Prevention of workplace bullying


This policy sets out the way ReGEN Strategic and its associated entities (the Company) aims to eliminate workplace bullying in its working environment. This is in accordance with the Company’s legal obligation to ensure, so far as is reasonably practicable, the health and safety of its employees and volunteers while at work and the health and safety of those workers affected by the Company’s activities.

Workplace bullying:

  • is a health and safety hazard
  • has the potential to seriously damage people’s lives, careers and reputations
  • creates toxic workplaces and affects productivity
  • exposes individuals and the Company to liability under work health and safety legislation, and
  • can cause serious damage to the Company’s business and reputation.

For these reasons, the Company is committed to stamping out workplace bullying. The Company encourages all employees and volunteers to report all instances of workplace bullying as soon as they occur.

Scope of this policy

This policy applies to all workers of the Company.

For the purposes of this policy, the term ‘‘worker’ includes:

  • an employee
  • a manager
  • an employee of a labour hire company who has been assigned to work in the Company (i.e. a ‘temp’)
  • an apprentice or trainee
  • a student gaining work experience, or
  • a volunteer.

This policy applies to conduct in any of the Company’s ‘workplaces’ as defined below.

The policy also applies to conduct on social media platforms where there is a connection to the Company’s workplace, or conduct using the Company’s IT (computer, email and internet) system, whether or not the conduct occurs during or outside of normal business hours. (Please refer to and read this policy in conjunction with the Company’s Social Media Policy and Acceptable Use of IT Policy.)

Employees and volunteers engaged by the Company must comply with this policy at all times in the course of their engagement by the Company. However, this policy does not form part of any person’s contract with the Company or create any enforceable rights or entitlements for them.

What is workplace bullying?

Workplace bullying is repeated, unreasonable behaviour directed towards one or more employees, volunteers, or contractors of the Company, which creates a risk to health and safety. 

Bullying is not acceptable in the Company’s workplace. Because workplace bullying creates a risk to health and safety, engaging in bullying conduct at work can lead to personal liability and even criminal sanctions under applicable work health and safety legislation applicable in the State in which the conduct occurs. 

Where is the Company’s ‘workplace’?

For the purposes of this policy, ‘workplace’ means:

  • all workplaces and places where people carry out work activities of the Company
  • wherever employees and volunteers are performing the duties of their engagement (including vehicles and aircraft), and
  • wherever employees and volunteers are engaging in other activities during the course of their engagement or which are related to or in connection with their engagement with the Company.

The Company’s workplace therefore extends outside the office to work activities including but not limited to activities undertaken at work-related social events and functions, and other events such as:

  • conferences
  • business and field trips
  • training programs, and
  • business or client functions

whether or not these occur during or outside of normal business hours.

What is ‘unreasonable behaviour’?

Unreasonable behaviour is behaviour which a reasonable person, having regard to all of the circumstances that the alleged perpetrator would reasonably be expected to know, would expect to victimise, humiliate, undermine or threaten the recipient of the behaviour.

Unreasonable behaviour includes actions of individuals or a group, and may involve using a system of work as a means of victimising, humiliating, undermining or threatening a person.

What is not bullying?

Reasonable management action is not bullying. Reasonable management action includes (but is not limited to) fairly and reasonably:

  • reviewing work performance
  • setting performance goals, standards and deadlines
  • allocating work
  • rostering and allocating working hours
  • transferring an employee
  • deciding not to select an employee for promotion
  • informing an employee about unsatisfactory work performance
  • informing an employee about inappropriate behaviour
  • implementing organisational changes
  • implementing and conducting performance management processes
  • conducting misconduct processes and implementing disciplinary outcomes, and
  • providing constructive feedback.

Further, having a mere difference of opinion or a personality clash with someone else in the office does not (of itself) mean bullying is occurring.

What about single instances of unreasonable behaviour?

Single instances of unreasonable behaviour will not constitute bullying. However, single instances of such behaviour may still constitute discrimination, sexual harassment, vilification, victimisation or other unacceptable conduct upon which the Company could act (including by taking disciplinary action against a person).

Examples of bullying behaviour

Workplace bullying can be direct or indirect. 

Examples of direct bullying include:

  • workplace violence
  • abusive, insulting or offensive language
  • spreading misinformation or malicious rumours
  • behaviour or language that frightens, humiliates, belittles or degrades another person, including criticism that is delivered with yelling or screaming
  • displaying offensive material in the workplace
  • making inappropriate comments about a person’s appearance, lifestyle or their family
  • teasing or regularly making someone the brunt of practical jokes
  • interfering with a person’s personal property or work equipment, and
  • engaging in conduct which would breach the Company’s Respect in the Workplace Policy.

Examples of indirect bullying include:

  • unreasonably overloading a person with work or not providing enough work
  • setting timelines that are difficult to achieve, or constantly changing deadlines
  • setting tasks that are unreasonably below or beyond a person’s skill level
  • deliberately excluding, isolating or marginalising a person from normal work activities
  • withholding information that is vital for effective work performance, and
  • deliberately denying access to information, consultation or work resources.
  • Aiding, abetting, encouraging or condoning other persons to engage in workplace bullying is likely to also constitute bullying.

