Sexual Harassment Policy Template for UK Businesses
A sexual harassment policy addresses the specific prohibition on unwanted conduct of a sexual nature under section 26(2) of the Equality Act 2010. This standalone policy is particularly important following the Worker Protection (Amendment of Equality Act 2010) Act 2023, which introduced a proactive duty on employers to take reasonable steps to prevent sexual harassment from October 2024. The EHRC's technical guidance recommends a dedicated sexual harassment policy as a key reasonable step.
Who Needs This Policy?
All UK employers should have a sexual harassment policy, particularly since the October 2024 positive duty. The Equality and Human Rights Commission (EHRC) guidance specifically recommends having a standalone policy on sexual harassment, separate from a general anti-harassment policy, to signal the seriousness with which the organisation treats the issue. Industries with higher risks (hospitality, retail, healthcare, entertainment) should treat this as essential.
What's Covered
This sexual harassment policy template covers 10 key sections:
Purpose
[your details] has zero tolerance for sexual harassment. This policy exists to protect all employees, workers, and job a...
Scope
This policy applies to all employees, workers, agency staff, contractors, and volunteers of [your details]. It covers co...
What Is Sexual Harassment?
Under section 26 of the Equality Act 2010, sexual harassment is: 1. that has the purpose or effect of violating a pers...
Prevention Measures
[your details] takes the following reasonable steps to prevent sexual harassment, in fulfilment of our legal duty: 1. :...
Procedures -- Reporting
If you experience or witness sexual harassment, you are encouraged to report it. You will not face any detriment for mak...
Procedures -- Investigation and Outcome
Formal complaints will be investigated in accordance with our Anti-Harassment and Bullying Policy. The process includes:...
Support for Those Affected
[your details] will provide support to anyone affected by sexual harassment, including: - Confidential access to [your ...
Roles and Responsibilities
will: - Take reasonable steps (and from October 2026, all reasonable steps) to prevent sexual harassment - Investigate ...
Related Policies
This policy should be read alongside: - Anti-Harassment and Bullying Policy - Third-Party Sexual Harassment Policy - Se...
Review
This policy will be reviewed annually, or sooner if there are changes to legislation or guidance. The next scheduled rev...
Legal Framework
This policy template is grounded in the following UK legislation and guidance:
How Complaiance Helps
Our sexual harassment policy goes beyond a generic template:
- Standalone policy meeting EHRC recommendations for the new positive duty
- Comprehensive definition of sexual harassment with workplace-specific examples
- Clear reporting procedures including options for anonymous and third-party reporting
- Risk assessment framework for identifying and mitigating sexual harassment risks
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Get Started FreeFrequently Asked Questions
What is sexual harassment under UK law?
Under section 26(2) of the Equality Act 2010, sexual harassment is unwanted conduct of a sexual nature that has the purpose or effect of violating someone's dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment. This includes physical contact, sexual comments or jokes, displaying sexual material, sending sexually explicit messages, and sexual assault. A separate form of harassment under section 26(3) covers less favourable treatment because a person rejected or submitted to sexual conduct.
What are 'reasonable steps' to prevent sexual harassment?
The EHRC guidance on the positive duty recommends: conducting risk assessments for sexual harassment, having a dedicated sexual harassment policy, providing regular training for all staff (including managers), establishing clear reporting channels, responding promptly to complaints, monitoring and reviewing the effectiveness of measures, and addressing power imbalances and workplace culture. What is 'reasonable' depends on the employer's size, resources, sector, and risk profile.
What is the 25% compensation uplift for failing to prevent sexual harassment?
If an employment tribunal finds that sexual harassment occurred and the employer breached its positive duty to take reasonable steps to prevent it, the tribunal can increase the compensation awarded by up to 25% under section 124A of the Equality Act 2010. This uplift applies on top of the existing compensation for injury to feelings (which is uncapped) and any financial losses. It creates a significant financial incentive for employers to comply with the new duty.