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Workplace Harassment Prevention Policy — South Africa
Every South African employer needs a written Workplace Harassment Prevention Policy. The 2022 Code of Good Practice on Harassment makes it mandatory, the 2025 Code of Good Practice on Dismissal makes it operationally essential, and Section 60 of the Employment Equity Act makes it the single most cost-effective vicarious-liability defence available. Our free template covers sexual, gender-based, racial, bullying, cyber, third-party and remote-work harassment in one document.
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WORKPLACE HARASSMENT PREVENTION POLICY
Meridian Group (Pty) Ltd · Republic Of South Africa · Effective 1 June 2026
Ref: HR-POL-HRT-2026-001
Next review: 1 June 2027
Meridian Group (Pty) Ltd (Registration No. 2015/123456/07) of 22 Fredman Drive, Sandton, Johannesburg 2196 (the "Organisation") is committed to providing a workplace free from harassment in all its forms. HR contact: Tel +27 11 234 5678 · Email hr@meridiangroup.co.za. This Policy is issued in accordance with the Code of Good Practice on the Prevention and Elimination of Harassment in the Workplace (Government Notice 1890, 18 March 2022), issued under the Employment Equity Act 55 of 1998 (EEA), and adopts a zero-tolerance approach to harassment.
1.
SCOPE OF APPLICATION
This Policy applies to All Meridian Group (Pty) Ltd premises, offices and remote-work locations of employees within the Republic of South Africa. Includes Company-organised events (year-end functions, off-site strategy sessions, team-building activities), Company-related travel (domestic and international), and any client premises at which a Meridian employee is performing services.. It expressly extends to remote-work locations, including the employee's home office and any other location at which work is performed. It covers harassment by and against third parties, including clients, customers, contractors, suppliers and visitors, consistent with the third-party-harassment obligations under the 2022 Code.
The Policy applies to: All employees, including permanent, fixed-term, part-time, temporary, casual, learners, interns and independent contractors performing services for the Company. Includes job applicants during the recruitment and selection process and former employees in respect of post-termination conduct connected to the employment relationship.
The Policy applies to: All employees, including permanent, fixed-term, part-time, temporary, casual, learners, interns and independent contractors performing services for the Company. Includes job applicants during the recruitment and selection process and former employees in respect of post-termination conduct connected to the employment relationship.
2.
FORMS OF HARASSMENT PROHIBITED
Harassment, as defined in section 6(3) of the EEA and the 2022 Code, is a form of unfair discrimination and is strictly prohibited under this Policy. The prohibition covers, without limitation:
(a) Sexual harassment — unwelcome conduct of a sexual nature, including unwanted physical contact, sexual advances, sexual comments, requests for sexual favours and the display of sexually explicit material.
(b) Gender-based violence and harassment — conduct directed at a person because of their sex, gender or sexual orientation, including violence, threats, stalking and discrimination.
(c) Racial, ethnic and social-origin harassment — conduct intended to humiliate, insult or threaten a person on the basis of race, ethnic or social origin, including racial slurs and offensive symbols.
(d) Bullying and cyber-bullying — repeated, unreasonable behaviour directed at an employee that creates a risk to health and safety, including via email, instant messaging, social media and other digital communication.
(e) Psychological abuse, humiliation, social exclusion and professional isolation — conduct that undermines an employee's dignity, work performance or workplace relationships.
(a) Sexual harassment — unwelcome conduct of a sexual nature, including unwanted physical contact, sexual advances, sexual comments, requests for sexual favours and the display of sexually explicit material.
(b) Gender-based violence and harassment — conduct directed at a person because of their sex, gender or sexual orientation, including violence, threats, stalking and discrimination.
(c) Racial, ethnic and social-origin harassment — conduct intended to humiliate, insult or threaten a person on the basis of race, ethnic or social origin, including racial slurs and offensive symbols.
(d) Bullying and cyber-bullying — repeated, unreasonable behaviour directed at an employee that creates a risk to health and safety, including via email, instant messaging, social media and other digital communication.
(e) Psychological abuse, humiliation, social exclusion and professional isolation — conduct that undermines an employee's dignity, work performance or workplace relationships.
