Sexual harassment policy, Kindred Lane Stores

Sexual harassment policy template built around the positive duty

A sexual harassment policy in Australia now has to show what the business is doing to prevent harassment, not only how it handles complaints, because employers carry a positive duty to eliminate it as far as possible. This five page policy for a 24 store retail chain sets out the definitions, the preventive measures with owners, five reporting options and a fair investigation.

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Kindred Lane Stores

Sexual harassment policy

Preventing and responding to sexual harassment, sex based harassment and hostile work environments in our stores, support office and warehouse.

Head of People
1 December 2026
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1
Scope
This policy applies to everyone who works for Kindred Lane Stores: about 600 staff across 24 stores, the support office and the warehouse, including casuals, contractors, labour hire workers and work experience students. It covers conduct by colleagues, managers, customers, suppliers and delivery drivers, at work, at work events, in work chats and on social media.
2
Definitions
These meanings come from the Sex Discrimination Act 1984. Whether conduct is harassment depends on how it affects the person and what a reasonable person would have anticipated, not on what the other person intended.
Term
Meaning
Retail examples
Sexual harassment
An unwelcome sexual advance, request for sexual favours or other unwelcome conduct of a sexual nature, where a reasonable person would anticipate the person might be offended, humiliated or intimidated
A customer commenting on a worker's body; a manager texting a casual late at night asking to meet
Sex based harassment
Unwelcome conduct of a seriously demeaning nature because of a person's sex, with the same reasonable person test
Telling a female storeperson the forklift is not for girls
Hostile work environment
A workplace that is offensive, intimidating or humiliating to a person because of their sex
Explicit images on a stockroom wall; sexual jokes in the store group chat
Victimisation
Treating someone badly because they made, or might make, a complaint
Cutting a casual's shifts after she reported a supervisor
3
Bystanders
If you see or hear something, you are expected to act in a way that is safe for you: interrupt it, check on the person afterwards, or tell a manager. You do not need the person's permission to report what you saw, and you are protected from victimisation in the same way as the person who was targeted.
4
Our positive duty
Under section 47C of the Sex Discrimination Act, Kindred Lane Stores must take reasonable and proportionate measures to eliminate, as far as possible, sexual harassment, sex based harassment, hostile work environments and victimisation. We do not wait for a complaint. These are the measures we take, and who owns each one.
Area
Measure
Owner
Leadership
The board reviews harassment data and actions every quarter
Chief Executive
Risk
Each store assesses its risks yearly, including lone closing shifts and customer behaviour
Store managers
Rostering
No one closes a store alone after 6 pm; two staff on every late shift
Area managers
Customers
Staff may refuse service and ask a customer to leave; the store bans repeat offenders
Store managers
Training
Induction training for all staff, bystander training each year, manager training on responding
People team
Monitoring
An anonymous staff survey every year, with results shared with all staff
Head of People
5
Reporting options
You choose how to raise it, and you can change your mind. You can report something that happened to you or something you saw, and you can bring a support person to any meeting.
Option
How
What happens next
Talk it through
Any manager, or the People team, in confidence
Advice on your options; nothing happens without your say, unless someone is at risk
Informal
Ask a manager or the People team to step in
A direct conversation, a roster change or a customer ban, usually within a week
Formal complaint
In writing or in a meeting with the People team
An investigation under section 7, with a written outcome
Anonymous
The confidential reporting line or online form
Used to act on patterns, such as one store or one customer
Outside the business
The Australian Human Rights Commission, the Fair Work Commission, or police
Their own process; you can use it at any time, with or without ours
If you are in danger
If you are threatened or assaulted, call 000 first. Then tell your manager or the People team, who will make sure you are safe before anything else happens.
6
When someone tells a manager
A manager who is told about harassment, or sees it, must on the same shift:
make sure the person is safe, and separate them from the other person if needed
listen, believe that the report is made in good faith, and avoid judging or questioning the detail
explain the reporting options in section 5 and the support in section 10
write down what was said, in the person's words, with the date and time
tell the People team within 1 business day, even if the person asks for nothing to be done
7
Investigation
A formal complaint is investigated by the People team or, where a senior manager is involved, by an independent external investigator. The steps are the same either way.
1.
The complaint is acknowledged in writing within 2 business days, and interim steps, such as separate rosters, are put in place.
2.
The person complained about is told the allegations in detail and given a fair chance to respond.
3.
Witnesses are interviewed and records such as messages, rosters and CCTV are reviewed.
4.
The investigator makes findings on the balance of probabilities, usually within 20 business days.
5.
Both people are told the outcome and the reasons, and any action is taken under the disciplinary procedure.
6.
The People team checks in with the person who complained at 4 weeks and 12 weeks.
8
Confidentiality
Details of a report are shared only with the people who need them to deal with it, and records are held by the People team, not at the store. You are free to talk to a support person, a doctor, a union or a lawyer. Confidentiality never stops us acting to keep someone safe, and no one will be asked to sign a confidentiality agreement as a condition of resolving a complaint.
9
Consequences
Staff who sexually harass anyone face disciplinary action up to and including dismissal, and a manager who ignores a report breaches this policy too. Customers and suppliers who harass staff can be refused service, banned or reported to police, and their employers are told.
10
Support
The employee assistance program offers six free confidential sessions to anyone involved. Paid time off for appointments, a change of store or shift, and help with a police report are available on request.
11
Records and reporting
The People team keeps a register of every report, informal or formal, with the store, the type of conduct, the action taken and the time it took. Names are removed before the register is reported to the board each quarter, so patterns such as one store or one customer can be acted on.
12
Review
The Head of People reviews this policy every year, with staff and the health and safety representatives, and reports to the board on whether the measures in section 4 are working.

