Work Code of Conduct - Help!

[FanFckingTastic]

I work for a decent sized US-led company. As part of our annual training we have to complete a code of conduct and confirm that we are compliant. This year there is a section on gender identity that makes me feel uncomfortable.

Firstly, there is a short video describing what gender identity is, this, of course, is presented in a way that implies that everyone believes in a gender identity in the first place...

There is an information section around revealing someone's gender identity without their consent "It's important to remember that if Barbara is trans, saying that she 'used to be a man' is not accurate. Transwomen are women, and they've never not been a woman. Their gender identity just doesn't align with the sex that they were assigned at birth"

Finally there is a topic question that must be answered around toilets. "Rebecca is transgender and today is her first day in the office since her team were told of her transition. When she goes to the ladies restroom her female colleagues see her and say that they don't want to share the same toilet as a man and walk out. Is this an example of harassment or discrimination based on sexual orientation or gender identity?"

I'd like to keep my job... but I also feel that I should say something here. Any tips for addressing? Has anyone else seen this and how have you handled it?

Are you employed in the UK and subject to UK law?

If you’re working in the UK then they are subject to UK law, and that clearly breaches it. So yes, go and say something.

This OP.
Companies in the UK are required to follow UK law - employment etc. Obviously your first responsibility is to stay safe work wise - trans activists are notorious for bullying anyone for daring to point out the law or anything about competing rights.
I'd screenshot the offending sections and if you're concerned about your safety, send them to HR (anonymously if necessary) pointing out the recent Supreme Court judgment. This is useful advice and although aimed at retailers, so much of it applies to most workplaces:

www.theretailbulletin.com/retail-solutions/legal-do-retailers-have-to-provide-single-sex-toilets-and-changing-rooms-for-their-customers-and-staff-19-05-2025/
.

Confidential letter to HR.

Clearly I got AI to help me write this but it's very useful to get it to stay on safeguarding and law and not mention trans ever.

CONFIDENTIAL
To: [HR Department or named HR contact]
From: [Your Name]
Subject: Concerns Regarding Mandatory Training Materials and UK Legal Compliance
Date: [Insert Date]

Dear [HR Manager’s Name],

I’m writing in confidence to raise a concern regarding this year’s mandatory Code of Conduct training module, particularly the section addressing gender identity. While I appreciate the company’s commitment to respectful workplace conduct, I believe parts of this training may conflict with current UK law—particularly around freedom of belief, compelled speech, and safeguarding obligations.

Specifically:

Compelled Speech and Freedom of Belief
The module includes statements such as “transwomen are women and have never not been women,” presented as factual rather than belief-based. In Forstater v CGD Europe (2021), the Employment Appeal Tribunal confirmed that gender-critical beliefs—such as believing sex is immutable—are protected under the Equality Act 2010. Forcing employees to affirm or endorse contrary views may constitute compelled speech and interfere with legally protected belief.
Single-Sex Spaces and Safeguarding
The training scenario involving a female colleague objecting to a male-bodied person using the ladies’ toilet is labelled as discriminatory. However, under Schedule 3 of the Equality Act 2010, it is lawful to provide single-sex spaces where justified—for reasons such as privacy, dignity, or safeguarding. The UK Supreme Court reaffirmed the legal relevance of biological sex in R (on the application of Fair Play For Women) v Registrar General (2025), making clear that sex-based distinctions remain lawful and necessary in certain contexts.
UK Jurisdiction and Compliance
While I understand the company operates globally, UK-based employees must be treated in accordance with UK law. The Equality and Human Rights Commission (EHRC), the UK’s statutory equality body, recently issued guidance confirming that social or organisational policies should not compel belief or silence lawful, respectful dissent on matters of sex and gender identity (EHRC interim guidance on single-sex services, April 2024).

I share this feedback respectfully and with the intention of ensuring that future training reflects the UK legal framework. I value working at [Company Name] and believe we can uphold dignity and inclusion without compromising employees’ protected rights or misrepresenting the law.

I’d welcome a conversation about how to bring the UK training materials into legal alignment, and I’d be happy to provide references or suggestions to support that.

Thank you for your time, and for treating this concern in confidence.

Yours sincerely,
[Your Name]
[Your Job Title]
[UK Office / Location]

When she goes to the ladies restroom her female colleagues see her and say that they don't want to share the same toilet as a man and walk out. Is this an example of harassment or discrimination based on sexual orientation or gender identity?

