UEL OfS E6 Policies
1. Introduction
ICEP Europe is committed to preventing and responding to all forms of harassment and sexual misconduct. All members of our community have a duty to ensure that all forms of harassment and sexual misconduct are eliminated.
This webpage sets out the institution’s approach to protecting students and staff from harassment and sexual misconduct, and acts as our Single Comprehensive Source of Information, which evidences our commitment to tackling these issues in line with the regulatory requirements of the Office for Students. More information can be found here: Condition E6: Harassment and sexual misconduct – Office for Students.
2. Key Definitions
ICEP Europe adopts the definitions of harassment and sexual misconduct as provided by UEL, in line with OfS Condition E6 requirements.
What is harassment?
- Harassment is both a criminal offence and a civil action under the Protection from Harassment Act 1997. This means that someone can be prosecuted in the criminal courts if they harass another person. It also means action can be taken against that person in the civil courts.
- Under the Equality Act 2010 there are three types of harassment
- harassment related to certain protected characteristics
- sexual harassment
- less favourable treatment as a result of harassment
- Harassment related to a relevant protected characteristic is unwanted conduct that has the purpose or effect of violating the individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. Conduct may be verbal, non-verbal or physical.
- The relevant protected characteristics are
- age
- disability
- gender reassignment
- race
- religion or belief
- sex
- sexual orientation
- Unwanted conduct related to marriage and civil partnership, or pregnancy and maternity, could be considered sexual or sexual orientation harassment.
- Sexual harassment is unwanted conduct of a sexual nature that has the purpose or effect of violating the individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.
- Harassment also occurs where an individual rejects or submits to the unwanted conduct and is treated less favourably than they would have been if they had not rejected or submitted to the conduct.
- In deciding whether the unwanted conduct has the effects described above consideration must be given to
- the perception of the person experiencing the conduct
- any other circumstances of the case
- whether it is reasonable for the conduct to have that effect. </.li>
- Harassment can occur where someone perceives another person to have a protected characteristic, for example a perception that someone is gay even if they are not.
- Harassment can also arise by association, where someone is harassed because they are associated with someone with a protected characteristic, for example having a family member of a particular religion.
- Examples of harassment include but are not limited to
- banter, jokes, taunts or insults that are sexist, racist, ageist, transphobic, homophobic or derogatory against any protected characteristic
- unwanted physical behaviour such as pushing or grabbing
- excluding someone from a social event or marginalising them from the group
- derogatory comments about pregnancy, maternity leave or IVF treatment
- mimicking or making fun of someone’s disability
- derogatory or offensive comments about religion
- displaying images that are racially offensive
- “outing” (i.e. revealing their sexual orientation against their wishes), or threatening to “out”, someone
- excluding or making derogatory comments about someone because of a perceived protected characteristic, or because they are associated with someone with a protected characteristic.
- Examples of sexual harassment include but are not limited to
- physical conduct of a sexual nature without consent
- unwelcome physical contact or intimidation
- persistent suggestions to meet up socially after a person has made clear that they do not welcome such suggestions
- showing or sending offensive or pornographic material by any means (e.g. by text, video clip, email or social media)
- unwelcome sexual advances, propositions, suggestive remarks, or gender-related insults
- leering, whistling or making sexually suggestive gestures
- gossip and speculation about someone’s sexual orientation or transgender status, including spreading malicious rumours.
Sexual Misconduct
Sexual Violence and Misconduct is defined as any unwanted conduct of a sexual nature. ICEP Europe outlines the following examples of sexual misconduct:
- Verbal harassment such as whistling, catcalling, or sexual innuendo.
- Making unwanted remarks of a sexual nature.
- Spreading rumours about a person’s sex life.
- Nonverbal harassment, such as looking someone up and down or displaying pictures of a sexual nature.
- Sending emails or messages containing sexual content and/or asking for sexual favours.
- Inappropriately showing sexual organs to another person.
- Sexual intercourse or engaging in a sexual act (including kissing) without consent.
- Attempting to engage in a sexual act without consent.
- Creating, disclosing or threatening to disclose nude, sexual or sexually explicit photos, films or messages without consent and with intent to cause distress.
- Touching inappropriately through clothes without consent.
3. Reporting harassment and sexual misconduct
ICEP Europe encourages all individuals—learners, staff, witnesses, or external parties—to come forward if they have experienced or observed sexual misconduct involving an ICEP Europe student. Creating a safe environment for disclosure and reporting is a core part of ICEP Europe’s commitment to safeguarding and wellbeing.
