sexual harassment risk assessments<\/a>\u00a0and expand them to address third party harassment across relevant protected characteristics.\u00a0 The assessment should map who interacts with employees, where those interactions occur and which roles, locations, working patterns or events create heightened risk. It is also important for employers to factor in online communications, remote working, travel, social events and customer-facing environments.<\/p>\nRisk assessments should not be a one-off exercise. Organisations should ensure they keep evidence showing how the organisation has identified risks, implemented controls and tested whether they work on an ongoing basis.<\/p>\n
Update policies, procedures and responsibilities<\/p>\n
Policies should explain the stronger harassment laws, expressly cover third party conduct and make clear that one incident may be sufficient. Employers should use practical examples relevant to the organisation, identify reporting and escalation routes, and explain the support available to affected employees. <\/p>\n
Senior leaders should own the prevention framework, with clear responsibilities for human resources (HR), managers, procurement teams and those managing sites or third party relationships.<\/p>\n
Prioritise trauma-informed investigation arrangements<\/p>\n
The EHRC have been clear that those investigating incidents of harassment need to be suitably qualified.\u00a0 An essential skill is understanding trauma and the impact on those involved.\u00a0 Trauma may affect memory, behaviour and communication. Investigators should not treat fragmented recall, emotional presentation or a non-linear account as evidence of unreliability.\u00a0<\/p>\n
Employers should ensure that those investigating are impartial and trauma-informed. <\/p>\n
Investigators should apply trauma-informed principles, including safety, trust, collaboration and choice, and guard against biases that favour a polished account over a hesitant one.\u00a0<\/p>\n
Reports should use neutral language and test inconsistencies against all available evidence. Employers should also support investigators exposed to difficult material. A trauma-informed approach can reduce bias and produce more defensible findings.<\/p>\n
Strengthen training and workplace culture<\/p>\n
Employers should refresh training for both employees and managers so that it addresses the \u201call reasonable steps\u201d standard, third party scenarios, safe bystander intervention and the practical response expected when concerns arise. Generic or infrequent training may not demonstrate that preventative measures operate effectively in practice.\u00a0<\/p>\n
Employers may complement training with active cultural diagnostics. These may include staff surveys, exit information, reporting data and focus groups. Leaders should model expected behaviour and reinforce that retaliation or victimisation will not be tolerated.<\/p>\n
Address supply-chain and commercial risks<\/p>\n
Where customer, supplier or agency workforces interact, both sides should assess risks before services begin and keep arrangements under review. Procurement documents and contracts may need obligations covering conduct standards, training, information sharing, preventative measures, incident reporting, cooperation when allegations arise and allocation of liability.\u00a0<\/p>\n
Existing contracts also deserve attention because harassment after 30 October may create exposure even where the commercial relationship began earlier. Employers may be able to adapt controls already introduced for sexual harassment to address wider third party risks.<\/p>\n","protected":false},"excerpt":{"rendered":"
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