Bullying, Harassment & Sexual Harassment Policy

1. Purpose

Divergent Edge Strategies ("we", "our", "us") is committed to ensuring all people engaged with our business — including employees, contractors, and clients — work in an environment that is safe, respectful, inclusive, and free from bullying, harassment, and sexual harassment.

We uphold this commitment under:

• Fair Work Act 2009 (Cth)
• Sex Discrimination Act 1984 (Cth)
• Work Health and Safety Act 2011 (Cth)
• Relevant state and territory anti-discrimination legislation

This policy applies regardless of whether you are working in our offices, remotely, or on client premises.

2. Scope

• All Divergent Edge Strategies employees, contractors, directors, suppliers, and interns
• All work-related interactions, including:
• While working at client sites
• During business travel
• At work-related events, functions, or online meetings
• In email, social media, and other electronic communications related to work

3. Definitions

• Bullying: Repeated, unreasonable behaviour directed at an individual or group that creates a risk to health and safety.
• Harassment: Unwelcome behaviour based on a protected attribute (e.g., race, gender, disability, religion, sexual orientation) that a reasonable person would consider offensive, humiliating, or intimidating.
• Sexual Harassment: Unwelcome sexual advance, request for sexual favours, or conduct of a sexual nature that a reasonable person would expect to cause offence, humiliation, or intimidation.
• Victimisation: Treating a person unfavourably because they made, intend to make, or have been involved in a complaint or investigation.

4. Policy Statement

We have a zero-tolerance approach to bullying, harassment, and sexual harassment. We will:

• Take all complaints seriously and act promptly
• Ensure investigations are fair, impartial, and confidential
• Protect complainants from victimisation
• Cooperate with client organisations’ WHS and HR teams where incidents occur on their premises

5. Working Within Client Organisations

• You must comply with both Divergent Edge Strategies’ policies and the client’s workplace policies on behaviour, safety, and conduct.
• If you experience or witness bullying, harassment, or sexual harassment:
  1. Follow the client’s internal reporting process and
  2. Report the matter to Divergent Edge Strategies management so we can support you and, if needed, escalate the issue.
• If you feel unsafe or unable to report via the client’s process, you may report directly to Divergent Edge Strategies and we will handle the matter on your behalf.

6. Reporting Process

Internal Reporting

• Report incidents to the Director or designated HR/Compliance Officer
• Reports can be verbal, written, or via email at enquiries@divergentedge.com.au
• Reports will be acknowledged within 2 business days

External (Client-Site) Reporting

• Follow the client’s reporting procedures (often via their HR or WHS department)
• Notify Divergent Edge Strategies so we can monitor and support resolution

7. Investigation Procedure

1. Acknowledge receipt of complaint
2. Determine whether the matter falls under this policy or another policy
3. Interview all relevant parties confidentially
4. Assess evidence and make findings based on balance of probabilities
5. Take appropriate corrective action
6. Provide feedback to complainant and respondent

8. Consequences of Breach

• Disciplinary action may include verbal or written warnings, suspension, termination of employment or contract, or removal from client site
• Serious breaches may be referred to external authorities

9. Support Services

• 1800RESPECT – 1800 737 732
• Fair Work Ombudsman – www.fairwork.gov.au
• Safe Work Australia – www.safeworkaustralia.gov.au
• Divergent Edge Strategies Employee Support Resources

10. Review & Updates

This policy will be reviewed annually or after a significant workplace incident, legal change, or client feedback requiring adjustment.