WORKPLACE ANTI-HARASSMENT POLICY

(State of Georgia – [COMPANY NAME])

TABLE OF CONTENTS

1. Document Header
2. Definitions
3. Policy Statement & Scope
4. Prohibited Conduct
5. Reporting Procedures
6. Investigation Protocols
7. Training Requirements
8. Retaliation Prohibition
9. Recordkeeping & Confidentiality
10. Enforcement & Disciplinary Actions
11. Risk Allocation & Liability
12. Dispute Resolution
13. General Provisions
14. Acknowledgment & Receipt

1. DOCUMENT HEADER

1.1 Parties. This Workplace Anti-Harassment Policy (“Policy”) is adopted by [COMPANY NAME], a [STATE OF FORMATION] [legal entity type] (the “Employer”), and applies to all employees, officers, directors, interns (paid or unpaid), volunteers, agents, and applicants for employment (each an “Employee” and collectively “Employees”).

1.2 Effective Date. This Policy is effective as of [EFFECTIVE DATE] (the “Effective Date”).

1.3 Governing Law. This Policy shall be construed and enforced in accordance with the laws of the State of Georgia and applicable federal law, including Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2, and the Equal Employment Opportunity Commission guidelines, 29 C.F.R. § 1604.11.

1.4 Purpose & Consideration. In consideration of continued employment and mutual promises herein, the Employer promulgates this Policy to (a) maintain a work environment free from unlawful harassment, discrimination, and retaliation; (b) comply with applicable law; and (c) establish clear procedures for reporting, investigating, and remedying prohibited conduct.

[// GUIDANCE: Georgia has no state-wide mandatory harassment-training statute for private employers. Nevertheless, robust internal policies and annual training significantly mitigate risk under Title VII and common-law negligent-retention claims.]

2. DEFINITIONS

For purposes of this Policy, the following terms have the meanings set forth below. Defined terms appear in Bold-Italic throughout and are alphabetically listed.

“Administrative Proceeding” – Any charge, complaint, or claim filed with a governmental agency (e.g., EEOC or Georgia Commission on Equal Opportunity).

“Complainant” – An Employee, applicant, or third party who reports alleged Prohibited Conduct.

“Harassment” – Unwelcome conduct, whether verbal, physical, visual, or electronic, that is based on a Protected Characteristic and that (a) explicitly or implicitly affects an individual’s employment; (b) unreasonably interferes with an individual’s work performance; or (c) creates an intimidating, hostile, or offensive work environment.

“Investigative Team” – The persons designated under Section 6.2 to conduct an Investigation.

“Investigation” – The fact-finding process described in Section 6.

“Protected Characteristic” – Race, color, religion, sex (including pregnancy, sexual orientation, and gender identity), national origin, age (40 or older), disability, genetic information, military status, or any other trait protected by applicable law.

“Prohibited Conduct” – Harassment, sexual harassment, discrimination, quid pro quo requests, bullying, hostile work environment, and retaliation, each as further defined in Section 4.

“Respondent” – The person(s) alleged to have committed Prohibited Conduct.

[// GUIDANCE: Add or modify Protected Characteristics to capture any local ordinances affecting specific worksites (e.g., City of Atlanta LGBTQ protections).]

3. POLICY STATEMENT & SCOPE

3.1 Zero-Tolerance Standard. The Employer maintains a zero-tolerance policy for all forms of Harassment or retaliation, whether by Employees, customers, vendors, or third parties on Employer premises or while conducting Employer business.

3.2 Scope of Coverage. This Policy applies to:
a. All work-related settings, including Employer-sponsored social events, travel, remote workplaces, and online platforms; and
b. Conduct by Employees toward non-employees (and vice versa) in connection with Employer business.

3.3 At-Will Employment. Nothing herein creates a contract of employment or alters any Employee’s at-will status.

4. PROHIBITED CONDUCT

4.1 Harassment Based on a Protected Characteristic. Examples include ethnic slurs, derogatory jokes, visual depictions, and workplace graffiti.

