Making the Business Case for Sexual Harassment Awareness

Around 29% of employees in the UK reported experiencing sexual harassment at work in the previous 12 months, but only 15% formally reported it (Government Equalities Office, 2021). Complaint numbers at any single organisation are therefore unlikely to show the full scale of the problem.

Underreporting persists partly because speaking up can carry personal consequences. The UK survey found that, among those who took action after experiencing harassment, 40% saw their job change and 41% saw no consequences for the person responsible (Government Equalities Office, 2021).

When the person who raises a concern bears the cost of speaking up, silence can become the safer option. An organisation that takes comfort from low complaint numbers may be seeing a reporting failure, not a culture with genuinely low incidence.

UK employers covered by the Equality Act 2010 must take reasonable steps to prevent sexual harassment at work. The Worker Protection (Amendment of Equality Act 2010) Act 2023 introduced a positive duty to prevent sexual harassment from 26 October 2024 (Worker Protection Act, 2023). Equality and Human Rights Commission (EHRC) guidance makes clear that employers must consider risks from colleagues and third parties, such as customers, clients, service users and members of the public (EHRC, 2024).

Prevention under the positive duty cannot be treated as a paper exercise. EHRC guidance says employers should anticipate where sexual harassment could happen and take action before an incident occurs (EHRC, 2024). An employer is unlikely to meet the duty without carrying out a risk assessment (EHRC, 2024).

“Reasonable steps” is not a fixed checklist. What counts as reasonable depends on the organisation’s size, resources, type of work, working environment, level of risk and the steps the employer has actually taken (EHRC, 2024).

A two-year-old training module, completed once and never revisited, is unlikely to be enough on its own. Training that staff do not understand, remember or take seriously is weak evidence of prevention.

Acas provides employers with a practical route to meeting the duty. Employers need to assess the risks in their own workplace and put proportionate measures in place before sexual harassment occurs (Acas, 2026).

A proper assessment should consider the sector, job roles, ways of working, customer or client contact, work-related social events, power imbalances and groups of workers who may be more exposed to harm (Acas, 2026).

UK law is moving towards stronger, more active prevention. Section 20 of the Employment Rights Act 2025 is expected to strengthen the duty by changing the test from ‘reasonable steps’ to ‘all reasonable steps’, although the provision is not yet in force (Employment Rights Act, 2025).

Acas states that the ‘all reasonable steps’ requirement is expected to apply from October 2026, with further detail on what ‘reasonable steps’ means expected in 2027 (Acas, 2026).

Good prevention needs more than a written policy. Employers need clear reporting routes, training for staff and managers, senior ownership, regular reviews of policies and training, and a workplace culture where sexual harassment is challenged rather than ignored, excused or treated as ‘part of the job’ (Acas, 2026; EHRC, 2024).

The business case for sexual harassment awareness is strongest when it is linked to costs leaders already recognise, including retention, reputation, productivity and leadership credibility. The legal duty matters, but the commercial case is often what makes the investment decision clearer.

People who experience harassment may leave without making a formal complaint or explaining the real reason in an exit interview. In the UK survey, 17% of those who took action looked for a new job (Government Equalities Office, 2021).

A global 2025 Deloitte survey found that only 5% of women planned to stay with their current employer for more than five years, with personal safety and non-inclusive workplace behaviour among the most common concerns (Deloitte, 2025). Replacement and onboarding costs are among the clearest commercial losses linked to harassment, but organisations often overlook them when building the board-level cost case.

Candidates often judge employers by how they handle concerns, not just by the policies they publish. A reputation for ignoring or mishandling harassment can undermine recruitment, while a credible commitment to a safe working environment can help employers compete for stronger candidates.

A workplace where harassment goes unchallenged loses more than the time spent handling individual incidents. Psychological safety, meaning the shared confidence that staff can raise concerns or admit mistakes without being punished, is likely to break down when harassment is tolerated.

Research in hospitality found that workplaces which tolerated sexual harassment saw higher emotional exhaustion and lower engagement, including among employees who were not directly targeted (Russen et al., 2024). A separate study found that even-handed management reduced both the likelihood of harassment and the productivity cost for victims and witnesses (Vara-Horna et al., 2023).

McKinsey’s 2025 Women in the Workplace research links workplace experience, inclusion, and career motivation and reports ongoing differences between women’s and men’s workplace experiences (McKinsey & Company, 2025).

The productivity cost of a culture that tolerates harassment commonly extends beyond those directly targeted.

In many organisations, staff watch how leaders respond to harassment, and the people the organisation most wants to keep often pay the closest attention. If a senior manager appears to protect a high-status offender, the message is not limited to that case. It may tell capable people that standards are applied unevenly, and they may act on that information.

Sexual harassment awareness training often fails because it is delivered as a one-off module that staff complete and quickly forget, rather than as part of a system that changes behaviour. The content is typically so generic that it does not reflect the situations people actually face at work.

Completion rates may rise while behaviour stays the same. In that case, training creates evidence of activity without creating a safer workplace.

A structured review of published research on workplace interventions found that they improve knowledge and attitudes more reliably than they change behaviour (Diez-Canseco et al., 2022). The US Equal Employment Opportunity Commission (EEOC) review reached a similar conclusion a decade earlier. Even effective training cannot do the work alone (Feldblum & Lipnic, 2016).

Training that shifts behaviour is tailored to the roles and risks of the audience. It uses scenarios that reflect real workplace dynamics, is refreshed regularly and includes specific content for managers. Bystander training — which prepares staff to recognise and safely intervene when they observe inappropriate behaviour — is especially useful because it moves the focus from individual victims to shared responsibility and increases willingness to intervene (Nielsen et al., 2025; Barta et al., 2026).

