Workplace Bullying Prevention & Response SWMS
Workplace bullying prevention, early intervention, and response — policy, risk assessment, reporting pathways, investigation procedures, and support mechanisms.
SWMS variants reference your state’s WHS legislation. Instant download after payment.
Workplace bullying is repeated unreasonable behaviour directed at a worker or group that creates a risk to health and safety. Under WHS Act 2011 s.19, PCBUs owe a primary duty of care to eliminate or minimise psychosocial hazards so far as is reasonably practicable, and bullying is explicitly captured as a psychosocial risk under the model WHS Regulations psychosocial amendments and the Safe Work Australia Preventing Workplace Bullying Code of Practice 2016. This SWMS documents how organisations identify bullying precursors, conduct psychosocial risk assessments, operate confidential reporting pathways, run procedurally fair investigations, and provide return-to-work support. It applies to all worker categories including employees, contractors, labour-hire and volunteers, and intersects with Fair Work Act 2009 s.789FD stop-bullying orders. A documented SWMS is mandatory because bullying is a foreseeable workplace hazard with established psychological injury outcomes, and regulators require evidence of systematic prevention, consultation under WHS Act s.47-49, and demonstrable control measures rather than reactive complaint handling.
Hazards identified
7 hazards covered, sorted by priority.
Psychological injury including adjustment disorder, depression and PTSD; workers compensation claim and potential Fair Work stop-bullying order
Team psychological harm, elevated turnover and accepted workers compensation claims for cumulative psychological injury
Supervisor psychological injury, breakdown of safety leadership and increased downstream incident rates
Continuous psychological harm without respite, evidentiary complexity and breach of the right to disconnect under Fair Work Act amendments
Acute stress reactions, vicarious trauma in colleagues and PCBU liability for failing to control third-party psychosocial exposure
Conflated complaints, procedural fairness failures and adverse Fair Work Commission findings against the PCBU
Breach of WHS Act s.104 discriminatory conduct provisions, criminal penalties and aggravated psychological injury to the worker
Control measures
Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.
- 1Elimination — Remove identified bullying perpetrators from the work group via disciplinary action, role redesign or termination where investigation substantiates conduct under the Code of Practice 2016 definition.
- 2Elimination — Redesign work systems that generate bullying precursors including unrealistic workloads, role ambiguity and unclear authority lines documented through psychosocial risk assessment under ISO 45003:2021.
- 3Substitution — Replace adversarial performance management processes with structured coaching frameworks and replace anonymous 360 reviews with facilitated feedback to remove channels routinely weaponised for bullying.
- 4Engineering — Implement confidential digital reporting platform with case-management workflow, audit trail and triage routing to ensure reports cannot be intercepted or suppressed by the alleged perpetrator's line.
- 5Engineering — Configure communication platforms with right-to-disconnect settings, after-hours message scheduling and group chat moderation tools to engineer out cyberbullying vectors.
- 6Administrative — Publish and consult on a Workplace Behaviour Policy aligned to the Preventing Workplace Bullying Code of Practice 2016, with annual worker consultation under WHS Act s.47-49.
- 7Administrative — Deliver mandatory bystander, manager and contact-officer training with documented competency assessment and biennial refresher cycles tracked in the LMS.
- 8Administrative — Operate a procedurally fair investigation procedure aligned with Briginshaw standard, including separate interviewer and decision-maker roles and written findings within 30 business days.
- 9Administrative — Provide Employee Assistance Program access, return-to-work planning and trauma-informed support for complainants, respondents and witnesses throughout and after the process.
- 10PPE — Not applicable as conventional PPE; psychological PPE substitutes include peer support officers, contact officer networks and on-call EAP clinicians available during high-risk investigation phases.
Applicable Codes of Practice
Defines repeated unreasonable behaviour, sets the risk management framework and prescribes prevention, early intervention and response duties for PCBUs.
Requires identification, assessment, control and review of psychosocial hazards including bullying with documented controls so far as reasonably practicable.
Provides the recognised methodology for psychosocial risk assessment, organisational controls and worker consultation underpinning the SWMS approach.
Establishes the worker right to apply to Fair Work Commission for stop-bullying orders, triggering PCBU obligations to evidence prevention systems.
