Anti-Harassment Policy

ANTI-HARASSMENT POLICY

Company: [________________________________]
Policy Number: [________________________________]
Effective Date: [__/__/____]
Last Revised: [__/__/____]
Approved By: [________________________________], [Title]
Applies To: All employees, applicants, contractors, interns, volunteers, vendors, and visitors

TABLE OF CONTENTS

1. Purpose and Policy Statement
2. Scope and Applicability
3. Definitions — Types of Prohibited Harassment
4. Examples of Prohibited Conduct
5. Sexual Harassment — Specific Provisions
6. Third-Party and Vendor Harassment
7. Harassment in Virtual and Remote Work Environments
8. Social Media and Off-Duty Conduct
9. Reporting Procedures
10. Bystander Intervention
11. Investigation Procedures
12. Corrective and Remedial Action
13. Anti-Retaliation Protections
14. Faragher-Ellerth Defense and Employer Obligations
15. Manager and Supervisor Responsibilities
16. Training Requirements
17. State-Specific Requirements
18. Confidentiality
19. Record Retention
20. Policy Administration
21. Acknowledgment

1. PURPOSE AND POLICY STATEMENT

[________________________________] ("Company") is committed to maintaining a work environment free from harassment based on any characteristic protected by federal, state, or local law. Harassment is a form of discrimination that undermines workplace dignity, morale, and productivity, and it violates the law.

The Company prohibits all forms of harassment — whether verbal, physical, visual, or electronic — by any person in the workplace, including supervisors, co-workers, independent contractors, vendors, clients, customers, and any other third party. This prohibition extends to all work-related settings, including Company facilities, remote work locations, business travel, Company-sponsored events, and virtual or electronic communications.

This policy is intended to comply with all applicable federal, state, and local anti-harassment laws. Where state or local law provides broader protections or imposes additional requirements, the Company will comply with the more protective standard.

2. SCOPE AND APPLICABILITY

2.1 Covered Individuals

This policy protects and applies to:

• All full-time, part-time, seasonal, and temporary employees
• Job applicants and candidates
• Independent contractors and consultants
• Interns (paid and unpaid)
• Volunteers
• Vendors, suppliers, and their employees while on Company premises or engaged in Company business
• Customers, clients, and other third parties interacting with Company employees

2.2 Covered Locations and Situations

This policy applies to conduct that occurs:

• At any Company facility, office, or worksite
• At remote or home-based work locations
• During business travel
• At Company-sponsored events, conferences, meetings, or social functions
• In Company vehicles
• During telephone calls, video conferences, and other virtual communications conducted for business purposes
• On Company-provided equipment, networks, and platforms
• On personal devices when used for work-related communications
• In any other context where the conduct may affect the work environment or employment relationship

2.3 Relationship to Other Policies

This policy should be read in conjunction with the Company's Equal Employment Opportunity Policy, Code of Conduct, Social Media Policy, and any other policies addressing workplace behavior. To the extent any provision of this policy conflicts with another Company policy, the more protective provision shall apply.

3. DEFINITIONS — TYPES OF PROHIBITED HARASSMENT

3.1 General Definition

Harassment is unwelcome conduct based on a protected characteristic that either (a) is made a condition of employment (quid pro quo) or (b) is sufficiently severe or pervasive to create a work environment that a reasonable person would consider intimidating, hostile, or abusive (hostile work environment).

Legal note: Under federal law as interpreted by the EEOC, harassment need not be both severe and pervasive; a single severe incident can establish a hostile work environment. The totality of the circumstances is considered, including the frequency of the conduct, its severity, whether it is physically threatening or humiliating, and whether it unreasonably interferes with the employee's work performance.

