1. The Guide shows how to create and maintain a professional, respectful and productive workplace environment for screen sector projects. It will help your business prevent and deal with bullying, harassment, discrimination and other forms of unacceptable conduct. It describes:
   1. the personal risks and harm that can be caused;
   2. how it plays out in the screen sector;
   3. who is most at risk;
   4. the relevant legislation;
   5. the benefits of good practice;
   6. what your business (and the industry as a whole) can do to improve; and
   7. what standards are expected of screen sector businesses.
2. Every business has a choice. We decide the steps we take to deal with unacceptable conduct. When we discuss a safe workplace, we are addressing a variety of harms that affect individuals differently depending on their overlapping identities. These harms are often intensified for those who belong to multiple marginalised groups:
   1. Systemic exclusion: describes the subtle or structural ways in which certain groups are consistently denied access to opportunities such as positions of power, networking, mentorship, or high-value projects.
   2. Micro-aggressions: are the brief and commonplace daily verbal, behavioural, or environmental indignities that communicate hostile, derogatory, or negative slights, regardless of whether they were intentional.
   3. Harassment and bullying: include unwanted conduct that violates dignity, which frequently takes more aggressive or targeted forms when directed at those with multiple protected characteristics.
   4. Discrimination: is the unjustified less favourable treatment based on one or more characteristics.
   5. Victimisation: is defined as treating a person less favourably because they have raised a concern, supported a whistleblowing disclosure, or acted as a witness.
      
      More detailed definitions appear in the Glossary.
       
3. While every team member deserves protection, research across the screen industries shows that individuals with intersecting identities face heightened risks. A person’s experience of harassment is often shaped by the presence of several factors (such as being both a woman and a person of colour, or being a disabled freelancer from an older age bracket). These experiences are not simply the sum of their parts; they are distinct forms of discrimination that require specific attention.
4. This Guide can’t cover everything, but it aims to introduce screen businesses to good working practices. Taking the first steps, even if not perfect, will help build up momentum. You, or someone you know, might be the problem, but nothing will change unless we all take responsibility for our actions.
5. Screen businesses (like every other sector) must follow laws that protect individuals from harm. This Guide suggests ways of working that take account of the legislation relating to good workforce relations across the four nations. It’s up to date as of June 2026, and it helps prepare for changes that are on the horizon.
6. In a move to help the sector comply with its legal obligations, the BFI/BAFTA Principles were first published in 2018, to address how the sector could fulfil its obligations to tackle bullying, harassment and racism. The current version of the Principles has been endorsed and supported by many sector bodies, broadcasters, funding bodies, unions, guilds, industry associations and member bodies, support and welfare associations, agencies, and management companies.
7. Since publication of the Principles, many other guides and codes have been made available. We also know that our laws and the screen industries have undergone a significant transformation. Hopefully the Principles will be updated and adapted so they remain relevant. The sector will inevitably continue to change as funding, legislation, regulation, technology, international trade, skills and political influences affect all of our businesses.
8. This 2026 Guide will help you follow good working practices that take account of:
   1. the relevant laws in the England, Northern Ireland, Scotland and Wales;
   2. the legally binding standards set by the Equality and Human Rights Commission (EHRC), Acas, the Labour Relations Agency (in Northern Ireland), the Information Commissioner’s Office (ICO) and the Health and Safety Executive (HSE); and
   3. the voluntary standards and principles set by the British Film Institute (BFI) and the British Academy of Film and Television Arts (BAFTA); the Creative Industries Independent Standards Authority (CIISA), and the Film and TV Charity (FTVC).
9. This Guide:
   1. does not replace the BFI/BAFTA Principles or duplicate the CIISA Standards or the FTVC Principles; and
   2. does not constitute legal advice. You should seek your own advice for specific compliance questions.

There’s lots more guidance, model documents, and signposts to support on the WorkWise for Screen website.

Whether you are an executive in a boardroom, a head of department on a night shoot, a games executive planning a ‘sprint’ or ‘scrum’, an animator collaborating with colleagues for the first time, or a cinema opening a new screen, this Guide will help you create and maintain a professional, respectful, legally compliant, productive workplace environment.

2.1 The moral case

Morally, businesses have an obligation to safeguard employees' mental and physical health, preventing burnout and long-term trauma associated with unsustainable work practices. Fair hiring practices, eliminating toxic "boys' club" studio cultures, and accommodating neurodiverse and disabled talent are examples of how to promote social equity and ensure marginalised voices aren't erased or silenced.

The Film and TV Charity’s Looking Glass Reports provide a definitive, data-driven map of the mental health crisis in the UK screen industries. Spanning from 2019 to 2024, these statistics suggest a systemic "mental health emergency".

2.2 The legal shift: the 'preventative duty'

The laws of England, Scotland and Wales have changed. As well as the long-standing health and safety and discrimination laws, there is now a mandatory statutory duty to take reasonable steps to prevent sexual harassment. Businesses can’t simply react to incidents; they must actively anticipate where harassment might occur and take steps to prevent it. Any report of sexual harassment automatically counts as a protected disclosure under whistleblowing rules, so the person making the report must not be subject to detriment.

Crucially, 'reasonable steps' are often synonymous with sound project management. Proactive prevention means identifying risks before they materialise, whether in a VFX studio, a games development house, or on a location shoot. By planning for these risks during pre-production or at project kick-off, you reduce the number of situations that could lead to unacceptable conduct.

The legal standard for the duty to prevent sexual harassment is expected to increase from taking "reasonable steps" to "all reasonable steps" from October 2026 (but the timetable for these October changes is subject to review). While businesses currently have a positive obligation to implement reasonable preventive measures, the revised standard sets a much higher legal threshold.

Employment tribunals evaluate corporate liability by direct reference to the EHRC Employment Statutory Code of Practice and the EHRC Technical Guidance on Sexual Harassment and Harassment at Work. Under the EHRC Employer 8-Step Guide, a business must demonstrate that its anti-harassment measures are active, visible, and continuously evaluated.

2.3 The financial risk

Any informal complaint will take time and energy to resolve. A formal legal complaint will incur costs. Failure to plan is therefore a significant financial risk. A sensible budget that includes welfare provision is far more cost-effective than the legal and reputational costs of a fine or tribunal claim. Remember that in rare cases, some health and safety breaches lead to a criminal conviction.

2.4 Industry accountability

Many major studios, broadcasters, streamers, and national funders make adherence to a set of standards a condition of working together. Insurance providers are increasingly assessing workplace culture. Businesses that can demonstrate they have 'planned in' dignity and safety are better placed to obtain funding, manage premiums and secure essential cover.

2.5 The creative and people case

To attract and retain the best creative and technical minds (especially in highly mobile sectors), businesses can foster a culture where everyone thrives. This can result in:

1. Reduced staff turnover: teams remain stable and productive when they feel respected and supported by realistic schedules.
2. Creative excellence: true innovation requires psychological safety; the freedom to take risks and collaborate without the fear of unacceptable conduct.
3. Reputational resilience: in our interconnected industry, a well-managed project is your best protection against reputational damage.

3.1 Antisemitism: The International Holocaust Remembrance Alliance’s working definition (adopted by the UK Government) of antisemitism is “a certain perception of Jews, which may be expressed as hatred toward Jews. Rhetorical and physical manifestations of antisemitism are directed toward Jewish or non-Jewish individuals and/or their property, toward Jewish community institutions and religious facilities”.