Who this is for
- →HR managers and people-and-culture leads across all sectors
- →WHS managers handling psychosocial risk in mid-to-large enterprises
- →Contact officers and harassment response officers in regulated industries
- →Executives and PCBU officers discharging due diligence under WHS Act s.27
What you receive
- ✓Editable DOCX template — Microsoft Word compatible
- ✓State-specific WHS legislation schedule (NSW/VIC/QLD/SA/WA/TAS/NT/ACT)
- ✓Hazard register with risk ratings + hierarchy-of-control mapping
- ✓Worker sign-on register, pre-start checklist, and incident escalation flow
Worked example
At a regional logistics distribution centre, the Shift Operations Manager runs the Monday pre-start brief covering 22 warehouse workers and two team leaders. She tables the Workplace Bullying Prevention & Response SWMS alongside the standard manual-handling SWMS because two informal concerns about exclusionary behaviour on night shift were raised the previous fortnight. Working through the hazard register, the team identifies lateral bullying and cyberbullying via the shift WhatsApp group as the live risks for this crew. Controls selected for the week include moving roster-related communications off WhatsApp onto the official scheduling app (engineering control), nominating a contact officer for night shift (administrative), and confirming EAP details are visible on the crib-room noticeboard. Each worker signs on, acknowledging the reporting pathway and confirming they understand that retaliation breaches WHS Act s.104. Mid-week, a worker discreetly raises a concern with the contact officer about a team leader's repeated public criticism. The contact officer applies the SWMS triage matrix, escalates to HR within 24 hours, and the SWMS is amended at Thursday's pre-start to add a temporary control: the team leader is paired with a peer coach pending preliminary assessment. The amendment is signed off, demonstrating dynamic risk management and procedural fairness in real time.
Related legislation
- WHS Act 2011 (model)
- WHS Regulation 2025
- Managing Psychosocial Hazards at Work CoP
Frequently asked questions
Is preventing bullying a WHS duty, or just an HR policy matter?
It is a WHS duty. Repeated unreasonable behaviour that creates a risk to health is a psychosocial hazard, so the primary duty under section 19 of the WHS Act requires it to be eliminated or minimised so far as is reasonably practicable, and the psychosocial provisions of the WHS Regulation require it to be identified, assessed, controlled and reviewed. The Preventing Workplace Bullying Code of Practice sets the framework a regulator will measure you against. This is not high risk construction work under section 291, so section 299 is not the trigger. What is expected is evidence of systematic prevention rather than reactive complaint handling.
Does this cover cyberbullying on work chat apps and after-hours messages?
Yes, and it is rated as a high-priority hazard because harm delivered to a personal phone continues after the shift ends, leaving the worker no respite. The controls attack the channel rather than only the conduct: move roster and operational communications off informal group chats onto the official scheduling platform where there is an audit trail, configure after-hours message scheduling and right-to-disconnect settings, and moderate group chats. The worked example does exactly this at a distribution centre, shifting shift communications off a private messaging group after exclusionary behaviour surfaces on night shift.
How do we tell bullying apart from reasonable management action?
The distinction is not whether the worker found it upsetting, it is whether the action was reasonable and carried out in a reasonable way. Performance management done badly is listed as its own hazard, because that is where complaints get conflated and adverse findings follow. The template addresses it through process: a documented procedure with the interviewer and the decision-maker as separate roles, findings made on the balance of probabilities with the seriousness of the allegation weighed in the assessment, and written outcomes issued within a defined timeframe. Structured coaching replaces adversarial review formats that are routinely weaponised.
What protects someone who reports, and what if they are punished for it?
Retaliation is treated as a distinct hazard, and it is also a separate legal exposure: the discriminatory conduct provisions of the WHS Act prohibit detrimental action against a worker for raising a safety concern or assisting an investigation. The engineering control that matters most is a confidential reporting platform with case-management workflow, an audit trail and triage routing that deliberately bypasses the alleged perpetrator's reporting line, so a report cannot be intercepted or quietly buried. Support through the process is extended to the complainant, the respondent and witnesses, since all three carry psychological risk during an investigation.
Does this apply to contractors and labour-hire, or only to employees?
All worker categories, including employees, contractors, labour-hire personnel and volunteers, because the WHS definition of a worker is broader than the employment relationship and the PCBU duty follows it. That matters most on mixed sites where a labour-hire worker may not know who their contact officer is. You receive a single editable Microsoft Word document, bought once, containing the psychosocial hazard register mapped to the hierarchy of controls, reporting and investigation procedures, a sign-on register and an escalation flow. Consultation with workers and health and safety representatives under sections 47 to 49 is yours to run and document.
Document details
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