment, access support and receive advice on how to proceed. GALIPS staff can also accompany complainants to meetings and tribunals for bullying and harassment cases.


Staff and students at Cardiff University who experience bullying and harassment can call a confidential central contact point, which will then refer them to the university’s network of Dignity Advisers. This network has been created to support the use and implementation of the university’s Dignity at Work and Study Policy. Dignity Advisers are volunteers who have received training in equality, diversity and university policy and procedure. They provide  advice and support to staff and students who feel they have been bullied or harassed, before and during the informal resolution stage. Two Dignity Advisers have been recruited from the University’s LGB staff network, to support LGB staff who want to speak to an Adviser with personal experience of LGB issues. Dignity Advisers acquire valuable skills that can help in their career, and are given teaching relief to carry out their duties.

Lothian and Borders Police employs a force liaison officer from the Gay Police Association who is part-funded by the Association of Chief Police Officers in Scotland and the Scottish Executive. The liaison officer holds regular drop-in sessions out of office hours, and is available for confidential meetings if staff require. There is also a third-party reporting scheme for LGB individuals who are too intimidated to report bullying and harassment directly – they can report incidents via the force liaison officer, who can mediate on their behalf. Posters publicising the service are on display in all offices, including front desks and public areas.


The Scottish Executive’s LGB staff network runs a confidential mailbox for communication from staff including the reporting, in confidence, of bullying and harassment. If a message is received, it is anonymised and sent to the HR team. The network then relays HR’s advice to the individual and works with them to resolve the issue sensitively. For new LGB recruits who want to access the network’s support and activities, but who are anxious about doing so, there is also a buddying scheme run by network members.

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Implementation

Key elements of the implementation of an effective policy and procedure are:

  • Leadership
  • Training
  • Consultation
  • Communication

LEADERSHIP To be credible, any initiative designed to prevent antigay bullying and harassment needs to be endorsed and validated by senior staff. This will ensure LGB staff have confidence that homophobia is an issue the organisation genuinely wants to address. It will also send a strong message to staff who perpetuate bullying and harassment of LGB staff that this will not be tolerated, and that the consequences will be serious.

It is also essential that all managerial staff are confident in implementing policy and helping to prevent anti-gay bullying and harassment. Some research suggests that the majority of workplace bullies are in fact managers. Those in positions of responsibility should be equipped to protect their LGB staff, and should not be allowed to ignore or condone discrimination.

At Accenture, reinforcing the understanding of policies and procedures is part of the promotion process for new managers and senior managers. The firm believes that with more responsibility, managers must be equipped with sufficient knowledge to protect their LGB staff from bullying and harassment. They must also be conscious of their own part in creating an inclusive workplace which does not inadvertently exclude LGB staff. Part of their training therefore includes tackling inappropriate office banter and analysing and modifying their own language in order to set the right tone within their team.


Through diversity training, Nationwide’s managers are trained to recognise and identify bullying and harassment, including on the grounds of sexual orientation. To reinforce confidence in the company’s policies, Nationwide believes it is important that its managers can deal with problems quickly and demonstrate to complainants, as well as the wider workforce, that they are handling problems effectively.


PricewaterhouseCoopers produces guides for managers to help them deal effectively with difficult or sensitive issues which could occur within their teams. One of these guides specifically looks at how to deal with any incidents of bullying or harassment on the grounds of sexual orientation.

TRAINING Training is an effective way to ensure policies are understood in practice. Staff who receive equalities training and are aware of the organisation’s position on anti-gay bullying and harassment will know what behaviour will not be tolerated at work. They will also be aware of the kind of support that is available if they do experience discrimination. Training is also an opportunity to raise awareness of the Employment Equality (Sexual Orientation) Regulations, and the related rights and responsibilities.


New recruits at PricewaterhouseCoopers undertake a mandatory equality and diversity e-learning programme. This includes bullying and harassment, and specifically covers the effects of anti-gay office banter and offensive jokes. Case study scenarios portrayed by actors highlight the impact on individual staff members as well as the wider organisation. The programme, established in 2004, has also been rolled out to existing staff.

All staff at Lothian and Borders Police undertake three days of compulsory equalities training. Half a day is spent on sexual orientation equality, with an external specialist organisation. Issues covered include bullying and harassment, and also policy, procedure and expected conduct in both work and service delivery. An active understanding of diversity in policy and practice is integral to career progression and promotion in the force. All senior staff attend five days of advanced training in this area.

CONSULTATION In order to develop and maintain an effective system which prevents antigay bullying and harassment, but also tackles the problem if it does arise, consultation with key stakeholders is vital. This is an important way of ensuring policy and procedure are tailored to the individual workforce, and will enable constructive feedback on their implementation and function.

Key stakeholders can include:

  • LGB staff networks
  • Senior management
  • Trade unions or staff associations

Stonewall’s Workplace Guide, Network Groups: Setting up networks for lesbian, gay and bisexual employees, explores how organisations can develop the consultative potential of their LGB staff networks.

Manchester City Council developed its Dignity at Work policy in consultation with the Lesbian, Gay, Bisexual and Trans (LGBT) Employee Group. The group’s members were able to provide information on the nature of anti-gay bullying and harassment, and on where LGB staff faced particular barriers to reporting. LGB Conciliation Officers have been recruited, and they are consulted on how the policy is working in practice for LGB staff.

