PREVENTION OF SEXUAL HARASSMENT QUALITY POLICY
Purpose: Sexual harassment prevention is about creating a culture that is free from sexual harassment and that allows all visitors to develop their personalities with dignity.
Mission: Prevention of sexual harassment is achieved by creating an environment where sexual harassment cannot go unnoticed, by offering immediate protection to visitors who are at risk of sexual harassment, by offering emotional support to victims of sexual harassment and by imposing restrictions on sexual harassers.
Strategic direction: The prevention of sexual harassment in nightclubs aims to ensure that every nightclub customer feels safe and that, in the event of sexual harassment, the victim is helped to regain their composure and the perpetrator is restrained as a response to their behaviour.
QUALITY MANAGEMENT PRINCIPLES
Customer Focus: Nightlife in European cities should be safe and inclusive for all. Nightlife entertainment venues should operate in a culture free of sexual harassment, built by staff and customers together. Nightlife venues should dynamically seek customer responses to evaluate and update quality management processes.
Leadership: Nightlife entertainment venues must operate on the basis of the values of gender equality and zero tolerance of all forms of discrimination and abuse. Sexual harassment is a form of violence that violates the dignity of a person at the core of human well-being. No expression of sexual harassment can be considered too minor to ignore. Victims must be given every possible support, while perpetrators must be condemned as they deserve to be.
Engagement: Creating a culture free of sexual harassment in a nightlife entertainment venue is a shared goal and effort among all employees of the establishment, including managers and assistants. Attitudes towards sexual harassment will be considered in both the recruitment and evaluation of staff. Nightlife entertainment venue staff are trained to involve the customers of the establishment in building a culture free of sexual harassment.
Process: Cases of sexual harassment must be documented. It must be recorded how the victims view the sexual harassment suffered and how the nightlife venue responds to it. It must also be documented what measures have been taken to prevent the recurrence of such sexual harassment. This will ensure that improving the prevention of sexual harassment in nightlife venues is a continuous process.
Continual Improvement and Innovation: Nightlife entertainment venue staff should regularly discuss their successes in stopping sexual harassment and the obstacles they have encountered, and suggest what actions could be taken in the future to make the culture of prohibiting sexual harassment more widespread and attractive. Opportunities should be sought to find measures that have proved successful in other nightlife entertainment venues, therefore discussions and cooperation with other nightlife entertainment venues should be encouraged locally.
Relationship Management: There must be a clear message that the nightlife entertainment venue supports the culture of nightlife free from sexual harassment. This message isn’t only important to solidify the venue’s position in the nightlife economy but also serves to build social support for the prevention of sexual harassment in the nightlife economy and in other social settings.
Prevention of sexual harassment is implemented by:
– Social prevention of sexual harassment. Nightlife entertainment venues must work to develop intolerance in society towards sexual harassment. They must send a clear and strong message, both on their premises and in public, that they maintain a culture free of sexual harassment and that any behavior inconsistent with that culture won’t be ignored or accepted.
– Situational prevention of sexual harassment: Nightlife entertainment venues must take all necessary measures to ensure that their premises and events don’t provide an opportunity for sexual harassment by:
o Managing the premises: Ensuring that the premises of nightlife entertainment venues are properly managed and that the managers of the entertainment venue have effective control over everything that happens on the premises.
o Detention of offenders: Ensure that there are no persons present who tend to sexually harass others and that there are persons who can deal appropriately with possible offenders.
o Victim protection: Ensure that no potential victims are present and that there are persons who can adequately protect potential victims.
– Victim support: Nightlife entertainment venues must advocate for victims of sexual harassment who have been sexually harassed on their premises or at their events. Immediate emotional support after an incident is critical to preserve the dignity violated by a sexual harasser. Referral of victims to victim support services and information about victim support services that can be requested are important elements of the sexual harassment prevention system.
Social prevention of sexual harassment
Nightlife entertainment venues must take care that the atmosphere created on their premises and at their events doesn’t promote gender stereotypes, the objectification of women, the understanding of violence as an expression of masculinity, and the secrecy of sexual desires. Sexualized red light environments, provocative outfits required of staff, masculinized „real men” environments and similar options are to be avoided.
A clear and strong message within the premises that any manifestation of sexual harassment in a nightlife entertainment venue won’t be ignored or accepted. Attention-grabbing ways must be sought to constantly communicate these messages, e.g. through original posters, coasters, or other methods.
Nightlife entertainment venues should take the opportunity to join broader social initiatives against sexual harassment and emphasise a culture free of sexual harassment in their advertising campaigns.