3.2 Bullying: offensive, intimidating, malicious, or insulting behaviour. It often involves an abuse or misuse of power intended to undermine, humiliate, or denigrate the recipient. In the screen industries, this can sometimes be mistaken for 'firm management', but the distinction lies in whether the behaviour is persistent, targeted, or unreasonable.

3.3 Crunch: refers to a prolonged period of intense, excessive overtime required to meet a looming project deadline (such as a shoot date, broadcast delivery, or software release). While historically framed as an inevitable industry norm in the screen sector, it becomes an unacceptable or coercive practice when workers are pressured into compliance through implicit management expectations, peer pressure, or the threat of contract non-renewal. Crucially, crunch often relies on unpaid hours that can push a worker’s average earnings below the National Minimum Wage or breach statutory rest limits under the Working Time Regulations 1998.

3.4 Data Protection: the fair and proper use of personal data, safeguarding the right to privacy by giving individuals control over how their information is collected, stored, used and shared whilst balancing the legitimate needs of businesses to process that information.

3.5 Dignity at Work Policy: a policy designed to be a business-wide statement to address unacceptable conduct.

3.6 Discrimination: occurs when a person is treated less favourably than others because of a particular characteristic (direct discrimination), or when a rule or arrangement that applies to everyone puts people with a particular characteristic at an unfair disadvantage (indirect discrimination). There are nine characteristics protected by legislation: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. Discrimination includes antisemitism, islamophobia and racism. Unacceptable conduct also includes unjustified discrimination based on other factors. In our sector, this often manifests as bias or prejudice based on perceived class, socio-economic background, or regional accent. Although not protected characteristics, these factors can also cause harm.

3.7 Duty of Care: the requirement to ensure, as far as is reasonably practicable, the physical and mental health, safety, and welfare of all people engaged on your project. This includes protecting your team from physical and psychological risks, as well as stress-related illness.

3.8 Harassment, sexual harassment, and sex-based harassment

1. Harassment: unwanted conduct related to a protected characteristic that violates a person's dignity or creates an intimidating or offensive environment.
2. Sexual harassment: unwanted conduct of a sexual nature. This includes suggestive remarks, physical touch, or displaying sexual materials.
3. Sex-based harassment: conduct related to a person’s sex or presumed sex (but which is not of a sexual nature) that has the purpose or effect of violating their dignity.

3.9 Intersectionality: a term describing how different aspects of a person’s identity overlap to create unique and complex experiences of discrimination or privilege.

3.10 Islamophobia: A term used to describe conduct, attitudes or beliefs that are prejudiced, hateful or discriminatory directed at Muslims or those perceived to be Muslim. It’s rooted in racism and targets expressions of “Muslimness.” 

3.11 Prescribed Person: an external independent body designated by government to receive whistleblowing disclosures. These entities are typically sectoral regulators, watchdogs, or public enforcement authorities (such as the Health and Safety Executive) that possess the statutory power to investigate operational malpractice, regulatory breaches, or legal non-compliance within their specific jurisdictions. CIISA is a prescribed person, but it is yet to launch its reporting or investigative service.

3.12 Proactive duties: the legal obligation to manage foreseeable work-related stress as a physical and mental health risk, the duty to prevent harassment, and the duty to make reasonable adjustments under equality legislation if you know (or ought to know) that someone has a disability.

3.13 Psychological Safety: The Film and TV Charity defines psychological safety as a workplace culture where individuals feel they can speak up, share ideas, or admit mistakes without fear of negative consequences to their reputation or career.

3.14 Racism: includes prejudice, discrimination, or antagonism by an individual against someone based on factors such as skin colour, nationality, ethnic origin, or national origin.

3.15 Transphobia: A term used to describe conduct, attitudes, or beliefs that are prejudiced, hateful, or discriminatory towards individuals who identify as trans or non-binary, or who have the protected characteristic of gender reassignment. In the workplace, such behaviour is unlawful when it manifests as harassment, direct discrimination or victimisation. Protection applies regardless of whether a person has undergone any medical process or holds a gender recognition certificate.

3.16 Unacceptable conduct: broadly encompasses bullying, harassment (including sexual and sex-based harassment), intimidation, aggression, victimisation, and coercion. It also includes all forms of unlawful discrimination and prejudice. By using this broad term, we avoid complex legal debates. Any behaviour that is aggressive, exclusionary, or intimidating will be unacceptable conduct.

3.17 Vicarious liability: the exposure of an organisation to liability for the actions of those it engages, even if it was unaware of the conduct that caused the liability, unless it can prove it took all reasonable steps to prevent it.

3.18 Victimisation: occurs when a person is treated less favourably because they have been (or they are believed to have been) involved with a complaint about unacceptable conduct. Protecting people from victimisation is essential for a 'safe-to-speak' culture.

3.19 Welfare Facilitator: a trained independent person who provides a safe, confidential channel for everyone on a project to raise concerns. They may be known as welfare officers, mental health first aiders, or assistance programme delivery partners. They may work face to face, online, or use digital communication tools.

3.20 Whistleblower: a worker who exposes wrongdoing, illegal activity, or malpractice taking place within an organisation. To receive legal protection, the individual must reasonably believe that their disclosure is made in the public interest and reveals a serious concern (such as a criminal offence, a breach of a legal obligation, or a danger to health and safety). Whistleblowers are statutorily protected from suffering any detriment, victimisation, or unfair dismissal as a result of speaking out (a ‘whistleblowing disclosure’ or ‘protected disclosure’).

3.21 Workplace triggers: aspects of workplace design or management that may cause psychological or physical harm. If left unmanaged, these factors lead to stre

4.1 Industry Frameworks: The three main frameworks for the screen sector are:

1. The BFI/BAFTA Principles to tackle and prevent bullying, harassment and racism: The BFI/BAFTA Principles mandate that everyone on the team shares responsibility for creating and maintaining an inclusive, positive and supportive workplace.
2. The CIISA Standards: The Creative Industries Independent Standards Authority (CIISA)’s framework of four minimum standards of behaviour expected across the creative industries to ensure safe and inclusive working environments.
3. The Film & TV Charity Principles for Mentally Healthy Productions: These Principles have three pillars (People Support, Content Impact and Work Planning) to embed mentally healthy working practices into UK film and television.

4. 2 Alignment with UK statutory standards: These industry frameworks do not exist in isolation; they provide the sector-specific detail required to meet broader UK legal and regulatory obligations.

1. Acas and, in Northern Ireland, the LRA: the public bodies providing workplace advice, training, guidance and resolution services. Their Codes of Practice on disciplinary and grievance procedures set the minimum standards of fairness. Employment tribunals will take these Codes into account in relevant cases.
2. The Equality and Human Rights Commission: an independent statutory body responsible for encouraging equality and diversity, eliminating unlawful discrimination and protecting and promoting the human rights of everyone in Great Britain. It has investigative and enforcement powers. Tribunals take their Statutory Codes of Practice into account in relevant cases. They publish technical guidance, which is also highly persuasive.
3. The Fair Work Agency (FWA): has recently started work to bring various workforce-related enforcement powers under a single regulator. It has the power to start tribunal claims, inspect records, issue improvement notices and levy fines. Its focus is expected to be on cases involving underpayment or exploitation, including the National Minimum Wage, statutory sick pay rights, holiday pay calculations and employment agency regulations.
4. The Health and Safety Executive or the Health and Safety Executive for Northern Ireland: are the regulators for work-related health, safety and illness. They act as the primary bodies responsible for enforcing health and safety legislation, providing guidance and setting standards for workplace safety.  In many cases, tribunals and courts will take their guidance into account in relevant cases.
5. The Information Commissioner’s Office: the UK’s independent supervisory authority for data protection. It enforces the rules and regulations relating to personal data. Tribunals and courts take the ICO’s statutory Codes of Practice into consideration, and the ICO will assess whether a business has followed its published guidance in the event of a regulatory investigation or data breach.

