Updated December 2024
Our Commitment to an Inclusive Workplace
Warner Bros. Discovery (WBD) and ‘Twenty Twenty’ (the Company) are committed to recruiting, hiring and maintaining a diverse workforce and providing a work environment free from discrimination and harassment, and where all members of the production are treated with respect and dignity.
The purpose of this Anti-Bullying & Anti-Harassment policy (the Policy) is to carry out this commitment and ensure that WBD and the Company and everyone working on this production (employees, workers, freelancers, contractors, on-screen cast, supporting artists, presenters and contributors), (“The Production Workforce”) as well as third parties, business partners, and visitors maintain a professional atmosphere and prohibits unlawful discrimination and harassment.
Harassment or bullying at work can be unlawful and will not be tolerated. The Company will take active steps to prevent the harassment and bullying of members of the production, including sexual harassment. Anyone who experiences or witnesses harassment or bullying is encouraged to report it in accordance with this policy. This will enable us to take appropriate action and provide support. Incidents of bullying, harassment or victimisation will be taken very seriously by the Company and may result in action up to and including termination of engagement.
We reserve the right to review, revise, amend or replace the contents of this Policy to reflect the changing needs of the business or to comply with new legal developments. This policy does not form part of your terms and conditions of employment or engagement.
Everyone who is asked to complete any training regarding this policy must do so in a timely manner.
If you have any questions about the contents of this Policy, please speak to Production P&C for further information.
Where and How does this Policy Apply?
All forms of bullying, harassment and discrimination are prohibited by the Company.
This Policy is applicable to all employees and members of Production workforce.
Regardless of how you are employed or engaged by the Company, you should not be bullied, harassed or discriminated against by anyone involved with the Company.
When bullying, harassment or discrimination occurs, it can bring about a climate of fear and insecurity, can demoralise those on the receiving end and can sometimes affect work performance. It is therefore vital that every member of the Production Workforce understands their responsibilities under this Policy.
All managers have a specific responsibility to operate within the boundaries of this Policy and ensure that all of the Production Workforce understand the standards of behaviour expected of them. Managers must consult with their Production P&C team on all complaints and incidents of which they are aware involving harassment or other prohibited conduct of anyone working on the production (including third parties). Please also see Production Ethics Policy, Additional Responsibilities of Supervisors.
Conduct prohibited by this Policy is unacceptable both in the workplace and in any work-related setting, such as location shoots, production meetings, production and business trips, field assignments, and Company related social events (including wrap parties), whether formal or informal including social events with colleagues, as well as during travel to and from work, and in accommodation provided by the Company.
Similarly, calls, texts, emails, and social media usage (including WhatsApp messages) by individuals working on this production can constitute unlawful workplace harassment even if those communications occur away from workplace premises, on personal devices, or during non-work hours. In addition, action may be taken against someone who carries out bullying or harassment against anyone outside of a work situation where the incident is relevant to your suitability to carry out your role with the Company.
Alcohol and drugs can affect behaviour and being under the influence of alcohol or drugs is not an acceptable excuse for a breach of this Policy.
The principles in this Policy also apply to the way in which the everyone at the Company must treat visitors, job applicants, clients, customers, suppliers, and former colleagues. Additionally, we will not tolerate and will take steps to address bullying or harassment towards our employees and others by third parties such as suppliers, customers, or visitors. Steps we may take to address third party harassment may include banning the third party from Company sites and reporting any criminal acts to the police. You are encouraged to report any act of bullying or harassment that takes place at work or is related to work.
Unacceptable Conduct Covered by this Policy:
Bullying is offensive, intimidating, malicious or insulting behaviour that can make an individual feel vulnerable, upset, denigrated, injured, humiliated, undermined or threatened. It often involves the misuse of power, but power does not always mean a position of authority; it can include personal strength and power to coerce through intimidation.
Harassment is unwanted conduct that has the purpose or effect of violating the recipient’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.
Although we will not tolerate any form of harassment, the law provides for additional specific protection from harassment that is related to “protected characteristics”. The protected characteristics are age; disability; race; religion or belief; sex; sexual orientation; and gender reassignment. The protection applies even if the individual affected does not have the protected characteristic; for example, if homophobic remarks are made to someone who is not gay, or if offensive comments relate to an individual’s partner or family member.
Sexual Harassment is unwanted conduct of a sexual nature that has the purpose or effect of either violating an individual’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment. The unwanted conduct may be verbal, non-verbal, or physical, and unwanted means unwelcome or uninvited; it is not necessary for the individual to have objected to the conduct.
Sexual harassment is gender-neutral and orientation-neutral and can be perpetrated by any gender against any gender.
