INTRODUCTION
The structural transformations in working life, increasing competition, and managerial pressures have made the phenomenon of mobbing—defined as psychological harassment in the workplace—more visible. Mobbing (psychological harassment), in the context of labor law, refers to a worker being subjected to systematic, intentional, and repetitive negative behaviors in the workplace, which leads to psychological, professional, and social exhaustion. Mobbing results in decreased productivity and workforce loss.[i] [ii]Although the concept of “mobbing” is not explicitly included in Turkish labor law, it is evaluated within the scope of the employer’s duty to protect the employee under the decisions of the Court of Cassation, the Constitution, the Turkish Code of Obligations, and the Labor Law. Through various legal remedies, compensation and other protective mechanisms may be applied. In this paper, the elements, types, and examples of mobbing, its place in the Turkish legal system, problems of proof, the employer’s preventive responsibility, and the legal remedies available to the employee will be systematically addressed.
INTERNATIONAL DEFINITIONS OF MOBBING
Although the ILO (International Labour Organization) does not directly use the term “mobbing,” in its 2019 Violence and Harassment Convention No. 190 it defines violence and harassment in the workplace as follows: “Violence and harassment in working life means a range of unacceptable behaviors and practices that cause, or are likely to cause, physical, psychological, sexual or economic harm to workers.”[iii]
[iv]The WHO (World Health Organization), on the other hand, defines mobbing as “the systematic and repeated humiliation, exclusion, belittlement, and discrediting of an employee.”
[v][vi]Swedish psychologist Prof. Dr. Heinz Leymann was the first scholar to introduce the concept of mobbing into academic literature. According to him, mobbing is “a psychological assault in which one or more persons engage in long-term, systematic, hostile, and degrading behavior against an employee with the aim of excluding, harming, or forcing the employee to resign from the workplace.”[vii]
ELEMENTS OF MOBBING
Mobbing must occur within the boundaries of the workplace. It can be applied by superiors to subordinates, by subordinates to their superiors, or between colleagues of the same level. It must be carried out systematically. It should be repeated frequently and continuously. It must be intentional. The purpose should be to intimidate, neutralize, or exclude the employee from work. It must cause harm to the victim’s personality, professional status, or health. Negative attitudes and behaviors toward the person can be either hidden or overt.[viii] [ix] [x] [xi]
Mobbing is a concept frequently encountered in working life but often confused with other behaviors. Not every negative behavior, conflict, or criticism from a manager can be considered mobbing. The exercise of managerial authority (employer’s rights), workplace stress and pressure, personal conflicts and disputes, disciplinary procedures, compulsory task or position changes, criticism, and feedback are mostly administrative practices, dynamics of work relationships, or due to personal differences and should not be confused with mobbing.
TYPES OF MOBBING
Vertical mobbing occurs when subordinates apply psychological harassment to their superiors. In this way, the subordinate, often together with several others, alters the power balance against the superior employee and carries out the mobbing action.
Downward mobbing arises when a superior initiates mobbing actions against a subordinate. The asymmetrical power relationship between the victim and the perpetrator makes it difficult for the victim to protect themselves by communicating with higher-ups or reporting, because this could result in the mobbed employee being dismissed.
Horizontal mobbing occurs among employees at the same hierarchical level. There can be several reasons for this. Generally, the aggressor evaluates the victim not based on rank within the hierarchy but based on personality, work, performance, or other factors, and the mobbing emerges accordingly.[xii] [xiii]
EXAMPLES OF MOBBING
When we talk about psychological harassment, we refer to a very broad spectrum. This type of violence can appear as a constantly loud voice from someone else or, at times, escalate to physical aggression. Examples include shouting at or swearing at a colleague, interrupting someone while they are speaking, continuously attacking a coworker’s personal or professional performance with unjustified criticism, spreading malicious rumors, engaging in verbally or physically threatening behavior, displaying sexually threatening or intimidating actions, deliberately withholding information to negatively impact a coworker’s performance, assigning excessive or irrelevant tasks, isolating and excluding the individual, blocking employees’ access to opportunities, insulting someone when alone or in front of others, giving derogatory nicknames, humiliating, or criticizing them in front of others. These behaviors are not limited to these actions but serve as examples of mobbing situations. [xiv]
PLACE IN TURKISH LAW
Although the concept of mobbing is not directly included in the Turkish legal system, regulations regarding psychological harassment in the workplace exist under the Turkish Code of Obligations No. 6098 and the Turkish Human Rights and Equality Institution Law No. 6701.
