1 · Law & definitions 2 · Atkins risks 3 · Responsibilities 4 · Case studies
Module 1 · Welcome
The law and definitions
Learning outcomes
  • State the legal definition of sexual harassment
  • Identify behaviours that constitute harassment
  • Understand how the law has strengthened since 2023
Atkins Search's position

Atkins Search has a zero-tolerance stance. Every individual — consultant, manager, or leader — has a responsibility to uphold dignity and respect in every interaction.

Section 1 · Legal framework
Three laws you need to know
Equality Act 2010

Defines sexual harassment under section 26. The legal test: unwanted conduct of a sexual nature that violates dignity or creates a hostile environment.

Worker Protection Act 2023

In force October 2024. Introduced a new proactive duty: employers must take reasonable steps to prevent harassment — not just respond to it.

Employment Rights Act 2025

April 2026: reporting harassment is a protected disclosure. October 2026: duty rises to "all reasonable steps." Employers liable for third-party harassment.

What this means for Atkins Search

We must proactively prevent harassment — from colleagues, clients, and candidates — and must document our steps to do so. Inaction is no longer a defensible position.

Section 2 · Definition
What is sexual harassment?
Legal definition (Equality Act 2010, s.26)

Unwanted conduct of a sexual nature that has the purpose or effect of violating a person's dignity, or creating an intimidating, hostile, degrading, humiliating, or offensive environment.

Sexual jokes, comments, or "banter"

Unwanted touching or hugging

Staring, leering, or suggestive gestures

Sending explicit images or messages

Sexual propositions linked to job opportunities

Repeated unwanted personal attention or invitations

Knowledge check · Q1 of 3
Test your understanding
Under the Equality Act 2010, which of the following is correct about intent?
Knowledge check · Q2 of 3
Test your understanding
The Worker Protection Act 2023 introduced which new obligation for employers?
Knowledge check · Q3 of 3
Test your understanding
From October 2026, which new liability will apply to Atkins Search under the Employment Rights Act 2025?

Module 1 complete

Score: —

You've covered the legal framework, the definition of sexual harassment, and key examples. Module 2 covers the specific risks Atkins Search consultants face.

Module 2 · Welcome
Risks specific to Atkins Search
Learning outcomes
  • Identify the three main third-party risk scenarios for Atkins consultants
  • Understand what "all reasonable steps" looks like in a recruitment context
  • Know that third-party harassment is your concern too — not just the client's
Section 1 · Third-party risks
Recruitment and third-party scenarios

Candidate harassment of a consultant

A candidate makes inappropriate comments — sexual jokes, remarks about appearance, or sends unwanted messages — to a consultant during or after the recruitment process.

Client behaving inappropriately

A hiring manager or client contact behaves inappropriately toward a candidate during an interview — for example, commenting on their body or making sexual remarks.

Site-based harassment during placements

A placed candidate experiences harassment at the client's site. Atkins Search retains a duty of care even once the placement is made.

From October 2026

Under the Employment Rights Act 2025, Atkins Search will be directly liable for third-party harassment. These scenarios are not the client's problem alone — they are Atkins Search's legal responsibility.

Section 2 · Reasonable steps
What "all reasonable steps" looks like
1

Documented risk assessment

Identifying where harassment risks exist — including client environments — and maintaining a written action plan.

2

Mandatory training

This training — plus annual refreshers — forms part of Atkins Search's evidence of taking reasonable steps.

3

Managing third-party risk

Setting clear behavioural standards with clients and candidates, and acting when those standards are breached.

4

Monitoring and accountability

Tracking complaints, acting on patterns, and holding leaders accountable for culture and compliance.

Knowledge check · Q1 of 3
Test your understanding
A candidate sends a consultant unsolicited late-night messages containing comments about their appearance. What is this an example of?
Knowledge check · Q2 of 3
Test your understanding
A hiring manager repeatedly comments on a candidate's appearance during an interview facilitated by Atkins Search. What are Atkins Search's responsibilities?
Knowledge check · Q3 of 3
Test your understanding
Which of the following best describes why completing this training matters legally?

Module 2 complete

Score: —

You've covered the three key risk scenarios for Atkins Search consultants and what reasonable preventive steps look like. Module 3 covers responsibilities and reporting.

