Introduction
This Sexual Harassment Prevention Plan is designed to help create a workplace where all employees feel safe, respected, and valued. Whirligig are committed to providing a work environment that is free from sexual harassment, discrimination, and inappropriate behaviour. This plan sets out how we will prevent sexual harassment, how we will handle any complaints that arise, and what support is available to those affected.
Scope
This plan applies to everyone in our workplace, including full-time and part-time employees, contractors, volunteers, and anyone else who interacts with our staff. It covers all areas of work, including our physical workplace, online communications, and work-related events, whether they are held on or off-site.
We believe that a harassment-free workplace is essential for the health, well-being, and productivity of our employees, and this plan will help guide us in maintaining that environment.
Identified Risks
We understand that sexual harassment can occur in any workplace, and it is important to identify potential risks early so we can take action to prevent them. Our risk assessment looks at where and how sexual harassment could happen in our workplace, considering factors such as workplace culture, employee interactions, and the nature of our work.
Based on our assessment, we have identified the following specific risks for sexual harassment in our workplace.
Table 2.1: Specific Risks for Sexual Harassment in the Workplace
| Risk Category | Description | Examples of Risk |
| Inappropriate Comments or Jokes | Verbal or written remarks that are sexual, suggestive, or offensive in nature. | Making sexual jokes or inappropriate comments during meetings or casual conversations.Sending suggestive or explicit messages via email, chat, or text.Commenting on a colleague’s appearance or clothing in a sexualised way. |
| Unwanted Physical Contact | Any non-consensual touch or physical interaction that makes someone feel uncomfortable. | Unwanted touching, hugging, patting, or kissing.Standing too close or invading personal space in an intimidating way.Unsolicited physical advances at work or work-related events. |
| Sexual Advances or Requests for Favours | Unwelcome flirtation, repeated advances, or offers of job benefits in exchange for sexual favours. | Persistently asking a coworker on dates despite rejection.Suggesting career advancement in exchange for sexual favours.Pressuring employees to engage in sexual discussions or activities. |
| Gender-Based Harassment | Discrimination, exclusion, or hostility directed at individuals based on gender or sexual identity. | Making derogatory comments about someone’s gender role or identity.Excluding women or non-binary individuals from work-related activities.Intentionally misgendering someone or making fun of gender identity. |
| Power Imbalances & Abuse of Authority | Harassment that occurs due to a power differential, where an individual abuses their authority. | A manager making inappropriate advances toward a subordinate.Threatening demotion or job loss if sexual advances are refused.Giving preferential treatment to employees who comply with inappropriate requests. |
| Workplace Social Events & Outings | Situations where professional boundaries become blurred due to a more casual environment. | Excessive alcohol consumption leading to inappropriate behaviour.Unwanted flirting or touching during work parties.Making suggestive comments or jokes in a relaxed setting. |
| Inappropriate Visual or Digital Content | Displaying, sharing, or distributing offensive, explicit, or sexually suggestive materials. | Sharing sexual memes, images, or videos in group chats.Sending explicit or inappropriate emails or texts.Displaying offensive materials on desks, screens, or workplace bulletin boards. |
| Isolation & Remote Work Risks | Increased risk of harassment due to a lack of supervision or oversight. | Employees working alone with supervisors who misuse their power.Harassment occurring via video calls, messages, or emails in remote settings.Limited witnesses or support in remote work environments. |
| Bystander Inaction | When coworkers witness harassment but do not intervene or report it. | Colleagues witnessing inappropriate behaviour but choosing to ignore it.Employees fearing retaliation if they report misconduct.A culture where harassment is normalised, leading to silence. |
| Retaliation Against Complainants | Negative actions taken against individuals who report harassment. | Demotion, unfair workload increases, or exclusion from meetings after filing a complaint.Spreading rumours or treating the complainant unfairly.Making the workplace uncomfortable for individuals who come forward. |
| Lack of Clear Reporting Channels | Employees may not know how to report harassment or fear repercussions for doing so. | Employees unsure who to report harassment to or whether they will be taken seriously.Lack of an anonymous or confidential reporting option.Complaints being dismissed or handled poorly, discouraging future reports. |
We are committed to reducing these risks by addressing them head-on and ensuring everyone knows what unacceptable behaviour is and how we will respond if it occurs.
