Your Anti-Bullying Policy May Be Protecting the Wrong Person
Many organizations have an anti-bullying policy, and in Ontario every employer must have a workplace harassment policy. One line of research argues that these policies often protect the institution rather than the person who reports. The studies point to the climate around a policy, and how it is carried out, as what shapes the outcome.
Built from Peer-reviewed studies. The argument is Hodgins, MacCurtain and Mannix-McNamara (2020). The evidence around it: surveys of health-service staff (Quine, 1999; Carter et al., 2013), a survey of 773 employees in six Australian service organizations (Van Gramberg et al., 2020), 280 complaints escalated to an outside regulator (Neall, Li and Tuckey, 2021), studies of climate, bystanders, leadership and implementation (Salin, 2003; Jönsson and Muhonen, 2022; Plimmer et al., 2022; Kwan, Tuckey and Dollard, 2016; Sheehan, McCabe and Garavan, 2020), and interviews with workers with musculoskeletal disorders (Lin et al., 2025). Much of this evidence comes from health care, and the Kwan study is twenty interviews. Ontario's requirements are taken from the Occupational Health and Safety Act and the province's own guide to it. References at the foot.
Does not establish That anti-bullying policies are useless, or that any particular organization's policy fails. The surveys here are cross-sectional and the rest are interviews, case files or reviews, so they show patterns rather than causes. The five tests are questions to put to a policy, not legal advice, and the Ontario requirements apply in Ontario.
The question is not whether you have a policy
In a survey of 1,100 health-service staff, two thirds of the people bullied in the previous three months had tried to do something about it. Most were dissatisfied with the outcome (Quine, 1999). In a later study of 2,950 staff, the main reasons people did not report were the belief that nothing would change, not wanting to be seen as a troublemaker, and the seniority of the person bullying them. They were also unsure how the policy would actually be applied (Carter et al., 2013).
The pattern holds outside health care. In a survey of 773 employees across six Australian service organizations, people whose dispute was about bullying, harassment or incivility were less likely than people with other kinds of dispute to see it resolved, however much voice they had at work (Van Gramberg et al., 2020).
So the question is not whether you have a policy. It is who the policy is built to protect.
A policy is also an exercise of power
In 2020, a team of researchers in Ireland asked why organizations so rarely protect people from bullying. Their answer is uncomfortable. They argue that “anti-bullying policies and procedures are themselves an exercise in institutional power protecting and reinforcing dominant power structures” (Hodgins, MacCurtain and Mannix-McNamara, 2020).
Policies, they argue, usually treat bullying as a problem between two people. The complaint becomes a contest between a target and an alleged perpetrator, in a phrase the authors borrow from an earlier writer, “a dance that is really just around the edges” of the larger problem: “a culture that permits the abuse of power and ill-treatment of workers.” On their account, the employer is the final judge of a bullying complaint, even when an outside investigator is brought in. The process can be fair on paper and still leave the culture untouched.
Complainants notice. In 280 bullying cases escalated to an outside health and safety regulator, people pointed to how information was gathered, how they were treated, and how slowly or poorly decisions were explained as the reasons they took the complaint outside (Neall, Li and Tuckey, 2021).
Why it keeps happening
Three conditions let bullying carry on, and none of them is written in the policy itself.
- The costs look low. Bullying needs enabling conditions, such as a perceived power imbalance and low perceived costs (Salin, 2003).
- Bystanders stay quiet. Colleagues and managers hold back out of fear of the consequences, because the behaviour gets excused, or because they are not part of the dominant group (Jönsson and Muhonen, 2022).
- Leaders step back. Across 1,231 employees in 47 New Zealand public agencies, a strong psychosocial safety climate went with less bullying, partly through constructive leadership. Hands-off leadership went with more (Plimmer et al., 2022).
Climate also shaped what bullied workers did. In interviews with 20 workers in Malaysia, where the organization’s climate for psychological health and safety was strong, people tended to speak up, and the bullying was resolved quickly. Where it was weak, they tended to withdraw or go along with it, then leave, and the bullying stayed unresolved (Kwan, Tuckey and Dollard, 2016).
Five tests for your policy
A policy that protects people looks different from one that protects the institution, and the difference shows in the details.
- Can someone report around the person they are reporting? In Ontario this is a legal requirement: a harassment program must let workers report to someone other than the employer or supervisor when that person is the alleged harasser (Occupational Health and Safety Act, s. 32.0.6).
- Does the person receiving the report have to declare a conflict? A recipient close to either party should step aside the same day.
