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How grey areas in the SU safeguarding policy and admin delays failed to protect students at Bristol University

In light of the SU's announcement that their Code of Conduct will undergo an external review, Amelia Jacob investigates the context of UBLHC's campaign to hold the SU accountable for their safeguarding responsibilities.

By Amelia Jacob, Co-Editor-in-Chief

At the University of Bristol, the SU is synonymous with the student experience. All students are automatically given SU membership upon registration, unless you choose to opt out, and the union supports over 350 student societies, including 60 sports clubs. 

It is an independent charity that works very closely with the University, which has some legal responsibilities to oversee the union.

In order to operate as a society, student groups must be approved by the union and complete a lengthy reaffiliation process, which includes signing the SU Code of Conduct. It is this Code of Conduct that lies at the centre of one society’s campaign to hold the SU accountable for their safeguarding responsibilities. 

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On 5 March 2024, UBLHC (University of Bristol Ladies Hockey Club) published an open letter online calling for the SU to update their Code of Conduct. They asked for explicit reference to the prohibition of sexual assault and rape; a concise framework for handling sexual assault for committee members and the SU; automatic suspension for society members under investigation for sexual assault and mandatory welfare training for all committee members to be added to the policy. 

Within 12 hours, the open letter received over 2000 signatures.

UBLHC argued in their open letter that the lack of explicit reference to sexual assault or rape in the Code of Conduct ‘raises questions about the code’s clarity and appropriateness.’

In a statement to Epigram, an SU spokesperson said the SU ‘recognise that there are things the Code of Conduct doesn’t currently have listed and we acknowledge that the Code should be more explicit about sexual violence and misconduct.'

They went on to advise that ‘the Code of Conduct was written in 2019 and was intended to sit alongside the University’s Code of Practice and disciplinary procedures, as well as the law.’

‘As part of the Student Agreement, students agree to follow the University’s rules and regulations for students, including the Acceptable Behaviour Policy, which is signed by all students.’

UBLHC’s open letter followed 12 complaints issued to the SU between 21 March 2023 and 5 March 2024, concerning two unrelated incidents of sexual assault. 

The first of these cases took place in the 2022/23 academic year, between an associate SU member and a student member of UBLHC. 

Associate members are paying members of the SU who are not registered students, whom sports society coaches can sign to play in weekend leagues at competitive levels. They cannot play BUCS (British Universities and Colleges Sport) but they are involved in all other aspects of the sports society.

When questioned by Epigram, an SU spokesperson stated, ‘individual student groups choose whether or not to accept Associate members when they set up their membership criteria,’ admitting they ‘do not background check any of our members, whether they are an associate member or UoB student'.

The SU advises associate members are covered by the SU Code of Conduct like any other member of the union. However, a non-student can’t be investigated through the University’s Acceptable Behaviour Policy, a grey safeguarding area the SU spokesperson told Epigram their external Code of Conduct review this year ‘will consider’. 

This grey area poses troubling questions: what does it mean to be covered by a safeguarding policy when a perpetrator can’t be held accountable for breaking it, and what does this say about the SU’s ability to protect its student members?

In 2022, following the assault, the victim reported the incident to the UBLHC committee, who in turn reported it to the SU. The club asked to arrange a meeting with the SU to discuss the incident, but when they arrived at the Richmond Building, the staff member who they were supposed to meet had not booked a room for the meeting.

According to UBLHC, this staff member asked if the club members were happy to discuss the incident in the corridor outside the SU offices, to which they said no.

In a conversation with Epigram, Esme Doherty, UBLHC’s EDI officer for 2022/23, noted: ‘I think that kind of set the tone for the whole way the SU handled it.’ 

The standard SU procedure when receiving a report of sexual violence is to signpost the student to the SRS (Student Resolution Service), to University Wellbeing Services and external support services and charities. 

The SRS has a team of male and female Sexual Violence Liaison Officers who have had specialist training to support and advise students one-to-one who have experienced any form of sexual violence. The service is available to all students, regardless of when or where the incident took place.  

According to the SU, ‘The University’s Student Resolution Service (SRS) has been specifically created for this purpose and we work in partnership with them. [...] We were involved in the creation of the SRS and we meet with them regularly.’

When the SU staff member eventually found an appropriate room to discuss UBLHC’s case, the club claims his only advice was to recommend the victim go to the police. The club were unhappy with this response, and contacted the SU Director of Community and Opportunity following the meeting to discuss the case further.

It took from 13 October to 24 November 2022 for the SU to decide to investigate the incident, for which they hired a third-party HR company to oversee called Intersol Global.

Esme says the experience with this company was ‘traumatic’ for the victim, who was told she would have to be interviewed alone, her interview would be conducted by a man, and that the alleged perpetrator of her assault would have access to the statement from her interview.

‘At the time, she was really struggling – obviously – and felt that she couldn't go through with the process. So she had her initial meeting with [the third-party HR company] and then withdrew, which was entirely fair enough.’