Control Measures
Prevention Strategies
To prevent sexual harassment from occurring in the first place, we have put several control measures in place. These include:
- Clear Anti-Harassment Policy: We have a zero-tolerance policy for any form of sexual harassment or inappropriate behaviour. This policy is communicated to all employees so that everyone understands the importance of creating and maintaining a respectful work environment.
- Training Programs: We provide regular training for all employees to ensure they understand what sexual harassment is, how to recognise it, and the importance of respectful workplace behaviour. Training includes practical examples and focuses on promoting inclusivity, respect, and a supportive work environment.
- Accessible Reporting Mechanisms: We have put in place clear, confidential ways for employees to report any incidents of sexual harassment. Employees can choose from several reporting channels, including direct communication with their manager, HR, anonymous reports, or using an online platform.
Workplace Culture
We are committed to building and maintaining a workplace culture where everyone feels safe, valued, and respected. To support this, we encourage:
- Open Communication: We encourage open discussions about behaviour in the workplace. Employees should feel comfortable addressing concerns with colleagues or management without fear of retaliation.
- Diversity and Inclusion: We foster a diverse and inclusive workplace by promoting respect for different backgrounds, cultures, and perspectives. This diversity helps ensure a work environment free from discrimination and harassment.
- Respect and Zero Tolerance: We have a zero-tolerance policy toward sexual harassment. Any inappropriate behaviour is taken seriously, and we are committed to addressing it promptly and effectively.
Support Mechanisms
We want to ensure that those affected by sexual harassment have the support they need. To provide this:
- Counselling and Support Services: Employees who experience sexual harassment are encouraged to access counselling services. We offer support for affected individuals, including assistance through Employee Assistance Programs (EAP), if needed.
- Disciplinary Procedures: Any employee who engages in sexual harassment will face disciplinary action, which may include counselling, training, warnings, or even termination, depending on the severity of the behaviour.
By putting these prevention measures in place, we aim to reduce the likelihood of harassment and foster a supportive environment where all employees can thrive.
This plan will be reviewed and updated at least once every three years or after a complaint of sexual harassment has been made to ensure it remains effective and in line with legislative requirements.
Reporting Complaints
We understand that reporting sexual harassment can be difficult, but it is important that any incidents are brought to our attention so we can address them. Employees have several options for making a complaint, including:
- Direct to HR or Manager: Employees can speak directly to a designated HR representative or their manager. We encourage all employees to come forward with concerns, as we are committed to handling reports confidentially and respectfully.
- Anonymous Reporting: If employees feel more comfortable, they can submit a complaint anonymously through our secure online reporting platform. We will investigate anonymous reports with the same level of seriousness as those made directly.
- Third-Party Reporting: If employees do not feel comfortable reporting harassment internally, they are encouraged to report it to external bodies such as Fair Work Australia or the Australian Human Rights Commission.
Employees who report sexual harassment have the right to:
- Confidentiality: We will maintain confidentiality throughout the process to protect the privacy of all parties involved. Only those who need to know will be informed of the details.
- Protection from Retaliation: Employees who make a complaint will not be retaliated against in any way. Retaliation is strictly prohibited, and any acts of retaliation will be addressed immediately.
- Fair Process: All complaints will be handled in a fair and timely manner. The complainant will be kept informed of the process and any actions taken in response to the complaint.
By ensuring that employees feel safe and supported when making a complaint, we can take appropriate action to address any issues and ensure a respectful workplace.
Investigation Process
Once a complaint is received, we will take the following initial steps to begin the investigation:
- Acknowledge the Complaint: The person handling the complaint will acknowledge receipt of the complaint as soon as possible, ensuring the complainant knows their report has been received and will be taken seriously.
- Assess the Situation: A preliminary assessment will be made to determine the severity of the complaint and whether immediate actions are needed to ensure the safety and well-being of the complainant.
- Confidentiality Assurance: We will remind the complainant and all involved parties about the importance of confidentiality throughout the investigation process.