3.
REPORTING CHANNELS
Any employee who experiences or witnesses harassment is encouraged to report it without delay. The primary reporting channel is the Human Resources Manager. Where the primary channel is unavailable (for example where the primary contact is the alleged harasser), the employee may use the alternative channel: Confidential Company Ethics Line on 0800 21 25 26 (24/7, operated by Tip-offs Anonymous). Reports may also be submitted by email to harassment@meridiangroup.co.za.. Anonymous reporting is supported and accepted, although the depth of investigation may be limited if the complainant cannot be contacted for follow-up. The Organisation guarantees the confidentiality of both the complainant and the alleged harasser during the investigation, subject only to what is required by law or a fair disciplinary process.
4.
INFORMAL AND FORMAL PROCEDURES
Informal procedure: The complainant may, where appropriate, request that the matter be resolved informally — for example, through a facilitated conversation, written request to the alleged harasser to stop the conduct, or mediation through HR. The informal procedure is at the complainant's election; the complainant retains the right to invoke the formal procedure at any time.
Formal procedure: Where the complainant elects the formal procedure (or where the seriousness of the conduct requires it), the Organisation shall:
(a) acknowledge receipt of the complaint within two (2) working days;
(b) commence a confidential investigation within 15 working days of receipt;
(c) interview the complainant, the alleged harasser and any witnesses;
(d) document the findings on the balance of probabilities; and
(e) convene a disciplinary hearing in accordance with the Company's Disciplinary Code, the 2025 Code of Good Practice on Dismissal (effective 4 September 2025) and LRA Schedule 8 principles where the investigation supports a charge of misconduct.
Formal procedure: Where the complainant elects the formal procedure (or where the seriousness of the conduct requires it), the Organisation shall:
(a) acknowledge receipt of the complaint within two (2) working days;
(b) commence a confidential investigation within 15 working days of receipt;
(c) interview the complainant, the alleged harasser and any witnesses;
(d) document the findings on the balance of probabilities; and
(e) convene a disciplinary hearing in accordance with the Company's Disciplinary Code, the 2025 Code of Good Practice on Dismissal (effective 4 September 2025) and LRA Schedule 8 principles where the investigation supports a charge of misconduct.
5.
PROTECTION AGAINST RETALIATION
The Organisation expressly prohibits any retaliation against an employee who reports harassment in good faith, who participates in an investigation, or who supports a complainant. Retaliation is itself a disciplinary offence and may give rise to liability under the Protected Disclosures Act 26 of 2000. The Organisation will not subject the complainant to any occupational detriment as a consequence of a good-faith report.
6.
HARASSMENT RISK ASSESSMENT
The Organisation shall conduct a harassment risk assessment annually, in consultation with employee representatives where applicable. The risk assessment shall identify roles, settings, work patterns or interactions that present an elevated harassment risk (including remote-work settings, customer-facing roles, lone working and night shifts), and shall inform the design and updating of preventative measures, training and reporting channels. This risk-based approach satisfies the preventative-steps element of the section 60 EEA defence.
7.
TRAINING
The Organisation will provide the following training:
Mandatory harassment-awareness e-learning module for all employees within thirty (30) days of joining and annually thereafter (45 minutes, with assessment). Live workshop for line managers (2 hours, annually) covering reporting procedure, investigation principles, recognising harassment patterns and victim support. Bespoke 4-hour induction module for HR Business Partners and Ethics Line operators on intake interviewing and trauma-informed practice.
Mandatory harassment-awareness e-learning module for all employees within thirty (30) days of joining and annually thereafter (45 minutes, with assessment). Live workshop for line managers (2 hours, annually) covering reporting procedure, investigation principles, recognising harassment patterns and victim support. Bespoke 4-hour induction module for HR Business Partners and Ethics Line operators on intake interviewing and trauma-informed practice.
8.
ONGOING AWARENESS
The Organisation will sustain awareness of this Policy through:
Annual Workplace Harassment Awareness Week in October, with executive sponsorship and visible CEO communication. Quarterly intranet bulletins on policy updates and anonymised case studies. Visible posters in all break-rooms, kitchens, lifts and toilets with the Ethics Line number. Mandatory annual policy acknowledgement on the intranet, with HR escalation for non-compliance. Inclusion of harassment topics in every all-hands meeting.
