Anti-harassment and Anti-bullying Policy

Swan Films (the “Company”) is committed to providing an environment in which all individuals, clients and the public are treated with dignity and respect. The Company is committed to promoting a working environment in which everyone is treated equally. This anti-harassment and bullying policy is core to the Company’s commitment and will be applied rigorously. This policy defines what the Company considers to be bullying and harassment which occurs at work and out of the workplace, such as on business trips or at work-related events or social functions, and sets out the procedure for reporting any incident of bullying or harassment.

All employees, directors, officers, consultants, contractors, interns, crew, talents artists and agency workers engaged, contracted or employed by or with the Company and third parties such as customers, suppliers or visitors to the Company’s premises (“Workers”) are responsible for acting in accordance with the standards detailed in this policy and applying to every situation the basic principles of fairness, honesty, integrity, and compliance with the law.  Workers must ensure that adherence to these standards and values are given the highest priority within the Company. 

Workers should feel that they are treated with the requisite dignity and respect.  Furthermore, we expect our management to act as role models in their business conduct and leadership style. Behaviour that goes against our standard of business ethics will be identified and investigated.

This policy is non-contractual and it does not form part of workers’ terms and conditions with the Company.  The Company reserves the right to amend this policy at any time.

Please study this policy and make sure you understand how it relates to your role and position within the Company.

Who has to comply with this policy?

This policy applies to all Workers.  It also applies to those individuals, subcontractors and suppliers visiting the Company’s premises and providing products and/or services to the Company. 

What happens if this policy is breached?

Failure to follow this policy may result in disciplinary action.  Breaches of the policy may also represent breaches of the law and may result in legal sanctions for the Worker and/or the Company.

What is considered bullying?

Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, undermined, humiliated, denigrated or threatened.  Power does not always mean being in a position of authority, but can include both personal strength and the power to coerce through fear or intimidation.  Bullying can take the form of physical, verbal and non-verbal conduct. 

Bullying may include, by way of example:

Physical or psychological threats;

Overbearing and intimidating levels of supervision;

Inappropriate derogatory remarks about someone’s performance.

Legitimate, reasonable and constructive criticism of a Worker’s performance or behaviour, or reasonable instructions given to Workers will not amount to bullying on their own.

What is considered harassment?

Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them.  A single incident can amount to harassment.  Unlawful harassment may involve conduct of a sexual nature or it may be related to race, colour, nationality, marital or civil partner status, pregnancy or maternity, disability, gender re-assignment, religion or belief, ethnic or national origin, sexual orientation or age.  Harassment is unacceptable even if it does not fall within any of these categories.

Harassment may take many forms and include:

conduct which is unwanted by the recipient and perceived as hostile or threatening;

conduct which gives rise to a hostile or threatening work environment;

conduct which creates an atmosphere in which it is feared that rejection or submission will be used as a basis for decisions which have an impact on the recipient at work.

The following are examples of types of behaviour which may amount to harassment:

Physical or sexual assault.

Requests for sexual favours in return for career advancement.

Unnecessary physical contact.

Exclusion from social networks and activities or other forms of isolation.

Compromising suggestions or invitations.

Suggestive remarks or looks.

Display of offensive materials, including on a computer screen.

Tasteless jokes or verbal abuse, including but not limited to any sent by email.

Offensive remarks or ridicule.

Dealing inappropriately or inadequately with complaints of harassment.

How I will be protected and supported?

If you are being harassed or bullied, consider whether you feel able to raise the problem informally with the person responsible.  You should explain clearly to them that their behaviour is not welcome or makes you feel uncomfortable.  If this is too difficult or embarrassing, you should speak to Caroline Turner or Joe Evans who can provide confidential advice and assistance in resolving the issue formally or informally.

If informal steps are not appropriate, or have not been successful, you should raise the matter under the Company’s Disciplinary procedure.  Where harassment is found to have occurred this will amount to misconduct or gross misconduct.