Upon receiving a complaint, immediate steps will be taken to protect the complainant, such as temporary reassignment, remote work arrangements, or a leave of absence, if necessary, while the investigation is ongoing
Investigation Procedures
Our investigation process is designed to be fair, thorough, and respectful of all parties involved. The key steps include:
- Interviewing the Complainant: The complainant will be interviewed to gather all necessary details about the incident(s) of harassment, ensuring that they feel heard and supported.
- Interviewing the Alleged Harasser: The person accused of harassment will also be interviewed to provide their side of the story. They will be informed of the complaint and given an opportunity to respond.
- Witness Interviews: If applicable, relevant witnesses will be interviewed to gather additional information about the incident(s) and understand the context surrounding the situation.
- Gathering Evidence: The investigator will gather any physical evidence, such as emails, messages, or documents, that may support the claims of harassment.
- Assessment and Findings: After completing the investigation, the findings will be carefully reviewed. The investigator will determine whether the allegations are substantiated and what, if any, action should be taken.
Disciplinary actions will range from mandatory training and counselling to formal warnings, suspension, or termination of employment, depending on the severity of the harassment.
Timelines for Investigation
We aim to complete investigations promptly while ensuring thoroughness. Typically, investigations should be concluded within [X] weeks from the date the complaint was received. However, some cases may take longer depending on the complexity of the issue. The complainant and the alleged harasser will be kept informed of the investigation’s progress.
Whirligig are committed to handling investigations fairly and with respect for all individuals involved, ensuring that all parties can be heard.
Informing Relevant Parties
Once the investigation is complete, the results will be communicated clearly and respectfully to both the complainant and the alleged harasser. The key steps include:
- Informing the Complainant: The complainant will be informed of the outcome of the investigation. They will be provided with a summary of the findings, including any actions that have been taken or will be taken in response to the complaint. We will ensure that the complainant understands the outcome and the steps moving forward.
- Informing the Alleged Harasser: The individual accused of harassment will also be informed of the investigation’s outcome. If the complaint is substantiated, they will be made aware of any disciplinary actions or corrective measures that will be implemented.
- Confidentiality Maintained: While informing both parties, confidentiality will be respected. Specific details about the other party’s statements or any personal information will not be shared unless it is necessary for the resolution of the matter.
Follow-Up Actions
After the results are communicated, the following steps will be taken:
- Support for the Complainant: If the complainant remains affected by the harassment, we will provide ongoing support, including access to counselling services or Employee Assistance Programs (EAP).
- Corrective or Disciplinary Actions: If the investigation confirms that sexual harassment occurred, appropriate actions will be taken, including counselling, additional training, or disciplinary measures up to and including termination, depending on the severity of the incident.
- Prevention Measures: We may implement additional measures to prevent future harassment, such as refresher training, policy reviews, or changes to the work environment, depending on the findings.
Both the complainant and the alleged harasser will be given the opportunity to follow up on the investigation’s outcome. If the complainant feels that their issue has not been fully addressed or if they have concerns about the process, they may request further clarification or appeal the decision.
Whirligig are committed to ensuring a transparent process that supports both the complainant and the alleged harasser throughout the investigation, while also taking appropriate action to resolve the matter and prevent future harassment.
Training and Awareness
Employee Education
To ensure all employees are aware of what constitutes sexual harassment and how to prevent it, we provide mandatory training for all staff. This training includes:
- Definition of Sexual Harassment: Employees will learn what sexual harassment is, including examples of inappropriate behaviour such as unwanted comments, physical contact, and any conduct based on gender or sexual orientation that creates a hostile work environment.
- Recognising Harassment: Employees will be taught how to recognise sexual harassment, both as victims and bystanders, and the importance of speaking up or reporting when they witness or experience such behaviour.
- Reporting Procedures: Employees will be educated on the different ways they can report incidents of sexual harassment, emphasising that they have the right to raise concerns in a safe, confidential environment without fear of retaliation.
- Respectful Workplace Practices: The training will also cover how to foster a respectful and inclusive workplace where everyone feels valued and safe.
Management and Supervisor Training
In addition to general staff training, supervisors and managers will receive additional training to ensure they understand their specific responsibilities in preventing, addressing, and investigating complaints of sexual harassment. This training includes:
- Handling Complaints: Managers will be trained on how to handle complaints professionally, respectfully, and confidentially, ensuring they respond appropriately if a complaint is made directly to them.
