An Employee Reports Harassment or Bullying: The Employer’s Step-by-Step Response

When an employee complains of harassment, sexual harassment or bullying by a colleague or manager, a Singapore employer should acknowledge the complaint promptly, protect the complainant without penalising them, appoint an impartial person to investigate, hear both sides, decide on the evidence, take proportionate action and keep confidential records. The Tripartite Advisory on Managing Workplace Harassment sets the current standard, and TAFEP will usually ask an employer to investigate independently if a complaint reaches it. From end-2027, the Workplace Fairness Act is expected to make grievance handling and investigation a legal duty for covered employers.

What counts as workplace harassment?

Workplace harassment covers threatening, abusive or insulting behaviour or communication, whether in person, by message or online, that causes harassment, alarm or distress. It includes sexual harassment, such as unwelcome touching, sexual comments or requests, and showing sexual images, and bullying, such as repeated humiliation, intimidation or deliberate exclusion. It can come from a manager, a peer, a subordinate, or a client or supplier the employee deals with.

Not every workplace conflict is harassment. A manager who sets targets, gives critical but fair feedback or starts a performance process is managing, not harassing. The line is crossed when the behaviour is abusive, degrading, targeted or out of proportion. An investigation exists precisely to decide which side of the line the facts fall on, so avoid labelling the complaint at the start.

What does the law expect of the employer now, and what changes in 2027?

In a written answer to Parliament in October 2026, MOM said TAFEP received 59 workplace harassment complaints in 2025, that it asks employers to carry out independent investigations under the advisory, and that once the Workplace Fairness Act is implemented MOM will be able to take enforcement action against employers who do not comply (MOM reply on workplace harassment complaints). MOM has indicated that firms with fewer than 25 employees will be exempt from the Act at the start, but the advisory applies to all employers. For the Act’s wider anti-discrimination rules, see our employer’s guide to the Workplace Fairness Act.

What should we do in the first 48 hours?

1. Acknowledge the complaint in writing. Thank the employee, explain the next steps and who will handle the matter, and confirm that raising a concern in good faith will not be held against them.
2. Check for urgent risk. If the complaint describes physical or sexual assault, threats of violence or stalking, tell the employee they may make a police report and do not discourage them. Where there is an immediate safety risk, act first and investigate after.
3. Put interim measures in place. Separate the two employees if needed, for example by changing reporting lines, seating, shifts or work location. The measures should not disadvantage the complainant. Moving the complainant to a less attractive role, against their wishes, can look like retaliation.
4. Consider suspending the respondent. If suspension is needed to protect people or evidence, remember that for employees covered by the Employment Act, suspension during an inquiry is limited to one week on at least half pay unless the Commissioner for Labour approves an extension. MOM explains the rules on its termination due to misconduct page.
5. Preserve evidence. Secure emails, chat logs, CCTV and access records before they are overwritten. Ask the complainant for screenshots and the names of witnesses.
6. Appoint the investigator. Choose someone with no reporting relationship to either party and no personal involvement. If the respondent is a senior manager, director or owner, use an external investigator or a board member who is clearly independent.

How do we run a fair investigation?

A fair process protects the complainant, the respondent and the company. It is also what TAFEP, a tribunal or a court will look at if the outcome is challenged.

1. Set terms of reference. Write down the allegations to be investigated, the investigator’s name, the expected timeline and who will receive the report.
2. Interview the complainant first. Record dates, words used, locations, witnesses and the effect on them. Let them bring a colleague for support if your policy allows.
3. Tell the respondent the specific allegations. Give enough detail for a real answer, and a reasonable opportunity to respond, including to name their own witnesses.
4. Interview witnesses separately. Ask open questions and record answers accurately. Ask each witness to keep the matter confidential.
5. Review documents. Messages and records written at the time are often more reliable than recollections months later.
6. Make findings on the balance of probabilities. Decide, for each allegation, whether it is more likely than not to have happened, and give reasons. A lack of witnesses does not mean a complaint must fail.
7. Write a short report. Set out the allegations, the evidence considered, the findings and any recommendations. The decision on disciplinary action should be made by management, not the investigator.
8. Tell both parties the outcome. Explain the conclusion and, at an appropriate level of detail, what the company will do.

Template: investigation outline

• Section 1, background: date and method of complaint, parties, roles and reporting lines, interim measures taken.
• Section 2, allegations: each allegation numbered separately, with dates.
• Section 3, process: investigator appointed, interviews held (dates and attendees), documents reviewed.
• Section 4, evidence: summary of each party’s and witness’s account, with key documents attached.
• Section 5, findings: substantiated, not substantiated or inconclusive for each allegation, with reasons.
• Section 6, recommendations: disciplinary referral, training, changes to reporting lines, policy updates, follow-up check-in dates.
• Section 7, confidentiality and storage: who holds the report and who may access it.

