From 30 October 2026, employers need to be ready for changes to their responsibilities around preventing third-party harassment. With the deadline approaching, now is the time to review your policies, assess the risks and make sure your people are protected.
When we think about workplace harassment, we often focus on behaviour between colleagues. But harassment can also come from customers, clients, suppliers, contractors, service users and members of the public.
Whether it happens in your workplace, at a client’s premises, during a meeting or while an employee is working in the community, employers need to consider how they protect their people from inappropriate behaviour by third parties.
What does this mean for employers?
The focus is on prevention, not simply responding after an incident has occurred. Employers should take a proactive, risk-based approach, with measures that reflect the nature of their organisation and the risks employees face.
There is no single checklist that guarantees compliance. However, there are practical steps every employer should consider.
- Assess the risks
Identify where employees may be exposed to harassment. Consider customer-facing roles, lone working, external visits, online meetings and interactions with suppliers or service users.
Speak to employees, review previous incidents and identify any patterns or areas of particular concern.
- Review your policies and procedures
Make sure your harassment policy explicitly addresses third-party behaviour. Employees should know how to report concerns, what support is available and what action the organisation may take.
Your policy should reflect what happens in practice, not simply set out what the organisation intends to do.
- Train managers and employees
Employees need to recognise harassment and understand how to report it. Managers need to know how to respond, support affected employees, assess risks and take appropriate action.
Use realistic scenarios to explore situations where the person responsible is a customer, supplier or important client.
- Establish trusted reporting channels
Make sure employees can raise concerns safely and confidently, including where the person involved is a senior colleague or commercially important contact.
Reporting routes should be clear, accessible and supported by a process that ensures complaints are taken seriously and followed up.
- Review customer, client and supplier arrangements
Consider whether contracts, terms of business and codes of conduct set clear expectations about respectful behaviour towards your employees.
Managers should understand what action can be taken when those expectations are breached, from raising concerns formally to changing working arrangements or ending a relationship where appropriate.
Your biggest customer is no exception. Commercial relationships should not mean employees are expected to tolerate harassment.
- Record incidents and review what works
Record incidents, the action taken and any support provided. Look for recurring issues and use what you learn to improve your preventative measures.
A policy and training session are not enough if the same problems continue to occur. Prevention requires ongoing review and a willingness to act.
A practical checklist for employers
With 30 October 2026 approaching, ask yourself:
- Have we assessed the risks of third-party harassment across our organisation?
- Have we reviewed our harassment policies and procedures?
- Do managers and employees know how to recognise, report and respond to harassment?
- Are our reporting channels accessible and trusted?
- Have we reviewed relevant customer, client and supplier terms?
- Do managers know what action they can take when a third party behaves inappropriately?
- Are incidents recorded, investigated and followed up?
- Do we review whether our preventative measures are working?
- Can we demonstrate the steps we have taken and explain why they are appropriate to our risks?
If you cannot confidently answer these questions, now is the time to identify the gaps and agree an action plan.
A policy in a folder won’t protect your people
Preventing harassment is about more than having the right wording in a policy. It requires a culture where employees feel safe raising concerns, managers know how to respond and the organisation is prepared to act.
Employees should not have to choose between protecting their dignity and keeping a customer happy. Nor should they feel that reporting inappropriate behaviour will be seen as an inconvenience.
The approaching deadline is an opportunity to review your approach, strengthen your procedures and make sure your commitments translate into meaningful action.
The question is not simply whether you have a policy. It is whether your people are protected and whether you can demonstrate what you have done.
Is your organisation ready?
Don’t wait for an incident to reveal the gaps. Review your current arrangements, identify areas for improvement and make sure your preventative measures are working in practice.
If you need support reviewing your policies, assessing risks or developing practical training for managers and employees, taking action now can help you build a safer and more respectful workplace.