5.1 Recruitment and Negotiation: Finding and engaging the best team members takes time. Don’t miss out on the chance to engage a diverse, engaged workforce because of poor or outdated recruitment processes. The quality of the recruitment process and subsequent negotiation of terms are important opportunities to match the reality of your workforce with your organisation’s vision.

5.2 Controls over Zero-Hours contracts and cancellation protection for workers on irregular hours are due to come into effect in 2027.

5.3 If you want to support junior crew, those with intersecting marginalised identities and freelancers, then thinking about your approach at this early stage will reap rewards. If no one involved in the selection processes has relevant lived experience, consider seeking support from external sources.

5.4 Training and Support: Recognising that everyone is different, and won’t start from the same place, means that you will need training and support policies and processes that are sufficiently flexible to offer extra support when required.

1. Management training: lead executives and heads of department (HODs) require support and training, especially if they have little experience of dealing with workplace practices. Training can help senior executives to lead a project with confidence that the relevant laws, Standards and Principles are being followed.
2. Workforce awareness: the entire workforce must be briefed and regularly reminded of the standards of conduct and the available, accessible reporting routes. The type of training provision and who provides support will depend on each person’s role.

5.5 Raising Concerns: Establishing accessible reporting pathways from the start is essential to ensure that someone can raise a concern the moment unacceptable conduct occurs. Prepare to provide multiple clear options for raising a concern, recognising that individuals may feel uncomfortable approaching their immediate line manager.

1. Welfare facilitators: Ideally, every project should have welfare facilitators to provide a safe, confidential channel for everyone on the project to raise concerns. Ideally, some or all of the facilitators will have relevant lived experience with the themes the project addresses. Their names and contact details should be included in an induction pack, displayed on call sheets, and posted in common areas and in shared online spaces.
2. Anonymous reporting: Implementing an independent reporting channel (such as a secure online portal or an external telephone-based hotline) allows everyone to raise a concern without revealing their identity. In line with statutory guidance issued by the EHRC, and the CIISA Standards, providing an anonymous pathway is highly effective for capturing vital cultural intelligence that might otherwise go unreported due to a fear of reprisal or professional detriment.

5.6 Risk assessments: Use a framework to identify potential 'hot spots' where unacceptable conduct is most likely to occur. This is a primary tool for fulfilling your preventative duties set out in the EHRC and HSE statutory guidance.

1. Identify triggers: assess if the current schedule or budget creates unnecessary pressure points (such as unrealistic 'crunch' periods or excessive night work).
2. Identify accessibility barriers: check for physical, digital, or structural barriers that can affect whether someone is exposed to unacceptable conduct.
3. Mitigation: plan for specific mitigations (such as additional rest periods, safe transport for late finishes, or increased support at industry social events).

5.7 The near-miss log: In health and safety management, a near-miss is an incident that could have led to an injury but didn't. In terms of conduct, a near-miss is a situation in which a workplace trigger or management issue was identified but did not result in a formal complaint. By logging these cases, specific issues can be identified, enabling structural fixes before anyone is harmed.

5.8 Contractual alignment: Your Dignity at Work Policy should be more than a recommendation:

1. Employment contracts: short-term, fixed-term and open-ended employment contracts can include a reference to a Dignity at Work Policy.
2. Contractors and freelancers: verify that all supply contracts include a clause requiring adherence to the policy and the relevant Principles or Standards.
3. The supply chain: if you are using third-party providers (such as security, catering, or tech hire companies), ensure their staff are also briefed on your Standards before they start work.
4. Insurance: Inform your insurers of your conduct protocols and risk mitigations.

5.9 The 'first hour' briefing: The first hour a person works on your project is the most important opportunity to establish a safety culture. Your induction process (whether physical or digital) could include:

1. A formal cultural briefing delivered by the project lead.
2. An opportunity to check if all access requirements and workforce risks have been raised and addressed.
3. An option to share information with a welfare facilitator if they have been exposed to unacceptable conduct on other projects. This could help identify potential triggers, especially when the perpetrator of prior unacceptable conduct is also involved in your project.
4. Access to relevant information about professional standards.
5. Details of your informal and formal independent, anonymous support and reporting processes.

6.1 Understanding workplace triggers: Preventing unacceptable conduct requires more than telling people how you expect them to behave; it also requires managing the work environment. Workplace triggers are aspects of project management or design (such as unrealistic deadlines or poor communication) that heighten the risk of harm. Research from The Film & TV Charity (specifically the 'Looking Glass' reports) suggests that these structural pressures are a primary driver of poor mental health and conduct issues in our sector. By planning to reduce these pressures, you create a healthier, safer, and more productive workspace.

6.2 Mapping your 'hot spots': Use the following categories to identify where risks are most likely to occur in your specific business area:

1. Power imbalances: Projects with small, 'inner-circle' teams where authority is concentrated can make people feel unable to speak up.
2. Physical environments: Working in isolated locations, at night, or in public-facing roles requires specific policies or procedures.
3. Misuse of Personal data: The use of unencrypted personal messaging apps, shared digital drives with inappropriate access controls or public call sheets can expose sensitive personal details and create a hostile or insecure environment.
4. Crunch periods: High-pressure or high-intensity work is a major trigger for stress and irritability. These periods can be more intense if a delivery date has been made public (for example, for a film or game release). Carefully considering scope, budget and timescales is the most effective way to prevent crunch periods escalating into unacceptable conduct.
5. Exposure to sensitive content: work involving intimacy, violence or traumatic themes can increase the psychological load on the team.
6. Social and industry events: Environments where the line between work and socialising is blurred (and where alcohol or recreational drugs are present) are high-risk areas for unacceptable conduct.

6. 3 Implementing the Framework: Documenting your mitigation steps is your primary evidence for meeting the 'all reasonable steps' legal threshold. For each trigger identified, you should record:

1. The risk: (e.g. a 14-hour night shoot on a remote location).
2. The trigger: (e.g. fatigue and lack of secure transport).
3. The mitigation: (e.g. mandatory rest periods, providing taxis for all crew, and having a welfare facilitator on site).

6.4 Feedback and Review: A risk assessment mustn’t be a standard box-ticking exercise. It needs to be a practical, working document that acknowledges that not everyone will have the same experience and that it will never address every single risk in detail. The best assessments are dynamic and incorporate regular feedback from the team.

7.1 The cultural lead: Identify which person or persons will define your workplace environment. Whoever it is, their behaviour dictates the 'social contract' of the project.

