Category: Discrimination

Zero Tolerance Anti-Harassment Policies

Zero-Tolerance Anti-Harassment Policies

Every organization should have a written anti-harassment policy. These policies should prohibit harassment based on all legally protected characteristics. This usually include sex, race, age, disability, and religion, among others. I suggest that most employers should have “zero tolerance” for violations of these policies. But what does that mean?

[Related Webinar: Investigating Workplace Harassment Complaints Without Making It Worse]

What Is Zero Tolerance?

I have written and reviewed anti-harassment policies for over a decade. I have even argued over them in court. You may be surprised that I’ve probably spent more time defending companies for firing employees who violated these policies than I have spent defending employers against claims of harassment itself! It turns out that employees don’t always accept that they’ve harassed someone or, at least, they don’t accept the consequences.

Over the years, I’ve realized that many people don’t understand what the “zero-tolerance” provision of their anti-harassment policy means. They often think it means they must fire anyone who violates the policy. But that’s not what it should mean.

You can have zero tolerance without automatically removing every offender from the workplace. You just have to take harassment seriously and address every violation of the policy appropriately.

Whom Does the Policy Cover?

Zero tolerance means the policy covers everyone.

This includes everyone in the organization, regardless of title, responsibility, performance, etc., all the way up to the CEO and owners. It also includes third parties who interact with the organization: contractors, vendors, customers, clients, etc. No one is important enough to be immune.

No one should be harassing your employees. If they are, do something about it!

Zero Tolerance Responses

Good employers also demonstrate zero tolerance by taking meaningful action when they decide someone has harassed an employee. They don’t decline to act just because the harassment isn’t illegal. (Read more about What Makes Workplace Harassment Unlawful.)

The anti-harassment policy should identify who is responsible for enforcing it and to whom employees should report harassment. Once management knows of a harassment allegation, the company must investigate promptly. Then, based on the investigation, it will decide what steps to take next.

Sometimes the company will conclude that no harassment occurred. Even if that’s the case, it should consider whether anything else should be done. Was there a misunderstanding to address? Will it still be too toxic to have certain employees working together?

And when there is some finding of harassment, the range of potential consequences is broad. In minor cases, it may be enough for the individuals involved to be reminded of the anti-harassment policy, made aware of the concerns, and directed not to retaliate or repeat the unwelcome behavior. Other times, the employer should discipline the offender(s). This can range from a verbal or written warning up to termination of employment.

Employers must also consider whether to act beyond the people involved in specific instances of harassment. Is it time to conduct anti-harassment training across the organization, or at least in a particular department or segment of the company? Do they need to update the anti-harassment policy itself?

 

If you are responsible for responding to harassment complaints in your organization, check out my free webinar on Investigating Workplace Harassment Complaints Without Making It Worse: My Top 7 Tips for Performing This Unenviable Task That Everyone Wishes Wasn’t Necessary!

Trick or Treat Sexual Harassment

Workplace Trick or Treat: Sexual Harassment

Sexual harassment is a hot topic in the media these days. Frankly, it’s hot in more than one sense. In the “hot potato” sense, in that no one really wants to touch it. But also in terms of these definitions of “hot” from Merriam-Webster: “of intense and immediate interest” and “marked by violence or fierceness.”

Trust me, I don’t want to be talking about sexual harassment myself. Mostly because I wish it didn’t happen.

I’m not here to give a personal story. I’m not a victim. But I do have experience dealing with claims of sexual harassment. This actually dates back to college, where I was not only involved in investigating student sexual harassment allegations, but also in training other students to investigate them. Fortunately, I guess, there weren’t that many investigations. But, on the other hand, what does that mean? Were there too many not coming forward?

Because I’m now an employment lawyer helping employers do the right things and protect themselves, I’m focusing on the workplace here. But, of course, sexual harassment, assault, and abuse also affects many other aspects of our lives.

Sexual Harassment: The Laws

Title VII of the Civil Rights Act of 1964 prohibits discrimination in employment because of sex (among other characteristics). Harassment is a form of discrimination. Thus, Title VII prohibits sexual harassment in the workplace.

Outside of the employment context, Title IX of the Education Amendments of 1972 prohibits sexual harassment (and other forms of sex discrimination) in educational programs and activities.

Most states also have employment discrimination laws that make sexual harassment unlawful.

Sexual assault is also illegal, of course. It can be both a criminal offense and a civil one (a tort). Beyond employment discrimination laws, employers could, in some cases, be held legally culpable for enabling, permitting, tolerating, etc., sexual assault.

Read here for more on What Makes Workplace Harassment Unlawful?

More Than a Legal Problem

The recent media attention on sexual harassment and assault identifies some high profile perpetrators. They may be celebrities. They may be wealthy. Regardless, they usually have jobs (or run their own businesses).

Sexual harassment and assault are wrong in themselves and in a million ways. But let’s just consider the employment context. What are some negative impacts?