Situational prevention of sexual harassment
Nightlife entertainment venues must take all necessary measures to ensure that their premises and events don’t provide an opportunity for sexual harassment by ensuring that the premises and vicinities of places of entertainment are properly managed and that those in charge of the place have effective control over everything that happens on the premises.
The customers of the nightlife entertainment venue who gather outside the doors of the establishment must be at least partially observed, e.g. by setting up surveillance cameras and avoiding obstructions to the view of what is happening outside (sufficient lighting, not covering the windows of the establishment, etc.).
Appropriate communication channels should be established between nightlife entertainment venues, police, municipalities, and non-governmental organizations to share information and identify possible threats and actual incidents in the common locality.
Bystanders should be encouraged to either intervene themselves if they see sexual harassment or report it to a staff member. A clear indication that everyone is encouraged to intervene if they see sexual harassment could also serve as a warning to potential perpetrators that they’re being watched, even if there are no staff members around.
With regard to premises that are constantly in the field of vision of the nightlife entertainment staff:
- the possibility for staff to notice manifestations of sexual harassment in these places must be averted:
- overcrowding should be avoided, there should be enough space for each person to avoid both accidental and deliberate touching by others.
- adequate lighting must be provided,
- music mustn’t preclude the possibility of speaking to staff, etc.
- all nightlife entertainment venue’ staff must have basic skills to scan their proximity and understand customers’ body language. Body language can lead to false alarms, but it doesn’t hurt anyone to ask customers if they are OK.
- DJs and performers must observe what is happening on the dance floor and inform security staff of specific identified risks of sexual harassment;
- The cloakroom staff should observe whether potential victims leave their mobile phones in the cloakroom and thus become more vulnerable and inform the security staff about it.
With regard to premises that are observed by staff less frequently than others (seating areas in nightclubs, smoking rooms, courtyards, etc.):
- the staff of a nightlife entertainment establishment must regularly check what is going on in these parts of the establishment;
- there must be no uncontrollable places on the premises (places without light in corridors leading to sanitary facilities, etc.). As a rule, it’s good to install mirrors in such places (e.g. toilets) in such a way that the inside can be seen in the mirror before entering.
- technical measures could be introduced to enable potential and actual victims to call for help (from alarm buttons to clearly visible information on how to contact staff through media channels). It should be noted that the use of apps to call for help could be beneficial as they’re usually confidential – victims could use them without the perpetrators realizing that.
- instruments that alert potential victims that their drinks have been spiked with date rape drugs (smart coasters, napkins, straws, and others) should be provided either free of charge or for a small fee. It’s important that potential victims are informed that these tools exist and how they can be used. These highly visible items would also serve as a warning to potential offenders that their attempts to use certain substances will be noticed and sanctioned.
In relation to premises with restricted access (toilets and other sanitary facilities):
- cleaners of nightlife entertainment facilities could be asked to inform the staff in charge about facilities that are occupied for longer than usual, overheard conversations, and other anomalies.
- restricted access to certain facilities could also be exploited to send certain messages to potential victims – e.g. code phrases that are understood as a call for help when sent to staff via messaging apps or „Ask for Angela” alternatives.
Holding of Offenders
Steps need to be taken to identify in advance who among the clients is prone to overstep the boundaries of what is acceptable. A dynamic security concept could be introduced: It is best if staff are in constant friendly communication with all clients so that potential risks emanating from their side can be identified. Potential offenders must be warned that their behavior will be monitored and that no sexual harassment will be tolerated.
Those who are in a state where they have difficulty controlling themselves won’t be served or will have to leave even before they start threatening or harassing other customers. Care is also taken to ensure that those who aren’t served don’t find middlemen who would buy alcohol for them.
Consideration should be given to the possibility of security personnel being present throughout the site and not just at the entrance.
Following an incident in a nearby nightlife entertainment venue, volunteers patrolling the nightlife streets, or even the police, should be warned that a particular person in a particular nightlife entertainment venue has caused certain problems. Sharing information in these cases could help others prevent the harasser from repeating his or her acts in another pub or public place. No private data of the offender may be disclosed.
Staff should know how to apply 5Ds technique (Direct, Delegate, Delay, Distract, and Document).
- D1 stands for direct intervention in a situation of sexual harassment. A perpetrator must be told clearly that his or her behavior has been noted and that no one will allow the sexual harassment to continue. Communication with the perpetrator should be prioritized when the victim isn’t present, as a public intervention may lead to secondary victimization of the victim. If there is no possibility to talk to the offender alone, intervention should be made in the interest of the victim, even if publicity cannot be avoided. It should be ensured that the perpetrator is the one to blame.