Disclosure vs. Formal Report
- A disclosure is when someone shares an experience of sexual misconduct with a staff member but does not necessarily wish to initiate a formal disciplinary process.
- A formal report involves submitting a written account that may lead to a disciplinary investigation under this policy.
Disclosures may be made to:
- The Student Support Officer
- The QAE Manager
- Any designated ICEP Europe staff member
Disclosures may be submitted by:
- A learner or staff member directly involved
- A third-party witness
- An external individual (subject to suitability assessment)
Disclosures can be made in person, via email, to [email protected] or using the designated reporting form. ICEP Europe aims to acknowledge receipt of all written reports within 5 working days.
4. How we handle information
Any information obtained in connection with incidents of harassment and/or sexual misconduct will be handled with sensitivity, confidentiality, and fairness, in line with ICEP Europe’s data protection policies and ethical commitments.
All records and data will be managed under ICEP Europe’s Information Management and Data Protection Policy. Information will be shared only with those who need to know for investigation, support, or safeguarding. Annual statistics on disclosed incidents of sexual misconduct, harassment, discrimination and related matters will be retained by the Institution for the purposes of education, training and any reporting or publication that may be required.  The statistics will not include any identifying information. Confidentiality breaches may result in disciplinary action.
5. Support for those affected
ICEP Europe is committed to providing support for all learners and staff affected by bullying, harassment, or sexual misconduct. Support is available to individuals whether they have experienced, witnessed, or been accused of such incidents.
Support at the Point of Disclosure
At the point of disclosure, the Reporting Party will be:
- Offered internal wellbeing support
- Provided with information on external specialist services (e.g. rape crisis centres, counselling, domestic violence support)
- Informed about their options, which may include:
- Submitting a formal report under this policy
- Reporting to the police
- Seeking informal resolution (if appropriate)
ICEP Europe respects the wishes of the Reporting Party and will support them whether or not they choose to initiate formal proceedings or report to external authorities. However, in cases where a risk to others is identified, ICEP may need to act to protect the wider learning community.
Our Student Support Officers are trained and equipped to respond sensitively to disclosures and support needs.
External Support Services
Emergency Services: 999
Equality Advisory and Support Service
For advice and support if you think you have been treated unfairly.
Victim Support help anyone who has been the victim of a crime. They can support you coping with the after-effects of crime and help with reporting to the police.
BAME support:
Community Security Trust, a charity that protects British Jews from antisemitism and related threats. You can report antisemitism directly to CST, as well as receiving psychological support tailored to the Jewish community’s needs.
Muslim Women’s Network operates a national specialist faith and culturally sensitive helpline that is confidential and non-judgmental, which offers information, support, guidance and referrals for those who are suffering from or at risk of abuse or facing problems on a range of issues.
Stephen Lawrence Charitable Trust
Was founded on the premise that inequality must be tackled in all its forms. This includes inequality of access, and of opportunity, wherever it occurs. The Trust are dedicated to transforming the life chances of young people and improving the world in which they live to enable them to develop and nurture their talent.
Tell Mama An independent, non-governmental organisation which works on tackling anti-Muslim hatred. The MAMA Project will provide a means for such incidents to be reported, recorded and analysed, working to ensure this data is accurate and reliable and the victims and witnesses affected receive support.
Disability support:
The largest charity representing the 11 million deaf and hard of hearing people in the UK. As a membership charity, they aim to achieve a radically better quality of life for deaf and hard of hearing people.
Activity Alliance Working to make active lives possible with a vision that disabled people are active for life
ADDISS – The National Attention Deficit Disorder Information & Support Service
People friendly information and resources to anyone who needs assistance.
Arc SafteyNet A range of national resources related to Hate Crime and disability free to download and use.
Change A human rights organisation led by people with learning disabilities. They deliver training & produce accessible books, booklets, Picture Bank CD-ROMs & individual pictures
The leading charity of its kind in the UK, run by and for people with experience of disability or health conditions.
Information, advice, resources, on all issues relating to autism.
Helps children and adults with learning disabilities who have experienced abuse or trauma, as well as those who have abused others, through psychotherapy, advocacy and other support.
Royal National Institute of the Blind
Offers practical support and advice to anyone with a sight problem.
Scope A charity concerned with achieving equality for those with disabilities, particularly those affected by cerebral palsy.
LGBTQ+ support
EACH – Educational Action Challenging Homophobia Helpline offering support for young people affected by homophobia.
Equality Advisory and Support Service An organisation that provides advice on discrimination and human rights issues.
