11. Equal Employment Opportunity and Anti-Discrimination Policy
Company Commitment.
As part of our commitment to the fair treatment for staff, Brothers Leagues Club Townsville
has developed policy on equal opportunity, grievance procedures, contact officers and the
role of Managers and Supervisors. Throughout your employment you will also have the
opportunity to attend information sessions about discrimination, sexual harassment, bullying,
vilification etc.
11.1 Brothers Equal Opportunity Policy
Brothers Leagues Club Townsville aims to be an equal opportunity employer and is
committed to promoting equal opportunities regardless of religious belief, age, colour, race,
marital status, gender, sexual orientation etc. All employees are treated on their merits,
without regard to race, age, sex, relationship status or any other factor not applicable to the
position. Selection criteria and procedures aim to ensure that employees are selected,
promoted and treated on the basis of their relevant merits and abilities.
Brothers Leagues Club Townsville believes that all employees should be able to work in an
environment free of discrimination, victimisation, sexual harassment and vilification. We
consider these behaviours unacceptable and they will not be tolerated under any
circumstances.
Under the Queensland Anti-Discrimination Act 1991 (the Act), discrimination, victimisation,
sexual harassment and vilification are illegal.
11.2 Discrimination
 Discrimination occurs when someone is treated unfairly or badly in certain respects. Not
all discrimination is against the law, even if it is unfair. Discrimination in employment on
the following grounds or attributes is against the law under the Anti-Discrimination Act
1991 : Sex
 relationship status
 pregnancy
 parental status
 breastfeeding
 age
 race
 impairment
 religious belief or religious activity
 political belief or activity
 trade union activity
 lawful sexual activity
 gender identity
 sexuality

family responsibilities
 association with someone with an attribute above
Discrimination may involve:
 Making offensive ‘jokes’ about another worker’s racial or ethnic background, sex, sexual
preference, age or disability.
 Expressing negative stereotypes about particular groups e.g. “Married women shouldn’t
be working”.
 Judging someone on their political or religious beliefs rather than their work
performance.
 Using selection processes based on irrelevant attributes such as age, race or disability
rather than on skills and merit.
11.3 Victimisation
An employee who believes they have been discriminated against or sexually harassed has
the right to make a complaint, either using Brothers Leagues Club Townsville internal
complaints procedure or to an external agency such as the Anti-Discrimination Commission
Queensland. An employer has a responsibility to ensure that a person is not victimised, or
treated unfavourably, because he or she has made a complaint or supported another person
to make a complaint.
Victimisation means subjecting a person to some form of detriment or threatening to
because he or she has:
 lodged a complaint of discrimination or sexual harassment
 provided information or documents regarding a complaint
 attended a conciliation conference at the Commission
 reasonably asserted their rights, or supported someone else’s rights, under antidiscrimination laws
 refused to discriminate against another person, victimise or sexually harass them.
 made an allegation that a person has acted unlawfully under anti-discrimination laws
 brought any proceeding under the Act.
Examples of victimisation may include:
 Bullying and intimidation by co-workers
 Individuals are refused requests for time off
 Denied promotion or training
 Ignored by their manager or colleagues
 Criticised continually for their work
 Unnecessary changes to work allocation or shift arrangements
11.4 Sexual Harassment
Sexual harassment is any form of unwelcome sexual attention. It includes unwelcome
touching or other physical contact, remarks with sexual connotations, smutty jokes, requests
for sex, or the display of offensive materials such as pictures, posters or computer graphics.
Sexual harassment is against the law wherever and whenever it occurs. Brothers Leagues
Club Townsville will not tolerate sexual harassment in the workplace or in any work-related
context such as conferences, work functions and business trips.
Sexual harassment has nothing to do with mutual attraction. Such friendships are a private
matter.
Sexual harassment can be a single incident - it depends on the circumstances. Obviously
some actions or remarks are so offensive that they constitute sexual harassment in
themselves, even if they are not repeated. Other single incidents, such as an unwanted
invitation out, may not constitute harassment if they are not repeated and are polite and
respectful.
There is no onus on the person being harassed to say he/she finds the conduct
objectionable. Many people find it difficult to speak up. All employees are responsible for
their own behaviour. If you think the behaviour may offend, then don’t do it.
Examples of sexual harassment include:
 Suggestive comments about a person’s body or appearance
 Leering or staring at a person or parts of their body
 Demands that revealing clothing be worn
 Tales of sexual performance
 Persistent, unwelcome proposals of marriage, requests for dates or outings
 Unwanted touching
 Asking questions about a person’s sex life
 Unwanted confidences about a person’s sex life of lack thereof
 Unwanted requests for sex
 Pornographic or nude posters in the workplace
 Sexual assault (criminal offence)
 Flashing (criminal offence)
 Obscene phone calls (criminal offence)
11.5 Vilification
Vilification is behaviour that:
 happens in a public place; and
 incites others to hate, to have serious contempt for or to severely ridicule individuals or
groups because of their race, religion, sexuality or gender identity.
Workplaces can be considered public places. This means that any conduct which can
possibly be observed by the public or any sort of communication either verbal or in writing to
the public can be considered to have happened in a public place.