3.2 Protected Characteristics

Harassment based on any of the following is prohibited:

• Race, color, or ethnicity
• National origin or ancestry
• Religion or creed (including religious dress and grooming)
• Sex (including pregnancy, childbirth, lactation, and related medical conditions)
• Sexual orientation
• Gender identity or gender expression
• Age (40 and over under federal law; broader in some states)
• Disability (physical or mental)
• Genetic information
• Veteran or military status
• Marital or familial status
• Citizenship or immigration status
• Reproductive health decision-making
• Any other characteristic protected by applicable federal, state, or local law

3.3 Quid Pro Quo Harassment

Quid pro quo ("this for that") harassment occurs when:

• Submission to unwelcome conduct is made, explicitly or implicitly, a term or condition of employment; or
• Submission to or rejection of such conduct is used as a basis for employment decisions (e.g., hiring, promotion, compensation, assignment, or termination)

Quid pro quo harassment typically involves a person in a position of authority — such as a supervisor, manager, or other individual who can affect the terms and conditions of employment. A single incident of quid pro quo harassment is sufficient to constitute a violation of this policy and of law.

3.4 Hostile Work Environment Harassment

A hostile work environment exists when unwelcome conduct based on a protected characteristic is sufficiently severe or pervasive to alter the conditions of the victim's employment and create an abusive working environment. The determination is based on the totality of the circumstances, evaluated from both a subjective and objective standpoint.

Factors considered include:

• The frequency of the discriminatory conduct
• Its severity
• Whether it is physically threatening or humiliating, or merely an offensive utterance
• Whether it unreasonably interferes with the employee's work performance
• The context in which the conduct occurred

Key precedent: Meritor Savings Bank v. Vinson, 477 U.S. 57 (1986), established that hostile work environment sexual harassment is actionable under Title VII. Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993), clarified that the conduct need not cause tangible psychological injury — the environment need only be one that a reasonable person would find hostile or abusive.

4. EXAMPLES OF PROHIBITED CONDUCT

The following are examples of conduct that may constitute harassment when based on a protected characteristic. This list is illustrative, not exhaustive:

4.1 Verbal Conduct

• Epithets, slurs, or derogatory comments
• Unwelcome jokes, ridicule, or mockery referencing a protected characteristic
• Threats or intimidation
• Unwelcome comments about a person's body, appearance, or clothing
• Offensive or unwelcome remarks about a person's age, disability, religion, race, sex, or other protected characteristic
• Repeated unwelcome requests for dates or sexual favors
• Sexual comments, innuendos, or stories
• Comments demeaning a person's gender identity or sexual orientation
• Use of denigrating animal imagery or comparisons based on race or ethnicity
• Mimicking a person's accent, speech, or mannerisms in a mocking way

4.2 Physical Conduct

• Unwelcome physical contact, including touching, patting, grabbing, hugging, kissing, or massaging
• Physically blocking or impeding someone's movement
• Assault or threat of physical harm
• Unwelcome gestures of a sexual or threatening nature
• Invasion of personal space after being asked to stop

4.3 Visual and Written Conduct

• Display, distribution, or transmission of offensive images, cartoons, drawings, or photographs
• Display of symbols of violence or hatred (e.g., nooses, swastikas, Confederate flags in contexts intended to demean)
• Offensive screensavers, posters, calendars, or objects
• Graffiti or defacement of property with offensive content
• Written notes, letters, or messages with harassing content
• Sharing sexually explicit or offensive material in the workplace

4.4 Electronic and Digital Conduct

• Harassing emails, text messages, instant messages, or chat messages
• Offensive social media posts, comments, or direct messages directed at or about a co-worker
• Sharing offensive memes, GIFs, images, or videos through electronic means
• Cyberstalking, trolling, or online bullying of co-workers
• Harassing conduct during video conferences or virtual meetings (including comments in chat functions)
• Unauthorized sharing of intimate or private images

4.5 Other Conduct

• Sabotaging a person's work or equipment
• Deliberate exclusion from work activities, meetings, or communications based on a protected characteristic
• Stalking or surveillance
• Making false accusations based on a protected characteristic
• Retaliation for reporting harassment or participating in an investigation (addressed further in Section 13)

5. SEXUAL HARASSMENT — SPECIFIC PROVISIONS

5.1 Definition

Sexual harassment is a form of sex discrimination that includes unwelcome sexual advances, requests for sexual favors, and other verbal, physical, or visual conduct of a sexual nature when:

1. Submission to such conduct is made explicitly or implicitly a term or condition of employment (quid pro quo); or
2. Submission to or rejection of such conduct is used as a basis for employment decisions; or
3. Such conduct has the purpose or effect of unreasonably interfering with the individual's work performance or creating an intimidating, hostile, or offensive work environment (hostile work environment)

