Brasenose College Policy and Procedure on Harassment

Version 1.1. Approved by Governing Body March 2026

1. Policy Statement - Brasenose College

1.1 Brasenose College does not tolerate any form of harassment (including sexual harassment), bullying or victimisation.

1.2 Harassment includes sexual harassment. The College does not tolerate sexual harassment by any of our employees against a third party, and does not tolerate sexual harassment of our employees, students or of anyone else in College.

1.3 Brasenose College expects all members of the College community, its visitors and contractors to treat each other with dignity, respect, courtesy and consideration.

1.4 Brasenose College is committed to fostering an inclusive culture which promotes equality, values diversity and maintains a working, learning and social environment in which the rights and dignity of all members of the College community are respected.

1.5 Brasenose College will investigate and log all reports of harassment, bullying or victimisation seriously, sensitively and confidentially. These may lead to disciplinary action including potential termination of employment.

2. Policy Aims

2.1 Promote that Brasenose College is committed to fostering a positive environment in which people are treated fairly and with respect.

2.2 Make it clear that all forms of harassment (including sexual harassment), bullying and victimisation are unacceptable, recognising that those behaviours may cause harm, physically or emotionally, and that all members of the College have an active role to play in creating an environment free from these behaviours.

2.3 Provide a framework of support for all members of the College community who feel they have been subject to these behaviours.

2.4 Provide a mechanism by which complaints can wherever possible be addressed in a timely way.

3. Policy Scope & Responsibilities

3.1 Applies to all members of the College, this includes all employees, fellows, students and third parties such as contractors and visitors to the college.

3.2 Covers harassment which includes sexual harassment and sexual harassment from a third party, bullying and victimisation.

3.3 Those in positions of authority within the College, such as the Governing Body, Senior Tutor, Dean, Chaplain, Equality and Diversity Fellow and Bursar, have formal responsibilities under this Policy and are expected to familiarise themselves with the Policy and Procedures on appointment.

3.4 All senior members of the College have a duty to implement this Policy and to make every effort to ensure that harassment and victimisation do not occur in the areas for which they are responsible and that, if they do occur, any concerns are investigated promptly and effectively.

3.5 All members must comply and demonstrate active commitment to this Policy and Procedures by:

a. Treating others with dignity and respect, behaving professionally towards each other.
b. Discouraging any form of harassment by making it clear that such behaviour is unacceptable; and
c. Supporting any member of the College who feels they have been subject to harassment, including supporting them to make a formal complaint if appropriate.

3.6 This Policy covers all harassment (including sexual harassment), bullying and victimisation which occurs primarily within the college environment (i.e. either on college premises in Brasenose or at another college, or on college business or at a college event, or online).

3.7 Incidents of harassment between staff or students at the University that occur outside the college environment and/or solely within the University environment will normally be dealt with under the appropriate University procedure.

3.8 If there is doubt as to whether the college or University procedure applies, you are advised to seek advice from one or more of the relevant college officers described in this Procedure, the Harassment Advisor Network, the University’s Harassment Line or University’s Director of Student Welfare and Support Services. See Annexe B for further support details.

3.9 For matters relating to a member of University staff who is not linked to the College please consult the University Harassment Policy/Procedure.

3.10 If a complaint is made to the College and there is doubt whether it should be considered by College or University, the Bursar or Dean will consider the circumstances and determine whether the incident should be considered a College matter, or a University matter (and so refer it to the Proctors), or whether it is too remote to fall within the College jurisdiction.

3.11 This Policy and Procedures should be read alongside other college policies and procedures, including the College disciplinary procedures for employees and for students, the student handbook, and policies on Freedom of Speech and IT usage. These can be found at: http://www.bnc.ox.ac.uk/about-brasenose/official-information or our Staff Intranet.

4. Guidelines & Definitions

4.1 General Guidelines on Harassment, Victimisation & Bullying

4.1.1. Annexe A sets out a non-exhaustive list of examples of such behaviours to support these definitions.

4.1.2 Harassment may involve repeated forms of unwanted and unwarranted behaviour, but a one-off incident can also amount to harassment.

4.1.3. The intentions of the alleged harasser are not always determinative of whether harassment has taken place. Harassment does not have to be intentional. If the conduct has the effect of violating a person’s dignity or creating a proscribed environment, it can still amount to harassment even if the perpetrator did not intend for it to have that effect. However, the effect of the conduct is assessed from the subjective perspective of the victim, and it must also be reasonable for the conduct to have caused such an effect. For example, if the victim is unreasonably sensitive, the conduct may not meet the threshold for harassment.