Some examples of vilification are:
 Placing a poster or sticker on the customer service counter which incites others to hate
people because of their race, religion, sexuality or gender identity.
 Hate graffiti written on work toilet walls which incites hatred because of race, religion,
sexuality or gender identity.
 Wearing of symbols, badges or clothing in the workplace with slogans that incite hatred.
 An employee abusing a person because of their race, religion, sexuality or gender
identity in the workplace which encourages others to hate people of that race, religion,
sexuality or gender identity.
 A work colleague making a speech in the work cafeteria that incites hatred of people
because of their race, religion, sexuality or gender identity.
11.6 Workplace Bullying
Workplace bullying is the repeated less favourable treatment of a person by another or
others in the workplace, which may be considered unreasonable and inappropriate
workplace practice. It includes behaviour that intimidates, offends degrades or humiliates a
worker, possibly in front of co-workers, clients or customers.
Examples of workplace bullying
 Yelling, screaming, abuse, offensive language, insults, inappropriate comments about a
person’s appearance, life or lifestyle, slandering a worker or his/her family
 Belittling opinions and constant criticism
 Isolating workers from normal work interaction, training and development or career
opportunities. Deliberately ignoring staff or co-workers.
 Overwork, unnecessary pressure, impossible deadlines
 Under-work, creating a feeling of uselessness.
 Undermining work performance, deliberating withholding work-related information or
resources, or supplying incorrect information.
 Unexplained job changes, meaningless tasks, tasks beyond a person’s skills, failure to
give credit where due.
 Tampering with a workers personal effects or work equipment
 Teasing or regularly being made the brunt of pranks/practical jokes.
11.7 Vicarious Liability
Under state anti-discrimination law, Brothers Leagues Club Townsville can be liable for
discrimination, sexual harassment and/or vilification which occurs in the workplace, unless
we can show we have taken reasonable steps to prevent it.
Managers and supervisors therefore must ensure that all employees are treated fairly and
are not subject to any of these behaviours. They must also ensure that people who make
complaints, or who are witnesses, are not victimised in any way.
Any reports of discrimination, victimisation, sexual harassment and vilification will be treated
seriously and investigated promptly, confidentially and impartially. (See our Grievance Policy
for more information).
Disciplinary action will be taken against anyone who discriminates against, victimises,
sexually harasses or vilifies a co-worker. Discipline may involve a warning, transfer,
counseling, demotion or dismissal, depending on the circumstances.
11.8 What should you do if you are suffering from bullying or harassment?
If you believe that you are being harassed there are a number of important steps you should
take:
 Tell the person that their behaviour is unacceptable and that they must stop. It is
important to say these things to your harasser otherwise they may interpret your silence
as consent. If you would feel too uncomfortable saying these things to your harasser,
this will not mean that you don’t have a valid claim.
 Report the behaviour or incident to a Supervisor / Manager. You may also wish to lodge
a grievance under the company’s Grievance Handling policy.
 Keep your complaint confidential – this will avoid idle gossip and the possibility of
defamation proceedings against you or the company.
11.9 Complaint Procedure
Brothers have a legal responsibility to take reasonable steps to prevent harassment and
bullying from happening in the workplace.
This involves educating employees about harassment, putting in place this policy,
implementing grievance procedures and ensuring compliance by all people in the workplace.
If you make a complaint of workplace harassment it will be taken very seriously and will be
dealt with promptly, sympathetically, confidentially and impartially. The complaint will be
investigated and, if found to be proved, appropriate warnings, or other disciplinary action will
be taken against the harasser. You will not be victimised or treated unfairly for making a
complaint. You are allowed to bring a support person to all interviews. On receiving your
formal complaint the following process will occur;
If you are not satisfied with the way in which your complaint has been dealt with by the
company, you can seek further advice from an outside agency such as the Human Rights
and Equal Opportunity Commission or the Anti-Discrimination Board. Please see 11.11
Contact Officers for information on whom to lodge any complaints with.
11.10 Grievance Procedure
Brothers Leagues Club Commitment
As part of our commitment to fair treatment for staff, Brothers has developed policy on equal
opportunity, grievance procedures, contact officers and the role of Managers and
Supervisors.
Grievance procedures
This policy aims to ensure that employees are treated justly and fairly, by providing a
straightforward process for dealing with complaints of discrimination, sexual harassment and
vilification.
The process for dealing with complaints or grievances is as follows:
 A complaint can be made to any Director or Supervisor of BLT.
 The complaint does not have to be in writing
 The complaint will be dealt with fairly and in good faith; there will be no victimisation as a
result of making a complaint
 The complaint will be dealt with confidentially by a person trained in investigation
techniques. This may be a Supervisor or senior staff member or a person appointed
from outside Brothers Leagues Club Townsville.
 The complaint will be dealt with as a matter of priority. The investigator will discuss the
issue with the complainant as soon as practicable after the complaint being lodged. The
view of other parties to the complaint will be sought and those involved in the complaint
will be advised of the outcome in a timely manner.
 If the outcome is not acceptable to the parties, an appeal can be made to the General
Manager to review the complaint.
 The investigator will monitor the outcomes of the complaint.
At any stage of this process, a complaint can be lodged with another agency such as the
Anti-Discrimination Commission, Queensland or Fairwork.