4.2 Sexual Harassment.
a. Quid Pro Quo – Conditioning employment terms on submission to unwelcome sexual advances.
b. Hostile Environment – Unwelcome conduct of a sexual nature that is severe or pervasive enough to create an intimidating or offensive workplace.

4.3 Bullying & Abusive Conduct not rising to the level of unlawful Harassment is nevertheless prohibited and subject to discipline.

4.4 Retaliation against any individual for reporting or participating in an Investigation under this Policy is strictly prohibited.

[// GUIDANCE: Use illustrative, non-exhaustive examples in employee handbook summaries, but retain higher-level language in the formal policy to avoid inadvertent limitations.]

5. REPORTING PROCEDURES

5.1 Duty to Report. Employees who experience or witness Prohibited Conduct must promptly report the matter, even if the conduct is directed at someone else.

5.2 Multiple Reporting Channels. Reports may be made:
a. To any supervisor or manager;
b. Directly to Human Resources (“HR”) at [HR EMAIL / PHONE];
c. Via the anonymous hotline at [HOTLINE NUMBER] (available 24 × 7); or
d. By submitting Form HR-AH-1 (attached as Appendix A).

5.3 Supervisor Obligations. Supervisors receiving a report must escalate it to HR within one (1) business day and must not conduct an independent investigation.

5.4 Emergency Situations. Where safety is at immediate risk, Employees should contact [SECURITY/911] before initiating a report under this Section.

5.5 Timeframe for Reporting. Prompt reporting is encouraged, but no fixed deadline applies. Delayed reports will be investigated to the fullest practical extent.

6. INVESTIGATION PROTOCOLS

6.1 Timeliness. HR will commence an Investigation within five (5) business days of receipt of a report.

6.2 Investigative Team. The Investigative Team shall comprise (a) an HR representative; (b) an impartial manager not in the Complainant’s chain of command; and, where appropriate, (c) outside counsel.

6.3 Process.
a. Collect and preserve evidence (documents, emails, CCTV, etc.).
b. Conduct separate interviews of the Complainant, Respondent, and relevant witnesses.
c. Maintain written summaries and obtain signed acknowledgments.
d. Aim to conclude fact-finding within thirty (30) calendar days, absent extenuating circumstances.

6.4 Confidentiality. Information will be shared strictly on a need-to-know basis.

6.5 Interim Measures. The Employer may implement temporary workplace adjustments (e.g., schedule changes, paid administrative leave) to protect the integrity of the Investigation.

6.6 Outcome & Notice. Upon completion, HR will issue a written determination to the Complainant and Respondent, summarizing findings and remedial steps, consistent with privacy obligations.

[// GUIDANCE: Maintain legal privilege by routing all Investigation notes through counsel when litigation is reasonably anticipated.]

7. TRAINING REQUIREMENTS

7.1 Mandatory Annual Training. All Employees must complete Employer-provided anti-harassment training within thirty (30) days of hire and annually thereafter.

7.2 Manager & Supervisor Training. Supervisors shall receive enhanced, instructor-led training covering (a) recognition of Harassment; (b) obligations under Section 5; and (c) prevention strategies.

7.3 Recordkeeping. Training attendance records shall be retained for not less than five (5) years and shall be producible to governmental agencies upon lawful request.

[// GUIDANCE: For public-sector Georgia employers, incorporate state executive-order requirements on sexual-harassment prevention; for private employers, these best-practice measures mitigate punitive-damage exposure.]

8. RETALIATION PROHIBITION

8.1 Protected Activity. Engaging in any of the following constitutes “Protected Activity”:
a. Reporting Prohibited Conduct in good faith;
b. Participating in an Investigation; or
c. Filing an Administrative Proceeding.

8.2 Prohibited Retaliatory Acts include, but are not limited to, demotion, discipline, reduction in pay, or negative performance evaluations prompted by Protected Activity.

