OSACO:

Civil Aviation Authority – Response to allegations of Sexual Harassment

In response to your question as to our thoughts on the CAA’s chair Nigel Gould’s reply when asked
about current staff speaking to a journalist rather than managers:

“…the CAA does take action on complaints and it has policies to support staff….And if they’re not
using those you’ve got to ask what their motive is in going the public the way they are through
you.”

It is quite astounding that the most senior member of the governing body of a crown entity that is
empowered to oversee aviation safety and acts in the public interest, would make a statement
that can be perceived as victim blaming. It is an attitude that has no place in today’s context.
Regardless of whether or not that was Mr Gould’s intent, the fact remains that sexual harassment
or harassment of any kind in the work environment is damaging behaviour and comments such as
his can perpetuate that damage. Additionally, how do his comments provide assurance to staff
that the organisation will take complaints of sexual harassment/harassment/bullying/abuse of
power seriously, especially those staff who do not know the details of the complaint?

In 2018 the Security-General of the United Nations made a clear statement of the UN commitment
to upholding a zero-tolerance approach to sexual harassment. This includes taking a
survivor/victim-centred approach.

Essentially this is a move away from an organisational culture where the needs of the organisation
are at the centre of an internal mechanism for dealing with complaints in the workplace.

Harassment in the workplace, whether sexual or otherwise, is a damaging behaviour. It is

generally perpetuated where the tolerance of such behaviour is minimised and tolerated,
insomuch as it is not addressed appropriately.

There are many reasons as to why a complainant/victim/survivor may disclose allegations of

sexual harassment outside of an organisation. Commonly it is because they fear or have
experienced retaliation and are disempowered when it comes to raising the issue internally. That
is to say they do not believe they will be listened to or supported or will face humiliation. While
the organisation may have an internal complaint mechanism this does not necessarily mean that it
has the ability to undertake a robust, objective, transparent investigation where the focus is to
determine the facts and address any lessons learnt.

SPECIALISTS IN
OVERSIGHT & COMPLIANCE SERVICES

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In our experience, we have noted that while an organisation may have an internal complaints
mechanism, they do not necessarily have appropriate tools to respond to allegations of
harassment or sexual harassment and abuse. It is essential that the allegation is taken seriously
and not subject to pre-determination by management as to whether they believe the matter to be
serious or not. This kind of pre-determination is another regular mistake we see. In the best-case
scenario an external entity is engaged, such as OSACO, as so often, the survivor does not believe
the organisation will be able to objectively undertake the investigation, and more often than not
they would be right. Regardless of good intentions, management and also in some cases staff
union representatives, struggle to put aside their own preconceptions, prejudices, motivations,
and need for self-preservation when tasked to investigate internal misconduct especially when
that misconduct involves harassment and sexual-harassment.