What action can we take after the findings?

Choose an outcome that matches the seriousness of what was found, the respondent’s record and any mitigating factors. Options include a written warning, mandatory training, a change of role or reporting line, loss of supervisory responsibilities, and, for serious misconduct, dismissal. For employees covered by the Employment Act, dismissal for misconduct without notice requires a due inquiry first; your investigation can serve that purpose if the respondent was told the allegations and given a fair chance to answer. Our guides on warnings, investigations and dismissal and on dismissing an employee for misconduct after due inquiry explain the disciplinary process in more detail.

If the complaint is not substantiated, that does not mean it was false. Unless there is clear evidence that it was made in bad faith, take no action against the complainant. Consider practical steps anyway, such as mediation or changed working arrangements, because the working relationship may still be damaged.

What are the risks if we handle it badly?

• Constructive dismissal claims. An employee who resigns because the employer ignored a serious complaint, or punished them for raising it, may argue they were forced out. Our article on constructive dismissal claims after a demotion or transfer explains how such claims arise.
• Wrongful dismissal claims by the respondent. Dismissing an alleged harasser without a fair inquiry can lead to a claim that the dismissal was wrongful.
• TAFEP and MOM scrutiny. TAFEP may ask the company to investigate and report back. After the Workplace Fairness Act takes effect, failure to handle grievances properly or retaliation against a reporter can lead to enforcement action against covered employers.
• Personal claims and police matters. The victim may seek a protection order or damages against the harasser under the Protection from Harassment Act, and sexual touching or threats may be criminal offences. Your company may be asked for documents or witnesses. Our article on POHA proceedings involving a company covers this.
• Staff turnover and reputation. Mishandled complaints are rarely kept quiet, and other employees watch how the first one is handled.

What records should we keep?

• The original complaint and your written acknowledgement
• Records of interim measures and the reasons for them
• Terms of reference and the investigator’s appointment
• Interview notes, signed or confirmed by each interviewee where practical
• Documents and screenshots reviewed
• The investigation report and the management decision on outcome
• Outcome letters to both parties and any appeal
• Follow-up check-ins with the complainant over the following months

Store these separately from general personnel files, limit access to those who need it, and handle the personal data in line with your data protection obligations.

Example: a complaint about a sales manager

Example: A junior executive at a 40-person distribution company tells HR that her sales manager has sent late-night messages commenting on her appearance and has criticised her loudly in front of clients after she stopped replying. HR acknowledges the complaint the same day, moves her reporting line temporarily to another manager without changing her pay or accounts, and preserves the messages. Because the HR manager reports to the sales manager’s close colleague, the company engages an external investigator. The sales manager is shown the messages and given three days to respond; he says the comments were jokes. Two colleagues confirm the public criticism. The investigator finds both allegations substantiated. Management issues a final written warning, removes the manager’s supervisory responsibilities, requires training and schedules check-ins with the executive at one, three and six months.

Frequently asked questions

The employee asked us to keep it confidential and not investigate. What should we do?

Respect the request as far as you can, but explain that the company may still need to act if there is a risk to others or a serious allegation. You can take protective steps, such as changing reporting lines, without a full investigation, and record the employee’s wishes and your reasons.

Can we investigate an anonymous complaint?

Yes, though it is harder. Look for objective evidence, such as messages, CCTV or patterns in exit interviews, and be careful not to try to identify the complainant in ways that could amount to retaliation.

What if the alleged harasser is a client or supplier?

Your duty to your employee does not end because the harasser is not on your payroll. Raise the matter with the other business, change who handles the account and, if needed, end the relationship.

What if the complaint is against a director or the owner?

Use an external investigator and have the findings considered by another director or the shareholders, not by the person complained about. Document every step, because independence will be the first thing questioned.

Do small companies need a written harassment policy?

The tripartite advisory encourages every employer to have one, and MOM’s FAQ on preventing and handling workplace harassment lists a prevention policy first. A short policy with two reporting channels and a clear process is enough for most SMEs.

Need help with a workplace harassment complaint?

If your company, or you as a director or shareholder, is dealing with a workplace harassment, sexual harassment or bullying complaint, contact the Raffles Corporate Services team at [email protected] or on WhatsApp at +65 8501 7133 or +65 9018 0072. We will help you understand the documents and deadlines. Where your matter needs a lawyer, we will refer you to a firm on our panel of Singapore law firms that regularly handles employment law. Raffles Corporate Services is a corporate services provider, not a law firm, and this article is general information, not legal advice.

The Raffles Corporate Services Editorial Team, Raffles Corporate Services