8.3 Reporting Retaliation. Alleged retaliation shall be reported and investigated under Sections 5 and 6.

9. RECORDKEEPING & CONFIDENTIALITY

9.1 Retention Schedule. Investigation files shall be maintained for the longer of:
a. Six (6) years after case closure; or
b. Any period required under applicable law or litigation hold.

9.2 Confidential Data. Personally identifying information shall be redacted from materials produced externally, except as required by law.

10. ENFORCEMENT & DISCIPLINARY ACTIONS

10.1 Corrective Measures. If Prohibited Conduct is substantiated, the Employer will impose proportionate discipline, up to and including termination of employment.

10.2 False Claims. Knowingly false or malicious allegations are themselves a violation and subject to discipline, but a good-faith report that is unsubstantiated will not result in adverse action.

10.3 Follow-Up. HR will monitor the workplace for retaliation or recurrence for at least ninety (90) days post-determination.

11. RISK ALLOCATION & LIABILITY

11.1 Employer Responsibility. The Employer assumes liability for acts of Harassment by supervisory personnel that result in an adverse employment action, subject to statutory defenses and limitations.

11.2 Indemnification of Employees. The Employer shall indemnify and hold harmless Employees against third-party claims arising from acts performed in good faith within the course and scope of employment, except where the Employee engaged in willful misconduct or Prohibited Conduct.

11.3 Limitation of Liability. Nothing herein expands liability beyond remedies available under applicable state or federal statutes; all damages shall be capped to the extent permitted by law (“Statutory Limits”).

11.4 Insurance. The Employer shall maintain Employment Practices Liability Insurance (“EPLI”) with minimum coverage of [COVERAGE AMOUNT].

[// GUIDANCE: Verify indemnification language against any D&O/EPLI exclusions to avoid uninsured exposure.]

12. DISPUTE RESOLUTION

12.1 Internal Resolution First. Employees are encouraged to exhaust the procedures in Sections 5 through 6 before pursuing external remedies.

12.2 Arbitration (Limited).
a. Except for Administrative Proceedings or claims seeking injunctive relief, any civil claim arising directly from this Policy shall, at the Employer’s election and with the Employee’s consent post-dispute, be submitted to binding arbitration under the [ARBITRATION SERVICE/RULES].
b. The arbitration clause shall not abridge statutory rights to file with or participate in EEOC or similar agencies.

12.3 Forum Selection. To the extent litigation proceeds in court, jurisdiction and venue shall lie exclusively in the state courts of competent jurisdiction located in [COUNTY], Georgia.

12.4 Jury Trial. Consistent with Article I, Section I, Paragraph XI of the Georgia Constitution, the right to trial by jury is preserved.

12.5 Injunctive Relief. Either party may seek temporary, preliminary, or permanent injunctive relief in court to prevent ongoing or imminent Prohibited Conduct.

13. GENERAL PROVISIONS

13.1 Amendment & Waiver. The Employer may amend this Policy at any time with or without notice, except that no amendment shall retroactively impair rights in a pending claim. No waiver is effective unless in writing and signed by an authorized representative.

13.2 Severability. If any provision is held unenforceable, the balance shall remain in effect, and the offending provision shall be reformed to the minimum extent necessary to achieve its lawful intent.

13.3 Integration. This Policy supersedes all prior anti-harassment policies and statements, whether written or oral.

13.4 Electronic Signatures. Execution and acknowledgment via electronic means (e.g., DocuSign) are deemed originals.

13.5 Successors & Assigns. This Policy binds and inures to the benefit of the Employer’s successors and assigns.

14. ACKNOWLEDGMENT & RECEIPT

I acknowledge that I have received, read, and understood the [COMPANY NAME] Workplace Anti-Harassment Policy, effective as of the Effective Date noted herein. I agree to comply with the Policy and understand that violation may result in disciplinary action, up to and including termination of employment.

END OF POLICY