Section by section

What each section is for, so you can keep the ones you need and drop the rest.

Cover
Contract cover with the retailer, title, purpose line and date.
1 to 3. Scope, definitions and bystanders
Who is covered, four defined terms with retail examples, and what bystanders should do.
4. Our positive duty
Section 47C and six measures with owners.
5. Reporting options
Five ways to raise it, from talking it through to outside bodies, and the danger callout.
6. When someone tells a manager
Five things a manager does on the same shift.
7. Investigation
Six steps from written acknowledgement to follow up at 12 weeks.
8 to 10. Confidentiality, consequences and support
Who sees what, outcomes for staff and customers, and counselling.
11 and 12. Records and review
The report register and the yearly review with staff.

How to adapt this document

First, redo the measures table from your own risk assessment; a hospitality venue would add late night transport and guest intoxication, an office would add work travel and after work drinks. Second, if you have no People team, name an external HR adviser or investigator for formal complaints so no complaint is investigated by someone close to it. Third, keep the customer provisions even if you deal mostly with businesses, renaming them for clients and contractors who visit or call your staff.

Which law the terms follow

The definitions and the positive duty come from the Sex Discrimination Act 1984: sexual harassment in section 28A, harassment on the ground of sex, hostile work environments, and the duty in section 47C. The Fair Work Act 2009 separately prohibits sexual harassment in connection with work and gives the Fair Work Commission power to deal with disputes. Work health and safety laws treat sexual harassment as a risk to health and safety, with guidance from Safe Work Australia.

What makes this document work

The positive duty is a table of measures

Clause 4 quotes the duty in section 47C, then lists six measures with owners: quarterly board review, yearly store risk assessments, two staff on every shift after 6 pm, the right to refuse service and ban customers, three kinds of training, and an anonymous survey. Prevention a regulator can check.

Customers are covered, not just colleagues

Scope names customers, suppliers and delivery drivers, the table's first example is a customer commenting on a worker's body, and the measures let staff refuse service. In retail much harassment comes from the public, and a policy limited to co workers leaves the main risk out.

Managers get a same shift checklist

Clause 6 tells a manager what to do on the shift they are told: make the person safe, listen and believe the report is made in good faith, explain the options, write down what was said in the person's words, and tell the People team within 1 business day, even if nothing is requested.

Questions people ask

What is the positive duty?

Since December 2022, section 47C of the Sex Discrimination Act 1984 requires employers to take reasonable and proportionate measures to eliminate, as far as possible, sexual harassment, sex based harassment, hostile work environments and victimisation. It applies whether or not anyone complains, and the Australian Human Rights Commission can enforce it.

What is a hostile work environment?

A workplace that is offensive, intimidating or humiliating to a person because of their sex, even if no one is targeted directly. Explicit images on a stockroom wall or constant sexual jokes in a store group chat are the policy's examples. It became unlawful under the Sex Discrimination Act in 2022.

Can a worker go to the Fair Work Commission about sexual harassment?

Yes. The Fair Work Act prohibits sexual harassment in connection with work, and a worker can apply to the Commission to deal with a dispute, including for an order to stop it. They can also complain to the Australian Human Rights Commission. The policy lists both as options outside the business.

Should a policy cover harassment by customers?

Yes. The positive duty extends to conduct by third parties such as customers and clients, so far as the employer can control the risk. That is why this policy lets staff refuse service, bans repeat offenders, rosters two people late at night, and tells customers' employers when harassment comes from a supplier or driver.

Can a complaint be settled with a confidentiality agreement?

This policy says no one will be asked to sign one as a condition of resolving a complaint. Non disclosure terms can silence victims and hide patterns, which undermines the positive duty. Some people want confidentiality for themselves, and it can be offered at their request, but never required.

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