Third-Party Sexual Harassment Policy Template for UK Businesses
A third-party sexual harassment policy specifically addresses harassment of your workers by people outside the organisation — customers, clients, service users, suppliers, contractors, and members of the public. The Worker Protection (Amendment of Equality Act 2010) Act 2023 reinstated employer liability for third-party harassment from October 2024, requiring employers to take reasonable steps to prevent sexual harassment from any source, not just colleagues.
Who Needs This Policy?
Employers in customer-facing industries should prioritise this policy: hospitality, retail, healthcare, social care, entertainment, transport, education, and professional services with significant client interaction. However, the positive duty under the Worker Protection Act 2023 applies to all employers. Industries where workers interact regularly with members of the public or service users face the highest risk of third-party sexual harassment.
What's Covered
This third-party sexual harassment policy template covers 12 key sections:
Purpose
This policy explains the duty of [your details] to protect employees and workers from sexual harassment by third parties...
Scope
This policy applies to all employees, workers, agency staff, and contractors of [your details]. It covers sexual harassm...
Policy Statement
[your details] will not tolerate sexual harassment of its employees by third parties. We recognise that certain roles --...
What is Third-Party Sexual Harassment
Sexual harassment by a third party is unwanted conduct of a sexual nature by a non-employee that has the purpose or effe...
Risk Assessment
[your details] will carry out regular risk assessments to identify roles, settings, and situations where employees may b...
Preventative Measures
[your details] will implement the following preventative measures to reduce the risk of third-party sexual harassment: ...
Reporting Third-Party Sexual Harassment
Employees who experience sexual harassment by a third party should report it as soon as possible to their line manager o...
Action Against Third Parties
Where a report of third-party sexual harassment is substantiated, [your details] will take appropriate action against th...
ERA 2025 Changes
The Employment Rights Act 2025 introduces the following changes relevant to third-party sexual harassment: - The preve...
Roles and Responsibilities
is responsible for: - Ensuring that the preventative duty is met and that all reasonable steps are taken to prevent thi...
Related Policies
This policy should be read alongside the following policies: - Sexual Harassment Policy - Anti-Harassment and Bullying ...
Review
This policy will be reviewed annually, or sooner if there are changes to legislation (including implementation of remain...
Legal Framework
This policy template is grounded in the following UK legislation and guidance:
- Worker Protection (Amendment of Equality Act 2010) Act 2023
- Equality Act 2010, s.40A (as inserted)
- Employment Rights Act 2025 (from October 2026: 'all reasonable steps' standard and third-party harassment liability)
- EHRC Technical Guidance on Sexual Harassment and Harassment at Work (2020, updated 2024)
- Health and Safety at Work etc. Act 1974, s.2
How Complaiance Helps
Our third-party sexual harassment policy goes beyond a generic template:
- Sector-specific risk assessment frameworks for common third-party harassment scenarios
- Clear escalation procedures for dealing with harassing customers, clients, and service users
- Guidance on when and how to ban or restrict access for persistent third-party harassers
- Staff training provisions on de-escalation and reporting of third-party incidents
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Get Started FreeFrequently Asked Questions
What is third-party sexual harassment?
Third-party sexual harassment occurs when a worker is sexually harassed by someone who is not employed by their employer — such as a customer, client, patient, service user, supplier, contractor, or member of the public. Under the Worker Protection Act 2023, employers have a positive duty to take reasonable steps to prevent sexual harassment from any source, including third parties, from October 2024.
Can an employer ban a customer who sexually harasses staff?
Yes. Employers can and should take action against third parties who sexually harass staff, including issuing warnings, restricting access, refusing service, or banning individuals. Failing to take action may constitute a breach of the employer's duty to take reasonable steps to prevent sexual harassment. The employer should document incidents and have a clear escalation process.
Is there a specific claim for third-party harassment in UK law?
The original third-party harassment provisions in section 40 of the Equality Act 2010 were repealed in 2013. The Worker Protection Act 2023 takes a different approach: rather than creating a standalone claim for third-party harassment, it imposes a preventative duty on employers. If the duty is breached, the EHRC can take enforcement action, and tribunals can apply a 25% compensation uplift in individual harassment claims.