A recent EAT ruling makes clear that, while disciplinary sanction for manifesting a religious belief is unlawful, an employer can lawfully discipline where the belief is manifested in an improper manner. InWastenet v East London NHS Trust, a senior manager had sought to convert a junior member of staff, subjecting her to inappropriate pressure and unwanted conduct without regard to her own position of power over the recipient. In light of the relative status of the employees, and given that the manager had previously been warned about the need to maintain boundaries between professional and spiritual lives, the imposition of a first written warning was proportionate.

Ideally an employer's dignity at work policy will make clear where the boundaries of acceptable conduct lie.