‘We went back to the SU and said, Is there anything else you can do? [...] and they said, no.’

Consequently, the club took matters into their own hands.

‘We made the decision to have a conversation with [the alleged perpetrator] and say, you're not welcome in the club anymore. We told the SU we were going to do this and they said we'd be wide open for the player to sue us. But we decided to do it anyway. [...] The SU gave us no support at all.’

Following these events, UBLHC asked for a full review of the SU complaints system and the SU Code of Conduct, specifically concerning the guidelines for associate members and sexual violence. 

In correspondence between the SU and UBLHC during this time, the SU admitted that ‘the complaint did take longer to investigate than we would have liked’ due to ‘gaps in our policy and procedures.’

They stated they had 'made the following recommendations which will be communicated and actioned internally to ensure we improve the process for any future complaints, including timescales for these actions to be taken.’

These actions included ‘[undertaking] a review of Associate Membership – within the 23/24 academic year’ and ‘[undertaking] a review of the Student Code of Conduct, with a particular view to ensure that this is applicable for Associate Members – in time for term 1 [of 2023/24].’

However, no such review took place. 

When questioned on their failure to review the Code of Conduct in this time frame, the SU said: 

‘Unfortunately, there was limited capacity within the team to complete this work last academic year, which is why it was due to take place this year.’

‘We absolutely recognise that we should have found the resources to complete the work earlier, or commissioned an external agency to support at an earlier stage and we are sorry we didn’t do this.’

As part of the planned review last year, a focus group was organised to discuss the Code of Conduct with the Club Captains of various sports societies at Bristol. UBLHC claimed this focus group was cancelled due to poor uptake, which the SU later confirmed to Epigram, again blaming ‘capacity’ for their failure to rearrange the focus group.

In conversation with Epigram, Sophie Rowson, the Club Captain of UBLHC during 2022/23, noted:

‘Fundamentally, I think this year-long wait [for the review] has resulted in more people not being given the help and support they needed this year. [...] it’s just so disappointing and frustrating to have not seen these promised changes be implemented.’

‘There was no urgency behind getting the Code of Conduct reviewed,’ Liv Merry, the current Club Captain of UBLHC, agreed.

‘It's a fact if this was in place before this academic year, like they said it was going to be, we wouldn't be in this situation right now.’

The ‘situation’ Liv referred to follows the second incident of sexual assault at UBLHC, which took place between a student member of UBMHC (University of Bristol Men’s Hockey Club) and Louise*, a student member of UBLHC. 

This ongoing case is the subject of the vast majority of UBLHC’s complaints to the SU since 16 February 2024. Between February and March 2024, UBLHC submitted 11 complaints to the SU from various committee members affected by the incident and the SU’s ensuing response. 

Louise was limited in what she was able to tell Epigram due to the ongoing investigation, but advised that an allegation of sexual misconduct was raised to the SU on 8 December 2023 by UBMHC with the input of UBLHC. She made a separate report herself to the university around the same time.

‘The SU suggested that they weren't going to suspend him,’ Louise said. ‘They were just going to ensure that if we had back to back training or back to back games, that he would have to leave fifteen minutes early or leave fifteen minutes late, so there’d be no crossover. 

‘But practically, what that means is I'd have to text the men's Club Captain, what training and what games I'd be playing during the week. And then [he] would tell the boy when I'd be playing or training to make sure that he leaves in time, if that makes sense. 

‘It clearly isn't feasible. This is also something the SU suggested [UBLHC] did last year, and [the club] fed it back last year that it was inappropriate and not going to work.’

Louise noted that this administrative process put undue stress on the men’s club to coordinate timings, as well as pointing out it provided her alleged perpetrator with her location at various times during the week. 

On 19 February 2024, after an off-policy meeting, the SU decided to change the UBMHC member’s restrictions to ‘all aspects of the men's hockey club – with the exception of Thursday training, when no women's teams play.’

This change was not forwarded to Louise, and she says there was no mention in this correspondence of what to do if the alleged perpetrator broke the terms of his sanctions.

The day before, on 18 February, Louise had submitted her first complaint to the SU, which was updated and resubmitted on 23 February, and again on 5 March.

She received the email below in response to her original complaint:

Despite the email’s promise, Louise said she did not receive a follow up of who was investigating her complaint. After updating and re-submitting her complaint, the SU eventually provided an update on 1 March.

By this time, the SU had engaged Atkinson HR to assist with the complaint process and to carry out an independent review of the Code of Conduct and complaints procedures. 

An SU spokesperson told Epigram that Atkinson HR works with ‘a wide range of students’ unions and other Voluntary Sector organisations’. They also advised the company has ‘strong experience working on conduct and complaints frameworks and processes.’ 

In email correspondence with Louise, The SU noted she had ‘raised a number of specific questions and requests for clarification’ in her complaint, and recommended UBLHC have a meeting with the SU Director of Impact and Influence and the SU Head of Student Opportunities.

