Dignity at Work Policy in Ireland: The 3 Stages Your Process Must Have

Search for "dignity at work policy" in Ireland and page one is almost entirely other organisations' policy documents: a public health body, a central bank, a teachers' union, a professional body, several schools. They are useful references. They are also the reason so many Irish policies look identical, and why so many fall apart the first time a real complaint arrives.

A dignity at work policy is not a statement of values. In Ireland it is the practical expression of a statutory Code of Practice, and when a bullying complaint reaches the Workplace Relations Commission or the courts, the question is not whether your policy sounds right. It is whether you followed the process the Code describes.

That process has three stages, and most failed complaints go wrong at the hinge between them. This guide explains each stage, what a good policy says about it, and where policies copied from elsewhere usually fall short. It is written for Irish employers and for UK and international groups with teams in Dublin, Cork, Galway or anywhere else in the Republic, especially in tech, legal, insurance, financial services and education.

---

What Sits Behind a Dignity at Work Policy

Three layers of Irish law and guidance meet in a single policy.

Health and safety law. Section 8 of the Safety, Health and Welfare at Work Act 2005 requires employers, so far as reasonably practicable, to manage and conduct work so as to prevent improper conduct or behaviour likely to put employees' safety, health or welfare at risk. Bullying is a workplace hazard, so it belongs in your risk assessment and your Safety Statement under section 20.

The bullying Code of Practice. The Code of Practice for Employers and Employees on the Prevention and Resolution of Bullying at Work (S.I. No. 674 of 2020), prepared jointly by the Health and Safety Authority and the Workplace Relations Commission, came into effect on 23 December 2020. It replaced the earlier HSA and Labour Relations Commission codes, and can be admitted in evidence in proceedings. Appendix 1 sets out how to prepare an anti-bullying policy.

Equality law. Harassment and sexual harassment on grounds such as gender, race, disability or age are dealt with under the Employment Equality Acts and the separate Code of Practice on Sexual Harassment and Harassment at Work (S.I. No. 208 of 2012). You can use one dignity at work policy for both bullying and harassment, as long as it reflects both codes.

Bullying, Harassment, or Neither?

The Code describes bullying as repeated inappropriate behaviour that could reasonably be regarded as undermining a person's right to dignity at work. A single incident may breach your dignity at work policy and need action, but it is not bullying under the Code. Reasonable management actions, such as fair performance management or a justified disciplinary process, are not bullying either. Harassment, by contrast, is linked to a protected ground and can arise from a single act.

Getting this distinction right at the start decides which process applies, which is why your policy needs to explain it in plain language with examples.

---

Before the Stages: Prevention

The Code expects prevention before resolution. A compliant policy should be developed in consultation with employees, introduced to new starters at induction, communicated regularly to existing staff, and supported by training for managers who will handle complaints. Bullying should also appear as a hazard in your risk assessment, with controls that go beyond the policy itself.

The HSA's bullying guidance sets out the regulator's expectations. For the wider picture on preventing harm before complaints arise, see work-related stress: 9 things the law actually requires and psychological safety at work.

---

Stage 1: The Initial Informal Process

What the Code expects: a prompt, low-key, problem-solving response. The person raising the concern is supported to address it directly, or a manager or contact person helps them do so. Many concerns can be resolved here, quickly and without lasting damage to working relationships.

What a good policy says:

• who staff can approach (a line manager, an alternative manager, a designated contact person, HR)
• that the conversation is confidential and records are kept separately from any later formal process
• that raising a concern in good faith will not lead to victimisation
• realistic timescales for an initial response

Where policies fail: they jump straight to "submit a written complaint". That turns every concern into a formal dispute, which the Code is specifically designed to avoid. Or they name a single contact person who happens to be the alleged bully's closest colleague.

Sector example (software and tech): in fast-growing Dublin tech teams, the "manager" may be a new team lead with six months' experience and no training in handling conflict. Stage 1 depends on that person knowing what to do. See tech health and safety in Ireland: 7 priorities for Dublin and global firms and our software sector page.

---

Stage 2: The Secondary Informal Process

What the Code expects: if the initial approach does not work or is not appropriate, a more structured but still informal process follows. A designated person with suitable experience works with both parties to understand the concern and find a resolution. Mediation, delivered by an impartial and competent third party, is an option at this stage if both parties agree.

This stage was one of the most important additions in the 2020 Code, and it is the stage most commonly missing from older or borrowed policies.

What a good policy says:

• that a secondary informal stage exists and when it is used
• who can act as the designated person, and that they will be impartial
• that mediation is voluntary
• that both parties will be offered support, and that agreed outcomes will be reviewed periodically

Where policies fail: a policy written before 2020 often has only one informal step. Employers then escalate straight to a formal investigation, and later find the process criticised for skipping a stage the Code expects.

Sector example (insurance and financial services): in regulated firms, there is a strong instinct to formalise everything. That instinct can backfire with bullying complaints, where a structured informal stage often produces a faster and more durable outcome. See our insurance sector page.

---

Stage 3: The Formal Process

What the Code expects: a formal complaint and investigation, used once informal routes have been exhausted or are inappropriate. Escalation is a significant step and should be a reasoned, evidence-based management decision, recorded as such. The process should follow fair procedures and natural justice.