4.1.4. Being under the influence of alcohol or drugs, or otherwise intoxicated, is not an excuse for harassment or bullying.

4.1.5 Harassment and bullying can take a variety of forms:

a. Individual behaviour: Either directly to the person or via a third party. This could be face to face, either verbally or physically or via other forms of communication, including but not limited to written communications and communications via any form of electronic media or mobile communications device *Note: such behaviour may also amount to a breach of the college’s regulations relating to the use of Information Technology.
b. Through a prevailing workplace or study environment which creates a culture which tolerates harassment or bullying.

4.1.6 Harassment and bullying are often confused. Bullying behaviour can be harassment if it meets the definitions below.

4.1.7 It’s possible that serious harassment could also be a hate crime.

4.2 Harassment Definitions

4.2.1 In discrimination law (Equality Act 2010) there are 3 types of harassment:

a. harassment related to certain ‘protected characteristics’
b. sexual harassment
c. less favourable treatment for rejecting or submitting to unwanted conduct of a sexual nature or that is related to gender reassignment or sex.

Harassment Concerning Protected Characteristics

4.2.2 Defined under the Equality Act 2010 (EqA 2010) as unwanted conduct related to a relevant protected characteristic that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment for them. Relevant protected characteristics include age, disability, gender reassignment, race, religion or belief, sex, and sexual orientation.

4.2.3 Therefore, harassment related to marriage and civil partnership, or pregnancy and maternity, does not fall within this provision. However, harassment because of these protected characteristics could give rise to sex or sexual orientation harassment claims. Alternatively, such conduct could amount to direct marriage and civil partnership discrimination or pregnancy and maternity discrimination.

Sexual Harassment

4.2.4 Unwanted conduct of a sexual nature or related to gender reassignment that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment.

4.2.5 Refer to Annexe A for example behaviours.

Less Favourable Treatment

4.2.6 Treating someone less favourably because they have submitted to or refused to submit to unwanted conduct of a sexual nature.

Third-Party Sexual Harassment

4.2.7 Third-party sexual harassment of Brasenose workforce is unlawful and will not be tolerated. The law requires employers to take steps to prevent sexual harassment by third parties. The College will also take steps to reduce the risk of harassment of our students and other College members by third-parties.

4.2.8 In employment law, third-party sexual harassment occurs when one of Brasenose’s employees or workers is subjected to sexual harassment by someone who is not part of our workforce but who has had contact in connection with work. This includes our students, customers, suppliers, members of the public, guests, friends and family of colleagues, delegates at a conference etc.

4.2.9 Outside the workplace, the law does not provide a mechanism for individuals to bring a claim of third-party harassment under the Equality Act, but other civil or criminal legal remedies may still apply. Within the workplace, failure by an employer to take reasonable steps to prevent third-party sexual harassment may result in legal liability for the employer.

4.2.10 Different procedures apply in different circumstances:

If any member of the Brasenose community (including an employee) is harassed by a third party in the College or in a College setting the College will warn the third party about their behaviour and may take steps to prevent risk of future harassment, including potentially banning them from Brasenose premises. Any criminal acts will usually be reported to the police.
If any member of the Brasenose community (including an employee) is harassed in a College setting by a Brasenose student, then the applicable procedure is “Procedure A: Complaints of harassment against a Student”; if they are harassed by another employee or member of College other than a student, then the applicable procedure is “Procedure B: Complaints of harassment against a member of College other than Student”.
If they are harassed outside the College setting, the College will usually not have any formal responsibility and will usually not be able to apply its disciplinary procedures, but may take informal steps to talk to both parties in order to increase awareness of the unacceptability of harassment, to mediate between members of College and to reduce the risk of future incidents.

Prevention of third-party harassment

4.2.11 Brasenose College will inform third parties i.e. suppliers, of our zero-tolerance sexual harassment policy within our supplier documentation.

4.2.12 In order to reduce the risk of third-party sexual harassment from occurring risk assessments will be conducted.

4.3 Bullying Definition

4.3.1 Bullying is characterised as unwanted behaviour that is either: offensive, intimidating, malicious or insulting, or an abuse or misuse of power that undermines, humiliates, or causes physical or emotional harm to someone or causes them to feel isolated or excluded.