5.2 Conduct of a Sexual Nature

Sexual harassment can occur between individuals of any sex or gender. It includes conduct directed at a person because of their sex, even if the conduct is not sexual in nature (e.g., gender-based hostility). Specific examples include but are not limited to:

• Unwelcome sexual advances, propositions, or flirtation
• Requests or pressure for sexual favors, including implied or explicit promises of preferential treatment or threats of adverse consequences
• Sexual comments, jokes, innuendos, or stories
• Comments or questions about a person's sexual activity, experiences, or orientation
• Display of sexually suggestive objects, pictures, or materials
• Unwelcome physical contact of a sexual nature
• Leering, staring, or making sexual gestures
• Sending sexually explicit communications (email, text, social media)
• Exposing oneself or performing sexual acts

5.3 Consensual Relationships

The Company recognizes that consensual romantic relationships between employees can raise concerns about conflicts of interest, favoritism, and potential harassment claims — particularly where a supervisory or power differential exists. Employees involved in romantic or sexual relationships with individuals over whom they have supervisory authority or influence must disclose the relationship to HR. Failure to disclose may result in disciplinary action. The Company may reassign reporting relationships to eliminate actual or perceived conflicts.

6. THIRD-PARTY AND VENDOR HARASSMENT

6.1 Harassment by Third Parties

The Company will take reasonable steps to protect employees from harassment by non-employees, including customers, clients, vendors, suppliers, delivery personnel, patients, visitors, and any other third party encountered in connection with work.

Employees who experience harassment by a non-employee should report the conduct immediately using the reporting channels in Section 9. The Company will take appropriate corrective action, which may include:

• Addressing the conduct with the third party or their employer
• Restricting the third party's access to Company premises
• Reassigning the affected employee (only at the employee's request and without adverse consequences)
• Modifying work arrangements to reduce or eliminate contact with the harasser
• Terminating the business relationship if warranted

6.2 Employee Conduct Toward Third Parties

Company employees are also prohibited from harassing customers, clients, vendors, or other third parties. Violations will be addressed through the corrective action process in Section 12.

7. HARASSMENT IN VIRTUAL AND REMOTE WORK ENVIRONMENTS

The Company recognizes that harassment can occur in virtual and remote work settings. The EEOC has confirmed that conduct within a virtual work environment — including comments made during video meetings, typed in group chats, or conveyed through other electronic channels — can contribute to a hostile work environment.

Examples of virtual/remote harassment include:

• Offensive or unwelcome comments during video conference calls
• Harassing messages in chat applications, whether in group channels or direct messages
• Inappropriate virtual backgrounds, images, or avatars
• Sending unsolicited or unwelcome personal messages, images, or videos through work platforms
• Excessive monitoring or micromanagement targeting an employee because of a protected characteristic
• Exclusion from virtual meetings, communications, or collaboration tools based on a protected characteristic

Employees working remotely are subject to the same standards of professional conduct as employees working on-site. All reporting and investigation procedures in this policy apply equally to virtual and remote conduct.

8. SOCIAL MEDIA AND OFF-DUTY CONDUCT

8.1 Social Media

While the Company respects employees' rights to personal expression, social media conduct may violate this policy if it:

• Is directed at or about a co-worker and is based on a protected characteristic
• Creates or contributes to a hostile work environment
• Constitutes cyberbullying, cyberstalking, or online harassment of a co-worker
• Involves the unauthorized sharing of intimate or private images of a co-worker

The Company may take disciplinary action for social media conduct that violates this policy, even if the conduct occurs outside of work hours or on personal devices, to the extent permitted by applicable law (including state laws protecting lawful off-duty conduct and the National Labor Relations Act).

8.2 Off-Duty Conduct

Conduct that occurs outside of work may be addressed under this policy if it has a nexus to the workplace and affects the work environment. For example, off-duty harassment of a co-worker at a non-work event may be actionable if it creates a hostile work environment.

