**[COMPANY NAME]

Workplace Anti-Harassment Policy
(Commonwealth of Pennsylvania)

TABLE OF CONTENTS

1. Document Header
2. Definitions
3. Operative Provisions
   3.1 Prohibited Conduct
   3.2 Training Requirements (Pennsylvania)
   3.3 Reporting Procedures
   3.4 Investigation Protocols
   3.5 Corrective & Disciplinary Action
4. Representations & Warranties
5. Covenants & Restrictions
6. Default & Remedies
7. Risk Allocation
8. Dispute Resolution
9. General Provisions
10. Execution Block

1. DOCUMENT HEADER

Policy Title: Workplace Anti-Harassment Policy
Employer: [COMPANY NAME], a [STATE OF INCORPORATION] [ENTITY TYPE] (“Company”)
Effective Date: [EFFECTIVE DATE]
Jurisdiction / Governing Law: Commonwealth of Pennsylvania, pursuant to the Pennsylvania Human Relations Act, 43 P.S. § 951 et seq., and applicable federal law, including Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.
Recitals:
A. The Company desires to foster a professional work environment free from all forms of unlawful harassment and discrimination.
B. In consideration of continued employment and mutual promises herein, the parties agree to the terms of this Policy.

[// GUIDANCE: Recitals provide contractual consideration language should the employer wish to incorporate the policy into employment agreements or employee handbooks.]

2. DEFINITIONS

For purposes of this Policy, capitalized terms have the meanings set forth below:

“Arbitration Program” – The Company’s alternative dispute resolution procedure described in Section 8.2.

“Complainant” – Any Employee or Covered Person who makes a Report of Harassment.

“Covered Person(s)” – All Company Employees, interns (paid or unpaid), volunteers, applicants, contractors, vendors, clients, visitors, and any other individual present at a Company Worksite.

“Employee” – Any individual employed by the Company on a full-time, part-time, seasonal, or temporary basis.

“Harassment” – Unwelcome verbal, visual, or physical conduct based on a Protected Characteristic that either:
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.

“Protected Characteristic” – Age (40 and over), ancestry, color, disability, national origin, race, religious creed, sex (including pregnancy, sexual orientation, gender identity or expression), genetic information, veteran status, and any other characteristic protected under applicable federal, state, or local law.

“Report” – Any oral or written communication alleging Harassment, Retaliation, or related misconduct.

“Respondent” – The individual(s) alleged to have engaged in Harassment.

“Retaliation” – Any adverse action taken against a Covered Person for reporting Harassment, participating in an investigation, or exercising rights under this Policy.

“Worksite” – Any Company-owned, leased, or controlled facility, vehicle, or off-site location where Company business is conducted, including remote or virtual environments.

3. OPERATIVE PROVISIONS

3.1 Prohibited Conduct

a. The Company strictly prohibits Harassment of any Covered Person by another Covered Person in any form.
b. Sexual Harassment—including unwelcome sexual advances, requests for sexual favors, and other verbal or physical harassment of a sexual nature—is expressly forbidden.
c. Retaliation is strictly prohibited.

3.2 Training Requirements (Pennsylvania)

a. Mandatory Training. The Company shall provide interactive anti-harassment training to all Employees:
i. within ninety (90) days of hire; and
ii. at least once every two (2) years thereafter.
b. Supervisor Training. Supervisors and managers shall receive additional training addressing:
i. their duty to prevent, detect, and respond to Harassment;
ii. investigative responsibilities; and
iii. personal liability risks under 43 P.S. § 955(e).
c. Recordkeeping. Completion records shall be maintained for a minimum of three (3) years.

[// GUIDANCE: While Pennsylvania does not currently mandate private-sector training, providing it mitigates risk and satisfies Philadelphia and Pittsburgh local ordinances where applicable.]

3.3 Reporting Procedures

a. Reporting Channels. A Covered Person may file a Report by any of the following means:
i. Verbally or in writing to any Supervisor or Human Resources (“HR”);
ii. Email to [DEDICATED HR EMAIL];
iii. Hotline: [TOLL-FREE NUMBER]; or
iv. Anonymous web portal: [URL].
b. Supervisor Duty to Act. Any Supervisor receiving a Report must forward it to HR within twenty-four (24) hours.
c. No Formal Complaint Requirement. A formal written complaint is not required to trigger an investigation.

3.4 Investigation Protocols

a. Initiation. HR shall begin a prompt, impartial, and thorough investigation within five (5) business days of receipt of a Report.
b. Investigative Steps. Protocols include, at a minimum:
i. assigning a trained investigator free from conflict of interest;
ii. interviewing the Complainant, Respondent, and relevant witnesses;
iii. reviewing pertinent documents, emails, and video footage;
iv. maintaining confidentiality to the extent practicable;
v. documenting all steps taken.
c. Duration. Investigations should be completed within thirty (30) calendar days absent extenuating circumstances, with written status updates provided to the Complainant every ten (10) days.
d. Findings. HR will issue a written determination of “Substantiated,” “Unsubstantiated,” or “Inconclusive,” along with recommended corrective action.

3.5 Corrective & Disciplinary Action

a. Upon a finding of Harassment or Retaliation, the Company shall implement remedial measures proportionate to the severity and frequency of the misconduct, including but not limited to: counseling, warning, suspension, demotion, or termination.
b. Remedial actions may include non-disciplinary measures such as workspace changes or no-contact directives.
c. The Company will communicate outcomes, consistent with privacy obligations, to the Complainant.