Compliance with this policy

Workplace bullying towards any employee, volunteer, contractor, supplier, customer, client or visitor in any work-related situation will not be tolerated by the Company under any circumstances.

All persons covered by this policy must comply with this Policy by ensuring they do not engage in or condone workplace bullying towards:

  • other employees and volunteers of the Company
  • any other co-workers
  • clients and service providers of the Company, or
  • any other person with whom the person has contact in connection with their employment or engagement with the Company.

Further, all persons covered by this policy have a legal duty under work health and safety legislation to:

  • take reasonable care for his or her own health and safety
  • take reasonable care that his or her acts or omissions do not adversely affect the health and safety of other persons
  • comply, so far as the person is reasonably able, with any reasonable instruction that is given by the Company to allow the Company to comply with its obligations under work health and safety legislation, and
  • co-operate with this policy.

Conduct by employees and volunteers found to be in breach of this policy may be considered misconduct and may constitute serious misconduct, either of which exposes a person to disciplinary action (which could include the termination of a person’s employment or engagement).

In addition, an individual engaging in unlawful conduct prohibited by this policy may be held individually (personally) liable for their conduct under work health and safety legislation or the criminal law. Under applicable legislation, this exposes an individual to criminal convictions, orders by a Court that the individual pay compensation and financial penalties, and even imprisonment in certain circumstances.


It is the responsibility of all persons covered by this policy to:

  • ensure they familiarise themselves with the terms of this policy
  • ensure their conduct in the workplace is in line with this policy, and
  • if they consider that workplace bullying may be occurring, ensure they take appropriate action in line with the policy process.


Without in any way limiting the other provisions of this policy, managers must:

  • ensure they familiarise themselves with the terms of this policy and their responsibilities in relation to it
  • conduct themselves in accordance with the terms of this policy
  • ensure they deal with any matter raised with them under this policy in accordance with its terms
  • take appropriate action to prevent conduct in the workplace that may be in breach of this policy, and
  • take immediate action to stop conduct in breach of this policy if they consider it is occurring.

Procedures to resolve complaints under this policy

This policy establishes the following procedures to resolve complaints of workplace bullying.

You may make a complaint about workplace bullying whether or not you are a victim of the behaviour about which you are concerned and managers in this Company will treat all complaints of workplace bullying seriously. If you are a victim, they are also able to discuss with you options to resolve the matter effectively.

If you feel comfortable doing so, you may wish to raise your concerns with the person engaging in the conduct. This may be enough to stop it. However, if you do not feel comfortable and/or you want the Company to take action in relation to your concerns, you must lodge a complaint in the way set out below.

Formal complaint procedure

If you want to lodge a formal complaint you must make a written, signed statement outlining:

  • what you believe to have occurred
  • relevant names, dates, and locations and any witnesses, and
  • provide the written statement to a manager of the Company and indicate in writing what outcome you seek.

The person to whom you provide your formal complaint will act on it in accordance with his/her responsibilities set out later in this policy.

The parties to the formal complaint resolution process will be the alleged victim and the alleged perpetrator. The resolution of formal complaints may include:

  • recommending that an appropriate person assist the parties to resolve the matter
  • mediation between parties or a facilitated discussion between the parties
  • investigating the incident/matters (whether internally or using an external investigator)
  • conducting a workplace review
  • investigating the matter as a misconduct investigation,
  • the Company taking disciplinary action against a bully and anyone found to have aided, abetted, encouraged or condoned bullying behaviour, and/or
  • referring the matter to an appropriate external agency (which may include a workplace safety regulator and/or the Police.

The Company has absolute discretion as to whether and, in what manner, a complaint made in accordance with this policy will be addressed.

Local and informal resolution of complaints is preferred and not all complaints will require a formal investigation. Some complaints, such as those arising from misunderstandings or miscommunication, can be adequately addressed by informal methods.


The Company will take all reasonable steps to ensure details of a complaint are only disclosed to those who strictly need to know those details. However, as workplace bullying is a health and safety hazard, it will not be possible for the matter to remain entirely confidential and the Company may determine in its sole discretion that it needs to take action as a result of receiving a formal complaint.

False allegations prohibited

Allegations of workplace bullying have serious consequences for the lives of the individuals involved and the Company.

If you make a report of workplace bullying:

  • spitefully
  • maliciously, or
  • without a genuine belief in the truth of the matters you are reporting,

you may be subject to disciplinary action (which may include the termination of your employment/volunteer engagement).

Complaints to external bodies

While employees and volunteers are encouraged to use the procedures in this policy, they have a right to seek advice from and/ or lodge a complaint with external bodies including (but not limited to):

  • the Police
  • [as applicable] WorkSafe Victoria, SafeWork South Australia, WorkSafe Western Australia, WorkCover New South Wales, Northern Territory WorkSafe, WorkSafe Tasmania, WorkSafe Australian Capital Territory or WorkSafe Queensland, or
  • the Fair Work Commission

at any time.

Consequences of contravening the policy

If you engage in conduct in contravention of this policy and/or applicable legislation, you will be subject to disciplinary action, which may include the termination of your employment or (if a volunteer) engagement.

In cases of serious contravention of this policy and/or applicable legislation, your employment may be terminated summarily (without notice) for serious misconduct.