4.3.2 The recipient does not need to have explicitly stated that the behaviour was unwanted.

4.4 Victimisation Definition

4.4.1 Victimisation is subjecting someone to detrimental treatment because they have done, or you believe that they have done or may do one or more of the following:

a. Make an allegation of harassment or discrimination.
b. Indicate an intention to make such an allegation.
c. Assist or support another person in bringing forward such an allegation.
d. Participate in an investigation of a complaint.
e. Participate in any disciplinary hearing arising from an investigation.
f. Take any other steps in connection with this Policy.

4.5 Freedom of Speech and Academic Freedom

4.5.1 These are protected by law and central tenets of College life as set out in our Code of Practice on Freedom of Speech. However, these rights must be exercised within the law. Exposure to any of the following is unlikely to amount to harassment:

a. The content of higher education course materials, including but not limited to books, videos, sound recordings, pictures
b. Statements made and views expressed by a person as part of teaching, research or discussions about any subject matter which is connected with the content of a higher education course;
c. Vigorous academic debate when conducted respectfully and without violating the dignity of others or creating an intimidating, hostile, degrading, humiliating or offensive environment for them.

4.5.2 However, in some cases otherwise-lawful speech can amount to harassment if the time, place, and/or manner of its expression interferes disproportionately with the rights of others. For example, speech which is acceptable as part of a formal debate on a controversial topic might nonetheless constitute harassment if delivered unprompted to an individual with a relevant protected characteristic in a social context.

4.5.3 Reasonable management/criticism of work or the commencement of internal college procedures are not within themselves a form of bullying or harassment.

Application of the Policy

5.1 Harassment (including Sexual Harassment), bullying and victimisation are serious forms of misconduct. Members of the College community who consider that they have been subject to harassment, bullying or victimisation or have witnessed such behaviour are encouraged to make a complaint via the appropriate procedure.

5.2 For full processes, refer to our website for ‘Procedure A – Complaints of Harassment Against a Student’ and ‘Procedure B – Complaints of Harassment Against People Other Than Students’. In brief these could include:

Formal Procedures

5.3 Wherever possible, the College will be guided by the wishes of those who have been subjected to alleged harassment in determining whether or not to begin formal procedures and in general will only usually investigate if they have received a report. However, the College reserves the right to investigate in the absence of a report from the person who has been subjected to alleged harassment or where they do not wish any action to be taken in certain circumstances (for example, where the alleged behaviour indicates a risk to others in the College community).

Informal Resolution

5.4 Where appropriate and where the alleged victim wishes, reports of harassment, bullying or victimisation may be resolved informally without recourse to formal investigation or other procedures. This does not mean no action is taken, just that other routes to resolutions and improvements are agreed and implemented.

Precautionary Measures

5.4 Where necessary, the College may also implement precautionary measures to ensure the safety of those involved or others on the College site. These may include (but are not limited to) the suspension or action short of suspension under the Colleges Investigations & Disciplinary Procedures.

Criminal Offences

5.5 When a criminal offence may have been committed, the relevant Procedures may not be appropriate. These cases will include, but not be limited to, serious assault or threat of serious assault. Student members can seek advice from Dean or Senior Tutor, and/or approach the Police directly; and staff members can seek advice from HR, Domestic Bursar or Bursar and/or approach the Police directly.

Support

5.6 Members of the College community who feel that they have been subjected to harassment, bullying or victimisation or have witnessed such behaviour or who are the subject of an allegation of such behaviour can find welfare support and/or support and advice on the options available to them from a variety of different sources. Annexe B sets out a list of resources and the various sources of support available.

Complaints in Good Faith Vs Malicious Complaints

5.7 No action will be taken against someone making a report of harassment, bullying or victimisation which proves to be unfounded if the report is judged to have been made in good faith. However, if someone is deemed to have known or to have reasonably been expected to know that a report was unfounded and the allegations made in bad faith, the allegation of harassment, bullying or victimisation may be judged to be vexatious or malicious, and disciplinary action may be taken in accordance with the relevant disciplinary procedure.

Confidentiality

5.8 All parties involved in a matter (including any witnesses who may be interviewed as part of any investigation, or other members of the College community, and/or trade union representatives supporting any of the parties) should maintain the confidentiality of the process. Where possible, those involved in advising complainants should seek the consent of the individual for the onward disclosure of relevant information to those with a clear need to know. Where such consent is not forthcoming, the person entrusted with the information should make it clear that, in exceptional circumstances, it may be necessary to disclose the information. If a matter proceeds to disciplinary action, the allegations would need to be put to the accused who has a right to see the evidence against them. Whilst anonymous allegations and evidence can be used, such anonymised evidence can carry less weight than where the accused is aware of who the accuser is. We understand this can make people feel disinclined to make allegations, and all reasonable support will be provided.