4. REPRESENTATIONS & WARRANTIES

4.1 Company Representations. The Company represents that this Policy:
a. complies with all applicable federal, state, and local anti-discrimination laws;
b. will be administered consistently and in good faith; and
c. shall be reviewed annually for legal compliance.

4.2 Employee Acknowledgment. By signing below, each Employee represents that he or she:
a. has read and understands the Policy;
b. agrees to comply with its terms; and
c. acknowledges that employment remains at-will unless otherwise provided by written contract signed by an authorized Company representative.

5. COVENANTS & RESTRICTIONS

5.1 Employee Covenants. Each Employee shall:
a. treat all Covered Persons with dignity and respect;
b. refrain from Harassment and Retaliation;
c. report suspected violations immediately; and
d. cooperate fully and honestly in any investigation.

5.2 Confidentiality. Information obtained in connection with a Report or investigation shall be shared strictly on a need-to-know basis, consistent with legal obligations.

5.3 Non-Disclosure of Proceedings. Employees shall not disclose investigation details except as permitted by law or HR.

6. DEFAULT & REMEDIES

6.1 Events of Default. A Covered Person is in default of this Policy upon:
a. engaging in Harassment or Retaliation;
b. knowingly filing a false Report; or
c. interfering with an investigation.

6.2 Notice & Cure. Where feasible, the Company will provide written notice of the default and a reasonable opportunity to respond before disciplinary action.

6.3 Remedies. The Company may impose any lawful remedy, including immediate termination, reassignment, or injunctive relief.

6.4 Attorneys’ Fees. The Company reserves the right to seek recovery of reasonable attorneys’ fees and costs from any individual found by a court to have brought a malicious or frivolous claim under this Policy.

[// GUIDANCE: Section 6 tees up fee-shifting only for bad-faith claims to avoid chilling legitimate complaints.]

7. RISK ALLOCATION

7.1 Indemnification. The Company shall indemnify Employees against third-party claims arising out of the good-faith performance of their duties under this Policy, except to the extent prohibited by law or resulting from willful misconduct.

7.2 Limitation of Liability. Nothing in this Policy limits statutory remedies or damages caps available under applicable law, including but not limited to the caps set forth in 42 U.S.C. § 1981a and any limitations under the PHRA.

7.3 Insurance. The Company shall maintain Employment Practices Liability Insurance (“EPLI”) with minimum limits of [INSURANCE LIMITS] to cover Harassment claims.

7.4 Force Majeure. Compliance deadlines may be reasonably extended due to events beyond the Company’s control (e.g., natural disasters, public health emergencies).

8. DISPUTE RESOLUTION

8.1 Governing Law. This Policy shall be governed by, and construed in accordance with, the laws of the Commonwealth of Pennsylvania, without regard to conflict-of-law principles.

8.2 Limited Arbitration.
a. Scope. Except for claims arising under federal or state discrimination statutes (including the PHRA and Title VII), which either party may elect to pursue in a judicial forum, all other employment-related disputes shall be resolved under the Company’s Arbitration Program.
b. Procedure. Arbitration shall be administered by [ARBITRATION ADMINISTRATOR] under its employment rules.
c. Costs. The Company will bear any forum costs that exceed the fee for filing a civil action in state court.

8.3 Forum Selection. Actions permitted to proceed in court shall be filed exclusively in the state courts sitting in [COUNTY], Pennsylvania.

8.4 Jury Trial. Consistent with Article I, Section 6 of the Pennsylvania Constitution, nothing herein constitutes a mandatory waiver of the right to a jury trial for statutory discrimination or harassment claims.

8.5 Injunctive Relief. Either party may seek temporary or permanent injunctive relief in a court of competent jurisdiction to enforce this Policy’s non-harassment, non-retaliation, or confidentiality provisions.

9. GENERAL PROVISIONS

9.1 Amendment & Waiver. The Company may amend this Policy at any time with notice to Employees. No waiver of any provision is effective unless in writing and signed by an authorized Company officer.

9.2 Assignment & Delegation. Employee rights and obligations under this Policy are personal and may not be assigned. The Company may delegate administration of this Policy to qualified third parties.

9.3 Severability. If any provision of this Policy is held unlawful or unenforceable, the remaining provisions shall remain in full force to the maximum extent permitted by law.

9.4 Integration. This Policy constitutes the entire anti-harassment policy of the Company and supersedes all prior oral or written policies on the subject.

9.5 Counterparts; Electronic Signatures. This Policy may be executed in counterparts, each deemed an original, and may be signed electronically under the federal E-SIGN Act, 15 U.S.C. § 7001 et seq.

10. EXECUTION BLOCK

IN WITNESS WHEREOF, the parties have executed this Workplace Anti-Harassment Policy effective as of the Effective Date first written above.

Company

[COMPANY NAME]
By: _____
Name: [AUTHORIZED OFFICER]
Title: [TITLE]
Date: ______

Employee Acknowledgment

I acknowledge that I have received, read, and understand the Workplace Anti-Harassment Policy. I agree to comply with its terms and understand that violation may result in disciplinary action up to and including termination.

Employee Signature: ____
Printed Name: ______
Date: _________

[// GUIDANCE: Retain signed acknowledgments for at least the statutory retention period for personnel records (currently no less than four (4) years under EEOC guidelines).]

© [YEAR] [COMPANY NAME]. All rights reserved.