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Anti-Bullying and Harassment Policy and Procedure

Equra College London
Version: 1.0
Approved by: Governing Body / Academic Board (as applicable)
Effective from: 25/01/2026
Review date: 15/01/2026 (annual review)
Owner: Equality Lead / Head of Student Services / Safeguarding Lead


1. Purpose

Equra College London (“Equra”) is committed to a safe, respectful learning and working environment. Bullying, harassment, sexual harassment, hate incidents and victimisation are not tolerated.

This policy sets out:

  • What bullying and harassment mean at Equra;
  • How to report concerns;
  • The support available; and
  • The investigation process and outcomes.

2. Scope

This policy applies to:

  • All students, applicants (where relevant), visitors, guest speakers and staff;
  • Conduct occurring on campus, online, off-site activities, placements, partner venues, and Equra events.

This policy covers student-to-student and student-to-staff concerns. Staff-to-staff matters are managed through internal HR processes, with appropriate safeguarding/EDI principles applied.


3. Definitions

Bullying: Offensive, intimidating, malicious or insulting behaviour, or an abuse/misuse of power that undermines, humiliates or causes harm. Bullying may be a single serious incident or repeated behaviour.

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

Sexual harassment: Unwanted conduct of a sexual nature (comments, gestures, messages, touching, pressure or coercion).

Victimisation: Unfair treatment because a person raised a concern, supported another person, or participated in a process.

Hate incident: Any incident perceived by the person reporting it (or anyone else) to be motivated by hostility or prejudice.

Online harassment: Harassment or bullying through digital channels including messaging apps, social media, email and learning platforms.


4. Examples (non-exhaustive)

Unacceptable behaviour includes:

  • Threats, intimidation, stalking, coercion, or persistent unwanted contact;
  • Insults, humiliation, repeated mocking, or targeted exclusion;
  • Sexual comments, unwanted attention, sexualised messaging or coercion;
  • Hate speech, slurs, or targeting someone’s identity or beliefs;
  • Sharing private information/images or recordings without consent;
  • Coordinated online harassment or “pile-ons” in group chats.

5. Immediate risk and emergencies

If there is immediate danger or serious threat:

  • Call 999 (or emergency services) first,
  • Then report to Equra as soon as possible.

6. How to report

Reports can be made by the person affected or by a witness.

Reporting routes:

Information to include (where possible):

  • What happened, when and where (or which online platform);
  • Names of those involved (if known);
  • Evidence (screenshots/messages), and witness names (if any);
  • Any immediate safety concerns;
  • What support you need.

Anonymous reports will be considered where sufficient detail exists, but may limit action.


7. Support available

Equra can offer supportive measures, which may include:

  • A wellbeing meeting and support plan;
  • Adjusted learning arrangements (where feasible);
  • Communication boundaries or no-contact arrangements;
  • Changes to group allocations (where feasible);
  • Signposting to specialist external support;
  • Safety planning where needed.

Support can be offered regardless of whether an investigation proceeds.


8. Confidentiality and information sharing

Equra will handle reports confidentially on a need-to-know basis. Confidentiality may be limited where there is a safety risk, a legal duty to act, or where external reporting is necessary.

Equra will explain what information will be shared and why.


Procedure

9. Step 1: Initial triage and risk assessment

Equra will acknowledge the report and assess:

  • Immediate safety risks;
  • Whether interim measures are required;
  • Whether the matter can be addressed informally or requires a formal investigation.

Equra aims to acknowledge reports within 3 working days.


10. Step 2: Interim measures (if required)

Where needed to protect individuals or the learning environment, Equra may apply proportionate interim measures such as:

  • No-contact instructions;
  • Adjusted access to learning spaces or online platforms;
  • Adjusted groupings/timetables where feasible;
  • Structured communication routes.

Interim measures are not a finding of fault.


11. Step 3: Informal resolution (where appropriate)

Informal resolution may be used only where it is safe and appropriate. It is not normally used for serious harassment, sexual harassment, threats, violence, stalking or hate incidents.

Informal options may include:

  • Clarification of boundaries and expectations;
  • Facilitated discussion (only if both parties agree);
  • Agreed no-contact or communication limits;
  • Support plans and monitoring.

Equra will confirm the informal outcome in writing where appropriate.


12. Step 4: Formal investigation

12.1 Appointment of investigator

Equra will appoint an investigator who is impartial and not directly involved in the matter.

12.2 Investigation process

The investigator may:

  • Take statements from parties and witnesses;
  • Review relevant evidence (emails, messages, platform logs);
  • Hold meetings with parties separately;
  • Produce written findings based on evidence.

12.3 Timescale

Equra aims to complete the investigation within 20 working days from the start of the formal investigation. If this is not possible, Equra will provide an updated timeline with reasons.


13. Step 5: Outcome and actions

Equra will determine whether the report is:

  • Upheld
  • Partly upheld
  • Not upheld
  • Inconclusive

Equra will confirm the outcome in writing and may take actions including:

  • Written expectations and behavioural boundaries;
  • Continued interim measures where necessary;
  • Required learning/training;
  • Restrictions on participation in certain activities where proportionate;
  • Referral to the student conduct route where a sanction decision is required;
  • Safety referrals where risk requires specialist input.

Equra may be limited in what it can share about actions affecting another person due to confidentiality, but will confirm that appropriate steps have been taken where possible.


14. Malicious or knowingly false reports

Equra encourages reporting in good faith. Where there is clear evidence that a report was made maliciously or knowingly falsely, Equra may address this as a conduct matter. Reports not upheld are not treated as malicious simply because evidence is insufficient.


15. Record keeping

Equra will keep secure records of reports, decisions, actions and outcomes in line with data protection principles and a retention schedule.


16. Review

This policy will be reviewed annually or sooner if required.


Appendix A: Timescale targets

Acknowledgement: within 3 working days
Informal resolution (if used): normally within 10 working days
Formal investigation completion: normally within 20 working days
Outcome letter: normally within 10 working days of investigation completion