1. Modelling professional standards: A leader who prioritises good working practices creates a protective barrier against unacceptable conduct. Awareness of how a person’s proximity to typical societal privilege (being a white, straight, non-disabled, cis-male, with a senior permanent role) can help a leader hear concerns.
2. Acknowledge multiple roles: in smaller businesses, it is not uncommon for one person to be the founder, senior executive and creative director. The absence of internal checks and balances makes it more important to consider external welfare facilitators and processes that allow anonymous reporting.
3. Early intervention: People with authority to deal with a team member’s concerns need to be available and easily contactable. If someone quickly addresses instances of unacceptable conduct, the damage they cause may be controlled.
4. Visibility of support: a leader’s role is to ensure that welfare facilitators and reporting routes are available, accessible and actively promoted.
5. Be prepared for feedback: Survey data suggest that the person most likely to cause harm is someone in power. You need a clear complaints process that can address concerns, even if the complaint is about the cultural leader, a senior executive, your best friend or a welfare facilitator. The feedback process may need external support to remain independent, so identifying that source of support at an early stage will enable a complaint to be dealt with without delay.
6. Call for feedback: To help normalise the feedback process, a business should not wait for a concern to be raised. If you proactively seek feedback at regular intervals (perhaps at set points of delivery of the project) or by sending out questionnaires, you may be able to identify hidden triggers early, so that adjustments can be made as soon as possible.
7. Equity and Equality: By including a level of flexibility in your project planning, it will be easier to provide the timely support each team member may need.

7.2 Continuous leadership: Because people may join a project at different times, setting the culture is a rolling responsibility.

1. Preparing for a new starter: The recruitment and contract negotiation stages are opportunities to ensure that dignity at work processes are visible and effective from the start. Screen sector contracts are often issued at the last minute (if at all), sometimes contain out-of-date, irrelevant or needlessly technical information and are presented in inflexible or inaccessible formats. Give people the information they need to understand their role and responsibilities, and to provide you with information about how they can thrive. Don’t pretend your contracts have fixed standard wording if they don’t. Provide glossaries or signposts to additional information so the deal is clear and understandable.
2. The 'first hour' briefing: ensure that every new person receives a relevant briefing on the project’s values and the 'safe-to-speak' protocols. Suggestions are in the ‘where to start’ section and in the ‘templates’ section.
3. Consistency across the project: Lead artists, directors and HODs must be aligned in their approach so that the whole team has a similar experience.

7.3 Psychological safety and the 'safe-to-speak' culture

1. Psychological safety: The CIISA Standards emphasise creating a culture in which people feel safe raising concerns without fear of professional repercussions. This is known as psychological safety.
2. Reducing the power gap: Projects with steep hierarchies often suffer from a 'silence trap' where junior members or freelancers feel unable to report issues. Actively invite feedback to normalise open dialogue.
3. The 'bystander': Managers have a specific responsibility to act if they witness unacceptable conduct. Staying silent is often interpreted as an endorsement of the behaviour. Intervention demonstrates that your Dignity at Work Policy is being followed. Everyone should feel comfortable intervening, reporting, and providing peer support if required.

7.4 Managing the 'talent excuse': A common industry enabler of poor culture is the 'talent excuse' (where high-performing individuals are allowed to behave poorly because of their creative or technical status). But a ‘creative genius’ label does not justify unacceptable conduct, and Dignity at Work policies must not be bypassed to keep talent happy. Positive role modelling from respected figures is a very effective lever for culture change. Consider:

1. Universal accountability: to satisfy the preventative duty, the standards of conduct must apply to everyone on the team, regardless of their seniority or 'star power'.
2. The cost of toxicity: leaders should recognise that the technical brilliance of one individual does not outweigh the productivity loss, turnover, and legal risk caused by a toxic environment.

8.1 Practical steps for fostering inclusion: Inclusion is a management task to foster a culture that supports the feeling of belonging. It requires consistent attention.

1. Prepare to make reasonable adjustments: If you fail to identify barriers, don’t make reasonable adjustments, or don’t respond to feedback or complaints, there is a risk that someone will be disadvantaged or experience unacceptable conduct.
2. Don’t expect everyone to conform: Sometimes the organisational culture needs to change so that everyone feels comfortable. People may not feel able to raise a concern; instead, it might seem easier and less risky for them to walk away, comply, or adapt to become a version of themselves they feel is more acceptable. If someone can’t be authentic in the workplace, or spends energy masking, that can harm the individual. Instead, celebrate different ways of working, and encourage managers to be clear, consistent, responsive and adaptable.
3. Transparent communication: ensure that all project information is shared through official channels so that no one is left out of the loop.
4. Active engagement: during project meetings or reviews, ensure everyone can contribute. This prevents the 'loudest voice' dynamic, which can often mask underlying conduct issues. Some participants may benefit from pre-meeting briefings or post-meeting reviews.
5. Celebrating contribution: acknowledge the technical and creative wins of the whole team, ensuring that credit is distributed fairly across all roles, including junior staff and freelancers.

8.2 Class and background: the 'invisible' triggers: In the UK screen industries, class and socio-economic background are examples of common significant interpersonal triggers which may not be protected characteristics.

1. Status signalling: be mindful that snobbery and referencing expensive tastes or experiences can alienate those from different backgrounds.
2. Professional relationships: treat every person (regardless of their route into the industry) as a professional colleague, remembering that some people may require additional support. This mindset shift is essential for maintaining a stable and respectful project environment.

8.3 Managing interpersonal triggers: Interpersonal triggers are often early warning signs of a deteriorating culture. They are not always explicit acts of unacceptable conduct, but they create an environment in which unacceptable conduct becomes more likely.

1. 'In-group' dynamics: tight-knit networks can inadvertently lead to 'cliquey' behaviour. When information or social invitations are only shared with a preferred group, it creates an environment of exclusion.
2. Harmful conduct: might be subtle acts of exclusion, such as repeatedly mispronouncing a name, ignoring contributions in meetings, or using gendered or exclusionary language. Their cumulative effect undermines the 'safe-to-speak' culture.
3. Assumptions about background: avoid making assumptions about a colleague’s experience or status based on their class, background, or accent. Professional respect must be the default.

8.4 Practical steps to foster belonging: Belonging cannot be mandated: it must be cultivated. It will occur when a person feels safe enough to be authentic, and feels genuinely valued for their unique perspective, not just tolerated.

9.1 Feedback loops: are an early warning system. They allow you to catch environmental stressors (such as budget friction or scheduling pressure) before they manifest as conduct issues. Be prepared to receive the feedback, and to explain what happens next.

1. Call for feedback: use a variety of methods to signpost all internal and external reporting routes.
2. The 'temperature check': Use brief, informal regular check-ins. These are not technical reviews, but a moment to ask: "How is the pressure? Are the communication lines clear?"
3. Anonymous reporting systems: providing an anonymous reporting system can help capture concerns that individuals may feel uncomfortable raising in person.
4. Open-door hours: establish specific times for 'no-agenda' chats. This reduces the friction of reporting and makes management feel accessible rather than isolated.
5. Neutral feedback: Research shows that whistleblowers in the arts sector often experience harm. It is easy to feel defensive and to rely on a majority view when a challenge is raised. Care needs to be taken that any feedback is collected neutrally and assessed properly.

9.2 The role of 'team representatives': Appointing a department representative or recognising a Union can help bridge the gap between the workforce and senior management.

