How to Set Up a Workplace Harassment Prevention Programme

What is a harassment prevention programme?

A harassment prevention programme is the set of people, routes, documents and habits an employer uses to stop harassment, bullying and discrimination before they happen and to respond fairly when they do. A policy is one part of it. The rest is what makes the policy true on the day someone speaks: a manager who knows what to say, a committee that has been trained, forms that keep an investigation on track, and a leader who has signed and meant it.

It helps to think of the programme as three loops. You build it once, which takes around twelve weeks for a small or mid-size employer. You run a yearly cycle of training, awareness, surveys and reporting. And you handle each concern through the same steps, every time. The table sets out the ten elements most good programmes share.

Why is prevention better than waiting for complaints?

Because most people who experience harassment never complain. In 2022 the International Labour Organization, Lloyd's Register Foundation and Gallup published the first global survey on the subject, based on interviews with nearly 75,000 employed people in 121 countries and territories. Almost 23 percent had experienced violence or harassment at work, and only about half of them had told anyone. The most common reasons for staying silent were that it would be a waste of time and fear for their reputation.

Those two reasons are a design brief. People stay quiet when they expect nothing to happen and when they expect to pay for speaking. A programme changes both expectations by being visibly fair, by acting, and by protecting people afterwards. Several countries now expect exactly this: the UK places a duty on employers to take reasonable steps to prevent sexual harassment, Australia has a positive duty, and India has required an Internal Committee in most workplaces since 2013. The details differ and change, so check your own law with counsel.

What should a workplace harassment policy include?

A useful policy is written for the person who is upset and wondering whether to say anything. It should tell them, in plain words, what counts, where to go, what will happen, and what protects them. Write one definition of each term that is at least as protective as the strictest law you face, and add examples from your own industry, including one from chat or video and one involving a customer.

The most common gap is scope. Much of the conduct a programme sees happens in messages late at night, at client dinners, on trips and on video calls. A policy that stops at the office door fails its first test.

• Commitment from leaders, signed and dated
• Who and where the policy covers, including remote work, events, travel and third parties
• Definitions of harassment, sexual harassment, bullying, discrimination and retaliation, with examples
• How to raise a concern, with every route named
• How concerns are handled, with the day counts you will actually meet
• No retaliation, confidentiality on a need-to-know basis, and records
• Support available to both people, including external helplines
• Training, review date and who owns the policy

How many ways should employees have to report harassment?

At least three. The line manager is the most familiar route, but the manager may be the subject of the concern, a friend of the subject, or simply someone the person does not trust with it. So offer the manager or any manager, the programme owner or HR, and a committee or responder team that includes someone from outside the organisation. An online form is a useful fourth route, and where your law provides an external body, name it.

Be honest about anonymous reports. An organisation usually cannot interview or update someone it cannot identify, and it rarely can act against an individual on one anonymous report. It can look for patterns, review the area and take protective steps. Saying that plainly builds more trust than a promise you cannot keep. Remote and frontline staff need a route they have actually met, such as a trained responder in their region who can take a concern by video.

Who should sit on a harassment committee?

Whether your law requires a formal committee or you build a responder team, the design questions are the same: credibility, independence and training. A chair with seniority and standing, at least two internal members from different departments or sites, an external member with relevant experience, and a secretary who keeps records. In India the POSH Act prescribes the Internal Committee's composition, including a senior woman as presiding officer and an external member; the Philippines also requires a committee. Elsewhere, balance and an external voice are still good practice.

Independence means nobody handles a matter involving their own manager, direct report or close colleague, and every member signs a conflict declaration for each case. When the concern is about a committee member or a leader, an external investigator handles it. Train members before the first case, not after it, and refresh the training every year.

What should a manager do when someone reports harassment?

The first ten minutes decide whether the person keeps talking. A trauma-informed approach, drawn from principles published by the US Substance Abuse and Mental Health Services Administration, puts it simply: make the person safe, be transparent, offer choices, and take no decisions about them without them. Accounts given under stress are often out of order, and that is normal, not a sign of dishonesty.

What a manager does not do is investigate, confront the other person, ask colleagues what they saw, or ask why the person did not speak sooner. Those steps belong to trained people, and they can cause harm in the wrong hands.

• Stop, find privacy and listen without interrupting
• Note the person's words, not your view
• Do not ask for proof or promise secrecy; promise to share only with the people who need to know
• Ask what they need today so work feels safe
• Explain the next step with a name and a day
• State the no-retaliation rule in one sentence
• Refer it to the programme owner the same day

How do you investigate a harassment complaint fairly?

Fairness means doing everything twice, once for each person. The person who raised the concern is heard first, at their pace, with a support person if they want one. The person responded to receives every allegation in writing before their interview, has time to respond, and faces no penalty before a finding. Both receive regular updates and a summary of the evidence to comment on before any conclusion.

Most internal processes ask whether, on the evidence, it is more likely than not that something happened. That is not the criminal standard of beyond reasonable doubt, and your law or policy may set something different, so write the standard on the plan. When accounts conflict with nothing else to go on, you still decide and explain why, weighing consistency, detail, whether the person told anyone at the time, and anything independent that fits one account better. Demeanour, delay in reporting and what anyone wore carry no weight.

• Write terms of reference and break the complaint into numbered allegations
• Notify the person responded to in writing with the allegations in full
• Plan interviews backwards from the deadlines your law and policy set
• Interview with an opening statement and open questions; send records back for correction
• Number every item of evidence and note how reliable it is
• Send both people a summary of the evidence for comment
• Write a finding for each allegation that points to evidence, then let a different person decide the outcome

How do you prevent retaliation after a complaint?

Retaliation is the harm most likely to follow a complaint. The US Equal Employment Opportunity Commission's charge statistics list it as the most common allegation in charges filed, year after year; in fiscal year 2024 it appeared in 47.8 percent of the 88,531 charges received. At work it rarely looks like revenge. It looks like a dropped invitation, a project that went to someone else, or a rating that slipped.

Make it visible. Send a no-retaliation notice to the managers of both people at intake, asking them to run decisions about either person past the programme owner. Schedule check-ins with both people and each witness, for example at 30 days and 180 days after closure, with three short questions. Treat any yes as a new concern, act the same day, and explain the fix to the people affected. Support both people throughout: a named contact, a support person at interviews and external helplines.

How do you know whether the programme is working?

Measure in pairs. A rise in complaints can mean more harm or more trust, and a fall can mean less harm or more fear, so read case numbers (open, by stage, overdue, days to close) beside programme numbers (training coverage, committee status, awareness activities and climate survey items). Run a short climate survey each year, report by group only where a group has more than ten people, and ask why any group scores lower.

Write an annual report for the board even where your law does not require one; where it does, as India's does for the Internal Committee, check the form and the date with your local authority. AI assistants can help draft policy wording, training scenarios and survey summaries from anonymised numbers. They should never see names or evidence in a tool your organisation has not approved, and never decide whether an allegation is proven or what outcome fits. People who will sit on a committee can check their readiness with the AssessAll Speak-Up: Raising a Concern and Hearing One assessment, then turn the gaps into a development plan; Jobulary explains how its plans work. The Harassment Prevention Programme Kit from Bodhih Training puts every step in this article into a workbook, forms and templates.