9. REPORTING PROCEDURES

9.1 Duty to Report

Any employee who experiences, observes, or becomes aware of conduct that may constitute harassment is strongly encouraged to report it promptly. Managers and supervisors are required to report any harassment they witness, are informed of, or reasonably should have known about, even if the affected employee does not wish to file a formal complaint.

9.2 Reporting Channels

Reports may be made through any of the following channels. The Company does not require that complaints be submitted through a particular channel, and no channel takes priority over another:

If the employee's supervisor is the alleged harasser, or if the employee is uncomfortable reporting to their supervisor for any reason, the employee should use any of the other available channels.

9.3 How to Report

Reports may be made verbally or in writing. Written reports are encouraged to preserve an accurate record. To assist in a prompt and effective investigation, reports should include, to the extent available:

• Name(s) of the person(s) involved in the alleged harassment
• Description of the alleged harassing conduct (what was said, done, displayed, etc.)
• Date(s), time(s), and location(s) of the incident(s)
• Names of any witnesses
• Any documentary or physical evidence (emails, text messages, photographs, recordings, etc.)
• Description of how the conduct affected the reporting individual
• Whether the reporting individual previously communicated to the harasser that the conduct was unwelcome (not required)

9.4 No Requirement of Confrontation

An employee is not required to confront the alleged harasser or to ask them to stop before filing a report. Nor is an employee required to report to the harasser's supervisor. Any reporting channel listed above is appropriate.

9.5 External Reporting Options

In addition to internal reporting, employees have the right to file a complaint with external agencies:

U.S. Equal Employment Opportunity Commission (EEOC)
- Website: www.eeoc.gov
- Phone: 1-800-669-4000
- Filing deadline: Generally 180 days from the alleged violation (300 days in states with a fair employment practices agency)

State and local agencies — See Section 17 for state-specific agency information and filing deadlines.

NOTE: Internal reporting is encouraged but is not a prerequisite to filing an external complaint. The Company's internal procedures do not extend or replace external filing deadlines.

10. BYSTANDER INTERVENTION

The Company encourages all employees to take an active role in maintaining a respectful workplace. Bystander intervention involves safe and constructive actions that an individual can take when they witness conduct that may constitute harassment.

Strategies for bystander intervention include:

• Direct — If safe and appropriate, speak to the person engaging in the conduct and let them know it is unwelcome or inappropriate
• Distract — Interrupt the interaction by changing the subject, creating a distraction, or redirecting attention
• Delegate — Report the conduct to a supervisor, HR, or another person with authority to address the situation
• Document — Take note of what happened, including date, time, location, parties involved, and what was said or done, to support a later report
• Delay — If you are unable to intervene at the time of the incident, check in with the affected person afterward to offer support and encourage reporting

No employee will face retaliation for engaging in good-faith bystander intervention.

11. INVESTIGATION PROCEDURES

11.1 General Principles

The Company will investigate all complaints of harassment promptly, thoroughly, and impartially. The goals of the investigation are to determine the facts, reach a reasonable conclusion regarding whether this policy was violated, and take appropriate action.

Key principles:

• All complaints will be taken seriously regardless of the identity of the parties involved
• The investigation will be conducted by a qualified, impartial investigator — either internal (e.g., HR) or external, as circumstances warrant
• The investigator will have no conflict of interest with any party
• Both the complainant and the accused will have a fair opportunity to present their account and identify witnesses
• Interim measures will be considered to protect the complainant and maintain the integrity of the investigation
• The Company will strive to complete the investigation within [____] business days, understanding that complex matters may take longer

11.2 Investigation Steps

Step 1 — Intake and Assessment

• Receive and document the complaint
• Assess the need for interim protective measures (e.g., separation of parties, no-contact order, temporary schedule changes, administrative leave for the accused)
• Determine whether the allegation, if true, would constitute a policy violation
• Develop an investigation plan identifying witnesses, documents, and other evidence to be gathered

Step 2 — Complainant Interview

• Conduct a detailed interview with the complainant
• Obtain a written statement if possible
• Identify all witnesses and documentary evidence
• Explain the investigation process, timeline, and anti-retaliation protections
• Assess the complainant's desired outcome (while reserving the Company's right to take action regardless)