Galop A charity working to prevent and challenge homophobic and transphobic hate crime
6. Processes for investigating harassment and sexual misconduct
ICEP Europe is committed to addressing allegations of harassment and sexual misconduct with fairness, transparency, and respect for the rights of all involved. Our procedures for handling such incidents are set out in the Sexual Misconduct and Harassment Policy.
The policy outlines the steps for reporting incidents, ranging from informal disclosures to formal investigations. We provide clear guidance on how cases are assessed, including the use of a Risk Assessment Group (RAG) for safeguarding and wellbeing, and we ensure that precautionary measures are considered where necessary. Allegations of sexual misconduct are treated with the utmost seriousness and undergo a formal investigation process.
The Sexual Misconduct and Harassment Policy details the roles of the Reporting Party, Responding Party, and witnesses, their rights during the process, and the support available to all parties. It also explains the range of potential outcomes, from informal resolutions to formal disciplinary actions, depending on the severity of the case.
For full details of the investigation process, decision-making, and appeal options, please refer to the Sexual Misconduct and Harassment Policy.
7. Communicating outcomes
Possible outcomes include:
- Dismissal of the allegation
- Continuation of precautionary measures
- No further action despite confirmed misconduct
- Proportionate sanctions, which may include:
- First or Final Written Warning
- Student Conduct Accountability Agreement
- Suspension
- Exclusion
- Expulsion (learners) or contract termination (staff)
If expulsion or contract termination is recommended, the case is escalated to the ICEP Provost (or nominee) for final review and ratification.
Panel outcomes will be shared with supported parties where appropriate, and all decisions will be recorded and retained in line with ICEP’s data protection policies.
Post-Hearing:
- The decision, rationale, and any conditions will be communicated to relevant parties within 3 working days
- Consent will be sought from the Responding Student before sharing the outcome with the Reporting Student
- The Student Support Officer will coordinate with academic staff to minimise academic disruption in cases of suspension or exclusion
8. Training
Staff Training
ICEP Europe is committed to ensuring that all staff are appropriately trained to support a safe, inclusive, and respectful learning environment. All staff are required to complete role-relevant training, with a particular focus on understanding institutional policies, procedures, and responses to incidents of harassment and misconduct.
ICEP ensures that all staff are made aware of these policies and procedures through a structured training process, with additional or enhanced training provided as appropriate to reflect specific responsibilities. Ongoing awareness is supported through periodic refresher training and other learning opportunities.
Student training
ICEP Europe ensures that all students receive training to raise awareness of the institution’s expectations, policies, and procedures in relation to harassment and sexual misconduct. This training includes information on sexual consent, reporting mechanisms, and the role of the active bystander in supporting a safe and respectful learning environment.
9. Personal Relationships between Staff and Students
ICEP Europe has a formal policy on Personal Relationships and Professional Boundaries, which outlines the institution’s expectations regarding personal relationships between staff and students. Where a personal relationship exists or develops between a staff member and a student in a context where a professional relationship is present (e.g., teaching, supervision, assessment, student support), the staff member is required to:
- Disclose the relationship promptly using the Conflict of Interest Declaration Form;
- Cooperate with any resulting measures to manage, mitigate, or eliminate the risk of bias, which may include reallocation of teaching or assessment responsibilities.
All ICEP Europe staff are also required to maintain professional boundaries at all times, including use of official communication channels, avoidance of informal or favouritist behaviour, and refraining from any conduct that could be interpreted as coercive or sexual in nature.
The aim of these provisions is to protect students from undue influence, power imbalances, or perceptions of unfair treatment, while also supporting staff in managing boundaries transparently and appropriately.
Further details can be found in the full ICEP Europe Personal Relationships and Professional Boundaries Policy and Conflict of Interest Procedure.
10. Taking Steps to Protect Students
Safeguarding Policy
ICEP Europe is committed to providing a safe, respectful, and supportive environment for all individuals (including staff, students, partners, and visitors), ensuring that everyone is protected from harm and exploitation.
- Prevention and Protection: Through raising awareness and providing relevant training, ICEP Europe aims to prevent abuse and other inappropriate behavior.
- Reporting Mechanism: All individuals can report any inappropriate behavior to ICEP Europe’s designated Safeguarding Lead (DSL). Reporting channels include face-to-face, email, and anonymous reporting options.
- Support and Response: ICEP Europe ensures that all individuals raising concerns receive appropriate support, including access to internal or external counseling and support services.
For more information on the Institution Safeguarding principles and procedures, please visit the Safeguarding Policy document.
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