- Are both parties told the result? Ontario requires that the worker, and the alleged harasser if they also work for the employer, be informed in writing of the results of the investigation and of any corrective action (s. 32.0.7).
- Are your managers trained to apply it? Across 1,507 employees in 47 hospitals, how well staff saw anti-bullying practices being carried out helped explain how much bullying harmed them, and targeted line-manager training strengthened that link. The authors conclude that what is needed to reduce bullying and its harm is effective implementation, backed by targeted training (Sheehan, McCabe and Garavan, 2020). It is the same pattern as supervisor training in return to work: training inside a system is what the evidence supports, not a document on its own.
- Do you measure the climate, not just the paperwork? Track whether people raise concerns, whether those concerns get resolved, and who leaves afterwards.
Why this matters for disability management
The people a weak policy is likely to fail first are the people disability management exists to support. In the health-service study above, staff with disabilities reported higher levels of bullying (Carter et al., 2013). In interviews with workers who had work-related musculoskeletal disorders, the most common form of bullying was “pressure not to claim something to which you are entitled” (Lin et al., 2025).
That is where a claim, an accommodation request or a return to work meets the policy. If the process protects the institution, the worker is likely to learn that asking for support carries a cost. If it protects people, asking becomes safer.
Psychologically safe disability management depends on that second kind of policy. Start with the five tests. If your policy fails one, fix that before you write another word of it.
References
Carter M, Thompson N, Crampton P, et al. Workplace bullying in the UK NHS: a questionnaire and interview study on prevalence, impact and barriers to reporting. BMJ Open. 2013;3(6):e002628. doi:10.1136/bmjopen-2013-002628
Hodgins M, MacCurtain S, Mannix-McNamara P. Power and inaction: why organizations fail to address workplace bullying. International Journal of Workplace Health Management. 2020;13(3):265-290. doi:10.1108/IJWHM-10-2019-0125
Jönsson S, Muhonen T. Factors influencing the behavior of bystanders to workplace bullying in healthcare: a qualitative descriptive interview study. Research in Nursing & Health. 2022;45(4):424-432. doi:10.1002/nur.22228
Kwan SSM, Tuckey MR, Dollard MF. The role of the psychosocial safety climate in coping with workplace bullying: a grounded theory and sequential tree analysis. European Journal of Work and Organizational Psychology. 2016;25(1):133-148. doi:10.1080/1359432X.2014.982102
Lin CY, Chung PH, Lee PH, et al. Experiences of workplace bullying among workers with work-related musculoskeletal disorders: a qualitative assessment using the Negative Acts Questionnaire. Safety and Health at Work. 2025;16(4):478-484. doi:10.1016/j.shaw.2025.09.003
Ministry of Labour, Immigration, Training and Skills Development. Guide to the Occupational Health and Safety Act. Government of Ontario; 2017 (updated 2026). https://www.ontario.ca/document/guide-occupational-health-and-safety-act
Neall AM, Li Y, Tuckey MR. Organizational justice and workplace bullying: lessons learned from externally referred complaints and investigations. Societies. 2021;11(4):143. doi:10.3390/soc11040143
Occupational Health and Safety Act, R.S.O. 1990, c. O.1, ss. 32.0.6, 32.0.7. Government of Ontario. https://www.ontario.ca/laws/statute/90o01
Plimmer G, Nguyen D, Teo S, et al. Workplace bullying as an organisational issue: aligning climate and leadership. Work & Stress. 2022;36(2):202-227. doi:10.1080/02678373.2021.1969479
Quine L. Workplace bullying in NHS community trust: staff questionnaire survey. BMJ. 1999;318(7178):228-232. doi:10.1136/bmj.318.7178.228
Salin D. Ways of explaining workplace bullying: a review of enabling, motivating and precipitating structures and processes in the work environment. Human Relations. 2003;56(10):1213-1232. doi:10.1177/00187267035610003
Sheehan M, McCabe TJ, Garavan TN. Workplace bullying and employee outcomes: a moderated mediated model. The International Journal of Human Resource Management. 2020;31(11):1379-1416. doi:10.1080/09585192.2017.1406390
Van Gramberg B, Teicher J, Bamber GJ, et al. Employee voice, intention to quit, and conflict resolution: evidence from Australia. ILR Review. 2020;73(2):393-410. doi:10.1177/0019793919876643
https://www.meaganangelucci.com/writing/your-anti-bullying-policy-may-protect-the-wrong-personPublished Oct 4, 2026