FV, actually <<I would suggest that any complaint should come from the "victim" and not from you.>> is out of date.
Take a case of an off-colour joke at the expense of say an Indian. No offence taken by the the subject but a bystander can be offended and successfully claim harassment.
In this case our observer is affronted by what is seen as inappropriat behaviour. Going to OC PMS may be a bit heavy. The padre is often valuable in this area and more private too.