No one who makes an allegation of harassment in good faith should be subjected to any detriment as a result.  If you believe that you have suffered any such treatment, you should inform Caroline Turner or Joe Evans immediately. If the matter is not remedied the matter should be raised formally using the Company’s Grievance Procedure.

“Good faith” does not mean that a reported concern must be correct, but it does require that a Worker be truthful when reporting a concern.  Company aims to encourage openness and will support whistle-blowers who raise genuine concerns under this policy, even if they turn out to be mistaken.

Retaliation against someone or the victimisation of someone who reports a problem in good faith may result in sanctions against the retaliator, up to and including termination of their contract with the Company.

If the Company concludes that a whistle-blower has made false allegations maliciously or with a view to personal gain, the whistle-blower may be subject to disciplinary action.

What happens if I raise a concern?

The Company will usually arrange a meeting as soon as possible to discuss the Worker’s concern. The Worker will be allowed to bring a colleague or trade union representative to any meetings. Any companion must respect the confidentiality of the disclosure(s) and any subsequent investigation.

Information about a complaint by or about a Worker may be placed on the individual’s personnel file, along with a record of the outcome and of any notes or other documents compiled during the process.  These will be processed in accordance with the Company’s data protection policy.

Will my concern be treated confidentially?

The Company intends that Workers will feel able to voice whistleblowing concerns or other concerns of bullying and harassment openly under this policy. Completely anonymous disclosures are difficult to investigate. If Workers would prefer to raise their concern confidentially, the Company will make every effort to maintain the identity of the Worker a secret and only reveal it where necessary, to those involved in investigating your concern.

Why we apply this policy

It is our wish to set a standard in the industry where people are treated fairly and as equals and where everyone should experience a safe work environment. The Company is committed to creating a working environment of mutual trust and respect with support for cultural diversity, an open and honest team.  Co-operation and an environment free of intimidation, fear and harassment form the basics of our corporate culture.

Can I alert someone external to the Company?

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases Workers should not find it necessary to alert anyone externally.

The law recognises that in some circumstances it may be appropriate for Workers to report concerns to an external body such as a regulator. The Company strongly encourages Workers to seek advice before reporting a concern to anyone external. Public Concern at Work operates a confidential helpline. Their contact details are at the end of this policy.

Who can you contact?

If you have any questions regarding the policy or you want to report an incident of harassment and/or bullying please speak to the person who is responsible for overseeing the Company’s bullying and harassment policy:

Name: Caroline Turner or Joe Evans

Position: Head of Production / Managing Director

Email: C/O

Public Concern at Work (Independent whistleblowing charity) Helpline: (020) 7404 6609 E-mail: Website:

Anyone working on a Channel 4 production will have access to Speak Up and it will be at the top of all call sheets:

Channel 4 is committed to maintaining the highest standards of integrity and behaviour in everything we do; this extends to our content creatorsand other third parties we work with.  As you are working on a programme commissioned by Channel 4, if you become aware of inappropriate conduct and you don’t feel comfortable talking to somebody at the company where you are working, our Speak Up facility, operated by Safecall, provides a confidential process to escalate concerns to senior Channel 4 management. 

To raise a concern, call UK freephone number 0800 915 1571 or go online to (  Please quote ‘Channel 4’ as the company name.  For further details on this service go to Producers’ Handbook – Speak Up Facility (

Useful links:

This course will be compulsory for all Workers working on a BBC production:

BFI Principles

A set of principles to tackle and prevent bullying and harassment in the screen industries.

 BFI Guidance

A practical workplace guide for the prevention of bullying and harassment in the screen industries.

The Film and TV Charity

The Film and TV charity provides information and a free support line.

BBC Bullying and Harassment Policy

The Policy explains the support available and how one can informally or formally address issues with bullying or harassment.

ITV Code of Conduct

A Code of Conduct for those working for ITV.

Channel 4 – Support Organisations

A list of organisations who can be contacted for support regarding bullying, harassment and internet safety, compiled by Channel 4.

Directors UK Bullying and Harassment Handbook

A handbook for screen directors which contains useful information about behaviours and their legal status, as well as Directors UK’s own code of conduct.