Introduction

MCC is committed to maintaining a safe, inclusive and respectful environment for all members of its community. The College values equality, diversity and mutual respect, ensuring that every student and staff member is treated with dignity and fairness in all areas of study and work. Midlands College of Commerce does not tolerate bullying, harassment, discrimination, sexual misconduct or violence in any form. Such behaviours undermine wellbeing, safety and academic success, and will be actively challenged and addressed in line with this policy and the College's Equity, Diversity and Inclusion Policy.

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All members of the College community are expected to uphold standards of respectful conduct, open communication and clear consent in their interactions. The College is committed to responding to all disclosures or reports of unacceptable behaviour with sensitivity, impartiality and discretion, ensuring appropriate support and access to specialist services.

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MCC will work with external experts and advisors, as well as within our governance to continually improve its approach to prevention and response. Proven instances of bullying, harassment, discrimination or violence may result in disciplinary action, up to and including termination of employment or exclusion.

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Our Commitment

MCC is committed to providing a learning and working environment that prioritises the student experience and fosters a culture of respect, inclusivity, and support in line with our values.

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We are dedicated to promoting diversity, equity, and harmonious relationships across our campus, ensuring that every student feels safe, valued, and able to thrive. Our goal is to inspire positive behavioural and cultural change, support student development, and ensure that our community upholds mutual legal, ethical, and professional standards.

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We actively encourage good relations, and removing barriers of bullying, harassment, sexual misconduct, and hate crime, embedding inclusivity into every aspect of student life. All allegations of harassment or misconduct will be taken seriously and addressed fairly, with integrity and professionalism.

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Concerns raised in good faith will be handled with sensitivity, confidentiality, and respect for the rights of all parties, ensuring that no student is victimised for speaking out. Through this commitment, MCC continues to engage with our wider communities, uphold social responsibility, and create an environment that reflects our values of respect, innovation, and integrity.

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DEFINITIONS

Defining experiences that encompass Sexual Misconduct can be difficult. The Sexual Misconduct Policy provides definitions regarding how each theme can be interpreted. For accessibility and to support the interpretation of these themes and related themes, the following non exhaustive list is provided.

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Q. What is Hate?​

Hate crime involves expressions or acts motivated by hostility or prejudice toward a person's identity or perceived identity. This may be based on characteristics such as race, religion, disability, sexual orientation, or gender identity. Hate incidents can include verbal abuse, harassment, threats, or physical violence.

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Q. What are Bullying and Harassment?​

According to ACAS, bullying is characterised as offensive, intimidating, malicious or insulting behaviour, or an abuse or misuse of power that undermines, humiliates, or causes physical or emotional harm. It can be physical, verbal, or psychological, and usually involves repeated behaviour.

Harassment is unwanted conduct related to a protected characteristic that violates an individual's dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment.

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Q. What is Domestic Violence?​

Domestic violence (or domestic abuse) is a pattern of abusive behaviours used by one partner to maintain power and control over another in an intimate relationship. It can include physical, emotional, psychological, sexual, or financial abuse, and occurs regardless of age, gender, or background.

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Q. What is Stalking?

Stalking is persistent and unwanted attention that causes fear or distress. It may include following someone, repeatedly contacting them, watching them, or monitoring their activities, including online or via social media.

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Q. What is Sexual Harassment?

Under the Equality Act 2010, sexual harassment is unwanted conduct of a sexual nature that has the purpose or effect of violating an individual's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. It may still be considered harassment even if unintentional or not directed at a specific person.

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Q. What is Sexual Misconduct?

Sexual misconduct is unacceptable behaviour of a sexual nature. It includes sexual harassment, sexual violence, intimate partner violence, sexual assault, grooming, coercion, sexual invitations, comments, and non-verbal conduct that create discomfort or hostile environments. It may involve abuse of power or the promise of benefits in exchange for sexual access.

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Q. What is Sexual Violence / Sexual Assault?

Encompasses acts ranging from verbal harassment to forced penetration, coercion (through intimidation or social pressure), or physical force. It includes sexual offences such as groping or forced kissing, which may be criminal offences.

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Q. What is Spiking?

Adding substances to someone's drink or body without their knowledge or consent, often to impair or harm them.

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Q. What is 'Honour'-Based Violence?

Crimes or incidents committed to protect or defend the honour of a family or community. These may include forced marriage, abuse, threats, or violence, often directed at individuals believed to have brought shame or dishonour.

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Q. What are Microaggressions?

Subtle, often unintentional, remarks or behaviours that convey prejudice or discrimination. Though minor individually, they can have a significant cumulative effect. Examples include stereotyping or backhanded compliments.

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Discrimination
Under the Equality Act 2010, it is unlawful to treat anyone unfairly or less favourably due to a protected characteristic. There are nine: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

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Violence
Extremely forceful actions intended to hurt individuals physically or cause damage to property.

