Bullying Harassment and Discrimination Policy
POLICY TYPE: People & Culture
LAST UPDATED: July 2026
Bullying, discrimination, vilification, victimisation and harassment can have adverse consequences for Limelight
People (, its workplace and its employees. It is the Company’s policy that all staff members are responsible for
maintaining, a workplace free of bullying, discrimination, vilification, victimisation and harassment and for reporting any such behaviour to the Company.
If you believe that you, or other staff members, have been or are the subject of bullying, discrimination, vilification,
victimisation or harassment, including sexual harassment, then you should promptly report the behaviour. If
appropriate, you should report the concern to your immediate manager. If this is not appropriate because the
situation involves your immediate manager, then you should report the incident to the next level of management. It is not necessary for you to speak directly to the other person. For More information please see our Disputes Policy Form
Bullying and Harassment
Workplace health and safety legislation requires the Company to ensure your health, safety and welfare at work. The Company must take active measures to prevent bullying and harassment from occurring in the workplace and must take reasonable steps to stop it, whenever it occurs.
What is bullying and harassment?
Bullying and harassment in the workplace is generally accepted to be repeated unreasonable behaviour directed towards staff that creates a risk to their health and safety. It may be direct or indirect and includes behaviour that humiliates, intimidates or offends an employee at their workplace.
The following are examples of direct bullying/harassment:
- threatening to harm someone;
- acts of violence;
- offensive or abusive language;
- public humiliation.
The following are examples of indirect bullying/harassment:
- deliberately excluding or isolating an employee from workplace activities;
- spreading malicious rumours about another employee;
- deliberately denying access to information or other resources;
- withholding access to information or other resources required by an employee to enable them to perform effectively at work.
This Policy applies to repeated behaviour and single or isolated incidents are relevant.
What is not bullying and harassment?
The Company and management have a legal right to direct you in relation to the performance of your duties at work, monitor your performance, identify performance problems and give feedback to you in relation to your performance.
This is not bullying.
The following examples do not constitute bullying or harassment:
- setting performance goals and deadlines;
- rostering and allocating work;
- performance management of an employee or notifying an employee of unsatisfactory performance;
- informing an employee about inappropriate behaviour; and
- restructuring or organisational changes.
Discrimination
Discrimination can be unlawful under Federal, State and Territory legislation. The Company may be liable for acts of discrimination committed by its employees and agents in connection with the performance of their duties.
The Company must take active measures and reasonable steps to prevent discrimination from occurring in the workplace and must take appropriate action whenever it occurs.
A person discriminates against another person if the person:
- treats the other person less favourably than in the same circumstances, or in circumstances which are not materially different, that the person treats or would treat another person because the other person belongs (or is thought to belong) to a particular group (i.e. direct discrimination); or
- segregates the other person; or
- requires the other person to comply with a requirement or condition which is the same for everyone but is not reasonable for the other person having regard to the circumstances as it has a disproportionate or unequal effect on the other person and the other person does not or is not able to comply with it (i.e. indirect discrimination).
Discrimination on any of the following grounds is unlawful:
- age (including requiring an employee to retire because of their age);
- carer’s responsibilities;
disability (including physical, intellectual or psychiatric disability); - homosexuality;
- marital status;
- race;
- sex;
- transgender status.
It is also generally unlawful to discriminate against a person because an associate or relative of theirs falls into one of the above mentioned categories.
Vilification
A person must not, by a public act, incite hatred towards, serious contempt for, or severe ridicule of, another person or group of persons on the grounds of race, transgender status, or because the other person or group of persons is/are HIV/AIDS infected or thought to be so infected. It is unlawful for a person to commit an act that members of the public may see, hear or read which would encourage members of the public to hate, hold serious contempt for, or severely ridicule another person or group of persons in circumstances where the members of the public did not already have those feelings. This is known as vilification.
Victimisation
A person who makes, intends to make, helps another person make, witnesses, or gives evidence or information in
relation to a complaint of discrimination, vilification or sexual harassment must not suffer any detriment or otherwise be harassed or punished as a result of such action. It is therefore unlawful for a person to subject another person to any detriment or otherwise harass or punish the other person by reason of any of those things. This is known as victimisation.
Sexual Harassment
Workplace health and safety legislation requires the Company to prevent sexual harassment and the Company may be liable for acts of sexual harassment committed by its employees and agents in connection with the performance of their duties. In order to minimise the risk of liability, the Company must take active measures and reasonable steps to prevent sexual harassment from occurring in the workplace and must take appropriate action whenever it occurs.
What is sexual harassment?
Sexual harassment is behaviour where a person:
- makes an unwelcome sexual advance;
- makes an unwelcome request for sexual favours; or
- engages in other unwelcome conduct of a sexual nature,
to another person in circumstances in which a reasonable person, having regard to all the circumstances, would have anticipated that the other person would be offended, humiliated or intimidated. This means that sexual harassment can occur even when the person engaging in the relevant behaviour does not intend to offend, humiliate or intimidate another person.
Sexual harassment:
- can be committed by any person in the workplace (including managers, employees, contractors or service providers);
- may occur within the workplace or outside the workplace;
may be a single incident or repeated behaviour; - involves not only the person who engages in the relevant behaviour, but may also involve any person who encourages or allows such behaviour to occur;
- may result in compensation being payable to the person who has been sexually harassed.
The following are examples of sexual harassment:
- physical contact (e.g. touching);
- staring or making gestures;
- telephone calls, social invitations or questioning unrelated to work;
sexual conversations, comments, jokes, questions or teasing; - sexual material contained in emails or at the workplace.
What is not sexual harassment?
Behaviour is not sexual harassment if it is consensual and/or reciprocated.
Responsibilities of Staff and the Company
The Company intends to prevent bullying, discrimination, vilification, victimisation or harassment, including sexual harassment, in the workplace by adopting this Policy, making you and other staff aware of it during induction and training processes and periodically from time to time, monitoring compliance with this Policy, reviewing this Policy from time to time and taking appropriate action when a report is made of behaviour that is in breach of this Policy.
You have an obligation to comply with this Policy by not behaving in a way that would be in breach of this Policy,
intervening if you witness behaviour or an incident that is in breach of this Policy, reminding other staff of their
obligations under this Policy and reporting any breach of this Policy.