Step 3 — Accused Interview

• Notify the accused of the allegations in sufficient detail to allow a meaningful response
• Conduct a detailed interview with the accused
• Obtain a written statement if possible
• Advise the accused of the anti-retaliation policy
• Identify any witnesses or evidence offered by the accused

Step 4 — Witness Interviews

• Interview all identified witnesses
• Ask open-ended questions to obtain firsthand observations
• Remind witnesses of the Company's anti-retaliation policy and confidentiality expectations

Step 5 — Evidence Collection and Review

• Collect and review all relevant documents, communications, electronic records, and physical evidence
• Review relevant Company records (e.g., prior complaints, performance records, attendance records)
• Review any surveillance footage or access records, if applicable

Step 6 — Analysis and Findings

• Evaluate all evidence gathered, including the credibility of witnesses
• Determine whether a preponderance of the evidence supports a finding that this policy was violated
• Consider the totality of the circumstances, including the severity and frequency of the conduct, the context, and the effect on the complainant

Step 7 — Report and Conclusion

• Prepare a written investigation report summarizing the complaint, evidence gathered, analysis, and findings
• Present findings and recommendations to appropriate decision-makers (e.g., HR Director, legal counsel, senior management)

Step 8 — Communication of Results

• Notify the complainant that the investigation has been completed and share the outcome, to the extent consistent with privacy obligations and applicable law
• Notify the accused of the outcome and any corrective action to be taken
• Neither party is entitled to a full copy of the investigation report, but both should receive sufficient information to understand the result

Step 9 — Follow-Up

• Monitor the situation after the investigation to ensure the harassment has stopped and no retaliation has occurred
• Follow up with the complainant at regular intervals (e.g., 30, 60, and 90 days) to confirm no further issues
• Document all follow-up actions

12. CORRECTIVE AND REMEDIAL ACTION

12.1 Corrective Action for Violations

If the investigation determines that a violation of this policy has occurred, the Company will take prompt corrective action that is reasonably calculated to end the harassment and prevent it from recurring. Corrective action will be proportionate to the severity of the violation and may include:

• Verbal counseling or warning
• Written warning
• Required harassment prevention training or counseling
• Performance improvement plan
• Loss of supervisory or management authority
• Reduction in responsibilities
• Demotion
• Suspension without pay
• Transfer or reassignment of the harasser (the complainant should not be involuntarily transferred unless they request it)
• Termination of employment
• Termination of business relationship (for non-employees)

12.2 Remedial Measures

In addition to corrective action against the harasser, the Company may implement remedial measures to address the effects of the harassment on the complainant and the work environment, including:

• Restoration of any benefits, opportunities, or conditions of employment adversely affected by the harassment
• Expungement of negative evaluations or disciplinary actions attributable to the harassment
• Monitoring the work environment
• Enhanced training for the department or workgroup
• Climate surveys or follow-up assessments

12.3 Inconclusive Investigations

Where the investigation is inconclusive (i.e., the evidence does not establish a policy violation by a preponderance of the evidence), the Company may still take preventive measures such as reminding the parties of this policy, conducting refresher training, or adjusting work arrangements.

13. ANTI-RETALIATION PROTECTIONS

13.1 Prohibition

The Company strictly prohibits retaliation against any individual who, in good faith:

• Reports or complains about harassment under this policy
• Participates in, cooperates with, or provides information in connection with an investigation
• Files a charge or complaint with the EEOC or any state or local agency
• Testifies, assists, or participates in any proceeding related to harassment
• Engages in bystander intervention
• Opposes any practice that the individual reasonably believes constitutes unlawful harassment

13.2 Definition of Retaliation

Retaliation means any materially adverse action taken against an individual because of their protected activity. Under Burlington Northern & Santa Fe Railway Co. v. White, 548 U.S. 53 (2006), a materially adverse action is one that would dissuade a reasonable person from engaging in the protected activity. Examples include but are not limited to:

• Discharge, demotion, or suspension
• Reduction in hours, pay, or benefits
• Unfavorable transfer or reassignment
• Denial of promotion or training
• Unjustified negative performance evaluation
• Increased scrutiny or changed working conditions not applied to others
• Threats, intimidation, or coercion
• Shunning, ostracism, or exclusion from work activities
• Badmouthing the individual to colleagues or future employers

13.3 Reporting Retaliation

Any individual who believes they have experienced retaliation should report it immediately using the channels in Section 9. Retaliation complaints will be investigated with the same procedures and seriousness as harassment complaints.

