TradedocSexual harassment policy
A blank workplace anti-harassment policy you can print and fill by hand. Or the faster option — fill it on your phone, signed and emailed to every worker in one tap. Tracks the Equality Act 2010 s.40A 'all reasonable steps' uplift (in force 1 October 2026).
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What it is
A workplace sexual harassment policy is the documented standard the employer commits to: what is prohibited, how to report it, what happens after a report, and how third-party harassment (by customers, suppliers, site visitors) is handled. Since 26 October 2024 employers have a positive duty to take 'reasonable steps' to prevent sexual harassment of their workers; from 1 October 2026 the duty is upgraded to 'all reasonable steps' — a materially higher bar.
UK legal requirement
Equality Act 2010, section 40A (preventative duty), inserted by the Worker Protection (Amendment of Equality Act 2010) Act 2023, in force 26 October 2024. Uplifted to 'all reasonable steps' from 1 October 2026 by the Employment Rights Act 2025. Tribunal can uplift any sexual harassment compensation award by up to 25% where the duty has been breached. EHRC has standalone enforcement powers and can investigate without an individual complaint.
Compliance status
This template tracks Equality Act 2010 s.40A — preventative harassment duty (uplift to 'all reasonable steps' from 1 October 2026). Our compliance radar crawls the publishing bodies every six hours — see the standards we build to today or the radar of what's coming next.
Engineer remains responsible for verifying compliance with the version applicable to their work. TradeDoc is a tool, not a regulator.
Who needs it
- ·Every UK employer of any size — duty applies from a single worker upwards
- ·Construction sites, gas/electrical/plumbing trades with mixed crews and lone-working customer visits
- ·Hospitality, retail and care providers where third-party harassment is a structural risk
- ·Letting agents and property managers exposed to landlord/tenant/contractor interactions
What goes on it
Every mandatory field, in the order the inspector or auditor will check them.
Statement of policy
Plain-English statement that sexual harassment is prohibited at work, on customer sites, at work events, and in any work-related communication. Applies to all workers, agency staff, contractors and visitors. Zero-tolerance; measured response.
Definition
Sexual harassment is any unwanted conduct of a sexual nature with the purpose or effect of violating dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment (Equality Act 2010 s.26(2)). Harassment connected to sex (s.26(1)) and less-favourable treatment for rejecting or submitting (s.26(3)) are both covered. Examples in plain English.
Third-party harassment
Conduct by customers, suppliers, site visitors, members of the public — the duty extends beyond co-worker conduct. Procedure for warning the third party, ending the engagement, or removing the worker from the situation. Lone-working risk assessment cross-reference.
Reporting
Multiple reporting routes: line manager, named alternative manager, external email/phone for cases involving line manager. Anonymous reporting channel as a backstop. No detriment for raising a concern in good faith.
Investigation
Indicative timescale (initial response within 5 working days; investigation usually within 20 working days; longer where complexity or witnesses unavailable). Investigator independent of the parties. Procedural fairness for both reporter and respondent. Duty of confidentiality, with explicit caveats.
Outcomes
Range from no action (where the conduct does not amount to harassment) through informal resolution, training, written warning, dismissal. Cross-reference disciplinary procedure. Reasonable adjustments and welfare support during and after the process.
Training and review
Mandatory training on hire and annually. Specific manager training on receiving and handling reports. Annual policy review (or sooner if incidents indicate failure of the policy). Records of training delivered, attended and refused — feeds the 'all reasonable steps' defence.
Risk assessment cross-reference
Reference to the standalone harassment risk assessment that sits alongside this policy — identification of risks (lone working, mixed-gender crews, customer-facing roles, evening shifts, alcohol at work events) and the controls in place. The risk assessment is the backbone of 'all reasonable steps'.
Common mistakes on a hand-filled one
The small things that get picked up on audit, insurance review, or when the next engineer reads it.
- ✗Adopting a policy without a parallel risk assessment — the EHRC technical guidance treats the risk assessment as evidence of having taken reasonable steps; a policy alone is rarely enough
- ✗Treating the 'reasonable steps' duty as reactive — the duty is preventative; 'we'd act if someone complained' is not compliance
- ✗Forgetting third-party harassment — customers and visitors are within scope, and lone-working risks are a structural blind spot
- ✗Single reporting route through the line manager — if the manager is the source of the harassment the route fails; offer alternatives
- ✗Annual policy review without recording training and updating risk controls — 'all reasonable steps' is a continuous duty, not a one-off launch
- ✗Using a generic large-employer policy in a small firm — the EHRC test is reasonable to the employer's size and resources, so a sole trader's policy can be short, but it must be real
- ✗Missing the 1 October 2026 uplift — 'reasonable steps' (current) and 'all reasonable steps' (from October 2026) are different bars; treat the upgrade as a re-baseline moment
The faster option
Fill one on your phone in 2 minutes
Pick the template. Answer the fields. Customer signs from their inbox. PDF saved in the vault with a unique number. Free forever on your first 100 docs a month. Pro £15/month adds custom branding and one-tap customer email. No card at sign-up.
Frequently asked questions
What does 'all reasonable steps' mean from 1 October 2026?+
It is a higher bar than the current 'reasonable steps' duty. EHRC guidance interprets 'all reasonable steps' as requiring the employer to have considered every step that would help prevent harassment and to be able to justify any step not taken. In practice that means a policy, a risk assessment, training, multiple reporting routes, and review — proportionate to size and risk, but more than tokenism.
Does a sole trader with one apprentice need this?+
Yes. The duty applies to every employer regardless of size. The bar is proportionate — a sole trader's policy can be short and the risk assessment lightweight — but having nothing on file means failing the duty and exposing yourself to up to a 25% uplift on any compensation award if harassment occurs.
What happens if there's no complaint but the duty is breached?+
The EHRC has standalone enforcement powers under the Equality Act 2006. It can investigate, issue a Section 23 unlawful act notice, and require an action plan with timed milestones. From 1 October 2026 employees can also bring a standalone claim for breach of the duty independent of any individual harassment claim.
Do I have to train every worker?+
Reasonable steps include training proportionate to the role and the risk. New starters should receive training on or shortly after induction; managers need additional training on receiving and handling reports. Refresher training at least annually is the EHRC's recommended baseline.
What about harassment by customers or visitors?+
Third-party harassment is within the duty. The employer must take reasonable steps to prevent it — risk assessment of customer-facing roles, lone-working procedures, the right to remove a worker from a situation, the right to refuse continued engagement with a third party, training in de-escalation. This is a particular blind spot for small trades and hospitality.
Is the disclaimer enough?+
No. A 'we don't tolerate harassment' line in the handbook is not 'all reasonable steps'. The duty is to do, not to say. The policy must be one part of an evidenced system: policy + risk assessment + training + reporting routes + investigation + review.