The meeting took place on 14 March, from 9:30am until around 2:30pm. The group broke every hour, including an occasion where one of the SU staff members started to cry.

According to UBLHC, one of the SU staff members in the meeting admitted to never having read the full Code of Conduct. Allegedly, the SU stated they were prohibited by the University to have training on handling sexual violence. But when UBLHC met with Vice-Chancellor Evelyn Welch the next day, on 15 March, the V-C denied this was the case.

Epigram asked the SU to provide some clarity on these disparate claims, to which a spokesperson responded:

‘We work in partnership with and seek not to duplicate the offer of the University’s Sexual Violence Liaison Team and Student Resolution Service. 

‘This means that previously only limited staff members have received training on responding to student experience and disclosures of sexual violence. [...] However, we are allowed to train our staff about anything that we determine necessary, including sexual violence, and the Review will look at how we develop that training.'

They apologised to ‘any students who have felt let down by this lack of staff training previously.’

Though the SU wants to avoid duplicating University services, it appears the grey areas in governance and responsibility between the union and the University failed to meet the pastoral needs of their students. 

UBLHC told Epigram they felt more positive following the meeting with the V-C, who they said told them that ‘we’ve heard you, and the SU will hear that we have heard you’. They noted the V-C seemed concerned they had not yet heard from Ben Pilling, the Chief Executive of Bristol SU. Three days after the club’s meeting with the V-C, Pilling contacted the club for the first time in the campaign.

As the weeks passed during their campaign, UBLHC was regularly updating their Instagram account with the outcome of their meetings with the SU. Their open letter, too, was gaining traction. On 20 March, the club protested at Coombe Dingle on Derby Day by walking off the pitch. 

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The following day, the SU issued a public apology on their website, stating:

‘We are incredibly sorry and saddened that this has led to a loss of trust and that students have felt unsupported around sexual violence.’

One question remains: In the light of UBLHC’s campaign, year-long administrative delays, and the SU’s admission that their safeguarding policy has gaps, will the SU refer themselves to the charity commission?

‘We haven’t and don’t currently plan to do so,’ the SU spokesperson said. ‘But we will review that if it becomes necessary to do so, as we would in any situation.’

By 2 April, UBLHC received 3237 signatures on their open letter, with support from over 200 student societies at Bristol. Liv Merry called this support ‘incredible’.

‘The amount of support we've had is amazing, it's really nice to see. I think one of our main things was, as a women's club, when we were launching it, all of us women have come together [...]  it's quite empowering. 

‘We're a group of women who just care about the situation and want to make that change. And it's quite like a – nice is the wrong word – but it's like a sense of empowerment and being together.’

It’s a small victory for the club among a series of inadequate and stressful interactions with the union. The tears of staff members during meetings with the club; the failure to book a private room to discuss a sexual assault complaint; the SU’s lack of capacity to be able to action administrative reviews – these are all incidents that threaten to dismantle the trust Bristol students have in their union to effectively deal with their complaints.

Today, 16 April, the SU announced their external Code of Conduct review will begin immediately and will be completed by July 2024.

In the announcement, the SU said:

‘UBLHC have correctly challenged us on our outdated Code of Conduct, and the systemic issue of sexual violence, and we thank them for doing so.’

‘We recognise the pervasive culture of sexual violence on campus and are committed to addressing this. [...] We’re sorry that we have let you down – we are taking this very seriously.’

The statement outlines the details of the external review, including a timescale and how to get involved in focus groups to provide feedback on the current Code.

The union admitted the Code of Conduct has been out of date ‘for some time’, and say they ‘unreservedly apologise for this.’

Ben Pilling, CEO of Bristol SU, stated he is ‘sincerely appreciative of UBLHC for raising their concerns, for challenging us and for championing this issue.'

‘They are an incredible student committee and I will make sure that we
deliver on our promises to them.’

A University of Bristol spokesperson said: ‘We want all our students to feel safe and supported while at university and we are absolutely clear that sexual violence is not acceptable.

‘For students who need support or impartial advice, we have trained wellbeing advisors, a Student Resolution Service and female and male Sexual Violence Liaison Officers who can help.

‘With Bristol SU, we frequently raise awareness about consent and the impact of sexual violence through campus events, social media and other communications.

‘Nobody should have to suffer sexual violence or harassment, but any student who feels they need support can find clear information on reporting abuse and getting help on our sexual misconduct web page. We would encourage anyone in need to contact our teams.’

*Names have been changed for anonymity.

Editor's note: An earlier version of this article (16/04) stated associate members are hired by SU coaches. This was incorrect and has been removed (17/04). Bristol SU does not employee or hire coaching staff for any groups. Coaching is sourced and paid for by clubs or done in partnership with SEH.

Image courtesy of Amelia Jacob and Jeffrey F. Lin (via Unsplash)

To seek support at University, students are encourage to access the Student Wellbeing Service, which is available both in and outside of term-time:

You can also use the following resources for support relating to sexual violence or harassment: