Every workplace needs a sexual harassment policy. And policies are needed now more than ever before. Recent changes to sexual harassment law have shifted responsibility onto employers to prevent sexual harassment, not just react to it.
If you’re writing or updating your organisation’s sexual harassment policy, this guide will help. It covers what should be included in your policy and how to avoid common mistakes that stop it from being effective.
This guide covers Great Britain (England, Scotland and Wales). Northern Ireland has separate equality legislation.
Sexual harassment at work is a serious issue in the UK. According to a 2020 government survey, nearly a third of respondents who were in employment (29%) experienced workplace or work-related sexual harassment in the previous 12 months.
Sexual harassment can have serious consequences. For employees, it can severely impact their mental health, job satisfaction and overall wellbeing. Many victims report stress, anxiety and a diminished sense of safety at work, which can completely derail careers.
There are ramifications for employers, too. Unchecked harassment erodes trust among staff, which affects collaboration, productivity and retention rates. It also makes further harassment likely. Workplace cultures can quickly become toxic if staff recognise offensive behaviour won’t be challenged and victims won’t be supported.
And if employees can’t find support within their organisation, they can go elsewhere. Wronged employees can bring sexual harassment claims to an employment tribunal. If a claim against an employer is successful, the tribunal can award compensation. There’s no statutory upper limit on compensation for sexual harassment.
You can’t prevent sexual harassment if your company doesn’t take a stand on it. A well-written sexual harassment policy communicates expectations for behaviour and reinforces that harassment will not be tolerated. It also explains how staff who experience (or witness) sexual harassment will be supported and their complaints taken seriously.
Since 26 October 2024, employers have had a duty to take reasonable steps to prevent sexual harassment of employees. The Worker Protection (Amendment of Equality Act 2010) Act 2023 introduced this duty.
The Employment Rights Act 2025 strengthens it to all reasonable steps from 30 October 2026. From that date, employers will also be liable if a third party harasses an employee in the course of employment and the employer failed to take all reasonable steps to prevent it. This protection extends beyond sexual harassment to other harassment covered by the Equality Act.
The Equality and Human Rights Commission (EHRC) can enforce the preventative duty. If an employer loses a sexual harassment claim and has breached that duty, a tribunal can increase compensation by up to 25%.
As mentioned, employers must currently take reasonable steps to prevent sexual harassment, with this duty strengthening on 30 October 2026. Your policy will help with this. Employees who know what is and isn’t acceptable are more likely to behave professionally. And clear disciplinary procedures can help deter harassment.
But a policy alone isn’t enough to meet your preventative duties. You need to assess the risks of sexual harassment and anticipate where it’s likely to happen. Based on this assessment, you can plan how harassment can be prevented.
Consider risks such as power imbalances, lone working, work-related social events and contact with customers or clients. Record the actions needed, who is responsible and how you will check they work. The EHRC’s employer guide sets out practical prevention steps.
A good sexual harassment policy serves two purposes:
- It sets out your organisation’s position on sexual harassment.
- It establishes procedures for handling sexual harassment complaints.
The first point is ideological. Putting your commitments to staff safety and equality in black and white makes it more likely you’ll uphold them.
The second point is practical. While preventing sexual harassment is the goal, you can’t control employees. Some may still offend, humiliate or degrade their colleagues (as the statistics show). If harassment happens in your workplace, you need clear procedures to deal with it and reduce the risk of it happening again.
Your policy can stand alone or form part of a wider harassment policy. Acas recommends consulting recognised trade unions or employee representatives when developing it.
Below, we’ve outlined the essential elements of an effective sexual harassment policy.
Staff need to know what is and isn’t acceptable at work. Your policy should make clear that calling behaviour “banter” does not excuse sexual harassment.
So, your policy must define:
- What sexual harassment is, with examples of unacceptable behaviour.
- How harassment is distinct from bullying.
- Where the policy applies, including work-related events, business travel, online communications and harassment from third parties such as customers and clients.
- Who the policy covers, including staff at every level, temporary and agency staff, contractors and job applicants.
It should also clarify that sexual harassment means unwanted conduct of a sexual nature that has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. No intention to cause harm is needed. When considering the effect, the person’s perception, the circumstances and whether it was reasonable for the conduct to have that effect all matter. Conduct intended to have one of those effects can qualify even if the person is not upset.
Employees need to know how to report incidents and feel confident that their concerns will be taken seriously.
Your policy should outline multiple reporting channels so employees can always speak to someone objective, including when their line manager is involved in the complaint.