Let’s face it, sexual harassment isn’t good for morale. Even unintentional, relatively minor instances (I’m not trying to define them here) can permeated the workplace. They may only upset one employee. Or one employee can tell another, and people get uncomfortable. An otherwise respected boss or co-worker falls out of favor (probably rightly so, though some are occasionally falsely accused).

Unfortunately, not all cases of sexual harassment are reported to human resources or others in the organization that could hopefully do something about it. But the ones that are demand action. That requires resources (time, money, etc.) that companies would rather be able to spend elsewhere. We can’t blame this on the victims. The blame is on those behaving inappropriately. But, nonetheless, we can all agree it would be better if there were no harassment to be investigated in the first place.

What’s the Fix?

Sexual harassment is wrong, and it’s bad. That doesn’t mean it’s easy to cure. But it also doesn’t mean we shouldn’t try.

Briefly, here are some basic elements every employer should implement:

  • Anti-harassment policy
  • Training all employees
  • Additional training for supervisors
  • Effective complaint procedures
  • Designated compliance officers
  • Prompt investigations
  • Effective remedial action

Additional steps may be appropriate for some employers. These could include, for example, conducting workplace satisfaction surveys, expanding the human resources team, and other initiatives to promote pervasive professionalism.

Don’t Ignore It

I hope the recent public disclosures and related dialogue about this subject will help reduce sexual harassment. But no one should assume it can’t happen to them or in their organization.

Employers and their management teams must take the lead to put out any flames before they spread. The financial motivation itself is real. Some legal settlements have recently been reported to reach the range of $32 million to a single victim. Most employers would not survive that loss, or even anything close. The public relations backlash could be even worse.

But, most important, people must live with themselves and sleep at night. That alone is reason enough not tolerate harassment on our watch.

Workplace Harassment

What Makes Workplace Harassment Unlawful?

Investigating Workplace Harassment Complaints
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Most employers do or should have zero tolerance policies regarding workplace harassment. These policies don’t exist just for legal reasons. Harassment is bad in itself, plus it interferes with productivity. But not all harassing behavior violates employment discrimination laws.

First, let’s define harassment. Then, we’ll discuss when harassment becomes legally actionable.

[Click here to get my FREE step-by-step Guide to Investigating Workplace Harassment Complaints!]

What Is Harassment?

Under state and federal employment discrimination laws, harassment is unwelcome conduct based on a protected category.

These laws collectively protect many characteristics.

At the federal level: Title VII protects race, color, sex, religion, and national origin. The Americans with Disabilities Act protects qualified individuals with disabilities. The Age Discrimination in Employment Act protects age, for workers 40 or older. The Genetic Information Nondiscrimination Act protects genetic information, which includes a broad range of information about family medical history.

State laws often protect these same categories, plus others. Some states protect sexual orientation, marital status, familial status, etc. Michigan law even protects workers from harassment because of height and weight.

These laws also usually protect against harassment based on an individual having complained of discrimination. In other words, they prohibit retaliation.

However, one or two isolated comments, even if unwelcome, may not violate these laws.

Unlawful Workplace Harassment

Harassment becomes unlawful where:

  1. enduring the offensive conduct becomes a condition of continued employment, or
  2. the conduct is severe or pervasive enough to create a work environment that a reasonable person would consider intimidating, hostile, or abusive.

The “reasonable person” standard means that it’s not enough that the specific employee involved feels this way. If most similarly situated people would not be offended, then the conduct wouldn’t rise to the level of being unlawful. Again, that doesn’t mean it is acceptable in the workplace.

Forms of Harassment

Harassment can come in numerous forms, including:

  • offensive jokes,
  • slurs,
  • epithets or name calling,
  • physical assaults or threats,
  • intimidation, ridicule or mockery,
  • insults or put-downs,
  • offensive objects or pictures, and
  • interference with work performance.

Note that the anti-discrimination laws protect employees from workplace harassment not only by co-workers and supervisors, but also by third parties. Thus, employers must prevent and remedy inappropriate conduct by vendors, customers, visitors, contractors, etc., against their employees. If employers permit harassment by outsiders to persist to the point of unlawful harassment, then the employer may be legally responsible.

How To Avoid Unlawful Harassment?

The best way to avoid unlawful harassment is to prevent harassment altogether. This is why employers should have anti-harassment policies that go beyond just what the law prohibits. It’s not a good idea to permit behavior that even comes close to the line.

In addition to a well-written and carefully followed policy, employers should also train employees about harassment. Many employers include anti-harassment training in their on-boarding process. But it is a good idea to also provide periodic group training to all employees. Several states require private employers to do so.

Finally, employers must respond promptly to all complaints of workplace harassment. Investigating thoroughly and taking appropriate action will hopefully avoid escalation. If not, the employer’s good faith attempt to keep the workplace free of harassment may still help avoid liability.

For more, read: Responding to Employment Discrimination Complaints and download my Guide to Investigating Workplace Harassment Complaints.