Harassment may also occur when someone experiences less favourable treatment because of how they have responded to previous sexual harassment or harassment related to sex or gender reassignment (whether they have submitted to or rejected the initial harassment); for example, if someone is not invited to participate in a meeting because in a previous meeting they had objected to offensive jokes and comments, or if someone is subjected to personal comments because they had previously allowed unwanted touching.
Unacceptable conduct can be intentional or unintentional and involve action or a failure to act. It can be targeted at a particular individual or group; or not targeted at all and can be perpetrated by an individual at the same or a different level/department to the recipient.
Unacceptable conduct may be repeated or an isolated incident and may take place in private or in front of colleagues. It does not have to take place face to face but can, for example, be through text, WhatsApp, email, or notes, visual images, or social media. Condoning, overlooking or excusing unacceptable conduct may be bullying or harassment in itself. Aggravating factors, such as abuse of power over a more junior colleague, will be taken into account in deciding what action will be taken.
Victimisation is targeting someone, excluding them, or treating them poorly because they have raised or may raise complaints or concerns about bullying, harassment, or discrimination, or because they have supported or been involved in the resolution of another individual’s complaints or concerns.
Examples of Unacceptable Conduct
Examples of unacceptable conduct include, but are not limited to, the following:
a) touching, staring, or making comments of a sexual nature about a person’s appearance or clothing;
b) unsolicited or unwelcome sexual advances or requests for sexual intimacy;
c) subjecting someone to a detriment for rejecting (or complaining about) unwelcome conduct of a sexual nature or indicating that acceptance of such unwelcome conduct will lead to favourable treatment;
d) verbal abuse including shouting, threatening, swearing or insulting behaviour;
e) sexist or racist jokes, jokes about an individual’s age, sexual orientation or physical or mental attributes, or jokes of a sexual nature;
f) unwelcome comments or “banter” that is offensive to the recipient even if they were not the intended target;
g) creating, displaying or sharing sexually explicit, offensive or racially abusive material;
h) ridiculing someone or picking on them in private or in public;
i) spreading rumours about or insulting somebody either directly or indirectly;
j) refusing to communicate, excluding individuals or groups or socially isolating them;
k) intentionally setting unrealistic objectives or deadlines;
l) controlling a colleague’s work to an extreme and/or unreasonable degree
m) belittling a person’s creative input or other abilities;
n) constant criticism which cannot be justified;
o) cyber bullying, for example, making or publishing discriminatory or derogatory comments on social media or abusing someone via text or instant messaging including WhatsApp; and
p) “mobbing” (where there is more than one perpetrator involved).
Please note that, it is unlikely that reasonable management action will constitute bullying, harassment or discrimination. Reasonable management action includes, but is not limited to, giving reasonable instructions, giving constructive feedback, carrying out performance reviews, dealing with minor disciplinary issues informally or following performance management or disciplinary procedures fairly.
Mature Content in the Workplace
It is important to recognise that adult-themed creative products and raw news footage are a part of WBD’s business. Some roles on this production may include discussion of or require exposure to materials (art, animation, filmed or video images) that are sexually explicit, that contain violence, nudity or partial nudity, or that relate to topics that otherwise might be considered inappropriate for other workplaces. With this context in mind, please understand that:
· By accepting and continuing to work on this production, you acknowledge that you may encounter such discussions or materials in the course of your work and that, in this context, your exposure to such discussions or materials does not constitute harassment.
· In keeping with its commitment to a workplace free of unlawful harassment, the Company expects that any such discussions or materials will be handled with professionalism and maturity, and will not be used to harass others, as defined in this Policy.
· If you feel that such discussions or materials are being used to harass, as defined in this Policy, you should raise your concerns through the reporting procedures below.
What Happens if you Breach this Policy?
The highest standards of conduct are required of everyone regardless of seniority and how they are employed or engaged by the Company. Breaches of this Policy will not be tolerated, and any employee or member of the Production Workforce found to have harassed or discriminated or breached this Policy in any other way, runs a significant risk of action up to and including termination of their employment or engagement. Please also see the Production Ethics Policy.
Reporting Bullying, Harassment or Discrimination
The Company encourages its Production Workforce to raise any concerns that they have under this Policy.
All complaints will be handled fairly and sensitively, and the Company takes a strong position against victimisation, coercion, intimidation, retaliation, interference or discrimination for reporting in good faith any alleged acts of bullying, harassment or discrimination or participating in an investigation of a bullying, harassment or discrimination complaint. Such victimisation is likely to be unlawful.
If, however, the Company reasonably considers that you have not acted in good faith (with an honest belief in the truth of your complaint) in making a complaint or as part of an investigation, it reserves the right to take appropriate action against you.
Concerns may be raised anonymously but you should be aware that anonymity might restrict the ability of the Company to investigate.
