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All reasonable steps, or just good intentions?

It’s easy to assume your business is small enough, modern enough, or well-intentioned enough that harassment “wouldn’t really happen here.” Or to quietly tell yourself, we’ll deal with it if it ever becomes an issue.

That is a dangerous approach.

Sexual harassment risk is not about size, sector or brand. It’s about whether you can evidence the steps you’ve taken to prevent it.

Under the Equality Act 2010, employers can be held vicariously liable for harassment carried out by employees, even without knowledge or approval.

The only meaningful defence is being able to show you took “all reasonable steps” to prevent it.

That means more than having a policy on paper. It means being able to demonstrate:

🚨Clear, current and visible behavioural standards
🚨Regular, meaningful training for all staff
🚨Trusted and accessible reporting channels
🚨 Risk assessments which are actioned
🚨Swift, consistent action when issues arise
🚨Leadership that models the behaviour expected

With increased scrutiny and strengthened duties around preventing sexual harassment, “we’ll deal with it later” is no longer a safe strategy.

If challenged tomorrow, could you evidence the reasonable steps you have taken before anything went wrong?