That's a tricky question. Harassment is usually treated as a personal-level issue. It's usually treated through different channels. Harassment is a typical response to whistle-blowing. It's probably the most pernicious, because it's really hard to prove that somebody is harassing somebody else and that it's related to the whistle-blowing.
Harassment would be considered a form of reprisal and should be treated differently from.... I don't want to call it “garden variety” but that's kind of what I'm getting at. The people who control the harassment procedures are often implicated in the wrongdoing where the harassment is being used as a reprisal. Does that make sense?
Harassment is a standard reprisal technique. If you want a fair hearing on normal harassment, you can go through the normal processes to get it addressed. However, if the harassment is a response to whistle-blowing, often the leadership in the organization will be implicated. They are also controlling the harassment process, so they can derail it. It's a tricky problem.
I get where you're going with it, but that would have to be handled very carefully.