Harassment including sexual harassment includes unwanted behaviour or conduct which has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment because of or connected to one or more of the following protected characteristics; age, disability, gender reassignment, race, religion or belief, sex and sexual orientation (S26 Equality Act 2010 and S1 the Protection from Harassment Act 1997 (in its entirety, and as interpreted by section 7 of the Act)).

In deciding whether behaviour constitutes harassment we’ll take into account perception of the reporting party, other circumstances and if it is reasonable for the behaviour to be taken as harassment.

Sexual misconduct means any unwanted or attempted unwanted conduct of a sexual nature and includes but is not limited to sexual harassment, sexual assault or rape as defined in the Sexual Offences Act 2003.

All Study Group students must be protected from harassment and sexual misconduct from other students, staff, and visitors, and as such there is zero tolerance of any form of harassment, inappropriate sexualised behaviour or sexual misconduct. This includes those instances that are face-to face or online. Staff members should refer to the Global Code of Conduct for further information.

The Student Harassment and Sexual Misconduct Policy defines what harassment and sexual misconduct are and sets out our approach to preventing and addressing harassment and sexual misconduct.

Being subjected to harassment, violence and/or abuse may breach a child’s rights as set out in the Human Rights Act, so for any incident of harassment or sexual misconduct that involves a student who is under 18 years old, consideration will be given to reporting the incident to Children’s Services and/or the police as per the requirements of Keeping Children Safe in Education 2025.

In the event a student is over 18 years old the decision to call the police will depend on the student’s wishes, the severity of the incident and/or the risk to others.

This 'single source of information’ is applicable to all Study Group Centres in the UK; online while studying through the Digital Learning Hub; where appropriate in student accommodations (private or university) and in the wider community. It also applies to students who are registered with a Centre but study remotely for reasons beyond their control.

This guidance also extends to our overseas Study Centres where Study Group operates as the provider or delivery partner. While specific procedures - such as reporting protocols, training requirements, and investigations - may differ based on local regulations, best practices should be adopted and implemented wherever feasible, provided they do not conflict with local laws or regulatory obligations.

For the purposes of the policy, any reference to ‘Centre’ includes International Study Centres and the Digital Learning Programme. 

All students undertake training on identifying behaviour that constitutes harassment and sexual misconduct. The training takes place during Welcome Week sessions or during the extended induction period. The training’s key learning outcomes are as follows: 

• To recognise the different forms of harassment and sexual misconduct, both in-person and online. 
• To gain a clear understanding of consent and the law whilst studying with us.  
• To learn how to be a positive bystander. 
• To understand how to report concerns effectively.  
• To identify available support resources.  

The training considers the needs of our students given they are an almost exclusively international cohort and that it is appropriate for our specific student population.

We recognise the importance of student voices, which is why student representatives undergo specialised training, which has been created by our Central Student Wellbeing Team in collaboration with lead student representatives across the Study Group network. This training ensures our students are equipped to uphold our commitment to a culture of safety for all and understand how to escalate students’ concerns where their peers may report incidents of harassment and sexual misconduct to them.

Training for students is accessible via your Centre’s Virtual Learning Environment.

Training for student representatives is accessible via your Centre’s Virtual Learning Environment.

There is further information about our training for students in the Student Harassment and Sexual Misconduct Policy.

All staff employed at our Centres are required to complete annual training led by the Centre’s Designated Safeguarding Lead or designate. The training is refreshed at least annually.

This training ensures that all staff at our Centres are equipped: 

• To have an up-to-date understanding of the resource on harassment and sexual misconduct. 
• To understand what behaviour constitutes harassment and sexual misconduct. 
• To know how to support students who wish to make an allegation of harassment and/or sexual misconduct. 
• To support students who have alleged and/or experienced harassment and/or sexual misconduct. 
• To support students who are the actual or alleged perpetrators of harassment and/or sexual misconduct. 

There is further information about our Training for Staff in the Student Harassment and Sexual Misconduct Policy.

All students must be made aware of the importance of raising concerns relating to themselves or others and not to act as a bystander. They must also be made aware of the means available to them to raise these concerns in an environment where they feel safe and supported without fear of judgment, while reducing anxiety and discomfort.

Information about the Centre’s Designated Safeguarding Lead, Deputy Designated Safeguarding Leads and welfare teams, and their contact details, is displayed prominently in communal areas with a description of their roles. This information is also prominently displayed on both the student and staff support sites on our Centres’ virtual learning environments.

There are multiple ways for students to report concerns. These include the following (please note this list is not exhaustive):  

• The Centre’s dedicated email address for student safeguarding and wellbeing concerns. 
• Anonymous reporting forms, which students can use to share bullying, discrimination, harassment, hate crime and sexual misconduct incidents without revealing their identity. 
• The Centre’s Designated Safeguarding Lead is contactable during working hours. 
• The Centre’s Student Wellbeing Team is contactable during working hours. 
• Our Student Assistance Programme for out-of-hours concerns. 

Reports are accepted on behalf of students who have alleged and/or experienced harassment or sexual misconduct, or on behalf of witnesses, from third parties, for example third party reporting centres.

Students who share concerns will be informed how information they share may be used, for example during a disciplinary process.   