Module 3 · Welcome
Responsibilities and reporting
Learning outcomes
  • Understand your responsibilities as an individual consultant
  • Know the four reporting routes available at Atkins Search
  • Understand what happens after a concern is raised
  • Know that raising a concern in good faith is protected
Section 1 · Responsibilities
Who is responsible for what

Board & senior leadership

  • Set and own the culture
  • Ensure compliance with legal duties
  • Own risk assessment and action plans
  • Hold leadership accountable

Managers

  • Act immediately on concerns raised
  • Reinforce behavioural standards daily
  • Never minimise or dismiss complaints
  • Escalate without delay

All individuals

  • Treat everyone with dignity and respect
  • Report concerns — your own or others'
  • Support colleagues who raise concerns
  • Complete mandatory training
Important

Witnessing harassment and staying silent is not a neutral act. As an individual at Atkins Search, you have a responsibility to report concerns — not just your own experiences, but those of colleagues and candidates too.

Section 2 · Reporting
How to raise a concern

Line manager

Your first point of contact for most concerns — unless your manager is involved in the complaint.

HR

For formal complaints, sensitive situations, or where you feel uncomfortable approaching your manager.

Senior leadership

Where the concern involves a manager or where previous reports have not been acted on.

Whistleblowing (confidential)

A confidential route for raising concerns. Protected by law from April 2026 as a protected disclosure.

Section 3 · What happens next
Investigations, outcomes, and support

Possible outcomes

Mediation, formal disciplinary action, or in serious cases, termination. The outcome reflects the severity of the behaviour and evidence.

Support available

Counselling, workplace adjustments, removal from the working environment, and advice on external reporting options.

Protection from victimisation

Anyone raising a concern in good faith is protected from detrimental treatment — dismissal, demotion, exclusion, or any other retaliation.

For the subject of the complaint

The process is fair and impartial. The subject has the right to respond to the allegations and to be supported through the process.

Atkins Search's commitment

No one at Atkins Search should ever feel they cannot raise a concern. The only wrong response to harassment is silence.

Knowledge check · Q1 of 3
Test your understanding
A consultant witnesses a colleague being harassed by a candidate but isn't directly involved. What is the consultant's responsibility?
Knowledge check · Q2 of 3
Test your understanding
A consultant wants to raise a harassment concern but their line manager is the subject of the complaint. Which route should they use?
Knowledge check · Q3 of 3
Test your understanding
What does "protection from victimisation" mean in the context of raising a concern at Atkins Search?

Module 3 complete

Score: —

You've covered responsibilities, the four reporting routes, and post-reporting protections. The final module puts everything into practice with three case studies.

Module 4 · Welcome
Case studies and final assessment
This module
  • 3 case studies — you decide what's happening and what to do
  • 4-question final assessment covering all modules
  • Programme completion on finishing
Case study 1 · Digital harassment
Late-night messages
Scenario A
A consultant receives late-night messages from a candidate containing inappropriate comments about their appearance. The candidate says they're "just being friendly" and the consultant hasn't explicitly told them to stop.
Is this sexual harassment?
Case study 2 · Client conduct
Interview behaviour
Scenario B
A hiring manager at a client site repeatedly comments on a candidate's body during an interview facilitated by Atkins Search. The candidate looks visibly uncomfortable but says nothing. The hiring manager is a senior contact and a key account for Atkins Search.
What are Atkins Search's primary obligations?
Case study 3 · Workplace banter
Sexual jokes in the office
Scenario C
Two colleagues regularly make sexual jokes in the office. A third colleague, Sam, feels uncomfortable and dreads coming in, but isn't sure whether it counts as harassment since the jokes aren't directed at Sam specifically and the other two seem to enjoy it.
Does Sam have grounds to report this?
Final assessment · Q1 of 4
Final assessment
Under the Equality Act 2010, harassment is defined by its effect on the recipient, not the intent of the person doing it. Which case study best illustrates this?
Final assessment · Q2 of 4
Final assessment
In Scenario B, a senior client contact harasses a candidate. Which statement is correct about Atkins Search's position from October 2026?
Final assessment · Q3 of 4
Final assessment
In Scenario A, the consultant has not explicitly told the candidate to stop. Does this affect whether the messages constitute harassment?
Final assessment · Q4 of 4
Final assessment
Which of the following best summarises Atkins Search's overall approach to sexual harassment?

Training complete

—
Final assessment score

You have completed the Atkins Search Sexual Harassment Safeguarding programme. Your completion has been recorded. This training should be refreshed annually in line with Atkins Search's mandatory training policy.

If you have any questions or concerns following this training, contact HR or your line manager. The only wrong response to harassment is silence.