Bullying and Harassment Policy

Date Created: February 2012

Date Last Reviewed: May 2017

Date Last Updated & Re-approved: March 2026

Next Date of Approval: March 2029

1. Purpose and Commitment

Wikimedia UK is committed to providing a safe, inclusive, and respectful environment for all employees, trustees, contractors, agency workers, and volunteers. Bullying, harassment, and victimisation are unacceptable behaviours that undermine dignity and respect at work and within our community.

This policy sets out Wikimedia UK’s approach to preventing, addressing, and resolving incidents of bullying and harassment in accordance with:

• The Equality Act 2010
• ACAS Code of Practice on Disciplinary and Grievance Procedures
• Wikimedia UK’s Equity, Diversity & Inclusion (EDI) Policy
• Confidentiality Policy (2024) and Grievance Policy (2025)

Wikimedia UK operates a zero-tolerance approach to all forms of bullying and harassment.

2. Scope

This policy applies to:

• All employees, trustees, volunteers, contractors, agency workers, and job applicants
• All Wikimedia UK activities, including events, meetings, online platforms, social media, and communications
• Conduct both in-person and online, whether during or outside working hours, where behaviour impacts Wikimedia UK or its people

3. Definitions

3.1 Harassment

As defined under the Equality Act 2010, harassment is:

Unwanted conduct related to a protected characteristic that has the purpose or effect of violating a person’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment.

Protected characteristics include: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

While socio-economic background or status is not a legally protected characteristic, Wikimedia UK recognises this as a possible subject of bullying or harassment, which also intersects with many other characteristics. For the purposes of this policy, class will be treated as a specific characteristic for which we will operate a zero-tolerance approach to bullying or harassment.  

Harassment may be:

• Verbal (offensive jokes, slurs, unwanted comments)
• Non-verbal (gestures, exclusion, offensive material)
• Written or digital (emails, messages, social media posts)
• Physical (threatening behaviour, unwanted contact)

3.2 Sexual Harassment

Unwanted conduct of a sexual nature that violates dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment.

3.3 Bullying

Persistent or one-off behaviour that intimidates, undermines, humiliates, or causes distress.

It may involve abuse of power, exclusion, malicious rumours, or setting impossible tasks.

3.4 Victimisation

Treating someone unfairly because they have made, or supported, a complaint of bullying or harassment.

4. Responsibilities

• All individuals are expected to treat others with dignity and respect, and to refrain from any form of bullying or harassment.
• Managers and trustees must lead by example and act promptly on any concerns raised.
• The Chief Executive Officer and Director of Finance & Operations are responsible for implementation, training, and oversight.
• Investigators and decision-makers must act impartially and uphold confidentiality.

5. Preventive Measures

Wikimedia UK will:

• Promote awareness through induction and ongoing training
• Embed EDI principles across all activities
• Provide accessible reporting routes and reasonable adjustments
• Monitor incidents and policy effectiveness annually

6. Reporting Concerns

6.1 Informal Resolution

Where appropriate and safe, individuals are encouraged to:

• Speak directly to the person involved, explaining that the behaviour is unwelcome
• Seek informal mediation or advice from a manager, CEO, or Director of Finance & Operations

Informal resolution may be appropriate for less serious or one-off incidents.

6.2 Formal Complaint

If informal resolution is unsuitable or unsuccessful, a formal complaint may be raised under this policy or via the Grievance Procedure.

The complainant should:

• Submit the complaint in writing to their line manager, CEO, or Chair (if the CEO is involved), clearly outlining the facts, dates, people involved, and desired outcome.

Wikimedia UK will:

• Acknowledge receipt within 5 working days
• Appoint an impartial investigator (internal or external) within 5 working days of the acknowledgement
• Offer the right to be accompanied by a colleague or trade union representative

7. Investigation Process

• Investigations will be fair, confidential, and conducted promptly
• Both complainant and respondent will be interviewed and may present evidence or witnesses
• Investigators may consult an EDI-trained advisor if appropriate
• Findings and outcomes will be communicated in writing

Where allegations are substantiated, disciplinary action may follow in line with the Disciplinary Policy, up to and including dismissal.

8. Appeals

If the complainant or respondent disagrees with the outcome, they may appeal in writing within 5 working days. The appeal will be heard by a senior manager or trustee not previously involved.

The appeal decision is final.

9. Confidentiality

All matters will be handled sensitively and in accordance with the Confidentiality Policy and Data Protection Act 2018.  Information will be shared only on a “need to know” basis.

10. Support

Wikimedia UK recognises the emotional impact of bullying and harassment. Support may include:

• Access to confidential advice or counselling
• Mediation or facilitated discussions
• Adjustments to working arrangements

No one will face retaliation for raising a concern in good faith.

11. Malicious Complaints

Deliberately false or malicious complaints will be treated as a disciplinary matter.

This does not apply where a complaint is made in good faith but not upheld.

12. Monitoring and Review

• The Director of Finance & Operations and Chief Executive will monitor application of this policy
• An annual review will assess effectiveness, with reports to the Board of Trustees
• The policy will be formally reviewed every three years or sooner if required by law or best practice

13. Related Policies

• Equity, Diversity & Inclusion Policy (2025)
• Grievance Policy & Procedure (2025)
• Confidentiality Policy (2024)
• Disciplinary Policy
• Safeguarding Policy