In practice

Undesirable behaviour in the workplace occurs more often than employers sometimes think.

This includes bullying, discrimination, sexual harassment, aggression, violence, or structurally inappropriate conduct.

As an employer, you are already required to ensure a safe working environment.
From 1 July 2026, an additional concrete obligation will be introduced: employers with ten or more employees must have a written code of conduct against unwanted behaviour.

This means that general core values or informal arrangements will no longer be enough. Employees must be able to clearly identify which behaviour is not accepted, where they can go, and what happens if the rules are breached.

The legal point

The Dutch Working Conditions Act requires employers to implement a policy against psychosocial workload. Unwanted behaviour falls within that scope.

The new obligation makes this more concrete. Employers with ten or more employees must have a code of conduct that addresses, at a minimum, unwanted behaviour in the workplace, such as bullying, sexual harassment, discrimination, aggression, and violence.

A good code of conduct does not merely describe what is prohibited, but also:

• which behaviour is regarded as unacceptable within the organisation;
• where employees can go with questions, concerns, or reports;
• how reports are followed up;
• what support is available;
• and what measures may follow in the event of a breach.

Simply drafting a document is not enough. The code of conduct must also be actively brought to employees’ attention. Otherwise, the policy remains little more than paperwork.

What does this mean for you?

Employers would be wise to check in time whether their existing policies comply.

Does your organisation already have an employee handbook, complaints procedure, or confidential adviser? If so, it is important to assess whether these arrangements properly align with the new code of conduct.

A standard text will usually not be sufficient.

The code of conduct must fit the reality of your organisation. An office environment entails different risks from a manufacturing company, healthcare institution, educational institution, or organisation with extensive customer contact.

In practice, problems often arise because rules are formulated too generally. Terms such as “respectful behaviour” or “professional conduct” are useful, but they do not give employees enough guidance if it is unclear what they mean in concrete terms.

Legally sharp – Tips for employers

Ensure you have a written code of conduct against unwanted behaviour.

In practice, this means:

• Describe specifically which behaviour is not accepted within your organisation.
• In any event, include bullying, discrimination, sexual harassment, aggression, and violence.
• Make clear where employees can go with questions or reports.
• Set out how reports are handled and what support is available.
• Describe what measures may follow in the event of a breach of the code of conduct.
• Align the code of conduct with the employee handbook, complaints procedure, confidential adviser, and any arrangements with the works council or staff representation.
• Actively bring the code of conduct to employees’ attention, for example during onboarding, in internal communications, and through periodic discussion.

Questions for employers

• Does your organisation already have a written code of conduct?
• Is it clear which behaviour is unacceptable within your organisation?
• Do employees know where they can go with questions or reports?
• Does the code of conduct fit the day-to-day reality of the workplace?
• Is it clear how reports are followed up?
• Is the code of conduct actively discussed, or does it exist only on paper?

In conclusion

From 1 July 2026, employers with ten or more employees must have a code of conduct against unwanted behaviour.

Employers who review their policies now can avoid having to introduce a standard document under time pressure later on that does not properly reflect workplace reality.

Would you like to know whether your code of conduct, employee handbook, or reporting procedure is compliant?

Please feel free to contact us without obligation. We would be happy to think along with you about the right approach.