1. Peer-to-peer reporting: people often feel more comfortable speaking to a peer than a manager. These representatives can gather collective feedback on workplace triggers and present them to the production team without identifying individuals.
2. Collaborative problem-solving: involving the team in the solution increases psychological safety and reinforces a professional peerage mindset.

9.3 Communication during high-pressure periods: When a project hits a crunch time, communication is often the first thing to fail. Ironically, this is when it is most needed.

1. The 'no-surprises' rule: keep the team informed of changes as early as possible. Uncertainty is a major trigger.
2. Transparent updates: if a schedule must change or a budget is cut, explain the 'why'. While you may not be able to share every detail, providing context helps the team feel respected.

9.4 Monitoring the 'silent' majority: A lack of complaints is not always a sign of a healthy culture; it can sometimes indicate a 'culture of silence'.

1. Active outreach: do not wait for people to come to you. Making sure that the welfare facilitator is approachable and available, ready for check-ins without waiting for warning signs. If any of your welfare Key Performance Indicators start to rise, proactively use your feedback loops to investigate, rather than waiting for a concern to be raised.
2. Closing the loop: If the team raises a concern about a workplace trigger, you must communicate what action has been taken (or explain why action isn't possible). Silence is a quick way to destroy trust.

10.1 Making training accessible: In the screen industries, time is a premium commodity. To be effective, training needn’t be a day-long lecture that disrupts production or development.

1. Micro-learning: use short briefings, discussions or sector-specific digital modules that can be completed during gaps in the schedule or as part of the onboarding process. Be aware that not all people find online sessions easy, and some find in person events difficult.
2. Refresher sessions: facilitate brief 'refreshers' on specific triggers.
3. Industry resources: utilise established programmes or support forums to ensure your training is consistent with wider industry standards.
4. Peer-to-peer support: even if it is not appropriate to provide training to contractors or freelancers (who are responsible for their own training), you can insist that everyone in your supply chain has some form of continuing professional development, and everyone can take part in peer-to-peer support.

10.2 Bystander intervention: the 'active' observer: A safe culture relies on the majority, not just the management. Bystander intervention training gives team members the confidence to challenge unacceptable conduct safely and professionally.

1. The '5 Ds of Bystander Intervention' framework (Direct, Distract, Delegate, Delay, and Document): this framework provides a practical toolkit for anyone to support a colleague without escalating a situation unnecessarily.
2. Normalising the 'check-in': encourage a culture where asking 'Are you okay?' or 'Is this pressure manageable?' is seen as a professional courtesy rather than an intrusion. This is a primary tool for managing workplace triggers before they manifest as conduct issues.
3. Reinforcement: Regularly highlight the signposts to your Dignity at Work Policy and sources of support for a constant, low-barrier reminder of the conduct expectations and reporting routes established during the initial briefing to reinforce when interventions would be helpful.

10.3 Specialist support and roles: Some environments require more than basic awareness. In addition to welfare facilitators, lawyers and HR professionals, you may need to budget for specialist support to meet your duty of care:

1. Access coordinators: identify barriers to access, and can act as a point of contact.
2. Chaperones: regulated under child employment legislation to safeguard children, ensuring child licensing compliance and protecting vulnerable members of the team.
3. Intimacy coordinators: essential for any production involving simulated sex or nudity to ensure consent and boundaries are maintained.
4. Mental health first aiders: provide immediate support for those experiencing stress or burnout caused by workplace triggers.
5. Welfare producers or cultural consultants: can help teams adopt good working practices, management techniques, feedback processes and handling conflict.

10.4 A collective professional standard: Training is not just about legal compliance; it is about professional development. By investing in skills, you improve the resilience of your workforce. Relevant accreditations, training, or equivalent industry credentials demonstrate a commitment to a professional, modern screen sector.

11.1 The cost of poor conduct: Unacceptable conduct causes harm. It is a direct threat to the wellbeing of your team and your business’s bottom line. Research across the creative industries shows that environments where unacceptable conduct is tolerated suffer from specific commercial drains:

1. Cognitive depletion: when a colleague is focused on navigating toxic dynamics, they have less mental energy for creative problem-solving or technical accuracy.
2. Increased turnover: losing skilled freelancers mid-project leads to recruitment delays and the loss of 'institutional memory' on the production.
3. Absenteeism and 'presenteeism': team members being physically present but mentally disengaged due to stress or burnout caused by workplace triggers.

11.2 Monitoring triggers: Workplace culture can be a key performance indicator (KPI). By monitoring certain data points, you can identify 'hot spots' before they lead to unacceptable conduct, harm to an individual, a full production shutdown or a legal claim:

1. The 'wrap' or 'sprint' debrief: report on team morale and pressure levels after major milestones.
2. Overtime patterns: excessive reliance on overtime is often a primary trigger for the fatigue that leads to conduct issues.
3. Sickness/absence rates can, in some situations, indicate workplace issues.
4. Quality control: if the accuracy of someone’s work is lower than expected, that could also be an indication of workplace issues.
5. Turnover rates: monitor if specific teams are losing more members than others (as this is often an early warning sign of poor leadership or a toxic sub-culture).

The workplace culture KPI can be used to set thresholds when a near-miss should be recorded or action taken to address the hot spot.

11.3 Creative Licence: Make boundaries clear, to allow all artists and technicians to take creative risks without fear of personal belittlement or other unacceptable conduct.

11.4 Integrating conduct into project reviews: Conduct and culture should be a standing item in your post-project reviews.

1. The 'what went well' check: did the reporting systems work? Were appropriate steps taken when an issue arose?
2. The 'trigger' audit: which workplace triggers (e.g. night shoots, technical failures, or budget constraints) caused the most friction, and how can they be better managed in the next phase or project?

12.1 Redefining the workplace: Conduct standards must apply to every digital platform used by your project.

1. The 'public' vs 'private' boundary: Remind all team members that 'private' channels or direct messages on business platforms are still part of the professional environment. Conduct that would be unacceptable in person (such as exclusionary jokes) remains unacceptable in digital form.
2. Tone and intent: Digital communication requires additional care because a person’s tone may not be obvious. It is tempting to send a message in haste, but something that is ill-phrased could cause harm. Encourage a culture of clarity and professional empathy in written communications to prevent unnecessary friction.
3. 'Camera-on' online meetings: should not be the default, since engagement can be maintained with chat or other means. A camera feed doesn’t ensure that someone is fully engaged in a meeting, and may create barriers for colleagues with sensory sensitivities, who are kinetic learners, who need reasonable adjustments for mental health needs or who work in difficult environments.

12.2 Managing the 'always-on' trigger: The primary workplace trigger in remote environments is the erosion of rest periods. When the workplace is in someone’s home, the pressure to be constantly available can lead to rapid burnout.

1. Allow everyone to disconnect: Establish clear 'core hours' and respect them. Avoid sending non-urgent messages or requests for updates late at night or over weekends.
2. Digital 'crunch' fatigue: in VFX and gaming 'sprints', remote workers are often more susceptible to overwork because their fatigue is less visible to management. HODs can schedule regular digital 'check-ins' to monitor workload and morale.

12.3 Remote oversight and trust: The use of surveillance or time-tracking software (while common in technical delivery) can be a significant trigger for stress and a breakdown in trust.

1. Transparency: if tracking software is used, its purpose and scope must be clearly communicated. It should never be used as a management tool or as a substitute for active leadership.
2. Privacy in the home: respect that remote workers are inviting the project into their private space. No one should be penalised for domestic interruptions (such as caring commitments or postal deliveries).