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Consent
Consent is the agreement to participate in a sexual act where the individual has both freedom and capacity to decide. It cannot be assumed from past consent, silence, or absence of resistance and can be withdrawn at any time.

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Freedom to Consent
Consent requires free participation. It is invalid if obtained through coercion, threat, exploitation of power, or from someone lacking capacity, even if no physical resistance is shown.

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Capacity to Consent
A person lacks capacity when asleep, unconscious, impaired (temporarily or permanently), or otherwise unaware that a sexual act is occurring. Conditions like cognitive or learning disabilities, or mental health crises, may also remove capacity.

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Incapacitation
May result from mental impairment, substance use, or intoxication. Indicators include slurred speech, loss of coordination, or unawareness of surroundings. Intoxication is never a defence for failing to obtain consent.

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Abuse of Power
The misuse of authority or influence to exploit, coerce, manipulate, or pressure others. It may involve grooming, intimidation, or creating dependency in personal or professional contexts.

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Grooming
A gradual process used by a person in power to manipulate someone, often leading to sexual abuse or exploitation. It usually begins with gaining trust or affection.

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Coercion or Force
Involves threats, intimidation, or harm that compel someone to engage in sexual activity against their will.

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Victimisation
Occurs when someone is treated less favourably for being involved in a discrimination or harassment complaint. Examples include exclusion, demotion, or dismissal after reporting misconduct. It is a form of discrimination under the Equality Act 2010.
 

Complicity
Any act that knowingly helps, promotes, or encourages sexual misconduct or other unacceptable behaviour.

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Disclosure
The act of an individual speaking to a Wellbeing Officer about their experiences to access support. It does not automatically trigger an investigation unless safeguarding duties apply.

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Reporting
Making an official complaint about an incident of bullying, harassment, or sexual misconduct, triggering an investigation as per institutional policy. The Reporting Party is the individual raising the concern; the Reported Party is the person whose behaviour is alleged to constitute misconduct.

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Roles in a Misconduct Case

• Complainant – person who raises a concern or reports sexual misconduct (may be the victim or a third party).

• Alleged Perpetrator – individual accused of misconduct.

• Witness – person who saw or can give evidence about an alleged incident.

• Investigator – trained person appointed to investigate where appropriate.

• Subject Matter Expert – specialist who may provide expert advice in complex cases.

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How To Make a Report

Who Can Make a Report?
Anyone who has experienced, witnessed, or been affected by an incident involving someone connected to the college can report it. This includes:

• Current students

• Staff members

• Applicants to courses or roles

• Visitors and members of the public

If you need to report an incident or concern, report to the Student Wellbeing Team immediately.

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Training

• STAFF: Staff complete a series of mandatory training and ongoing CPD sessions via our staff portal. The training record is tracked in the staff portal, and ensures that all colleagues have an awareness of Sexual misconduct and support available.

Our Equity, Diversity, and Inclusion Committee is established to uphold and respectful values, as well as support the wider consideration of these themes across MCC. EDI committee and the Head of Wellbeing support training.

• Prevent

• Safeguarding (HE) Essentials

• First Aid

• GDPR - Data Protection

• Equality, Diversity and Inclusion (EDI)

• Health and Safety

• Manual Handling

• Fire Safety

• Mental Health and Wellbeing

• Sexual Misconduct (including harassment and bullying)

Periodic refreshers and information shared within Provost Surgerys or other mandatory trainings.

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• STUDENT: In accordance with the course requirements, Students will learn about Sexual Misconduct in induction sessions or other appropriate times on the course.

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Monitoring and Evaluation of Training

Training resources are reviewed annually and via committee. MCC also liaise with partners to ensure alignment with training.

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Student feedback regarding any policies or procedures, or training, can be provided to your program coordinator. Feedback can also be provided via Course Committees, or other committees which welcome student voice. If you are interested to join as a student representative, please contact Program Coordinator or email admissions@midlandscollegeofcommerce.co.uk.

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Staff Feedback is also requested following mandatory trainings, and training logs are recorded for mandatory trainings via HR portal.

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Confidentiality and Data

All complaints will be handled confidentially and sensitively, in accordance with relevant legislation and internal policies, including the Data Protection Policy. However, details of a complaint may need to be shared with other authorised persons or organisations where necessary to conduct an investigation, achieve a fair resolution, or ensure the safety and wellbeing of the College community.

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Information obtained from credible anonymous disclosures may nonetheless be used to inform policy review, institutional learning and preventative action.

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Data is handled under the MCC Data Protection Policy and UK GDPR (2018) to meet data handling and statutory reporting requirements.

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False Reporting

MCC takes deliberate or malicious false reporting seriously. Any individual found to have submitted a report or concern in bad faith may face disciplinary action under the relevant staff or student procedures.