Surely an example of women exercising their legal right!

Sorry OP but I think you are getting appalling advice here

I have very little sympathy for this - and dislike the trans activist bullying PPs have raised, but I think you need to just tick the box and keep your job - to raise this issue is implied criticism of the company, are you valued enough at work to be the one raising this?

Assuming UK law applies I might ask whether the training is consistent with UK law and has it been updated as a result of the supreme Court ruling.. It mentions discrimination on the basis of gender identity which is not a PC in the Equality Act (the PC is gender reassignment) and the use of workplace toilets is based on sex.

I think I'd do this. Keep the tone light and 'I was wondering… '

This attitude is what got us into this mess.

Thanks all for the suggestions. To answer one of the initial questions, yes I am employed in the UK.

Maybe in the US they can just fire you out of hand, but they can’t do that here. They certainly cannot fire her for gender critical beliefs (already been confined in law).

In the UK, you absolutely can and should speak to your employer when they break UK law. This company are breaking the law in the UK.

I would tweak this just to really hit home that if they call their toilets “‘male” and “female” then those toilets must only be accessible by biological males or biological females. They cannot call them single sex and allow trans people to go where they want. They then have to call them mixed sex and follow the law on how mixed sex toilets are laid out. It’s not a choice.

Either single sex, so trans people must use the toilet matching their sex at birth or mixed sex in self contained floor to ceiling rooms with a toilet and sink.

I wouldn't put my name to a letter but I might send in an anonymous letter

Oh definitely, needs tweaking, main thrust is to stick to equality law, not mention trans anythign, keep it legal etc etc

I would only mention the trans thing in reference to the question they have asked her to answer; about a trans woman using the female only toilets, as they’ve worded it as if that person would have the legal right to use those toilets when it is very explicitly the opposite in UK law.

This is the same scenario as Maya Forstater. Woking in the UK for a US based company and they just could not get their head around the fact that UK employment and equality law applies to all UK based employees. Got them in a right pickle.

Don’t know if this matters but I work for a US company but I am based in UK. It is repeatedly made clear that while we are representing the company we are subject to UK and US laws. Not sure what happens when the two jurisdictions contradict each other though as it’s never come up.

Their gender identity just doesn't align with the sex that they were assigned at birth"

"Please could you provide a list of each gender identity that Your Company plc believes aligns with the female sex, and which align with the male sex?"

As others have said if you’re in the UK then this training is not compliant with the equality act.

if you don’t feel able to raise it in person, there should be an anonymous whistleblower line

Do you have a whistleblowing or "speak up" facility? This is what they are for (and where I work, your submission would be anonymous).

Is there an HR department or do you have line manager you could approach informally.

If so could you make out that you have concerns because as far as you know as the office is in the UK UK laws apply.

And you know from all the media coverage that for instance guidance has been given re toilets. If necessary give them a link to EHRC interim guidelines.

And of course you are only raising it because you really like working for them, or some such soft soaping, and you wouldn't want them to be breaking the law.

So as a starting point and if you want to avoid confrontation.

But if as PP have said there is an annonymous method, go with that.

And if they dont believe you (FWR) google AI confirms it!

Yes, US companies operating in the UK must adhere to the UK's Equality Act 2010, including any Supreme Court rulings interpreting it. This includes the recent Supreme Court ruling that defines "sex" in the Equality Act 2010 as biological sex

Clearly I got AI to help me write this but it's very useful to get it to stay on safeguarding and law and not mention trans ever.

It's people like you that will get AI banned.

@FanFckingTastic what you need to do is be business focused. For example pointing out the risk to reputation and financial cost.

Point out US firm may not be aware of the legal position in the UK and you just want them to manage risk to the business if managers act as per the code of conduct. These are examples of costs and reputational damage

I don’t have time now, sorry, to do this properly but quickly

• CDC vs Forstater link to judgement highlight damning phrase and awarded £
• phoenix vs Open University link to judgement plus quote 18 academics lacked rigour in their evidence plus ££ award
• allison Bailey vs GCC - judgement, finding and £
• Eleanor Frances vs DCMS and DSIT - settlement cost £116k
• SC judgement - cost to Scottish gmt as ordered to pay FWS costs.

I think it’s 80% of ETs relating to GC employees win, much higher win rate than any other area of discrimination.

If they want to do business in the UK they need to comply with UK law. Which means they need a different code of conduct for the UK without this bullshit in it.