1.1 Introduction 

This is Spherica’s (‘the Company’s’) policy for preventing harassment of its people by third parties. 

Spherica is committed to a working environment in which everyone is treated with dignity and respect. That commitment does not end at our own front door. Our people spend much of their working day with customers, suppliers and contractors, on site, by phone and through remote support, and they are entitled to the same respect in those interactions as they receive from colleagues. 

This policy sets out what Spherica undertakes to do to prevent harassment of our people by third parties, and the standards we expect of everyone who works with us. It covers harassment in all its forms, with particular emphasis on sexual harassment, and supports our obligations under the Equality Act 2010. 

We expect our customers, suppliers and contractors to share these values, and we will act decisively where they are not upheld. This policy should be read alongside our Anti-Harassment & Bullying policy, Whistleblowing Policy, and Sexual Harassment Prevention Risk Assessment in annex A.  2

1.2 Policy detail 

1.2.1 Scope and definitions 

This policy applies to every interaction between Spherica personnel and third parties, wherever and however it takes place. 

Who this policy protects: All Spherica employees, workers and apprentices (‘Spherica personnel’). 

Who this policy applies to: Any individual or organisation that is not Spherica or a member of Spherica personnel, including: 

• customers and clients, including their employees, managers and end users; 

• suppliers, vendors and their representatives; 

• contractors, subcontractors, consultants and freelancers; 

• visitors, partners and members of the public. 

Settings covered: The policy applies in any setting connected with Spherica personnel’s work, including: 

• customer and supplier sites, including on-site support visits; 

• remote interactions, such as service desk calls, remote support sessions, video meetings, email, ticketing systems, instant messaging and social media; 

• work-related travel, events, conferences, training and social functions. 

Definitions: The following definitions reflect the Equality Act 2010. 

Whether conduct amounts to harassment depends on the perception of the person affected and whether it is reasonable for the conduct to have that effect. Intent is not required. 

1.2.2 Our commitment 

Spherica will take all reasonable steps to prevent its personnel being harassed by third parties, and will act promptly and fairly whenever concerns are raised. In particular, we will: 

1. Communicate this policy to customers, suppliers and contractors at onboarding, at contract renewal and whenever it is materially updated, and publish it on our website. 
2. Assess the risk of third-party harassment across our services, including lone working, on-site visits, out-of-hours support and high-pressure customer interactions, and put proportionate controls in place. 
3. Train all personnel on recognising, challenging and reporting harassment. 
4. Provide accessible, confidential reporting routes. 
5. Support any member of personnel who raises a concern, including practical measures to protect them from further contact with the individual concerned. 
6. Investigate reports promptly, proportionately and impartially, and act on the outcome, up to and including suspending or ending a commercial relationship. 
7. Protect anyone who reports harassment in good faith from victimisation or detriment of any kind. 
8. Expect the same standards of our own personnel when working at third-party sites or with third-party staff. 
9. Record, monitor and review incidents and the effectiveness of these measures at least annually.
10. Standards expected of all third parties

1.2.3 Standards expected of all third parties 

Every third party must treat Spherica personnel with dignity and respect at all times. Unacceptable behaviour includes, but is not limited to:

• Sexual Harassment and/or sexual misconduct;
• unwelcome physical contact, including touching, hugging, brushing against someone or invading personal space;
• sexual comments, jokes, innuendo or remarks about a person’s appearance, body, clothing or private life;
• sexual propositions, repeated requests for dates or pressure for personal contact after it has been declined;
• displaying, sharing or sending sexual or offensive images, messages or material, including through remote support sessions, screen sharing, email or messaging platforms;
• comments, slurs, stereotyping or ‘banter’ related to any protected characteristic;
• intimidating, aggressive, threatening or abusive language or behaviour, whether in person, by phone or in writing;
• requesting personal contact details or social media connections for non-business purposes, or contacting personnel outside agreed working channels;
• treating someone less favourably because they rejected, objected to or reported unwanted conduct;
• Offending a person regarding their age, sex, race, religion/belief, disability, marital status, sexual orientation, pregnancy/maternity, pronouns and/or gender reassignment;
• Harassment and bullying;
• Any behaviour that is not consented by the receiving individual or surrounding individuals;
• Being offensive, abusive, malicious, insulting or intimidating;
• Engaging in unjustifiable, destructive criticism;
• Implementing performance-based consequences without the sufficient seniority to do so or correct procedural instruction to justify said consequence;
• Changing an employee’s duties or responsibilities without the correct procedural instruction to justify changes in their duties or responsibilities.We also expect third parties to:
• Ensure their own staff, contractors and representatives who interact with Spherica personnel are made aware of these standards;
• Take reasonable steps within their own premises and systems to prevent harassment of Spherica personnel;
• Cooperate fully and promptly with any investigation;
• Report any concern about the conduct of Spherica personnel so that we can act on it.