The concept of psychological harassment was introduced into Turkish legislation for the first time with the Turkish Code of Obligations No. 6098. It is regulated under Article 417, titled “Protection of the Employee’s Personality,” which governs the employer’s duty to protect the employee. According to the article, the employer is obliged to protect the employee’s personality in the employment relationship, to show respect, and to ensure an order in accordance with the principles of honesty at the workplace. Within this scope, the employer must take necessary measures to prevent employees from being exposed to psychological and sexual harassment, and also to prevent those who have been subjected to such harassment from suffering further harm. Compensation for damages arising from death, bodily injury, or violation of personality rights due to the employer’s conduct contrary to the law or contract is subject to the provisions on liability arising from breach of contract. [xv]
Some psychological harassment behaviors can constitute criminal acts under the Turkish Penal Code No. 5237, and therefore may be subject to criminal sanctions. Examples of offenses related to psychological harassment include sexual harassment (Art. 105), threat (Art. 106), blackmail (Art. 107), violation of freedom of work and employment (Art. 117), discrimination (Art. 122), insult (Art. 125), disturbing the peace of individuals (Art. 123), obstruction of communication (Art. 124), violation of confidentiality of communication (Art. 132), listening to and recording private conversations (Art. 133), invasion of privacy (Art. 134), and recording of personal data (Art. 135). [xvi]
While the Labor Law No. 4857 does not directly regulate psychological harassment in workplaces, it contains certain provisions that indirectly sanction these behaviors. The legal consequences of psychological harassment vary depending on the position of the person carrying it out. If the employer engages in psychological harassment, the employee may, generally and depending on each case, claim discrimination compensation due to violation of the duty to act equally (Art. 5), or terminate the employment contract for just cause if the conditions are met (Art. 24/II). If psychological harassment is committed by another employee, the employee can report it to the employer using internal communication and reporting mechanisms and request necessary measures. If no action is taken and conditions are met, the employee may terminate the employment contract for just cause (Art. 24/II). Similarly, the employer may terminate the employment contract of an employee who engages in psychological harassment, if the conditions for psychological harassment are fulfilled. [xvii]
Under the Turkish Human Rights and Equality Institution Law No. 6701, the concepts of “Workplace Bullying” and “Harassment” are defined and evaluated within the scope of discrimination. Discrimination based on gender, race, color, language, religion, belief, sect, philosophical and political opinion, ethnic origin, wealth, birth, marital status, health, disability, and age is prohibited (Art. 3). Workplace bullying is considered a type of discrimination (Art. 4). Individuals or legal entities claiming to have suffered harm from violation of the prohibition of discrimination in working life can apply to the Human Rights and Equality Institution free of charge (Art. 17/I). Applications regarding discrimination claims within the scope of Labor Law Article 5 can be made after following the complaint procedures set out in the Labor Law, if no sanction decision is taken (Art. 17/V). Before applying to the Institution, the person must request the cessation of bullying (discrimination) from the relevant party. If this request is rejected or no response is given within 30 days, an application can be made to the Institution. However, in cases where irreparable or impossible-to-compensate damages are possible, the Institution may accept applications without this requirement (Art. 17/II). The Institution finalizes applications within a maximum of 3 months. This period can be extended once for up to 3 additional months (Art. 18/I). After hearing the parties’ opinions, the Institution may invite them to reconciliation either ex officio or upon request, depending on the nature of the review (Art. 18/II, III). In applications to the Institution, if the applicant presents strong evidence and circumstantial facts regarding the truth of their claim, the other party must prove that they have not violated the prohibition of discrimination and the principle of equal treatment (Art. 21). In case of violation of the prohibition of discrimination, administrative fines ranging from 1,000 to 15,000 Turkish Lira may be imposed on responsible public or professional organizations, individuals, or private legal entities. The Board may convert the administrative fine into a warning once (Art. 25/I, IV). [xviii]
Presidential Circular No. 2025/3 introduced comprehensive regulations aimed at preventing psychological harassment behaviors such as deliberate, systematic humiliation, belittlement, exclusion, and damage to personality and dignity in workplaces. The main objectives include not only resolving individual problems but also protecting work efficiency, workplace peace, and employee motivation. The Psychological Harassment Combat Board was re-established as an updated version of the board established under Circular No. 2011/2. The board includes TİHEK, Ministry of Labor, Ministry of Justice, academics, and social partners. Furthermore, psychologists on the ALO 170 line are assigned to provide support, information, and counseling to mobbing victims. [xix] [xx]
EXAMPLES OF MOBBING BEHAVIORS IN SUPREME COURT DECISIONS
According to the decision of the Supreme Court 22nd Civil Chamber, E. 2013/693, K. 2013/30811, dated 27.12.2013, mobbing included: “While accepting a lower-level position to avoid problems related to themselves and performing their duties, being subjected to verbal attacks and insults at the workplace, such as supervisors shouting from a distance, giving instructions to work while ignoring the employee’s phone conversations or speech, and shouting phrases like ‘you cannot do this job.’” [xxi]
According to Supreme Court 9th Civil Chamber, E. 2009/30916; K. 2012/6093; dated 28.2.2012, “The assignment of a 56-year-old married female plaintiff, who worked uninterrupted for 14 years as a lawyer at the Istanbul branch of the defendant bank, to short-term positions in Adana and other provinces for 9 months, with 30 forced relocations, constituted proof of mobbing.” [xxii]
According to Supreme Court 9th Civil Chamber, E. 2010/1911; K. 2012/11638; dated 5.4.2012, “Considering the plaintiff’s work, education, and career, it was understood that she was forced to work under adverse conditions in a place with no door, only a desk, an unhygienic toilet, and close to a dog kennel. Being forced to work in this place clearly constitutes mobbing, and the fear of losing her job does not imply that accepting to work for a certain period legitimizes this continuous application.” These decisions demonstrate precedent cases illustrating how mobbing occurs in the workplace. [xxiii]
EVIDENCE IN MOBBING CASES
In mobbing cases, if the mobbing occurs between the employer and the employee, and the perpetrator is the employer, the burden of proof largely lies with the employee. Written documents (e-mails, messages, written warnings), witness statements, and psychological reports are considered important evidence. If there are written correspondences, and these are dated and preserved after each incident of harassment, they can systematically serve as proof of mobbing.
However, according to recent case law of the Supreme Court (Yargıtay), in situations where the employee alleges mobbing, the burden of proof shifts to the employer to demonstrate that mobbing did not occur. Therefore, the evidence presented by the employee regarding mobbing must be refuted by the employer.