14. FARAGHER-ELLERTH DEFENSE AND EMPLOYER OBLIGATIONS

14.1 Legal Background

Under Faragher v. City of Boca Raton, 524 U.S. 775 (1998), and Burlington Industries, Inc. v. Ellerth, 524 U.S. 742 (1998), an employer may avoid vicarious liability for supervisor harassment that does not result in a tangible employment action by establishing two elements:

1. The employer exercised reasonable care to prevent and correct promptly any harassing behavior; and
2. The employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to otherwise avoid harm.

14.2 Company Commitment

This policy and the procedures set forth herein are designed to satisfy the employer's duty of reasonable care. The Company:

• Has established a clear, written anti-harassment policy that is widely disseminated
• Provides multiple reporting channels so that employees can bypass any involved supervisor
• Conducts prompt, thorough, and impartial investigations of all complaints
• Takes appropriate corrective action when violations are found
• Provides regular anti-harassment training to all employees and supervisors
• Prohibits retaliation against individuals who report harassment or participate in investigations

14.3 Employee Obligation

Employees are strongly encouraged to report harassment promptly using the reporting channels in this policy. An employee's unreasonable failure to use these reporting channels may limit the Company's ability to prevent or correct harassment and may be relevant in any legal proceeding.

NOTE TO EMPLOYER: The Faragher-Ellerth defense is not available where the harassment resulted in a tangible employment action (e.g., discharge, demotion, undesirable reassignment). It applies only in the context of supervisor harassment claims under Title VII. State law standards may differ. Some state laws (e.g., NYCHRL) impose strict liability for supervisor harassment regardless of the employer's preventive efforts.

15. MANAGER AND SUPERVISOR RESPONSIBILITIES

Managers and supervisors bear heightened responsibility for preventing and addressing harassment. They are often the first point of contact and their actions or inaction can create significant liability for the Company. Specifically, managers and supervisors must:

☐ Model respectful, professional behavior at all times

☐ Refrain from engaging in harassment or any conduct that could be perceived as harassment

☐ Report any harassment they witness, are informed of, or reasonably should know about to HR or the EEO Officer immediately — regardless of whether the affected employee wants to file a formal complaint

☐ Never discourage an employee from filing a complaint or suggest that an employee "handle it on their own"

☐ Cooperate fully and honestly in any investigation

☐ Maintain the confidentiality of complaints and investigations to the greatest extent possible

☐ Ensure that no retaliation occurs against any individual who reports harassment or participates in an investigation

☐ Implement any corrective action or protective measures directed by HR or management

☐ Complete all required anti-harassment training on time

☐ Monitor the workplace for signs of harassment, hostility, or exclusion and take proactive steps to address concerns

☐ Consult HR before taking any action in response to a harassment complaint

Failure of a manager or supervisor to report known or suspected harassment, or to take appropriate action, may itself constitute a violation of this policy and result in discipline up to and including termination. The Company may be held liable for harassment that a supervisor knew about or should have known about, regardless of whether a formal complaint was filed (constructive knowledge doctrine).

16. TRAINING REQUIREMENTS

16.1 Company-Wide Training

The Company is committed to providing anti-harassment training that meets or exceeds the requirements of all applicable jurisdictions. Training shall be:

• Interactive — Involving questions, hypothetical scenarios, and discussion (not passive viewing alone)
• Comprehensive — Covering all forms of prohibited harassment, reporting procedures, investigation process, anti-retaliation protections, and bystander intervention strategies
• Documented — Attendance and completion records maintained

16.2 Training Schedule

16.3 State-Specific Training Requirements

The following states have mandatory anti-harassment training requirements. The Company will comply with the most protective standard applicable to each employee:

NOTE TO EMPLOYER: Additional cities and counties may have training requirements (e.g., Chicago, IL requires annual training plus bystander intervention training). Verify all applicable local requirements.