What a good policy says:

• how a formal complaint is made, and that the decision to escalate is recorded
• that the investigation will have written terms of reference
• that both parties will be told the objectives, timeframe and possible outcomes
• that statements will be taken in writing and shared with the parties
• that both parties may be accompanied by a colleague or employee or trade union representative
• that both parties have a right of appeal
• what happens at the end, including follow-up and, where needed, work to rebuild the team

Where policies fail: investigations without terms of reference, investigators with a conflict of interest, no right of appeal, and nothing at all after the outcome letter. A team that has been through a formal bullying investigation rarely recovers without deliberate follow-up.

Sector example (legal): law firms are well placed to run fair procedures, but a partner investigating a complaint about another partner in the same practice group will rarely look impartial. Your policy should allow for an external investigator. See our legal sector page.

If Internal Stages Do Not Resolve It

Where internal procedures have been exhausted and the matter remains unresolved, the employee may refer it to the Workplace Relations Commission. The HSA can also look at whether an employer is meeting its duty to manage bullying as a hazard. Your policy should say so, clearly and without discouraging anyone.

---

Hybrid and Remote Work

The Code applies wherever work is carried out, including from home and on the move. Bullying by email, chat, video call or social media is covered, and your policy should say so explicitly. Many Irish teams are now partly or fully remote, which makes it easier for poor behaviour to go unseen and harder for informal resolution to happen naturally. See our posts on combating cyberbullying and abuse through a screen.

---

How Ireland Compares for UK and International Groups

Many groups apply one global policy everywhere. In Ireland, that is risky unless it reflects the Code's three stages.

Jurisdiction	How bullying and harassment are addressed	What it means for your policy
Republic of Ireland	2005 Act duties plus the 2020 bullying Code and the 2012 harassment Code	Three-stage process, consultation, induction and regular communication
Northern Ireland	Separate legislation, and the Republic's Codes do not apply	Needs its own approach; see Northern Ireland
Great Britain	General health and safety duties, the Equality Act 2010, and since 2024 a preventative duty on sexual harassment under the Worker Protection Act 2023	Prevention steps and risk assessment, with HSE's Management Standards covering relationships at work
Australia	Psychosocial hazard duties, including bullying and harassment, and a positive duty on sexual harassment	Hazard-based risk management as well as complaints handling; see Australia WHS

A group policy can work across all four if it sets one standard for behaviour and allows local procedures. The Irish procedure needs its own section.

---

Sector Notes

Education: schools, colleges and universities often adopt sector templates. Check that the template reflects the 2020 Code's secondary informal stage, and that it covers staff on placements and visiting staff where relevant. See our education page.

AI and data: small, specialised teams and heavy reliance on remote collaboration make informal resolution harder and conflict more visible to everyone. See our AI and data page.

Offices generally: the behaviours the Code describes are just as common in a 20-person professional practice as a 2,000-person multinational. Scale changes the procedure, not the duty. See our offices page.

---

How Arinite Helps

Arinite has supported 1,500+ businesses across 50+ countries for 15+ years, protecting 100,000+ employees, with 95%+ client retention. Our qualified consultants treat bullying as the health and safety hazard Irish law says it is, and work alongside your HR and legal advisers on the policy and procedures. See our Ireland page.

• Done For You: our health and safety consultants review your dignity at work policy against both Codes, update your Safety Statement and risk assessment, and test how it works in practice through independent health and safety audits.
• Done With You: we consult your staff, train the managers and contact persons who handle Stage 1 and Stage 2, and help you design follow-up after formal outcomes.
• DIY: you hold your policy, risk assessments, training records and actions on our health and safety consultants and software platform, with expert help on call.

For groups with teams in Ireland and elsewhere, our international health and safety consultants build one group standard with local procedures, and our global health and safety consultants keep them aligned as rules change. For more on our Irish work, see health and safety consultants in Ireland.

---

Frequently Asked Questions

Is a dignity at work policy a legal requirement in Ireland?

Employers have a legal duty under the Safety, Health and Welfare at Work Act 2005 to prevent improper conduct that puts employees at risk, and the 2020 Code of Practice sets out how to prevent and resolve bullying, including preparing an anti-bullying policy. In practice, an up-to-date policy that follows the Code is the clearest way to show you are meeting your duties.

Can one policy cover both bullying and harassment?

Yes. A single dignity at work policy can cover both, provided it reflects the 2020 bullying Code and the separate Code of Practice on Sexual Harassment and Harassment at Work.

Is a one-off incident bullying?

Not under the Code, which describes bullying as repeated behaviour. A single serious incident may still breach your dignity at work policy and need action, and may amount to harassment if linked to a protected ground.

Do we have to use the informal process before a formal investigation?

The Code expects informal routes to be used first where appropriate, including a secondary informal stage. Moving to a formal process should be a recorded, evidence-based decision, not automatic.

Does the Code apply to remote workers?

Yes. It applies wherever employees work, including from home or while mobile, and covers bullying through digital channels.

---

Check Your Policy Against All 3 Stages

If your policy has one informal step, no secondary stage, or nothing about follow-up after a formal outcome, it is out of step with the Code. Book a free gap analysis with Arinite and we will review your dignity at work policy and Safety Statement, alongside your UK and international arrangements, and show you what to update first.

Request your free gap analysis