Confidentiality is a fundamental principle in fostering a culture where our students feel safe to raise concerns about harassment and sexual misconduct. We are committed to taking all reasonable measures to protect the privacy and confidentiality of those who come forward. However, there may be situations - such as when an individual’s safety is at risk - where it is necessary to share information with relevant agencies or internally. Our Centres may be obligated to breach confidentiality and share information either internally or with external agencies if a student is under 18 years of age and has experienced or is at risk of significant harm. This also applies if information is provided regarding a child or young person under 18 who is facing, or is at risk of, significant harm, or if the individual is a vulnerable adult meeting these criteria. Refer to the Information Sharing Principles.

Our Student Disciplinary Policy details how incidents are investigated where allegations have been made against students. It also details our Outcomes and Appeals Process and its associated supporting documentation.

Our Disciplinary Policy and Procedure (UKEU) details how incidents are investigated where allegations of harassment and sexual misconduct have been made against staff. There is additional information in our Global Code of Conduct.

These documents outline the process for investigating allegations fairly, including clear timelines, stages, potential penalties, and provisions for appeal.

We have support systems in place for students who have made allegations and complaints related to harassment and sexual misconduct. The format can vary, such as in-house or through a third-party. This support could involve (please note this list is not exhaustive): 

• The student is assigned a dedicated staff member for ongoing guidance and assistance during working hours.    
• The student is placed on a personalised support plan, developed in collaboration with the Centre's Student Wellbeing Team (usually, the dedicated staff member). 
• The student is provided with support throughout the process of reporting to the police or other external authorities.  
• The student is signposted to external specialist support, such as counselling. 
• The student is supported academically, such as applying for extenuating circumstances, or to ensure the continued academic engagement where they wish to continue studying.  
• The student is supported in relation to decisions about attendance, continuation, suspension or cessation of study. 
• The student is referred to our Student Assistance Programme.  

Students facing allegations will be provided with a named staff member who they can contact for support.

Support is also provided to students who have witnessed such behaviours. Support is available to students who have alleged and/or experienced harassment or sexual misconduct, whether or not they decide to make a formal report about an incident.

We take into account the diverse support needs of students, including mental health diagnoses, experiences of trauma or abuse, sexuality, gender identity, or any other factors that may increase their vulnerability. All support should be provided with these considerations in mind to ensure it is appropriate and inclusive.

The decision to contact parents and/or agents will be made on a case-by-case basis dependent on the disclosure, the safeguarding risk to the student and the student’s wishes. Refer to the Information Sharing Principles.

In certain situations, the Centre may need to act without the student's consent, particularly if there are concerns about a significant risk of harm to the student or others. In such cases, the student will be informed and supported, unless doing so is unreasonable, impossible, or impractical under the circumstances.

Our Centres provide a safe and inclusive environment for both students and staff, whether on campus or in our online spaces. We are committed to respecting and upholding the dignity of all individuals, in line with our values of equality and diversity, and in accordance with protected characteristics.

We are committed to implementing meaningful and impactful measures that protect students from harassment and sexual misconduct. Our actions include: 

• Analysing and sharing data on harassment and sexual misconduct trends, while reviewing our training programmes for staff and students to address emerging risks and trends across our Study Group network. 
• Gathering feedback through surveys from both students and staff to assess the effectiveness of our training and using this data to refine and enhance our approach. 
• Collaborating with our university partners to review training resources and policies on harassment and sexual misconduct. 
• Attending external events to maintain current knowledge. 
• Running regular campaigns to raise awareness about harassment and sexual misconduct, using a variety of platforms including social media, student newsletters, and more. Our campaigns promote inclusivity and offer information on recognising red flags, understanding consent, our reporting procedures, and the support available to students both within the Centre and externally. 

From 1 September 2024 the Office for Students has prohibited the use of non-disclosure agreements (NDAs) in relation to student allegations of harassment and sexual misconduct. Study Group will not use NDAs in relation to complaints of sexual harassment, abuse, misconduct, or other forms of bullying and harassment.

We are dedicated to safeguarding students from any actual or potential conflicts of interest or abuse of power arising from intimate personal relationships with staff. To uphold this commitment, Study Group has enacted a strict ban on personal relationships between staff and current students.

Study Group has a zero-tolerance approach to unlawful discrimination, bullying and harassment. At the same time, we recognise the fundamental importance of freedom of speech for staff, students, and visitors. Study Group is committed to fostering a culture of tolerance which is essential to the academic debate of a wide range of ideas, including those that may be controversial, whilst supporting the safeguarding and welfare of students.

All centres must uphold the principles of lawful free speech and academic freedom. Our policies are designed to ensure they do not unduly restrict lawful expression, even when addressing student misconduct. We apply the requirements of the OfS Condition E6 only in ways that do not conflict with lawful speech protections.

Mandatory training ensures staff are aware that:

• Unlawful harassment is unwanted conduct related to a protected characteristic that violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment.
• Unlawful discrimination occurs when someone is treated less favourably or disadvantaged because of a protected characteristic.

Appropriate actions that uphold free speech while addressing serious misconduct include:

• Prompt removal of hate-promoting graffiti or images.
• Investigating threats of violence, with appropriate support for affected students or staff.

Refer to the External Speakers Policy and Code of Practice for Freedom of Speech.