Annual Workplace Harassment Awareness Week in October, with executive sponsorship and visible CEO communication. Quarterly intranet bulletins on policy updates and anonymised case studies. Visible posters in all break-rooms, kitchens, lifts and toilets with the Ethics Line number. Mandatory annual policy acknowledgement on the intranet, with HR escalation for non-compliance. Inclusion of harassment topics in every all-hands meeting.
9.
VICTIM SUPPORT — EMPLOYEE ASSISTANCE PROGRAMME
Any employee affected by harassment — whether as complainant, witness or accused — has confidential access to the Organisation's Employee Assistance Programme (EAP), including professional counselling, legal advice and practical support. Where harassment has caused medical or psychological harm, the Organisation may grant additional paid sick leave beyond the BCEA statutory minimum, in line with the support obligation in the 2022 Code.
10.
INVESTIGATOR — EXTERNAL OPTION
For serious matters, matters involving senior employees, or matters where internal investigation may be perceived as biased, the Organisation reserves the right to appoint an external investigator (typically a registered labour practitioner or legal practitioner with workplace-investigation experience) at the Organisation's cost. The external investigator's findings will be considered by the chairperson of any subsequent disciplinary hearing.
11.
PRECAUTIONARY SEPARATION DURING INVESTIGATION
Where the integrity of the investigation, the safety of the complainant, or the wellbeing of colleagues so requires, the Organisation may place the alleged harasser on precautionary suspension on full pay for the duration of the investigation and disciplinary process. This precautionary measure is not itself a sanction and is consistent with the principles confirmed in Long v South African Breweries (Pty) Ltd 2019 (5) BCLR 609 (CC). Alternative measures (such as temporary relocation, change of reporting line or work-from-home) may be applied where suspension is not appropriate.
12.
SANCTIONS
Sanctions for harassment will be determined in accordance with the Company's Disciplinary Code and the 2025 Code of Good Practice on Dismissal:
Sanctions range from documented counselling and coaching for first-time, lower-severity matters; through documented verbal warning, first written warning and final written warning for moderate misconduct; to summary dismissal for serious misconduct including sexual assault, physical violence, repeated harassment after a final written warning, or harassment that involves a senior or position-of-trust employee. Sanctions are imposed by the chairperson of the disciplinary hearing convened under the Company Disciplinary Code, with the employee's right of internal appeal preserved.
Sanctions range from documented counselling and coaching for first-time, lower-severity matters; through documented verbal warning, first written warning and final written warning for moderate misconduct; to summary dismissal for serious misconduct including sexual assault, physical violence, repeated harassment after a final written warning, or harassment that involves a senior or position-of-trust employee. Sanctions are imposed by the chairperson of the disciplinary hearing convened under the Company Disciplinary Code, with the employee's right of internal appeal preserved.
13.
SECTION 60 EEA COMPLIANCE
The Organisation commits to taking all reasonable steps required under section 60 of the EEA to prevent harassment, including (a) issuing and maintaining this Policy; (b) communicating the Policy to every employee on commencement of employment and annually thereafter; (c) conducting periodic risk assessments; (d) providing training and awareness; (e) maintaining accessible reporting channels; (f) investigating reported harassment promptly and impartially; and (g) imposing appropriate sanctions. These steps are intended to establish the employer's defence under section 60 in any subsequent vicarious-liability claim, following Biggar v City of Johannesburg, Emergency Management Services [2011] 6 BLLR 577 (LC) and Pretorius v Britz NO and Others (2017) 38 ILJ 696 (LC).
14.
EXTERNAL REFERRAL — CCMA, BARGAINING COUNCIL AND LABOUR COURT
Where a complainant is dissatisfied with the outcome of the internal procedure, or believes that the harassment constitutes unfair discrimination, the complainant may refer the dispute under section 10 of the EEA to: (a) the relevant Bargaining Council with jurisdiction; (b) the Commission for Conciliation, Mediation and Arbitration (CCMA) using the appropriate referral form; or (c) the Labour Court for adjudication. The complainant retains the right to seek civil remedies and, in cases involving criminal conduct (including sexual assault), to lay criminal charges with the South African Police Service.
