Employment & HR

Anti-Harassment Policy

Singapore has no statutory internal committee, no prescribed inquiry timetable and no mandated composition for handling harassment. The Protection from Harassment Act gives victims civil and criminal remedies directly; the employer’s duty arises from the common law duty of care, the tripartite standards, and — once commenced — the Workplace Fairness Act. That means the process here is the employer’s to design, and to design well.

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[HEADER — replace with your organisation’s letterhead, if used]

[COMPANY NAME]

Item	Detail
Approved by	[NAME], [DESIGNATION], on [DATE]
Effective from	[DATE]
Policy owner	[DESIGNATION]
Reporting contacts	[NAME], [EMAIL] — and [NAME], [EMAIL]
Applies to	All employees, and to anyone at the workplace — see Clause 2
Review	Annually

1. Commitment

1.1Every person at this workplace is entitled to be treated with dignity and respect. Harassment of any kind will not be tolerated, whoever the person responsible and whatever their seniority.

1.2The Company will take reasonable steps to prevent harassment, will provide clear routes to report it, will inquire into reports fairly and confidentially, and will act where a report is substantiated.

1.3Nothing in this policy limits any right a person has in law, including the right to seek a protection order or to make a police report. The Company will support any person who chooses to pursue those remedies.

2. Who This Policy Covers

2.1This policy protects every person at the workplace, regardless of sex or gender, and regardless of whether they are employed by the Company — including employees, directors, contractors and their personnel, agency staff, interns, trainees, volunteers, and visitors.

2.2It applies to conduct by any person at the workplace, including employees at every level, clients, customers, suppliers and visitors.

2.3It applies wherever work is carried on or work relationships operate, including client premises, business travel, offsites, work-related social events, and electronic channels used for work, including messaging applications and social media where the conduct arises out of the work relationship.

2.4Where a report concerns conduct by a person the Company does not employ, the Company will still act — by raising it with that person’s employer, by changing arrangements to protect the person affected, or by ending the engagement.

3. What Harassment Means

3.1Harassment includes using threatening, abusive or insulting words or behaviour, or making such communication, that causes or is likely to cause harassment, alarm or distress to another person.

3.2It includes, without limitation:

(a)Sexual harassment — unwelcome sexual advances; requests for sexual favours; unwanted physical contact; sexual comments, jokes or questions; displaying or circulating sexual images; persistent invitations after refusal; and conduct made explicitly or implicitly a condition of, or a factor in, an employment decision;

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Notes for use

These notes accompany the template and explain the drafting choices, the compliance points and the mistakes most often made with this document. They appear as a final page in the Word file, intended to be deleted before the document is executed.

There is no statutory internal committee here

Employers familiar with jurisdictions that mandate an internal committee, a prescribed composition including an external member, and fixed statutory timelines will find none of that in Singapore. The Protection from Harassment Act gives remedies to individuals rather than imposing an inquiry structure on employers. The employer’s duty comes from the common law duty of care, tripartite standards and, once commenced, the Workplace Fairness Act. Do not import a committee model wholesale; do adopt an equivalent standard of fairness, because nothing lower will withstand scrutiny.

The Act protects everyone, not only women

Protection is not limited by sex or gender. A policy drafted to protect only female employees is both under-inclusive and out of step with the legislation. Clause 2.1 states the position plainly.

Individuals have direct remedies

A person subjected to harassment may seek a protection order, an expedited protection order in urgent cases, or damages, and certain conduct is criminal. The employer’s process runs alongside those remedies and must never be presented as an alternative to them. Clause 1.3 says so, and an employer that discourages a police report or a court application creates serious exposure for itself.

Cover contractors, interns and visitors

Many harassment incidents involve people the employer does not employ — contractor personnel, agency staff, clients. Clause 2.4 requires the Company to act even where it cannot discipline the person, by raising it, changing arrangements, or ending the engagement. Passing the problem back to the person affected is not an answer.

Effect, not intention

Clause 3.3 is the point that most needs explaining in training. The test is the effect on the person experiencing the conduct. Inquiry officers who apply an intention test reach the wrong conclusions, and "it was a joke" is not a defence.

Do not move the victim

Clause 5.3 addresses the most common failure in handling reports: relocating, reassigning or changing the shift of the person who complained, because it is administratively easier. That is experienced as punishment and frequently is one. Move the person against whom the report is made, unless the person affected prefers otherwise.

Never require mediation or confrontation

Requiring a person to raise it directly with the alleged harasser, or to mediate as a precondition to an inquiry, is a serious failure and deters reports. Clause 4.5 prohibits it. Mediation may be appropriate in some cases if the person affected freely chooses it, but never as a gate.

Independence may mean going outside

In a small company, or where the person concerned is senior, no internal person is genuinely independent. Clause 6.2 provides for an external investigator. The cost is far less than the cost of an inquiry that is later shown to have been conducted by someone who reported to the respondent.

Due inquiry still applies to the respondent

Where the outcome may be dismissal, the requirements of due inquiry under the Employment Act apply to the person against whom the report is made — the allegation put with particularity, a genuine opportunity to respond, and an independent decision-maker. A rigorous process protects the complainant’s outcome as much as the respondent’s rights, because a dismissal set aside on procedure helps nobody.

Unsubstantiated is not false

Clause 7.3 separates the two deliberately. Where employees believe an unproved report will be treated as a false one, genuine reports stop being made. Bad faith requires separate proof through its own inquiry.

Follow up afterwards

Step 10 of the timeline is the step organisations skip. Checking after four to six weeks that the conduct has stopped and that the person has not been quietly disadvantaged is what distinguishes a process that works from one that merely concludes.

Confidentiality has limits — say so honestly

A person reporting will often ask for absolute confidentiality. It cannot be given if the matter is to be inquired into, because the allegation must be put to the person concerned. Clause 8.1 is honest about this. Explaining the limits at the outset is far better than discovering them mid-inquiry.

Workplace Fairness Act interaction

Harassment related to a protected characteristic will also engage the Workplace Fairness Act once it commences at the end of 2027, with a Tribunal claims route and civil penalties. Where a report raises both, coordinate the processes and tell the person which applies to which element.

Records and patterns

A confidential register recording reports, outcomes and time taken is what allows the Company to see a pattern — repeated reports about one person, one team, or one site — that individual case handling conceals. It is also the evidence that the Company takes the issue seriously.

Current as of

Reflects Singapore law current as of {{DATE OF USE}}. The Protection from Harassment Act and its remedies, tripartite standards, and the pending Workplace Fairness Act all change — have this policy reviewed by an employment adviser, and train the reporting contacts before the first report rather than after it.

This is a ready-to-use template provided for convenience. Laws and requirements change, and every situation is different — please have it reviewed by a qualified professional (a lawyer, corporate secretary, or accountant as relevant) before you rely on it.