12.4 Virtual third-party harassment: For those working in community management, live-ops, or public-facing digital roles, the risk of harassment from the public (fans, players, or trolls) is high.

1. The digital shield: Ensure your project has a clear policy for handling external digital abuse. Colleagues should know that the business will support them and intervene if they are targeted by outsiders in the course of their work.
2. Cookies, privacy policies, and data protection: All of these can promote transparency and protect your team from harm, but can also be a source of frustration or disquiet, especially if the policies are not practical, enforced, and kept up to date.

To fulfil your preventative duty, safety protocols must extend to every space where your team is required to work. Some environments move the project away from the controlled setting of the home office or studio, introducing specific workplace triggers such as unfamiliar surroundings, communal travel, and interaction with individuals outside the immediate team.

13.1 Professional visits: client and partner premises: Visiting a client’s studio (or hosting a partner at yours) changes the physical environment and the power dynamic. Even in a professional office, conduct risks can arise.

1. Power imbalances: Being a guest in another business’s space can make people feel they have less agency to challenge unacceptable conduct. Ensure that everyone on the team knows the Dignity at Work Policy still applies; they are protected by your standards regardless of whose building they are in.
2. Pre-visit briefings: if a team is visiting a third-party site, brief them on who to contact if they encounter issues with host staff or other contractors.

13.2 Markets, festivals, trade shows and other large venues: Industry events (where networking, socialising, and business are intertwined) are high-risk areas for 'blurred boundaries'.

1. The 'always-on' trigger: the pressure to network late into the evening can lead to exhaustion and a lack of professional inhibition.
2. Alcohol and conduct: While socialising is part of the sector, the timing, venue and nature of social events can exclude colleagues who may not wish to take part (for any reason). A mix of events encourages a broader engagement and ensures that alcohol isn’t the default social activity. Being drunk does not grant a 'free pass' for poor behaviour. Managers should set clear expectations before events and ensure that 'after-hours' interactions remain respectful.
3. Any public premises or events with a capacity of over 200 people in England, Scotland and Wales: Martyn’s Law will require everyone responsible for larger-scale events to be trained and prepared for security and terrorist threats (expected Spring 2027). Similar regulations apply to events in Northern Ireland.

13.3 The 'location bubble' and communal living: When a team is required to stay away from home (whether for a film shoot or a multi-day conference), the erosion of private time can lead to lapses in conduct.

1. Accommodation standards: Ensure that accommodation is safe, calm and private, and that it meets accessibility and inclusion standards. Shared rooms are not appropriate. They are a major trigger for discomfort, and everyone should have access to a private space. Seek feedback to keep accommodation lists up to date.
2. Isolation and lone working: avoid situations where any person (particularly a junior colleague or freelancer) is sent to a remote site or a client meeting alone without a 'check-in' protocol and access to funds.

13.4 Third-party harassment: clients and the public. Your duty to provide a safe environment includes protecting everyone from harassment by third parties (including fans, clients, residents, or venue staff).

1. The 'safe haven': on any off-site project, there should be a designated contact or a physical 'safe space' where individuals can go if they feel threatened or overwhelmed.
2. Intervention protocols: ensure the team knows that the business will support them if they choose to walk away from an interaction with an abusive client or member of the public.

A properly implemented policy is only as effective as the reporting culture that supports it.

14.1 Creating different ways to make a report: For a reporting system to be trusted, it must be accessible. This is especially vital for people who may feel they lack the job security to speak up. By making multiple routes for reporting a concern available, it will be easier for neurodivergent team members, or those who may find a written or formal route harder to navigate. An oral process (recorded with consent and transcribed) could well be the easiest to access for the majority of the workforce, but some may prefer an anonymous system. Consider:

1. Welfare facilitators: As a first point of contact, they can provide confidential support and help an individual navigate their options.
2. Heads of department: HODs should be trained to handle concerns before they get worse.
3. Internal HR or management: For studio-based businesses or larger productions, a direct line to a senior manager or HR representative must remain open.
4. External bodies: For those who feel an internal route is not appropriate (or if the business is too small to ensure impartiality), team members should be signposted to an appropriate external body, such as an online anonymous reporting tool.
5. Anonymous reporting processes: Implement a well-publicised secure, independent channel (such as a third-party digital platform or an external telephone hotline) that allows everyone to flag misconduct without revealing their identity. Crucially, the process should incorporate a secure, encrypted two-way messaging functionality, enabling the investigator to ask follow-up questions and provide progress updates to the anonymous reporter, which builds trust while robustly protecting the business from legal and operational risk.

14.2 Informal and formal resolution: Not every issue requires a full-scale investigation. A well-managed project adopts a layered approach to resolution:

1. Informal resolution: This often involves a facilitated conversation, a simple apology, or a change in working arrangements (such as adjusting a schedule or moving a desk). This is often the most effective way to resolve issues related to workplace triggers and minor lapses in conduct.
2. Formal resolution: This is required for serious allegations of unacceptable conduct. It involves a structured investigation, usually led by a trained individual. In smaller organisations, this may require bringing in an external investigator to ensure fairness.
3. Careful implementation: All resolutions will benefit from active listening and keeping records that are neutral, without interpretive language, and avoiding assumptions. Otherwise, there is a risk that the listener’s own background could affect what they hear and how they record a concern or complaint. For many, the reporting process can itself be a source of unacceptable conduct.

14.3 Who should resolve a concern or complaint: The identity of those responsible for resolving a dispute could affect whether a report is made and whether the concern will be successfully addressed. The wrong person dealing with a report could cause distrust or even harm. A report handler must be neutral, trained, and preferably independent. If there is a significant identity or power imbalance (for example, a woman raising a concern in a room full of men, or a Black person with an all-white panel), consider whether an alternative might be better, or if the person making the report should be offered support. Consider the linguistic preferences of the complainant (especially in Wales, where English and Welsh have equal status).

14.4 Confidentiality and the use of Non-Disclosure Agreements (NDAs): Trust in the system relies on privacy. While absolute anonymity cannot always be guaranteed (specifically if there is a legal requirement to act), the privacy of all parties must be prioritised to prevent gossip or reputational harm. Non-disclosure agreements (NDAs) must never be used to silence victims or prevent the reporting of unacceptable conduct to the police or regulators. Neither should they be used mid-process, since that becomes coercive by nature. Settlement agreements should explicitly state that a worker is not prevented from making a 'protected disclosure' (whistleblowing) or discussing their experience with support services.

14.5 Personal Data: Remember that your records are likely to contain personal data which you may be disclosed to the subject, and kept in accordance with data protection policies.

14.6 Protecting the 'Safe-to-Speak' culture: Following a report, ensure that no victimisation occurs. This means monitoring the working environment to ensure the person who raised the concern (and any witnesses) does not suffer any professional detriment or social exclusion.

15.1 Be aware that it is easier for someone to change if they are made aware of the need for change: Everyone must know that concerns will be heard and action taken. If not, incidents will occur, nothing will be said, and the cycle will continue without challenge.