Nationwide works closely with the Nationwide Group Staff Union, which incorporates the LGBT Advisory Committee, to develop policy and procedure and to ensure its reporting structures are fully accessible to all staff.BT’s LGBT staff network Kaleidoscope was involved in the firm’s Let’s Cut it Out anti-bullying campaign. The network liaised with


BT’s personal counselling service to ensure it was equipped to handle LGB-specific issues. Following the launch of the campaign, Kaleidoscope carried out a membership survey which included a specific question on anti-gay bullying and harassment, to assess the impact of the campaign on LGB staff. This will be repeated in future surveys to enable the tracking of any trends.


When developing structures to support LGB staff, PricewaterhouseCoopers consulted its lesbian and gay staff network and used its online discussion database to find examples of LGB issues in the workplace, including how bullying and harassment might affect LGB staff.

COMMUNICATION Effective communication of the organisation’s position on anti-gay bullying and harassment is essential for:

  • Creating a working environment which is productive and where everyone is valued
  • Ensuring LGB staff know their rights and where to get help
  • Informing the wider workforce of acceptable and unacceptable behaviour
  • Preventing anti-gay bullying and harassment at a grass-roots level and complying with the law

There are a number of practical ways to communicate anti-bullying messages to the wider workforce using existing infrastructures, such as intranet systems and in-house publications, as well as notice boards and staff briefings. It is important that communications on policies and procedures are repeated if the make-up of the workforce experiences any major changes, such as mass recruitment or a merger.


BT launched its anti-bullying campaign, Let’s Cut it Out, in June 2005. The aim of the campaign was to reinforce the message that bullying behaviour, including anti-gay bullying, is not acceptable. BT launched an intranet site containing links on identifying and reporting bullying, also featuring interactive scenarios to stimulate debate. An animation about bullying was also emailed to all staff.

Middle and senior managers from each area of the business attended a campaign briefing, to ensure they could disseminate key messages and resource materials to their teams and were able to provide their teams with training and support. Speakers at the event included BT’s Chairman and Chief Executive and experts on the nature of bullying. Campaign resources included:

  • A video about bullying and its emotional, psychological and financial impact

  • Videos depicting bullying scenarios in different areas of the business

  • An interactive theatre and discussion piece

  • Wristbands to indicate support for the campaign

    An additional video, aimed at witnesses of bullying who do not speak up, is being developed. The message is that all employees have a responsibility to tackle the problem.

Accenture raises staff awareness of its policy on bullying and harassment, which includes anti-gay bullying, through:

  • The employee mentoring programme

  • A telephone helpline

  • The Accenture UK LGBT Network

  • A compulsory annual exercise to update and re-familiarise all staff with company policy

  • The induction procedure


Cardiff University publicises its Dignity at Work and Study Policy using:

  • Staff training and induction

  • Staff and student intranet

  • The equality and diversity website

  • The LGB staff network’s website

  • Posters with a central contact number

  • Pamphlets with simplified summaries of policy and procedure

  • The electronic noticeboard

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Measuring effectiveness

It is good practice to monitor and evaluate the uptake and effectiveness of any policy and procedure on a regular basis. Monitoring can be used to examine patterns of bullying and harassment and to clarify how reporting structures are being accessed. This will enable an organisation to evaluate how successful those structures have been, and whether they need  to be adapted to respond to the needs of the workforce.

HR departments should ensure they are able to collect this information on the nature of bullying and harassment complaints, including whether the complaint relates to sexual orientation. In some cases, it may be possible to obtain formal or informal feedback on anti-bullying policy and procedure from complainants and others after the process has been completed.

Many organisations include specific questions about the experience of bullying or harassment in their staff surveys. This can also include questions about the existence of various types of bullying in the organisation, awareness and understanding of organisational policies and procedures for tackling bullying, and feedback on employees’ experience of these procedures.


Nationwide uses questions in its employee opinion survey to ask about sexual orientation. This information can be compared with responses to questions about experiences of bullying and harassment. The organisation can therefore examine and respond to any differences in experience between its LGB employees and the rest of its workforce.

BT monitors incidents of bullying and harassment via its central contact point, where employees can initially report the problem. Incidents are monitored by the type of bullying, as well as location within the business.By including sexual orientation in its workforce diversity monitoring, Lothian and Borders Police can track its retention of LGB staff. The force also asks employees how confident they would feel about reporting bullying and harassment. This enables the force to assess the effectiveness of its reporting mechanisms, and make changes if necessary. HR also records the nature of grievances, including anti-gay bullying and harassment cases.


Cardiff University has a central contact point, which deals with initial queries about bullying and harassment. This mechanism conducts anonymous monitoring on the nature of the complaint, including whether it was sexual orientation-specific. This indicates how far LGB staff appear to be using the system, and will enable the university to take positive action if necessary.

The university is currently developing a survey tool, which can be accessed through the intranet noticeboard. This will ask about experiences of all types of bullying and harassment and should provide a snapshot of what is happening across the university. The LGB staff network is also developing an online anonymous discussion space. Any discussion around bullying and harassment will feed into the on-going development of policy and procedure.

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