In proving mobbing, definitive evidence is not required; presenting facts that raise suspicion about the occurrence of mobbing—such as witness testimonies, medical reports, and camera recordings—is sufficient. [xxiv] [xxv] [xxvi] [xxvii]
SUPREME COURT DECISIONS REGARDING THE PROOF OF MOBBING
According to the decision of the Supreme Court, 22nd Civil Chamber, E. 2013/693, K. 2013/30811, dated 27.12.2013, it is not necessary for personality rights to be “severely violated” for the existence of mobbing to be acknowledged; any unlawful infringement of personality rights is sufficient. The Court also emphasized that in mobbing allegations, “conclusive evidence beyond doubt” is not required. It is sufficient for the employee to present facts that raise suspicion of being subjected to mobbing, while the burden of proving that mobbing did not occur falls on the employer. In earlier years, the Supreme Court required “strong indications” for mobbing, but with this decision it accepted that, given the difficulty of proving mobbing in modern working life, the existence of evidence that creates reasonable suspicion is adequate for establishing mobbing. Victims should record incidents containing elements of mobbing in a consistent, sincere manner, specifying dates, and ensuring coherence among the allegations. This increases the likelihood that the court will find the employee’s statements about mobbing credible. [xxviii]
According to the decision of the Supreme Court, 22nd Civil Chamber, E. 2014/2157, K. 2014/3434, dated 21.02.2014, the Court ruled that in civil proceedings regarding mobbing, and especially in allegations based on mobbing, absolute proof is not required. The demand for evidence “beyond reasonable doubt” belongs to criminal proceedings. In civil and labor law proceedings, proof sufficient to establish judicial conviction is enough. The Court further stated that if there is any doubt about the validity or strength of the evidence, the principle of interpretation in favor of the employee should apply. In other words, the Supreme Court emphasized that: (i) absolute, conclusive evidence is not required to prove mobbing, (ii) it is sufficient for the plaintiff employee to present facts raising suspicion of being subjected to mobbing in the workplace, (iii) the burden of proving that mobbing did not occur falls on the defendant, and (iv) witness statements, medical reports, and expert reports should be taken into consideration. [xxix]
EMPLOYER’S PREVENTIVE RESPONSIBILITY
Within the framework of the employer’s duty of protection in terms of mobbing, the employer must prevent other employees or managers from engaging in mobbing against workers and safeguard the rights of employees. Employees who are victims of mobbing may apply to their employer and request protection.
The employer’s obligation to protect both the physical and psychological health of employees is explicitly regulated under the Labor Law and the Turkish Code of Obligations (Art. 417 of the TCO, Art. 77 of the Labor Law).
Supreme Court (Yargıtay) decisions have also reinforced the employer’s responsibility in preventing mobbing. Even if the employer does not personally engage in mobbing, their passive attitude or failure to take preventive measures may result in liability for compensation.
EMPLOYEE RIGHTS AND LEGAL REMEDIES AGAINST MOBBING
Under Article 24 of the Labor Law, an employee subjected to mobbing may immediately terminate their employment contract for just cause on the grounds of “circumstances contrary to morality and good faith principles.” Since mobbing is systematic and intentional, it falls within this scope. In such a case, the employee is entitled to severance pay.
Additionally, the employee may claim non-pecuniary damages under Article 58 of the Turkish Code of Obligations for the moral harm suffered due to mobbing. If there are material damages (such as medical expenses, loss of income, etc.), pecuniary compensation can also be claimed. A lawsuit for compensation can be filed against both the employer and the individuals directly committing mobbing. According to the Labor Courts Law No. 7036, in disputes between employer and employee, mediation is mandatory before filing a lawsuit. Therefore, the mediation process must be completed before compensation and termination lawsuits can be initiated. If mediation fails, the employee can file a lawsuit before the Labor Court. Such cases generally involve determination of mobbing, claims for compensation, and employment contract-related demands (such as severance pay or validity of termination). Courts examine psychological reports, witnesses, and behavioral patterns before reaching a decision. [xxx] [xxxi] [xxxii] [xxxiii]
The Violence and Harassment Convention, 2019 (ILO Convention No. 190), explicitly defined psychological harassment, violence, and bullying in the workplace at the international level for the first time. It provides detailed preventive and remedial policies directed at employers, trade unions, and states. The systematic nature of mobbing is indirectly addressed in these texts, emphasizing the protection of employees within the framework of employer obligations, employee rights, and workplace behavioral norms. Turkey contributed to the preparation of this convention but has not yet ratified it into domestic law. [xxxiv]
