A new legal duty for all employers
Since 26 October 2024, all UK employers have been under a legal duty to take reasonable steps to prevent sexual harassment at work.
This isn’t a vague recommendation or a future change to plan for, it’s already in place. If you haven’t taken those steps yet, your organisation could be exposed to legal, reputational and operational risk.
The bar is now higher. Employers are expected to be proactive, not reactive. You can’t wait for an incident to happen before acting and the duty doesn’t stop after one round of training or a policy update, it’s ongoing.
But what does “reasonable” actually mean in practice?
Although the updated guidance from the Equality and Human Rights Commission (EHRC) is still out for consultation, there are some helpful pointers. Employers need to take a contextual, risk-based approach depending on their size, industry, and how their people work.
Here’s a practical summary of what that looks like in real terms to take reasonable steps to prevent sexual harassment at work.
Why This Matters
If your business hasn’t taken reasonable steps to prevent sexual harassment at work, you’re already at risk. There was no grace period, no transition phase, no waiting for the dust to settle. The obligation is active now, and it doesn’t end after the first intervention.
What’s more, although the final legislation removed a specific duty to prevent harassment from third parties (like customers or clients), the EHRC guidance makes it clear: employers are still expected to take reasonable steps to protect staff from that kind of behaviour too.
In short, this is about protecting your people, your culture, and your business.
A Practical Framework for Employers
1. Risk Assessment
Start by getting honest about the risks in your own organisation. That might include:
Gender imbalance or power dynamics within teams
Use of alcohol at work events or social functions
Lone working, remote settings or unsupervised spaces
Exit interviews or internal surveys flagging culture concerns
Whether third-party contact is common (clients, customers, suppliers)
Past complaints or how previous allegations were handled
How accessible and trusted your reporting routes really are
No workplace is zero risk. The point is to show that you’ve thought about it and taken action based on that.
2. Training
Without training, you’re unlikely to meet the legal threshold.
Annual refreshers are a sensible benchmark, especially with new joiners or turnover
Training should be tailored – different content for managers, leaders, and employees, and specific to your company’s needs
Cover the legal definitions, real-world examples, bystander guidance, and how to report concerns
Delivery matters – carve out proper time, use skilled trainers, and make senior leaders visible and accountable
Track attendance and check the training actually lands
This isn’t about running a 3-day course, it’s about getting the core messages across in a meaningful, memorable way.
3. Policies and Contracts
Your anti-harassment policy should be:
Clear, current, and reviewed at least once a year
Easy to find (not buried in an HR drive)
Realistic in tone, especially around what “zero tolerance” means in practice
Referenced in induction processes and contracts
Think beyond employees too. What message are you sending to:
Contractors, agency staff and freelancers?
Clients and suppliers?
Visitors to your premises?
If you’ve got third parties interacting with your people, it’s worth making expectations explicit.
4. Employee Experience
How your people experience your process is just as important as what’s written down.
Do managers respond with empathy, urgency, and confidentiality?
Are complainants supported, not sidelined?
Are policies followed in practice or quietly ignored when it’s inconvenient?
Are responses proportionate, fair and evidence-based?
Even the best policy or training won’t count for much if real-life situations are handled poorly.
5. Taking Action Now
You don’t have to be perfect, but you do need to show that you’ve tried.
If you’re just starting to engage with this, the priority is to take visible, documented action. That could mean:
Scheduling mandatory training
Updating your policy and making it more accessible
Running an employee pulse survey or culture audit
Getting support from an external HR partner
Doing something is better than doing nothing and even partial progress helps you demonstrate intent if challenged.
No more grey areas – this law is here
There’s no single checklist for the prevention of sexual harassment and no one-size-fits-all approach, but doing nothing is no longer a valid option.
If you’re not confident your business is meeting the duty, now is the time to assess the gaps and put things right. The reputational and legal consequences of falling short are real. But so are the benefits of getting this right – for your people, your culture and your credibility as an employer.
How Popoki HR can help
We support businesses of all sizes to create safer, more inclusive and legally compliant workplaces. This includes:
Conducting risk assessments and culture audits
Reviewing and updating your policies
Designing and delivering engaging, legally accurate training on the preventions of sexual harassment at work
Supporting managers to handle allegations sensitively and correctly
Providing advice and coaching around tricky situations
If you need help understanding your obligations or building a practical plan, we’re here to help.
Let’s make sure your business is compliant and your people feel protected.