Training is necessary, but only works when the conditions around it support action. People need to recognise harassment in ambiguous situations. Managers need to know how to respond. Those who report concerns need to believe action is likely to follow. Without those conditions, even good training is likely to stall.

Effective sexual harassment prevention works as a system of mutually reinforcing controls, not as a single intervention. Four elements matter most.

Senior leaders who delegate prevention entirely to HR leave a gap in the cases where authority matters most. Serious concerns often require visible leadership, not just a process managed in the background.

Visible commitment means taking part in training, responding to concerns openly and applying the same standard to high-status colleagues as to everyone else. Where leaders step back, the workplace standard becomes whatever they appear willing to tolerate.

Generic scenarios rarely change how people think or behave. Training is more likely to work when it reflects the actual workplace, including the sector, team structure, power dynamics and exposure to third parties. EHRC guidance recommends adapting training to role, seniority and risk profile (EHRC, 2024).

People need more than one way to raise a concern, and they need confidence that speaking up is unlikely to count against them. Multiple reporting channels, backed by visible follow-through, build that confidence over time.

Acas (2026) recommends combining named and anonymous reporting routes with regular climate surveys. A climate survey is a short, anonymous staff poll that tests whether people feel safe enough to speak up.

One training session a year is not a prevention programme. Organisations that maintain the standard build prevention into induction, manager one-to-ones, climate surveys and incident reviews. The EHRC recommends comparing complaint data with survey responses, exit interviews and absence patterns to detect what formal reporting may miss (EHRC, 2024).

McKinsey’s Women in the Workplace research recommends repeated, relevant, high-quality training supported by managers. It also highlights the importance of refreshers and a speak-up culture for addressing non-inclusive behaviour before it becomes normalised (McKinsey & Company, 2023).

Organisations commonly make four mistakes in sexual harassment prevention.

In many organisations, sexual harassment is treated as an HR problem rather than a leadership one, with HR left to manage concerns without the level of authority often needed. When this happens, the response is likely to stall in the cases that matter most.

Some leadership teams treat a low complaint rate as evidence that harassment is not happening. The prevalence figures above make that assumption unsafe unless the organisation has actively built the conditions for reporting.

The EHRC advises against treating complaint volumes as a proxy for safety, because reporting is shaped by trust, fear of retaliation and perceived consequences (EHRC, 2024).

Thorough investigation matters. But an organisation that focuses only on handling complaints correctly, rather than reducing the conditions that lead to them, is acting after harm and business cost may already have occurred.

The legal duty under the Worker Protection Act 2023 is preventive by design. The cultural and commercial case points the same way. Organisations should treat a complaint as a warning sign, not the starting point for prevention.

Harassment does not only come from colleagues. Customers, clients, suppliers and visitors can all create risk, especially in public-facing sectors. Acas (2026) flags lone working, alcohol, work travel and overnight stays as higher-risk conditions. A prevention system that only considers colleague-to-colleague harassment leaves a significant gap.

Making the internal case for sexual harassment awareness starts with framing it as an investment, not a training cost. The strongest case connects prevention to measures senior leaders already understand, such as turnover, absence, productivity, legal exposure and reputation.

The argument becomes stronger when it starts with what unresolved harassment can cost. The EEOC task force identified several cost channels: legal representation, settlements, litigation, tribunal awards, unreported harm, productivity loss and turnover (Feldblum & Lipnic, 2016). Most organisations connect only some of these costs to harassment, so the full commercial impact is often underestimated.

A direct comparison makes the argument clearer. A structured prevention programme has a defined and bounded cost: policy review, manager training, scenario-based employee learning and functioning reporting routes. A single unresolved case can absorb management time, HR investigation hours, legal fees, tribunal exposure, team productivity and replacement costs.

In many organisations, prevention is easier to justify once it is compared with the cost of a mishandled or unresolved case. The case for investment becomes clearer when it is framed as risk control, not as a standalone training budget line.

The strongest proposal is practical and structured. It should look closer to the ‘reasonable steps’ expected by UK regulators than to a single training purchase.

A practical pathway would be to:

1. Review the existing policy against current EHRC guidance.
2. Train managers to recognise concerns and respond appropriately.
3. Provide scenario-based learning for all employees.
4. Set up named and anonymous reporting routes.
5. Run a climate review every six months to test whether confidence and behaviour are improving.

The legal duty supports urgency, but it is often more persuasive as reinforcement than as the headline of the proposal (EHRC, 2024; Acas, 2026).

If the case is built around measurable indicators, leadership can see what they are signing off and how progress can be judged over the next twelve months. Useful indicators include confidence in speaking up, time from report to first response, consistency of outcomes, exit interview patterns and clusters of third-party incidents.

This article has explained how widespread sexual harassment remains in UK workplaces, what the positive duty under the Worker Protection Act 2023 requires of employers and why effective prevention creates commercial as well as legal value.

Low complaint numbers are not evidence that harassment is not occurring. Training alone does not change behaviour unless it sits within a system that includes clear standards, safe reporting routes, manager accountability and regular review. The internal case for prevention is strongest when it is framed as risk control and compared directly with the cost of a mishandled or unresolved case.

If your organisation is building or strengthening a prevention programme, Human Focus’s sexual harassment awareness course gives employees and managers the knowledge and confidence to act as part of that system. The course provides scenario-based learning tailored to workplace roles and risk profiles.