17. STATE-SPECIFIC REQUIREMENTS

17.1 California

Governing Law: California Fair Employment and Housing Act (FEHA), Cal. Gov. Code § 12940 et seq.

Key Requirements:

• Scope: FEHA applies to employers with 5 or more employees for discrimination; employers with 1 or more employees for harassment
• Supervisor liability: Individual supervisors may be held personally liable for harassment under FEHA
• Protected categories: Include all federal categories plus marital status, sexual orientation, gender identity, military status, reproductive health decision-making, hair texture and protective hairstyles, and others (see EEO Policy for full list)
• Training: 2 hours for supervisors, 1 hour for non-supervisors, every 2 years; must include harassment based on gender identity, gender expression, and sexual orientation; must be provided to temporary and seasonal employees within 30 days or within 100 hours worked, whichever comes first; training must include practical examples and be provided in a classroom, e-learning, or webinar format
• Filing deadline: 3 years from the alleged violation to file with CRD
• Policy distribution: Required to distribute written harassment prevention policy to all employees; the CRD provides a model policy (DFEH-185)

Filing Agency: California Civil Rights Department (CRD) — www.calcivilrights.ca.gov

17.2 New York

Governing Law: NYSHRL (N.Y. Exec. Law § 296); NYCHRL (N.Y.C. Admin. Code § 8-107)

Key Requirements:

• NYSHRL scope: All employers regardless of size (as of 2019); harassment claims evaluated under a lower "treats less well" standard than federal law
• NYCHRL scope: Employers with 4+ employees (all employers for gender-based harassment); evaluated under the broadest possible standard
• Training: All employers must provide annual interactive anti-sexual-harassment training that meets minimum standards set by the NYS Department of Labor and Division of Human Rights
• Policy requirements: All employers must adopt a written anti-sexual-harassment prevention policy meeting specified minimum standards or use the model policy provided by the state
• Complaint form: Employers must provide employees with a complaint form
• Filing deadline: NYSHRL — 3 years (civil court) or 1 year (DHR); NYCHRL — 3 years (civil court) or 1 year (CCHR)
• Individual liability: Supervisors and aiders/abettors may be personally liable under both NYSHRL and NYCHRL

Filing Agencies:
- New York State Division of Human Rights (DHR) — www.dhr.ny.gov
- NYC Commission on Human Rights (CCHR) — www.nyc.gov/cchr

17.3 Illinois

Governing Law: Illinois Human Rights Act (IHRA), 775 ILCS 5/

Key Requirements:

• Scope: Applies to employers with 1 or more employees
• Training: Annual sexual harassment prevention training required for all employees (SB 75); restaurants and bars must provide supplemental training addressing industry-specific issues
• Disclosure: Employers must disclose annually to the Illinois Department of Human Rights (IDHR) any adverse judgments or rulings regarding sexual harassment or unlawful discrimination in the preceding year
• Filing deadline: 300 days from the alleged violation with the IDHR

Filing Agency: Illinois Department of Human Rights (IDHR) — www.illinois.gov/dhr

17.4 Connecticut

Governing Law: Conn. Gen. Stat. § 46a-60 et seq.

Key Requirements:

• Scope: Applies to employers with 3 or more employees
• Training: All employers with 3+ employees must provide 2 hours of training to all employees within 6 months of hire; supplemental training required for new supervisors within 6 months of assumption of supervisory role
• Filing deadline: 300 days from the alleged violation with the Commission on Human Rights and Opportunities (CHRO)

Filing Agency: Connecticut Commission on Human Rights and Opportunities (CHRO) — www.ct.gov/chro

17.5 Delaware and Maine

Delaware: Employers with 50+ employees must provide interactive anti-harassment training to all employees within 1 year of hire and to supervisors with additional supervisor-specific content. Retraining required every 2 years. Del. Code tit. 19, § 711A.

Maine: Employers with 15+ employees must provide training to all employees within 1 year of hire. Supervisors and managers must receive additional training within 1 year of promotion. 26 M.R.S.A. § 807.