15.
CONSULTATION WITH EMPLOYEE REPRESENTATIVES
This Policy was developed in consultation with employee representatives and any recognised trade unions operating in the Organisation, in accordance with the 2022 Code's expectation of collaborative policy design (in particular for third-party harassment protections). The Policy will be reviewed in the same consultative manner.
16.
POLICY REVIEW AND ACKNOWLEDGEMENT
This Policy is scheduled for review by 1 June 2027. It will be reviewed earlier where required by amendments to the EEA, the LRA, the Code of Good Practice on the Prevention and Elimination of Harassment in the Workplace, the 2025 Code of Good Practice on Dismissal, or any other applicable law, or in light of operational experience. Every employee is required to acknowledge receipt and understanding of this Policy. Failure to comply with this Policy may result in disciplinary action up to and including dismissal.
POLICY OWNER
Pieter van der Merwe
Head of Human Resources
Meridian Group (Pty) Ltd
Date: ____________________
EMPLOYEE ACKNOWLEDGEMENT
________________________
I acknowledge receipt and understanding of this Policy
Employee
Date: ____________________
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What Is a Workplace Harassment Prevention Policy?
A Workplace Harassment Prevention Policy is a written organisational document that prohibits harassment in all its forms, defines reporting channels and grievance procedures, sets out sanctions, and commits the employer to preventative measures such as risk assessment, training and awareness. It is the employer's primary instrument for discharging its obligations under the Employment Equity Act 55 of 1998 (EEA) and the 2022 Code of Good Practice on the Prevention and Elimination of Harassment in the Workplace (Government Notice 1890, 18 March 2022).
Under section 6(3) of the EEA, harassment is a form of unfair discrimination — it does not have to be linked to one of the listed prohibited grounds in section 6(1) to be unlawful. The 2022 Code expressly broadens the scope of "harassment" beyond sexual harassment to cover: gender-based violence and harassment; bullying including cyber-bullying via email, instant messaging and social media; racial, ethnic and social-origin harassment; psychological abuse and humiliation; social exclusion and professional isolation; and the use of power resulting in adverse consequences for vulnerable groups. The Code also extends protection to remote-work settings and to third parties such as clients, contractors and visitors.
Section 60 of the EEA creates vicarious employer liability: an employer is liable for an employee's contravention of section 6 (including harassment) unless the employer can prove that it took the reasonable steps required to prevent the contravention. The leading case is Biggar v City of Johannesburg, Emergency Management Services [2011] 6 BLLR 577 (LC), where the employer was held vicariously liable for racial harassment because it had not taken adequate preventative steps. A written, communicated, trained-on and enforced harassment policy is the most important single piece of the section 60 defence — without it, the defence is very difficult to mount.
What's Covered in This Template
Eight-section policy implementing every element required by the 2022 Code, with expert-tier vicarious-liability protection.
Organisation Details
Name, address, CIPC, policy owner with title, effective date, scheduled review date, internal reference.
Comprehensive Scope
Geographic scope, remote-work coverage, third-party coverage (clients, contractors, visitors) and all employee categories (permanent, fixed-term, learners, contractors, applicants).
All Forms of Harassment
Sexual harassment (mandatory), gender-based violence, racial / ethnic, bullying / cyber-bullying, psychological abuse — toggleable per organisational risk profile.
Reporting Channels
Primary channel (HR Manager / line manager / Ethics Line / dedicated email), alternative channel, anonymous reporting option.
Informal + Formal Procedure
Optional informal route, formal investigation with timeline (10/15/20/30 working days), documented findings, disciplinary hearing route.
Anti-Retaliation Clause
Express prohibition on retaliation, plus Protected Disclosures Act 26 of 2000 reinforcement.
Risk Assessment & Training (Expert)
Annual / 18-month / 2-year risk assessment, mandatory training program, ongoing awareness program (Awareness Week, intranet bulletins, visible signage).