Complaints against the Handling of a Report

5.9 If an employee is not satisfied with the outcome following the investigation of the formal written complaint, they may refer to the Principal who will make the final College decision and advise the complainant on the right to seek an external review. A Completion of Procedures letter should be issued.

6. Access, Monitoring & Review

6.1 This Policy and procedures may be found at http://www.bnc.ox.ac.uk/Intranetabout-brasenose/official-information or the college intranet. Copies in alternative formats are available on request.

6.2 This policy is reviewed regularly (every three years, or when new legislation is applied) to ensure it remains up to date. HR are responsible for reviewing with Governing Body having overall responsibility for the policy.

6.3 This policy does not form part of employees’ terms and conditions of employment and may be subject to change at the discretion of Brasenose College.

Annexe A: Example Behaviours

1. Behaviours that may amount to harassment

1.1 Repeated unwanted and unwarranted behaviour

1.1.1 Sharing or publishing any statement or material about an individual that could cause them alarm or distress, or making statements that purport to come from some else that may cause them alarm or distress.

1.1.2 Posting offensive comments on electronic media, including using mobile communication devices.

1.1.3 Tampering with, or taking any property that belongs to another person.

1.1.4 Sending a threatening message to more than one person or repeatedly sending someone threats of violence or harm.

1.1.5 Following, spying watching someone repeatedly, in person or online (stalking).

1.1.6 Sending graphic content, such as violent or hateful images, to someone.

1.1.7 Offensive comments, including insults, jokes or gestures and malicious rumours.

1.1.8 Displaying open hostility, or making verbal or physical threats. This includes all forms of harassment and abuse on the grounds of disability, race, sexual orientation, or other protected characteristics.

1.1.9 Humiliating, intimidating, insulting, abusive, embarrassing or patronising behaviour or comments.

1.1.10 Demeaning criticism without providing constructive support to address any performance concerns.

1.1.11 Persistently shouting at, insulting, threatening, disparaging or intimidating an individual.

1.1.12 Persistently overloading an individual with work that they cannot reasonably be expected to complete.

1.1.13 Threatening to disclose, or disclosing, a person’s sexuality or disability to others without their permission.

1.1.14 Isolation from normal work or study place, conversations, or social events.

1.1.15 Being excluded, criticised or ignored e.g Excluding someone from normal work or study related conversations after they have previously rejected an unwanted sexual advance.

1.2 Related to protected characteristics:

1.2.1 Jokes or derogatory comments about someone’s disability.

1.2.2 Verbal and physical threats, or intimidating behaviour linked, for example, to gender reassignment, sex or sexual orientation.

1.2.3 Sending memes mocking another person’s religion to that person.

1.2.4 Repeatedly questioning an individual’s qualifications or right to be on a course or in a position at work based on aspects of their background, such as their gender, ethnic or racial identity.

1.2.5 Consistently excluding someone from group work due to perceived religious, cultural, or gender differences.

1.2.6 Publishing, circulating or displaying pornographic, racist, homophobic, sexually suggestive or otherwise offensive pictures or other materials.

1.2.7 Deliberately using the wrong name or pronoun in relation to a transgender person, or persistently referring to their gender identity history.

2. Related to Sexual Harassment

2.1 Inappropriate body language such as standing unnecessarily close to someone or staring at them in a way that feels uncomfortable or intimidating.

2.2 Unwelcome touching or physical contact such as hugging, massaging, placing a hand on someone’s thigh, lower back, or shoulder.

2.3 Sending unwanted sexual messages or emails, text messages or messages via other social media that are humiliating, disrespectful or aggressive.

2.4 Displaying or sharing pornographic or sexual images, or other sexual content, sexual posts or contact in online communications including on social media.

2.5 Making repeated sexual comments about someone’s body or appearance.

i. Sexually explicit remarks, gestures, innuendoes or jokes that may be referred to as ‘banter’.
ii. Grooming or similar gradual development of relationships where there is an imbalance of power in the relationship.
iii. Making unwanted propositions and sexual advances.
iv. Making promises in return for sexual favours.
v. Intrusive questions about a person’s private or sex life or a person discussing their own sex life.
vi. Spreading sexual rumours about a person.

3. Behaviours that may amount to bullying

3.1 Constantly putting someone down and giving them unfair criticism in a work or study setting.

3.2 Excluding someone from events or study groups.

3.3 Putting humiliating, offensive or threatening comments or photos on social media.

3.4 Mocking someone because of their socio-economic background.

4. Behaviours that would not amount to harassment or bullying

4.1 Receiving constructive and reasonable criticism or instruction from your line manager. College Officers, officials to students or staff given reasonably and with due purpose and in respectful and appropriate ways.