17.6 Texas and Florida

Neither Texas nor Florida currently mandates anti-harassment training by state law. However, the Company provides training to employees in all states as a best practice and to satisfy Faragher-Ellerth obligations.

18. CONFIDENTIALITY

The Company will maintain the confidentiality of harassment complaints, investigations, and outcomes to the greatest extent possible, consistent with its obligation to conduct a thorough investigation and take appropriate corrective action.

Confidentiality obligations:

• Information regarding complaints and investigations will be shared only with those who have a legitimate need to know
• Witnesses and parties will be advised of the confidentiality expectations during the investigation
• Investigation files will be maintained separately from personnel files, in a secure location with restricted access
• The Company will not disclose the identity of the complainant or witnesses except as necessary to conduct the investigation, comply with legal requirements, or take corrective action

NOTE: The Company cannot guarantee absolute confidentiality, as the need for a fair and thorough investigation may require disclosure of certain information. The Company will, however, take reasonable steps to limit the scope of any disclosure.

19. RECORD RETENTION

The Company will retain the following records in accordance with applicable law:

NOTE: Some states require longer retention periods. Consult counsel for specific state requirements.

20. POLICY ADMINISTRATION

20.1 Dissemination

This policy shall be:

• Distributed to all employees upon hire and upon any material revision
• Included in the employee handbook or posted on the Company intranet
• Posted in conspicuous locations at all Company facilities
• Made available in languages spoken by a significant portion of the workforce, where required by law
• Provided to remote workers electronically
• Made available in alternative formats upon request

20.2 Annual Review

This policy shall be reviewed at least annually by HR and legal counsel to ensure continued compliance with applicable federal, state, and local law, and to incorporate any changes in EEOC guidance, case law, or best practices.

20.3 Responsible Official

The following individual has overall responsibility for the administration of this policy:

Name: [________________________________]
Title: [________________________________]
Phone: [________________________________]
Email: [________________________________]

21. ACKNOWLEDGMENT

By signing below, I acknowledge that I have received, read, and understood the Company's Anti-Harassment Policy. I understand my obligation to comply with this policy and to report any conduct that may violate this policy. I understand that violations may result in disciplinary action, up to and including termination.

I understand that this policy does not create a contract of employment or alter the at-will nature of my employment (where applicable under state law).

Employee Name (Print): [________________________________]

Employee Signature: [________________________________]

Date: [__/__/____]

Manager/Witness Name (Print): [________________________________]

Manager/Witness Signature: [________________________________]

Date: [__/__/____]

SOURCES AND REFERENCES

• Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.
• Meritor Savings Bank, FSB v. Vinson, 477 U.S. 57 (1986)
• Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993)
• Faragher v. City of Boca Raton, 524 U.S. 775 (1998)
• Burlington Industries, Inc. v. Ellerth, 524 U.S. 742 (1998)
• Burlington Northern & Santa Fe Railway Co. v. White, 548 U.S. 53 (2006)
• Bostock v. Clayton County, 590 U.S. 644 (2020)
• EEOC Enforcement Guidance on Harassment in the Workplace (April 2024)
• EEOC Enforcement Guidance on Retaliation and Related Issues (2016)
• California FEHA, Cal. Gov. Code § 12940 et seq.; SB 1343; AB 1825
• New York State Human Rights Law, N.Y. Exec. Law § 290 et seq.
• New York City Human Rights Law, N.Y.C. Admin. Code § 8-101 et seq.
• New York Labor Law § 201-g (anti-sexual-harassment training and policy)
• Illinois Human Rights Act, 775 ILCS 5/; SB 75
• Connecticut Gen. Stat. § 46a-54(15)(B); § 46a-60
• Delaware Code tit. 19, § 711A
• Maine Rev. Stat. tit. 26, § 807
• EEOC Model EEO Programs: www.eeoc.gov/federal-sector/model-eeo-programs-must-have-effective-anti-harassment-program

This template is provided for informational purposes only and does not constitute legal advice. It must be reviewed and customized by a qualified attorney licensed in your jurisdiction before use. Anti-harassment laws vary by jurisdiction and change frequently. Do not implement this policy without professional legal review tailored to your specific circumstances.

Generated by ezel.ai — Last updated 2026-02-26