- D2 stands for delegating the suppression of sexual harassment to someone better prepared to deal with it, e.g. the security staff of a nightlife entertainment venue. Victims mustn’t be left alone when they focus on the offender.
- D3 stands for documenting the incident of sexual harassment so that the victim can use the documentation as evidence in a court case if he or she wants to. Audio or video recordings shouldn’t be preferred because of possible breaches of data protection rules. However, the need to record unlawful acts of the victim may be sufficient to justify such recording. The recordings may not be disclosed to anyone except law enforcement authorities if necessary. Data will be recorded from persons who have observed the incident and are willing to testify upon request.
- D4 represents the distraction of an offender from a victim so that the victim can leave the place where he or she is at risk of sexual harassment. Alternatively, the victim himself or herself may be distracted and led away from the place where the risky behavior took place.
- D5 stands for delayed intervention when direct intervention isn’t possible. If the sexual harassment couldn’t be prevented, the victim should be emotionally supported and the perpetrator sanctioned.
Security staff should be aware of people who have caused certain problems in nightlife entertainment venues in the past and either prevent these people from entering or observe them with special attention. All staff should remember customers who cause certain problems and share this knowledge with their colleagues, especially those who weren’t present at the scene or at the time of the incident.
Staff should intervene in incidents of sexual harassment in a victim-centered, non-aggressive manner, bearing in mind that scandal can hurt the victim emotionally, if not physically.
Clear pathways should be created for victims to call for help. Alarm buttons or signs pointing to media apps to communicate with staff are possible options. Staff also need to be familiar with the codes that can be used by victims asking for protection:
- „Ask for Angela”: Any customer who needs the support of the staff to defend themselves against sexual harassment or to leave the venue discretely can ask to call a fictitious employee named Angela.
- „Angel Shot”: Ordering a fictitious cocktail is a cry for help. A simple „Angel Shot” indicates a general need for help, „Angel Shot on the Rocks” means calling a taxi to discreetly take the victim outside, and „Angel Shot Neat” is a code name for asking to be escorted to the victim’s car, and finally „Angel Shot with Lime” means a request to call the police.
- An alternative approach must also be found to change the code names and find a way to communicate them confidentially with the potential victims, e.g. by placing messages with code words in the sanitary facilities, placing them on special coasters given to guests who are considered potential victims by the staff, etc.
Staff must also be familiar with basic non-verbal calls for help when there is a risk of a sexual offense, such as the one-handed sign, which involves showing the palm of the hand as if to give a high five, then placing the thumb in the palm and lowering the remaining four fingers over it. Other measures to communicate non-verbal calls for help should also be considered, e.g. „Shake to Safety” style apps that send a call for help to a specific number by shaking the phone or pressing the phone’s power button a certain number of times, apps that send a SOS by flashing the phone’s lights are important if an incident occurs in a hard-to-reach place, e.g. in the middle of a dance hall, etc.
Victims shall be encouraged to protect themselves, e.g. by warning a potential victim that they consume too much alcohol and may become vulnerable, that they are communicating with someone who has sexually harassed another person in the past, etc..
Bystanders should be encouraged to take an active stance against sexual harassment.
Any group of friends visiting a nightclub should be suggested to choose a chaperone – the one who stays sober all night and looks after everyone else in the group. Chaperones could identify themselves with a wristband or sticker that they have the confidence of their friends to intervene and stop serving alcohol to friends who are approaching a vulnerable state. If a group of friends wear the same bracelets or stickers, this could also serve as a warning to potential offenders that someone is looking after a potential victim, even if the friends aren’t around.
Ensure that there are staff of different genders in every nightclub, because for female victims the stereotypical fear of being blamed for sexual harassment is an obstacle to seeking protection, and for male victims, the stereotype that men should always be able to protect themselves is an obstacle to seeking protection.
Nightlife entertainment venues shall stand for victims of sexual harassment who have been sexually harassed on their premises or at their events.
Emotional support for a victim must be given in a calm and confidential manner. Victims must be helped to understand that they aren’t to blame for what has happened. It can be important to ask the victim how they feel, to encourage them to speak out, but more importantly to listen to the victim without judging or giving advice. On the premises of a nightclub, there should be a place where it’s possible to talk to a victim without anyone else being present.
Staff must have basic knowledge of how to refer victims to victim support organizations in order to pass on information on where they can apply for further help and what support they can receive there.
Victims should also be given basic information on how to report the incident, what the first steps in criminal proceedings are, and what obligations and rights victims have when criminal proceedings are initiated. Leaflets with this information should be easily accessible in nightlife entertainment venues.