15.2 Identification and the 'quiet word': The moment unacceptable conduct is identified, it should be addressed.

1. Prepare: before taking action, double-check if there really has been a breach of conduct, or if there has been a way of communicating that may have been misunderstood. If there is a possibility of bias, then consult before taking further action.
2. The setting: find a private, neutral space away from the rest of the crew or the studio floor to have a brief, informal conversation.
3. The approach: use 'I' statements to describe the behaviour rather than the person (e.g. 'I noticed that the tone in the production meeting earlier felt quite aggressive' rather than 'You were being aggressive').
4. The goal: seek to understand if a workplace trigger (such as an unrealistic deadline or lack of resources) contributed to the behaviour. Treat this as a ‘near miss’, keeping an appropriate record so that it is easier to tell if a pattern is emerging.

15.3 The facilitated conversation: If an issue involves a friction between two team members, a manager or welfare facilitator can act as a neutral facilitator.

1. Ground rules: both parties must agree to listen without interrupting and focus on a resolution.
2. The 'purpose or effect' test: allows the individual who raised the concern to explain the impact the behaviour had on their work or wellbeing.
3. The resolution: a sincere acknowledgement of the impact and a commitment to change is sometimes enough to restore the working relationship and prevent future incidents.
4. If change is needed but doesn’t take place, there will be times when an incident is too serious for an informal intervention, or when someone refuses to change or does not wish to find a resolution. Be ready to take formal action when the need arises.

15.4 Environmental adjustment: Sometimes the resolution is not about an individual, but about the 'triggers' in the project design. Consider if a structural change is required:

1. Scheduling: (e.g. adding a rest day or moving a delivery deadline to reduce 'crunch' pressure).
2. Workspace: (e.g. adjusting a studio layout or seating plan to reduce friction).
3. Supervision: (e.g. increasing HOD presence during high-risk periods).

15.5 The 'check-in' and record-keeping: Even if an issue is resolved informally, closing the loop is essential for fulfilling the preventative duty.

1. Communication: Consider how best to communicate at every stage of the relevant process. Be prepared to discuss the resolution, or the reasons why a resolution hasn’t been possible.
2. The follow-up: check back in with the parties after a suitable time period to ensure the resolution is holding and that no victimisation is occurring.
3. The informal log: keep a brief, confidential note of the conversation and the outcome as part of your near-miss log. This is not a disciplinary record, but it provides essential evidence that the business is taking 'all reasonable steps' to manage the workplace and prevent unacceptable conduct. Any log must comply with data protection rules, including the right for a subject to receive copies of their personal data and your obligations to only retain records for as long as necessary.

16.1 Immediate response and triage: The priority following a report is the safety and wellbeing of the individuals involved.

1. Safety first: assess whether there is an immediate risk of harm. If necessary, implement temporary working arrangements while the matter is investigated.
2. Confidentiality: ensure that information is shared only with those who strictly need to know, and follow all data protection policies. Remind all parties that gossiping about the incident can be considered a breach of conduct.
3. Support: offer immediate access to support services (such as the Film & TV Charity support line or welfare facilitators) to the person making the report and the person being reported.

16.2 The formal investigation process: If an informal resolution is not appropriate or possible, a formal investigation should be conducted to establish the facts.

1. Impartiality: appoint an investigator who is not involved in the incident, has no conflict of interest, and ideally has some specialist knowledge and/or lived experience of the matter in question. In some cases, this may require an external professional to ensure the process is robust.
2. Fact-finding: the investigator should collect evidence (including written statements, digital records, and witness accounts). The goal is to establish a clear and objective timeline of events.
3. Right to respond: the person who has been reported must be given a fair opportunity to hear the allegations and provide their own account of the situation.

16.3 Skills and training for incident management: To manage an incident effectively, the people involved must have the appropriate skills. Training should not be a one-off event but a rolling commitment to professional development across the whole team. Encourage completion of training to prevent unacceptable conduct to ensure a baseline level of awareness for everyone on the project.

16.4 The role and impact of an apology: Many leaders hesitate to apologise for fear that it might expose them to an uncomfortable level of risk or criticism, or even amount to a formal admission of legal liability. In the UK, this is largely a misconception.

1. De-escalation: a sincere expression of regret for the impact of an action can often prevent a low-level friction from escalating into a formal Incident or legal claim.
2. The effective apology: focus on acknowledging the impact ("I am sorry that my tone caused you distress") rather than simply defending the intent. This validates the other person’s experience and can begin the process of repairing the working relationship without prejudice to a formal investigation.

17.1 Outcomes and resolution: Once the investigation is complete, you must decide on the appropriate outcome based on the findings.

1. For employees: if the allegations are upheld, the organisation should follow its established disciplinary procedures. This can range from a formal warning to the termination of a contract or engagement. Any employee with a continuous service period of at least two years must not be unfairly dismissed (a threshold due to be reduced to six months in 2027). The current cap for compensatory awards is also due to be removed in 2027.
2. For freelancers and contractors: because disciplinary policies may not apply to a contract for services, outcomes are governed by the terms of the engagement. Upheld allegations may result in a formal notice of breach, the immediate termination of the contract (if provided for in the 'conduct' clauses), or a decision not to engage the individual for future projects.
3. Communication: both the person who reported the incident and the person reported should be informed of the outcome in a timely manner (within the bounds of privacy laws and confidentiality).
4. Timing: Using the imminent end of a contract as a reason to avoid a difficult conversation is not acceptable, it just passes the problem onto the next project.
5. Right to appeal: provide a clear process for either party to appeal the decision if they believe the process was flawed or the outcome was unfair.

17.2 Alternative Dispute Resolution (ADR) and external resolution: When internal processes are exhausted or inappropriate (particularly in cases of complex interpersonal conflict or a lack of trust in the internal hierarchy), external resolution routes should be considered.

1. Mediation and conciliation are voluntary processes in which an impartial third party helps individuals reach a mutually acceptable resolution. This is particularly effective for preserving working relationships among freelancers who may need to collaborate again on future projects. For matters involving employees that may lead to an employment tribunal, Acas or LRA early conciliation is a mandatory step to try to settle a dispute without litigation.
2. Arbitration: is a formal method of alternative dispute resolution (ADR) where an independent, neutral third party (the Arbitrator) reviews the arguments and evidence from both sides of a workplace conflict to make a binding decision (the Award) to resolve the issue.

17.3 Remediation and organisational learning: An incident often signals underlying workplace stressors or cultural gaps. Use the resolution of an incident as a prompt for improvement.

1. Root cause analysis: evaluate whether specific environmental factors (such as excessive workloads or lack of clarity in roles) contributed to the situation.
2. Policy review: determine if existing policies or training need to be updated to prevent a recurrence of the incident.
3. Reintegration: if parties are to continue working together, consider using professional mediation to repair the working relationship.

18.1 Culture audits: A culture audit is a regular check designed to identify emerging workplace triggers before they lead to unacceptable conduct.

1. Frequency: For fast-moving productions or high-intensity development sprints, this could be a weekly or monthly exercise. For longer-term studio environments, a quarterly review may be appropriate.
2. Scope: The audit should look beyond formal grievances and complaints. It should assess team morale, the visibility of welfare facilitators, and the effectiveness of the communication loops.
3. Inclusivity: Ensure that freelancers are included in the audit process. Their perspective is often the most revealing, as they may have experienced different cultures across the sector.