Also, highlight that reporting is a positive step, and anyone who makes a sexual harassment complaint will be listened to and supported. Explain how confidentiality will be protected and its limits: information may need to be shared with those involved in investigating or resolving the complaint fairly. Do not promise complete secrecy or anonymity.
Explicitly prohibit victimisation, such as treating someone badly because they raised or supported a discrimination or harassment complaint. An unsuccessful complaint does not by itself justify disciplinary action; false allegations made in bad faith are different.
Link to your whistleblowing procedure too. Since 6 April 2026, sexual harassment has been an express category under whistleblowing law. Protection still depends on the legal conditions, including a reasonable belief that the disclosure is in the public interest. Confidentiality requirements must not prevent protected whistleblowing or reporting a crime to the police.
Employees need to understand what happens after a report is made and trust that their complaints will be resolved appropriately. There are two main routes:
- Informal resolutions: Where appropriate, employees can choose to seek an informal resolution. Mediation may help in some cases, but participation must be voluntary. Employees must not be pressured into an informal process. Serious allegations may require formal action even if the employee does not want to raise a formal grievance.
- Formal resolutions: More serious complaints, or those raised formally by employees, should trigger a structured investigation. This involves an impartial, suitably trained investigator gathering evidence and all parties presenting their version of events. If complaints are upheld, appropriate disciplinary action may follow, up to and including dismissal after a fair procedure.
Set out employees’ right to appeal and workers’ right to request a colleague or eligible trade union representative at formal harassment grievance meetings. Explain how written decisions will be communicated, following the Acas Code of Practice.
For third-party harassment, explain what action you can take against customers or clients, such as warnings, banning access or ending contact. Review the risk assessment and prevention measures after complaints.
Keep written records of complaints and outcomes, with secure storage, restricted access and retention periods that comply with data protection law.
Employees might not report harassment if they see other complaints being ignored or cases dragging on. Including timescales can help ensure complaints are handled promptly.
While most cases should follow the standard timeline, complex situations will take longer to resolve. If there are any delays, be transparent with all parties and provide regular updates.
Take delayed reports seriously. Explain that internal complaints and appeals do not pause tribunal deadlines. For most claims concerning events on or after 1 October 2026, the limit is six months minus one day; earlier events generally have a three-month-minus-one-day limit. Timely notification to Acas pauses the limit during early conciliation. Direct employees to Acas guidance on time limits, especially for continuing harassment or multiple incidents.
Sexual harassment can be extremely distressing. Your policy should summarise how employees who’ve been affected by harassment will be supported. Provide information about counselling or employee assistance programmes available to staff.
Include support for witnesses and those accused, without prejudging the complaint. Explain arrangements for time off related to harassment, such as counselling or sickness absence. Acas advises that this should usually be paid and should not count towards absence triggers.
Also, be sure everyone who handles complaints has been trained to do so.
Training helps make your policy effective and understood. Include:
- Mandatory staff training that covers what constitutes harassment, how to report it and your zero-tolerance policy.
- Manager-specific training on handling complaints, conducting investigations and supporting employees.
- Refresher courses to reinforce key points and address any policy changes.
Awareness training should be supported by role-specific training for anyone responsible for investigating complaints or making disciplinary decisions.
Even the best-written policies will fail if they’re not implemented correctly. Below are common mistakes to avoid.
Policies that aren’t regularly reviewed can become outdated or ineffective. Set a clear schedule for reviewing your policy – at least annually and after significant changes in law or workplace dynamics. Use employee feedback and incident data to refine the policy and ensure it stays relevant and effective.
Employees won’t pay much attention to policies that are hard to follow or access. Provide personal copies (either in print or digital) so employees can read them privately.
Use plain, straightforward language to make it easy for everyone to understand, regardless of their role or literacy level.
If employees don’t confirm they’ve read and understood the policy, it weakens its effectiveness. Ask all staff to sign an acknowledgement form to confirm they have read the policy. Check understanding through training and questions; a signature alone does not demonstrate it.
Managers play a key role in enforcing your policy. If they fail to champion it or handle complaints consistently, the policy will lose credibility. Train managers to understand and follow the policy and encourage them to remind staff regularly of its key points. Visible commitment from leadership reinforces the organisation’s stance against harassment.
To help fulfil your legal duty to prevent sexual harassment, managers need to implement your policies and handle complaints appropriately.
Our online Sexual Harassment Awareness Training course helps employees and managers recognise unacceptable behaviour, understand legal responsibilities and know what to do if they experience or witness sexual harassment. It also covers ways to help prevent harassment at work.
