In another case involving work-related stress, this time in the context of employment policies, the CA ruled that an employer was not under a contractual duty to act sensitively toward an employee when conducting an investigation into allegations of harassment. In Deadman v Bristol City Council, Mr Deadman alleged that an equal opportunity policy stipulating that complaints would be handled sensitively was incorporated into his employment contract, and that the Council’s manner of conducting an investigation and informing him of a renewed investigation by leaving a letter on his desk breached his contract. He claimed to have suffered stress at work as a result. The CA upheld the Council’s appeal. It found that while the equal opportunity policy was incorporated into Mr Deadman’s contract there was no contractual term to handle the investigation sensitively and further it was not reasonably foreseeable that he would suffer psychiatric illness as a result. Sensibly, the CA were unwilling to conclude that the manner in which information was conveyed could give rise to a liability when the information by itself could not.