18.2 Key performance indicators (KPIs) for culture: Your records will provide the evidence that your preventative measures are working. Track the following metrics to build a clear picture of your project’s health:

1. Turnover and early exits: High turnover in a specific team may be an indicator of a toxic subculture or unmanaged workplace triggers. Track patterns of absence that correlate with crunch periods or high-pressure milestones, as these often suggest burnout.
2. Reporting rates: A healthy, safe culture often sees a higher volume of low-level reports. This indicates that everyone on the team trusts the system enough to use it. A 'zero reports' environment can be a sign of a culture of silence. A change in reporting rates might indicate that a specific issue or workplace trigger has been introduced or addressed.
3. Training completion: monitor the percentage of those completing relevant training.

18.3 The near-miss log: By logging instances where unacceptable conduct or harm could have taken place, specific factors can be identified, enabling structural fixes before someone is harmed.

18.4 Reporting to leadership: Monitoring data must lead to action. Audits and KPI tracking should be presented to senior management, studio heads, or project leads to inform strategic decisions.

1. Trend analysis: (looking for patterns over time). Is the culture improving as the project progresses, or is the pressure of the delivery date beginning to erode professional standards?
2. Accountability: use data to hold managers accountable for the culture in their specific areas, ensuring that relevant standards are applied consistently.
3. Feedback: be ready to let everyone know that reports lead to change (or explain why you are not making any changes). It’s important that you are clear and consistent, so that the quality of the response isn’t diminished if the number of concerns increases. Remind everyone what they can do if they are not satisfied with the action taken to address identified concerns.
4. Wrap Reviews: make time to carefully prepare for feedback at the end of a person’s involvement with the project. Exit interviews, questionnaires, or offboarding processes that focus on the project rather than the person’s experience of it may fail to capture important information that could help ensure the same mistakes are not repeated.

19.1 The 'first hour' briefing script (the toolbox talk): This script is designed as a professional standard-setting exercise that should be integrated into the technical or safety briefing for every person joining the team.

It is great to have you on the team. Before we start, I want to be clear about how we work here. Our goal is to deliver a world-class project, and we can only do that if every person feels respected and safe. We follow our Dignity at Work Policy and [the BFI/BAFTA Principles]. This means we will always address unacceptable conduct (including bullying, harassment, or prejudice). We also align with [insert]. This means we prioritise work planning and workload management to protect the team's wellbeing. If you feel the schedule is becoming a source of stress, or if you notice something that does not feel right, please speak up. You can come to me, or you can talk to our welfare facilitators, [Name] and [Name]. If you prefer, the [insert] independent reporting route is also available. Reporting a concern will never be seen as a risk to your future work. If you have access requirements or need us to make reasonable adjustments to help you do your best work, please let me know. We are here to support you.

19.2 The 'quiet word' talking points for HODs: When an HOD needs to address harmful conduct or an interpersonal trigger, they should use this structure to ensure the conversation is constructive and professional:

1. Opening: "I’d like to have a brief, private chat about something I noticed earlier."
2. Observation: Use neutral descriptions. "I noticed that the tone during the review meeting was quite dismissive of [Name]’s input."
3. Policy link: "As you know, our Dignity at Work Policy requires us to maintain a professional attitude where every contribution is respected."
4. Enquiry: "Is there a specific trigger (such as the current delivery pressure) that is causing friction at the moment?"
5. Resolution: "How can we adjust our communication moving forward to ensure we stay aligned with the project standards?"

Script for receiving an initial disclosure: This script is for managers or welfare facilitators when a person first comes forward with a concern. The goal is to listen and document without reaching immediate conclusions.

1. "Thank you for coming to talk to me. I want to start by saying that we take all concerns seriously (and that your decision to speak up is respected). My role right now is to listen and ensure we have an accurate record of what you are sharing.
2. Please take your time to tell me what has happened. I will be taking some notes to ensure I don't miss any details. I will need to share my notes with [name/role of senior lead] so we can decide on the best way forward. We will only share this information with those who strictly need to know, and it will be stored and deleted in accordance with our data protection policy.
3. [Listen and take notes without interruption]
4. I want to make sure I’ve understood correctly. What I have noted is... [summarise back]. Is there anything I’ve missed?
5. Do you have any immediate concerns about your safety or your current working arrangements? Are there any accessibility adjustments or support I can implement to make you feel more comfortable while the matter is investigated?
6. I will get back to you by [time/date] to explain the next steps."

19.3 Template for a file note (documenting a conduct conversation) to be used by the manager immediately following any 'quiet word' or disclosure meeting.

1. Date and time of conversation:
2. Participants:
3. Nature of the discussion: (e.g. initial disclosure, quiet word, follow-up).
4. Specific facts shared: (describe the behaviours, dates, and locations reported).
5. Impact described: (how the person stated the behaviour affected them).
6. Immediate actions taken: (e.g. separated parties, signposted to support, informed senior lead).
7. Agreed next steps: (e.g. follow-up meeting scheduled for [date]).
8. Signature and date: (manager name).

19.4 The end-of-project review (offboarding): This form should be completed by every person (including freelancers and contractors) before they leave the project. It provides the data needed for the monthly audit.

1. Culture: Did you feel the project was inclusive and that your contribution was valued? (Yes/no; please provide details).
2. Triggers: Were there specific 'workplace triggers' (such as workload, working patterns, or communication failures) that you felt impacted your wellbeing or performance?
3. Safety: Did you feel safe to speak up about concerns? If not, what were the barriers?
4. Conduct: Did you experience or witness any unacceptable conduct? (If yes, was it resolved to your satisfaction?).
5. Leadership: Did your line manager adhere to the project's professional standards?

Immediate action: containment and triage: When a high-risk incident is reported, the priority is to stabilise the situation without making premature judgments.

• Neutralise the environment: Assess whether an immediate separation of parties is required. For senior roles, this may involve a 'neutral' period of paid leave or a temporary change in reporting lines while the facts are established.
• Identify the decision-making unit: Form a small, confidential response team. Avoid wider internal discussion to protect the integrity of any future investigation.
• Document the initial report: ensure the exact nature of the disclosure is recorded immediately.

The 24-hour risk assessment: Look beyond the incident to the broader impact on the project.

• Legal and statutory risk: Decide if the report triggers mandatory reporting requirements to the EHRC , ICO, or other regulatory bodies.
• Contractual risk: review disciplinary processes and 'conduct' clauses of those involved (specifically looking for the right to suspend engagement pending investigation).
• Reputational and stakeholder risk: prepare a 'holding statement' for internal and external use. The message should be: "We are aware of a concern, we are following our professional standards protocol, and we are taking the matter seriously."

Strategic resolution routes: Choose the path that best ensures a robust and fair outcome.

• Internal fact-finding: appropriate for low-to-medium risk issues where the internal hierarchy is not conflicted.
• Independent external investigation: essential for high-profile allegations or where senior leadership is involved. Using an external investigator (such as a specialist solicitor or HR consultant) provides an objective 'firewall' that protects against accusations of bias.
• Alternative dispute resolution (ADR): where the goal is to resolve a conflict between high-value team members, consider a facilitated professional dialogue.

Balancing production needs with conduct standards: The hardest executive decision is often whether to pause production.

• The 'reasonable' test: Would a reasonable person think the environment is safe if production continues without a resolution? If no, a temporary pause is legally and ethically safer than proceeding into a high-liability environment.
• Insurance and cost mitigation: engage with production insurers early if a conduct issue is likely to cause a significant delay or require a change in key personnel.