- Supporting Affected Employees: Managers will learn how to support employees who may be affected by sexual harassment, providing guidance on offering support and connecting individuals to resources like counselling services.
- Investigating Complaints: Managers will be trained on how to manage investigations, including gathering evidence, conducting interviews, and ensuring a fair process for all parties involved.
Regular Reviews and Updates
To keep training relevant and effective, we will review and update our training materials regularly. This ensures that our employees and managers stay informed about any changes to policies, regulations, or best practices related to sexual harassment prevention.
At the end of each training session, employees will complete an anonymous feedback survey to assess the effectiveness of the session. The results will be used to update and improve future training.
In addition, we will offer refresher training annually to all staff to reinforce our commitment to a harassment-free workplace and ensure that everyone is aware of their rights and responsibilities.
Accessibility and Awareness
It is important that all employees have easy access to the Sexual Harassment Prevention Plan. To ensure this, the plan will be made available in the following ways:
- Intranet/Shared Platform: A copy of this plan will be uploaded to the company’s intranet or shared digital platform where all employees can easily access it at any time.
- Hard Copies: Hard copies of the plan will be available in common areas such as the break room, HR department, or any other accessible location within the workplace.
- On Request: Employees who prefer a physical copy or require assistance in understanding the plan can request it directly from their manager or HR. We are committed to making sure that everyone has access to the information they need.
Communication with Employees
We will communicate the existence of the Sexual Harassment Prevention Plan to all employees in the following ways:
- Onboarding for New Employees: All new employees will be introduced to the plan as part of their induction process. They will receive a copy of the plan and will be required to acknowledge that they have read and understood it.
- Ongoing Reminders: Regular reminders about the plan, reporting procedures, and the importance of maintaining a respectful work environment will be communicated during team meetings, through internal emails, and on notice boards.
- Management’s Role: Managers and supervisors will ensure that their teams are aware of the plan and know where to find it. They will also emphasise the importance of adhering to the policies outlined in the plan during team discussions.
Ensuring Understanding
It’s not enough for employees just to have access to the plan – they need to understand it as well. We will ensure that all employees are familiar with the key points of the plan by:
- Clear Language: The plan is written in straightforward, easy-to-understand language, avoiding legal jargon and technical terms.
- Training and Discussion: The key components of the plan will be reviewed during regular training sessions and discussions, ensuring employees understand the reporting processes, their rights, and their responsibilities.
By making the plan accessible and ensuring that employees are aware of it, we are fostering a transparent and informed workplace where everyone understands their role in preventing and addressing sexual harassment.
Conclusion
Whirligig provide a workplace where everyone is treated with dignity, respect, and fairness. This Sexual Harassment Prevention Plan is an essential part of our commitment to creating and maintaining a safe work environment. We take sexual harassment seriously and believe that every employee has the right to work in an environment free from harassment and discrimination.
This plan is not just a document; it reflects our values and our pledge to ensure the well-being of every individual within our workplace. We recognise that fostering a respectful and safe workplace is an ongoing process, and we will continue to improve and adapt our practices as needed.
Point of Contact
For any questions or concerns regarding this Sexual Harassment Prevention Plan, or if you need support or guidance, please contact:
| IMS Manager’s Name: | {{Name 2}} | Phone: | {{Phone 2}} |
| Email: | {{email 2}} |
Alternatively, you can reach out to any member of the management team or use our reporting channels for further assistance.
Together, we can create a positive, inclusive, and harassment-free workplace. Thank you for your commitment to maintaining a safe and respectful work environment for everyone.
Consultation
This plan was developed in consultation with Whirligig employees, workplace representatives, and relevant parties, including our health and safety committee. Their input has helped shape the prevention strategies and reporting mechanisms in place to ensure the plan is both effective and practical for our workplace.
Consultation involved:
- Employee Surveys: Anonymous surveys were conducted to assess perceptions of workplace safety and identify areas of concern.
- Staff Meetings & Workshops: Employees participated in discussions about sexual harassment risks, prevention strategies, and reporting procedures.
- Feedback from Health & Safety Representatives: The company engaged with workplace safety representatives to ensure compliance with WHS obligations.
- HR & Leadership Input: Management and HR worked collaboratively with staff to ensure all perspectives were considered.