Witnessing bullying, harassment, or sexual harassment
We all share responsibility for taking steps to maintain a supportive and positive working environment. The Company encourages you to take action as soon as possible in relation to any acts of bullying, harassment or discrimination, either against you or that you have witnessed against someone else. Anyone who witnesses such an act is encouraged to take appropriate steps to address it. Depending on the circumstances, this could include:
a. Intervening where you feel able to do so.
b. Speaking to the harasser to make it clear their behaviour is unacceptable.
c. Supporting the target to report it or reporting it on their behalf.
d. Reporting the incident where you feel there may be a continuing risk.
e. Cooperating in any investigation into the incident.
All witnesses will be provided with appropriate support and will be protected from victimisation.
How and Where to Raise Concerns
Informal steps
If you are being bullied or harassed, consider whether you feel able to raise the problem informally with the person responsible. Where possible and if appropriate, bullying, harassment and sexual harassment issues may be resolved informally by clearly telling the person responsible that their behaviour is unwelcome and unacceptable and asking that person to change their behaviour.
If the behaviour continues or if you do not feel able or willing to deal with the issue in this way, you should report it to your direct supervisor/manager, to the Producer, a member of Production P&C or a member of the People Relations team.
Formal steps
If it is not appropriate to try to resolve the matter informally or you wish to make a formal complaint, you should do so in writing by contacting Production P&C. If you are an employee, you may use the Company’s Grievance Policy
Your complaint should set out full details of the conduct in question, including the name of the person responsible, the nature of the bullying or harassment, the date(s) and time(s) at which it occurred, the names of any witnesses and any action that has been taken so far to attempt to stop it from occurring.
Depending upon the nature of the complaint, the Production P&C team will discuss with you how it will be investigated and managed, your complaint may be investigated by the People Relations team, who are a specialist team responsible for conducting impartial investigations into complaints of bullying, harassment, sexual harassment, and retaliation.
Other options for reporting under this policy
Alternatively, you may report the matter to the Ethics Hotline (contact details below) The Ethics Hotline is operated by a third-party vendor and is available 24 hours a day, seven days a week. Your calls will be taken in confidence and your concerns reported to relevant personnel for appropriate action. Your calls to the Ethics Hotline may be made on an anonymous basis, but please be aware that anonymity might restrict the ability of the Company to investigate.
You may also contact the People Relations team directly (contact details below)
Action Following a Formal Complaint of Bullying, Harassment or Discrimination
Where you raise a complaint, it is likely that you will be asked to provide further information as part of the investigation. The alleged harasser or bully have a right to be told the details of the allegations against them, so that they can respond. It may be necessary to interview witnesses to any of the incidents mentioned in the complaint. If so, the importance of confidentiality will be emphasised to them.
The Company expects that all those involved in any investigation to fully cooperate with the investigation, provide information to the investigator as requested, attend any meetings or interviews as needed and observe their confidentiality obligations.
Any factual finding that an employee of the Company may have breached this Policy, or another Company Policy is likely to be handled confidentially under the Company’s Disciplinary Policy.
A member of the Production Workforce who is found to have breached this Policy will be subject to appropriate action, up to and including immediate termination of engagement.
If the harasser or bully is a third party such as a customer or other visitor, the Company will take what action it reasonably can and would be appropriate to deal with the problem. This may include termination of the relationship and/or a ban on entering Company sites.
Whether or not your complaint is upheld, the Company will consider how best to manage any ongoing working relationship between you and the person concerned.
Confidentiality and Record Keeping
Confidentiality is an important part of this Policy. Everyone involved in making a complaint or involved in an investigation is responsible for observing the high level of confidentiality that is required.
It may be necessary for details of the investigation and the names of the person making the complaint and the person accused to be disclosed on a "need to know" basis only; for example, where a complaint is being investigated, or leads to disciplinary action or where the Company is legally obliged to disclose the information to a third party. The Company may also have an obligation to address issues you raise even if you decide not to make a formal complaint.
We will monitor the outcomes of complaints of bullying, harassment, sexual harassment, or victimisation we receive to ensure that they are properly investigated and resolved, those who report or act as witnesses are not victimised, and training is targeted where needed.
Support for those involved
The Company offers support to all internal parties involved in any complaint of bullying, harassment or discrimination, through its Employee Assistance Programme (EAP). Further details of the EAP are available from the Production P&C team.
Production P&C Contact Details:
Felicity Rothwell P&C Director
Email: Felicty.Rothwell@wbd.com
Victoria Andrews P&C Partner, Productions
Email: Victoria.Andrews@wbd.com
People Relations & Ethics Hotline Contact Details:
Website: wbd.ethicspoint.com
Phone Number: 0800 0668106
Email: ethics@wbd.com or PeopleRelations@wbd.com