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Anonymity, False Reporting and Vexatious Claims
MCC is committed to maintaining a safe, respectful and supportive environment in which individuals feel able to raise concerns and seek appropriate guidance.

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While the College does not normally act upon anonymous complaints, it recognises that some individuals may wish to share information without revealing their identity. In such cases, anonymous information may still be reviewed for potential patterns, risks, or safeguarding implications; however, the College's ability to investigate or take direct action may be limited.

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All concerns raised will be treated seriously and with fairness. The College reserves the right to disregard complaints that are unfounded, malicious or vexatious. Any individual found to have made a deliberately false or vexatious allegation may be subject to disciplinary action in accordance with the College's policies and procedures.

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While anonymity can enable individuals to come forward, it can also restrict the College's ability to investigate effectively. Where possible, individuals are therefore encouraged to report concerns through established channels, reporting form, or line management, that allow for direct communication, safeguarding support and equitable resolution.

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Campus Safety & Support

Available Support and advice
MCC recognises that experiencing or witnessing discrimination, harassment, bullying, or violence can be deeply distressing.

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While internal reporting and support mechanisms are available, individuals may also wish to seek independent, confidential help from external organisations. The following internal, and also national services, offer specialist advice, emotional support, and practical guidance to anyone affected by hate crime, sexual violence, domestic abuse, or other forms of harm. These organisations operate independently of MCC and can be contacted directly for free, confidential assistance.

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Internal for staff:

• Colleagues

• Line managers

• HR Staff wellbeing service

• Union representatives

• Contact hr@midlandscollegeofcommerce.co.uk for more information

Internal for students:

• Student wellbeing service – student.wellbeing@midlandscollegeofcommerce.co.uk

• Complaints team – complaints@midlandscollegeofcommerce.co.uk

MCC Wellbeing Team
The Wellbeing Team is here to offer guidance, information, and support on matters related to health, disability, specific learning differences, safeguarding, and overall wellbeing.

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If you have experienced anything that has made you feel unsafe, targeted, disrespected, or harmed, please remember, you are not alone, and it is always okay to speak up or report it.

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Student Safeguarding Concerns

Speaking up can make a real difference. Your action could help prevent serious harm and ensure that the right support is provided as quickly as possible.

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Safeguarding is everyone's responsibility, by staying aware and acting, students play a vital part in creating a safe and supportive community.

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If you are worried about someone's safety or wellbeing, please request the Designated Safeguarding Lead, or contact the team directly at safeguarding@midlandscollegeofcommerce.co.uk.

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Book a 1:1 Wellbeing or Program Coordinator Support Session

Speak to the Health and Wellbeing Team – You can book an appointment with a wellbeing officer by emailing student.wellbeing@midlandscollegeofcommerce.co.uk. One of the team will respond to book an appointment at a convenient time, or are available to liaise over email if preferred.

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Speak with your Program Coordinator – If you are unsure about where to access any of the information or support you need, feel free to contact your allocated SST who will help to signpost you to a colleague to support your query.

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SAFEGUARDING: CODE OF CONDUCT

Introduction
This Code of Conduct should be considered in conjunction with the College's Safeguarding Policy and reflects the importance the College attaches to the safety and protection of children, young people and vulnerable adults.

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Code of behaviour and good practice

1. All children and adults at risk should be treated with respect.

2. All activities with children and adults at risk should have more than one adult present or at least one that is within sight or hearing of others.

3. All activities should respect the right to personal privacy.

4. In all activities, staff are required to be aware that physical contact with a child or adult at risk may be misinterpreted.

5. In all activities, staff should recognise that special caution is required when discussing sensitive issues with children or adults at risk.

6. Any physical or manual touching required should be provided openly and if this is in a sporting situation, it should be in accordance with the guidelines provided by the appropriate National Governing Body.

7. In activities, feedback should be constructive rather than negative.

8. In all activities, staff are required to challenge unacceptable behaviour.

9. Any allegations or suspicions of abuse should be reported immediately to the relevant Designated Safeguarding Officer.

In all dealings with children or adults at risk, staff should never:

• Play rough physical games or sexually provocative games

• Share a room with a child or adult at risk

• Enter a private room (e.g. bedroom) unless it is absolutely necessary, and if entering a room must do so accompanied

• Allow or engage in any form of inappropriate touching

• Allow children or adults at risk to use inappropriate language without challenging it

• Make sexually suggestive comments even in jest

• Reduce a child or adult at risk to tears as a form of control

• Allow safeguarding concerns or allegations of abuse to go unchallenged, unrecorded or not acted upon

• Do personal things for a child or adult at risk which they can do for themselves. If a child or adult at risk has a disability any tasks should only be performed by a dedicated support worker, in accordance with recommendations made in a relevant care plan and with the full understanding and consent of the parents/guardians/carers.

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