Sexual harassment policy

Our commitment

The law requires employers to take reasonable steps to prevent sexual harassment of their workers, including by clients, customers and other third parties. We aim to take all the steps that are reasonable for a business of our size, without waiting for a complaint.

This policy applies to everyone, whatever their role or seniority, including the CEO.

Who this policy covers

It covers employees, workers, interns, people on work experience, freelancers, contractors and job applicants. It applies wherever work happens: at home, at client premises, at events and work socials, while travelling for work (including overnight stays), and online.

What sexual harassment is

Sexual harassment is unwanted conduct of a sexual nature that violates someone’s dignity, or creates an intimidating, hostile, degrading, humiliating or offensive environment for them. It counts whether or not the person meant it, and it can be a single incident. It also includes treating someone less favourably because they rejected, or gave in to, that kind of conduct.

Examples include:

• unwanted touching, hugging or brushing against someone
• sexual comments, “jokes” or questions about someone’s appearance, body or private life
• sending sexual images, messages or links, including in work chats
• sexual comments or messages from clients or the public, including on social media accounts and review pages we manage
• suggesting that work, promotion or a good review depends on a sexual favour

Other harassment, including harassment related to sex that is not sexual in nature, is covered by our equality, diversity and inclusion policy.

How we prevent it

Risk assessment. We carry out a written sexual harassment risk assessment. The current one is dated 27 October 2026. We review it at least once a year, and after any complaint or change in how we work. It covers risks including:

• working from home and alone, including one-to-one contact with clients or suppliers in person, on video calls and in messages
• travel and overnight stays, including trips linked to Powerful Tickets
• events and social occasions where alcohol is served
• online contact with the public through social media, reviews and messaging
• power imbalances in a small team, and freelancers or junior staff who may feel less able to speak up

We record the steps we take for each risk and check they are working.

Clear standards. We make it clear to staff, freelancers, clients and suppliers that sexual harassment is not acceptable, and set expectations for behaviour at work events and on trips. Staff can decline to meet a client alone.

Training. Everyone receives training on this policy at induction, within their first month, and a refresher at least once a year. It covers what sexual harassment looks like, how to report it, how to step in safely as a bystander, and third-party harassment. Anyone handling complaints gets extra training. We keep a record of who completed what training and when.

Speaking up. We encourage people to report incidents and also situations where they felt at risk, even if nothing happened.

Harassment by clients, customers and other third parties

Sexual harassment by clients, customers, suppliers or members of the public is not acceptable. Please report it in the same way. Depending on what happened, we may warn the person, remove you from contact with them, block or report them on a platform, end the work or the supplier relationship, or report it to the police. You will not be disadvantaged if work is lost as a result.

How to report it

You can raise a concern in whichever way you feel most comfortable:

• speak to Andrew Todd, CEO, in person or by phone
• email info@powerfuldigitalmarketing.com, marking your message “Private”
• if your concern is about Andrew Todd, or you would rather not raise it with him, ask for it to be handled by an independent external adviser, such as an HR consultant or an Acas-trained mediator, appointed for that case

You can ask for a concern to be dealt with informally or make a formal complaint, although some incidents may be too serious to deal with informally. You can bring a colleague or trade union representative to any formal meeting. Witnesses are encouraged to report what they saw.

If you are in immediate danger, or a crime has been committed, call the police on 999.

Investigation

We will act promptly, normally within five working days of a report. A formal complaint will be investigated fairly by someone who is not involved, which may be an independent external adviser appointed for that case. We will speak to those involved and any witnesses, keep a written record and share information only with those who need it.

We may take temporary steps to protect those involved while we investigate. We will tell both the person who raised the concern and the person accused of the outcome. Either can appeal in writing within ten working days. An appeal is heard by someone who was not involved in the investigation, which may be an independent external adviser.

If a complaint is upheld against someone who works for us, it may lead to disciplinary action, up to and including dismissal, or the end of a freelance contract. Abuse of power over a more junior colleague makes it more serious.

No victimisation

Nobody will be treated badly for raising a concern in good faith, giving evidence or supporting someone else, even if it is not upheld. Victimisation is itself a disciplinary matter. We will not use confidentiality agreements to stop anyone reporting sexual harassment.

Support

We will offer practical support to anyone affected, including time off for related appointments and changes to work or contacts. Free, confidential advice is also available from the Acas helpline on 0300 123 1100.

Review

Andrew Todd, CEO, is responsible for this policy, the risk assessment and the training records. We review them at least once a year, after any complaint, and when the law or guidance changes.

Policy details

• Policy owner: Andrew Todd, Director and CEO
• Approved by: Andrew Todd, Director and CEO
• Effective date: 27 October 2026
• Last reviewed: 27 October 2026
• Next review: 27 October 2027