Victim Support — EAP (Expert)
Confidential EAP access and additional paid sick leave for harassment-affected employees.
External Investigator Option (Expert)
For serious / senior matters, removes perceived bias.
Precautionary Separation (Expert)
Long v SAB (2019 CC) framework — alleged harasser on full pay during investigation.
Section 60 EEA Defence (Expert)
Express reasonable-steps statement establishing the employer's vicarious-liability defence under Biggar / Pretorius v Britz framework.
CCMA / Labour Court Referral (Expert)
External dispute-resolution route under EEA s.10 — Bargaining Council, CCMA and Labour Court.
How to Create a Workplace Harassment Policy in South Africa
Five steps from gap analysis to a Section 60 EEA-defensible policy.
- 1
Pick the Scope
Decide whether the policy covers remote work and third parties (recommended — required for full 2022 Code compliance). List all employee categories explicitly.
- 2
Cover All Forms of Harassment
Sexual harassment is mandatory. Gender-based, racial, bullying, cyber-bullying and psychological harassment are strongly recommended for Code compliance.
- 3
Set Reporting Channels
Primary channel + alternative channel (in case primary is the harasser) + anonymous option. The Ethics Line is the SA market norm for anonymous reporting.
- 4
Add Risk Assessment, Training and Awareness
These three elements are the heart of the section 60 EEA defence. Commit to specific frequency and content — generic commitments fail the test.
- 5
Issue, Train and Document Acknowledgement
Have every employee acknowledge receipt and understanding in writing. Without acknowledgement, the section 60 defence is fragile.
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Legal Considerations
Workplace harassment exposes employers to vicarious liability — a written policy is the most important single mitigant.
This template is for informational purposes only and does not constitute legal advice. Consult a qualified South African attorney or registered labour practitioner for advice specific to your situation.
Reviewed for South African law
2022 Code of Good Practice — Mandatory Employer Obligations
The Code of Good Practice on the Prevention and Elimination of Harassment in the Workplace (Government Notice 1890, 18 March 2022) replaced the previous 1998 Code on Sexual Harassment. The new Code imposes three specific duties on employers: (1) conduct an assessment of the risk of harassment to employees in the workplace; (2) implement an appropriate written policy addressing harassment; and (3) conduct training to educate employees about the various forms of harassment and implement ongoing awareness programmes. The Code requires that policies be developed in consultation with employee representatives, particularly for the third-party harassment protections. Non-compliance with the Code does not in itself give rise to a cause of action, but the Code is used as the standard against which employers are measured at the CCMA, the Labour Court and the Equality Court.
EEA Section 60 — Vicarious Liability Defence
Section 60 of the EEA imposes vicarious liability on the employer for an employee's contravention of section 6 (unfair discrimination, including harassment). The defence is available only if the employer can prove that it took the necessary steps to prevent the contravention. The four-step framework set out by the Labour Court is: (a) was the alleged contravention reported; (b) did the employer consult the alleged victim and take the necessary steps to eliminate the contravention; (c) did the employer take the necessary steps to prevent the contravention; (d) did the employer comply with its EEA obligations. In Biggar v City of Johannesburg [2011] 6 BLLR 577 (LC) the City was held vicariously liable for race-based harassment at a fire station because it had not taken adequate steps. In Pretorius v Britz NO and Others (2017) 38 ILJ 696 (LC), the employer successfully proved the section 60 defence by demonstrating an active policy, training and immediate disciplinary response.
Interaction with the 2025 Code on Dismissal
The new 2025 Code of Good Practice on Dismissal (effective 4 September 2025) governs the disciplinary procedure that follows a harassment finding. Harassment is typically classified as serious misconduct, and where a fair procedure is followed and the trust relationship is destroyed, summary dismissal at first offence remains permissible. The 2025 Code's requirement that allegations be communicated in a language the employee can reasonably understand applies equally to harassment hearings — an interpreter must be available on request. The Workplace Harassment Policy should be incorporated by reference into the employer's broader Disciplinary Code so that the two regimes interlock cleanly.
Frequently Asked Questions
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