4.2 Reasonable criticism by a tutor (or another student in a tutorial context) of a student’s work.

4.3 The commencement of an internal college procedure e.g. student or staff disciplinary.

Annexe B: Support Available

If you feel you have experienced harassment, bullying or victimisation there are a number of people who are available to help and assist you by clarifying the options open to you assisting you throughout the resolution of your concerns, whether formally or informally. Reference procedures on our website for ‘Complaints of Harassment – Student Related’ and ‘Process Guidance – Complaints of Harassment – Non-student Related’ for specific guidance but there is also:

1. Brasenose College

Students who feel they have been harassed, bullied or victimised can raise this/seek advice from:

The Dean
Sub Dean
Senior Tutor
Tutor for Graduates
Equality & Diversity Fellow
The Chaplain

Alternatively refer to points 2 and 3 for external advice and support.

Non-Academic Staff who feel they have been harassed, bullied or victimised can raise this/seek advice from:

Line Manager
Human Resources Manager: Holly Richards-Morris: holly.richards-morris@bnc.ox.ac.uk
Human Resources Director: Kirsten Morgan: Kirsten.morgan@bnc.ox.ac.uk
Bursar: Philip Parker: philip.parker@bnc.ox.ac.uk
Equality & Diversity Fellow
The Chaplain

Academic Staff who feel they have been harassed, bullied or victimised can raise this/seek advice from:

Senior Tutor: Freyja Madsen: freyja.madsen@bnc.ox.ac.uk
Human Resources Director: Kirsten Morgan: Kirsten.morgan@bnc.ox.ac.uk
Bursar: Philip Parker: philip.parker@bnc.ox.ac.uk Equality & Diversity Fellow
The Chaplain

All Staff

Brasenose Employee Assistance Confidential Support Care First.

2. Oxford University Resources/Support

University Harassment Advisors Network

Harassment Advisor Network | Equality and Diversity Unit: A network for staff who feel they have been harassed or bullied.

Tel. 01865 270760 or e-mail harassment.line@admin.ox.ac.uk

Note: Harassment Advisors will not approach the alleged harasser on behalf of an individual.

Information and training on bystander intervention and how to support others safely. No formal steps are needed to speak with someone. Responsible Bystander | Equality and Diversity Unit

Peer Support

In addition to the above there are options for informal discussion with the following: Peer Support

This link to the University Website provides information on how peer support at Oxford works and how you can contact and find different peer supports be that college, departmental, divisional as well as coffee ambassadors, peers of colour, rainbow peers, peers of faith and disability diversity peers.

Oxford SU Student Advice Service: Advice and information service exclusively available to Oxford Students.

Tel. 01865 288452 or e-mail enquiries@oxfordsu.ox.ac.uk

Oxford University Counselling Service

Oxford University Counselling Service

Sexual Harassment and Violence Support Service

Oxford University Sexual Harassment & Violence Support Service A safe space to be heard, with advisors offering free support and advice to any current student impacted by sexual harassment or violence.

Supporting Students at Oxford: Preventing and Responding to Harassment and Sexual Misconduct | University of Oxford

The University ISVA Service Independent of a student’s college or department. Can support as an advocate if reporting sexual violence to their college, the Proctors Office or police. Information on the criminal justice process as well as support.

3. External Resources

Further Support | University of Oxford – This site provides details of organisations locally and nationally providing specialist support to individuals affected by sexual harassment.
Sources of advice | Equality and Diversity Unit
Women who’ve experienced sexual harassment at work can get free legal advice from Rights of Women– England and Wales.
Samaritans
LGBT Foundation
Galop– LGBT+ sexual violence support
Rape Crisis England and Wales
The Survivors Trust
SurvivorsUK– male rape and sexual abuse support
Victim Support– in England and Wales

4. To contact the police

Call 999 in an emergency
Call 101 if it’s not an emergency
Report a crime online in England and Wales

When you’re reporting a crime, you can ask to speak to a specialist officer who’s trained to deal with sexual violence.

5. Accused of harassment/bullying/victimisation:

The above resources are all available as well for those accused of harassment, bullying or victimisation.

A confidential specialist support service for students who are subject to an allegation of harassment or sexual misconduct.

NOTE: if both the reporter and the subject of a report both seek welfare support and advice the welfare team/human resource lead will make sure that an adviser is available for both people and that confidentiality is preserved.