At KeystoneHR, we know that small and medium-sized businesses often face the same workplace challenges as larger organisations, but without the luxury of dedicated HR teams. One of the most sensitive issues is handling harassment complaints—where the stakes are high for employee wellbeing, legal compliance, and company reputation. This case illustrates how SMEs can respond effectively and proportionately, using clear processes that protect individuals, meet legal obligations, and reinforce a culture of respect. This example we’ll show how practical steps, trauma‑informed practice, and fair investigations can safeguard both people and business.
Background
Client: A brewery owning 4 pubs with 20 to 30 perm and casual employees
Issue: An employee, Alex, reports that their line manager, Jordan, has made repeated inappropriate comments about their appearance and excluded them from team meetings. Alex feels anxious and believes this is affecting them negatively at work.
Challenge:
- Power imbalance: The Jordan is in a position of authority, which can intimidate Alex and complicate impartiality.
- Business impact: Removing or disciplining a manager in a small team risks operational disruption, yet failing to act undermines trust and exposes the business to legal risk.
- Cultural sensitivity: SMEs often pride themselves on close-knit cultures, but this can blur boundaries and make it harder to distinguish “informal banter” from harassment.
- Compliance risk: Without clear processes, SMEs may mishandle investigations, leading to reputational damage or tribunal claims under the Equality Act 2010.
Our Approach
We worked with the client to bring in a new harassment policy as they didn’t have one. And then followed the below steps:
Step 1. Initial Complaint Handling
- Acknowledge promptly: Thank Alex for raising the issue, reassure confidentiality.
- Document the complaint: Record date, time, and nature of allegations.
- Immediate support: Offer access to EAP, wellbeing resources, or a trusted contact, this will depend on what the company has available.
Step 2. Preliminary Assessment
- Assess whether the complaint falls under harassment (Equality Act 2010 in the UK). Even if it doesn’t the company should enquire into the concern.
- Consider interim measures (e.g., temporary reporting line change, flexible working, suspension).
Step 3. Formal Investigation
- Appoint an impartial investigator (not directly connected to either party and at an appropriate management level).
- Gather evidence: Interview Alex, Jordan, and witnesses; review emails, meeting notes.
- Maintain neutrality: Avoid leading questions, ensure trauma-informed interviewing.
Step 4. Outcome & Decision
- Provide an investigation report to an outcome manager, where business structure allows, alternatively the investigating manager can hold this role where appropriate.
- If allegations are substantiated:
- Apply disciplinary action (warning, training, or dismissal depending on severity) with appropriate appeal options.
- Reinforce anti-harassment policy across the team.
- If not substantiated (even if partially):
- Document findings clearly.
- Offer mediation or team rebuilding support.
- Sometimes some elements are partially upheld, so you need to balance the outcome decision.
Step 5. Follow-Up
- If appropriate check in with Alex regularly to ensure wellbeing and prevent retaliation.
- Review workplace culture - are policies clear, training effective, leadership accountable? Do you live and breath what you say you are as a leadership and as a company
Outcome
In this situation the investigation found that Jordan had not intended harm but was unaware of the impact his comments and exclusionary behaviour had on Alex. While the behaviour met the threshold for concern, it was judged to be more a matter of poor awareness than deliberate misconduct.
- Informal Warning: Jordan received a formal record of the complaint and an informal warning, making clear that future incidents would trigger formal disciplinary action (inline with the policy).
- Training & Development: He was required to attend training on workplace respect, unconscious bias, and inclusive leadership, with follow‑up coaching to embed learning.
- Apology & Restoration: Jordan offered a sincere apology to Alex, facilitated by management and helped by KeystoneHR in a safe setting. Alex reported feeling heard and supported, and agreed to continue working under Jordan’s management with regular management check‑ins.
- Cultural Reinforcement: The company reinforced its anti‑harassment policy across the team, reminding all employees of reporting channels and the importance of respectful conduct.
This outcome balanced accountability with development, ensuring the complainant felt protected while giving the manager an opportunity to learn and improve. For SMEs, this approach demonstrates how proportionate action can resolve issues, strengthen culture, and avoid escalation to tribunal claims.
Key takeaways
- Early intervention prevents escalation.
- Trauma-informed interviewing builds trust and reduces re-traumatization.
- Transparent communication strengthens organizational credibility.
- Policies must be living documents, reinforced through training and leadership modelling.
In summary: Alex raised concerns about inappropriate comments and exclusion by their manager, Jordan. KeystoneHR guided the SME through a fair investigation, which found Jordan unaware of the impact of his behaviour. He received an informal warning, undertook respect and inclusion training, and apologised directly to Alex, who felt supported throughout. KeystoneHR helped the business balance accountability with development, reinforcing policies and embedding a culture of respect without costly disruption.