1.2.4 Customers and clients 

As a managed service provider, our people regularly work inside customer environments, both physically and remotely. In addition to the standards in section 1.2.3, we ask customers to: 

1. Share this policy internally with staff who raise tickets, contact our service desk or host our engineers on site. 
2. Provide a safe working environment when Spherica personnel attend site, including a named host contact, a suitable workspace and access to your own reporting procedures. 
3. Advise us in advance of any known risks on site, such as lone working, out-of-hours access or individuals with a history of inappropriate behaviour. 
4. Act on concerns raised about your staff, including taking appropriate action under your own disciplinary or conduct procedures and confirming to us that action has been taken. 
5. Nominate a senior contact who will work with Spherica to resolve any report quickly and confidentially. 

How we will respond to harassment by customers. Where an incident occurs, Spherica will take whatever action it considers appropriate to protect its personnel, depending on the circumstances and severity. 

1.2.5 Suppliers, contractors and subcontractors 

Suppliers and contractors who work alongside Spherica personnel, or on our behalf with our customers, must meet the standards in section 1.2.3. In addition, they must: 

1. Confirm acceptance of this policy at onboarding, at each contract renewal and when it is updated, by signing the acknowledgement in section 1.3. 
2. Suppliers to maintain their own anti-harassment policy and reporting procedure, proportionate to their size, and provide a copy on request. 
3. Brief all individuals they deploy to Spherica, systems or projects on these standards before work begins. 
4. Report promptly to Spherica any allegation of harassment involving Spherica personnel, whether the alleged harasser is their own staff, Spherica personnel or another party. 
5. Remove or replace individuals from Spherica work where Spherica reasonably requests this following a substantiated concern, or as an interim measure during an investigation. 
6. Flow down equivalent obligations to any subcontractors they engage on Spherica work. 
7. Read the related policies that Spherica commits to in Annex A 

Contractors working under Spherica’s direction. Individual contractors working within Spherica teams are expected to follow our Anti- Harassment & Bullying Policy as if they were employees, complete our harassment awareness training, and use the reporting routes in section 1.2.6 both to raise concerns and to receive protection. 

Supplier selection. Commitment to harassment prevention forms part of our supplier due diligence. A refusal to accept this policy, or a failure to act on a substantiated concern, may result in the supplier not being approved or being removed from our approved supplier list.

1.2.6 Reporting and response 

Anyone who experiences or witnesses harassment involving Spherica personnel should report it as soon as possible. Reports can be made informally or formally, and anonymously if preferred, although anonymity may limit the action we can take. 

Reporting routes for Spherica personnel 

• Line manager or any other manager 

• HR Director: [email protected] – 07715474186 

• Whistleblowing procedure, where the concern is that harassment has occurred, is occurring or is likely to occur 

Reporting routes for customers, suppliers and contractors 

• Your Spherica account manager or main contact 

• HR Director: [email protected] – 07715474186 

What happens  

1. Immediate safety. Where needed, the person affected is removed from the situation straight away, for example by ending a remote/phone session or leaving site. 
2. Acknowledgement. HR acknowledges the report within two working days and agrees support with the person affected. 
3. Interim measures. Proportionate measures are put in place to prevent further contact while the matter is considered. 
4. Engagement with the third party. Spherica raises the matter with the third party’s nominated senior contact, sharing only the information needed. 
5. Investigation. The concern is investigated fairly and impartially, with both parties given an opportunity to respond where appropriate. 
6. Outcome and action. The person affected is told the outcome, as far as confidentiality allows, and agreed actions are implemented. 
7. Record and review. The incident and actions are logged confidentially and reviewed for lessons learned and any changes to risk controls. 

The person affected will be kept informed throughout. They will not be required to deal directly with the alleged harasser and will not suffer any detriment for raising a concern in good faith. 

Signed:  

 J.Harper

Dated: 21.10.2026