The report by the Ministry of Family and Social Policies defined psychological harassment and systematically examined humiliating, exclusionary, and personality-damaging behaviors faced by employees. It discussed mobbing forms such as verbal attacks, social exclusion, task overloading, and transfer of responsibilities. The report highlighted that these behavioral patterns negatively affect adaptation to work, job satisfaction, and the overall working environment. It also proposed effective solutions such as institutional measures, training programs, and psychological support, and included recommendations for the effective implementation of provisions under the Labor Law and the Turkish Code of Obligations. The report presented case studies, prevalence rates, and demographic analysis of mobbing incidents across different sectors (public and private), emphasizing sector-specific variations. These findings were supported by practices carried out in cooperation with the Ministry of Labor and Social Security. Complaints of mobbing are handled through the ALO 170 hotline, where victims also receive support from psychologists. Applications submitted via CİMER (Presidency’s Communication Center) and the Labor Inspection Board are examined and resolved accordingly. [xxxv] [xxxvi]
COMPENSATION FOR DISCRIMINATION IN LABOR LAW
Discrimination compensation refers to the non-pecuniary and/or pecuniary damages that an individual may claim to cover the harm suffered as a result of being subjected to unequal treatment, in violation of the principle of equality, particularly within the scope of an employment relationship. This type of compensation functions as a remedy for infringements of an individual’s fundamental rights and freedoms. Under Article 5 of the Labor Law No. 4857, if an employer acts contrary to their duty of equal treatment, the employee may be entitled to discrimination compensation of up to four months’ wages. [xxxvii] [xxxviii]
According to Article 10 of the Constitution of the Republic of Turkey, everyone is equal before the law regardless of language, race, sex, political opinion, philosophical belief, religion, sect, or similar reasons. This article establishes the constitutional basis for the prohibition of discrimination.[xxxix] The prohibition is guaranteed not only by national law but also by international conventions to which Turkey is a party. Article 14 of the European Convention on Human Rights (ECHR) stipulates that no one shall be discriminated against on grounds such as sex, race, color, language, religion, political or other opinions, national or social origin in the enjoyment of the rights and freedoms set forth in the Convention. [xl]ILO’s anti-discrimination conventions particularly safeguard equality in working life. The Discrimination (Employment and Occupation) Convention No. 111 prohibits discrimination on the basis of race, color, sex, religion, political opinion, or national origin.[xli] The International Covenant on Economic, Social and Cultural Rights (ICESCR) explicitly prohibits discrimination and requires member states to uphold the principle of equality.[xlii] The Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW) obliges states to take active measures against discrimination faced by women in economic and social life. Turkey became a party to CEDAW in 1985. [xliii]
Discrimination compensation especially comes into play in cases such as gender-based wage disparities, discriminatory practices in recruitment, promotion, or dismissal, differential treatment due to trade union activities, and unequal treatment based on disability, pregnancy, marital status, or age.[xliv]
CONCLUSION
In labor law[xlv], mobbing and discrimination are serious legal issues that violate employees’ fundamental rights, disrupt workplace harmony, and directly impact productivity. Both situations are closely linked to the employer’s duty of equal treatment and the protection of employees’ personal rights. While mobbing creates psychological destruction on employees through continuous and systematic pressure, discrimination often manifests as violations of the principle of equal treatment—commonly based on gender, ethnic origin, or disability. The imposition of sanctions by the legal system against such practices aims not only to remedy individual grievances but also to preserve the broader sense of justice, ethics, and equality within the workplace.
Although mobbing and discrimination compensation are grounded in different legal bases in labor law, they become directly interconnected when mobbing is motivated by discriminatory intent. In such cases, both non-pecuniary damages for the harm caused by mobbing and discrimination compensation for violation of the principle of equality may be claimed together. In other words, not every mobbing case constitutes discrimination, but every discrimination-based mobbing case may give rise to both types of compensation.
In this context, compensation for mobbing and discrimination serves as a crucial tool not only for addressing material damages but also for remedying moral suffering, thereby reinforcing the employer’s liability and safeguarding the employee. For this reason, supporting these mechanisms with effective monitoring and evidentiary systems is of critical importance to ensure the deterrent effect of the law.
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Editor: Baver UÇAR (Attorney at Law)
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