EEOC: It’s time for your company to re-imagine anti-harassment training

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Welp, it looks like there’s still plenty of time for me to get my money’s worth on creepy Wikipedia stock images of sexual harassment — Thank you By Leon israelOwn work, CC BY-SA 4.0, https://commons.wikimedia.org/w/index.php?curid=38824206. 

The click-bait headline, “No Evidence That Training Prevents Harassment, Finds EEOC Task Force,” from a recent SHRM article may be somewhat exaggerated.

Or maybe not.

On Sunday, EEOC Commissioner Victoria Lipnic told a SHRM Annual Conference audience, “What we want people to understand is that if you are thinking training alone is a panacea to helping out any type of harassment, [it’s not]. It doesn’t work.”

Lipnic’s comments were part of a sneak peak into yesterday’s release of the “Select Task Force on the Study of Harassment in the Workplace: Report of Co-Chairs Chai R. Feldblum and Victoria A. Lipnic.” The Task Force is calling for businesses to “reboot” workplace harassment prevention efforts.

What kind of reboot are we talking about here? No. No. No.

Oh, right. Instead, let’s try this redacted block-quoted excerpt from the Executive Summary:

The importance of leadership cannot be overstated – effective harassment prevention efforts, and workplace culture in which harassment is not tolerated, must start with and involve the highest level of management of the company. But a commitment (even from the top) to a diverse, inclusive, and respectful workplace is not enough. Rather, at all levels, across all positions, an organization must have systems in place that hold employees accountable for this expectation. Accountability systems must ensure that those who engage in harassment are held responsible in a meaningful, appropriate, and proportional manner, and that those whose job it is to prevent or respond to harassment should be rewarded for doing that job well (or penalized for failing to do so). Finally, leadership means ensuring that anti-harassment efforts are given the necessary time and resources to be effective.

Ok. Get everyone involved. Make people accountable. I get that. It makes sense.

We believe effective training can reduce workplace harassment, and recognize that ineffective training can be unhelpful or even counterproductive. However, even effective training cannot occur in a vacuum – it must be part of a holistic culture of non-harassment that starts at the top. Similarly, one size does not fit all: Training is most effective when tailored to the specific workforce and workplace, and to different cohorts of employees. Finally, when trained correctly, middle-managers and first-line supervisors in particular can be an employer’s most valuable resource in preventing and stopping harassment.

While the one-size-does-not-fit-all mantra seems a little tired to me, the EEOC does offer some solutions:

We heard of several new models of training that may show promise for harassment training. “Bystander intervention training” – increasingly used to combat sexual violence on school campuses – empowers co-workers and gives them the tools to intervene when they witness harassing behavior, and may show promise for harassment prevention. Workplace “civility training” that does not focus on eliminating unwelcome or offensive behavior based on characteristics protected under employment non-discrimination laws, but rather on promoting respect and civility in the workplace generally, likewise may offer solutions.

We suggest exploring the launch of an It’s on Us campaign for the workplace. Originally developed to reduce sexual violence in educational settings, the It’s on Us campaign is premised on the idea that students, faculty, and campus staff should be empowered to be part of the solution to sexual assault, and should be provided the tools and resources to prevent sexual assault as engaged bystanders. Launching a similar It’s on Us campaign in workplaces across the nation – large and small, urban and rural – is an audacious goal. But doing so could transform the problem of workplace harassment from being about targets, harassers, and legal compliance, into one in which co-workers, supervisors, clients, and customers all have roles to play in stopping such harassment.

The full report details ways to “aid in designing effective anti-harassment policies; developing training curricula; implementing complaint, reporting, and investigation procedures; creating an organizational culture in which harassment is not tolerated; ensuring employees are held accountable; and assessing and responding to workplace ‘risk factors’ for harassment.”

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  • MarySchaefer

    Hi Eric. This brought up a lot for me, so I think you in advance for tolerating my rant.

    I think I have a fair amount of credibility to speak on this subject having trained hundreds of employees and managers on sexual harassment prevention. I actively participated in developing the next version of intervention on a corporate level team while I was still a corporate employee at a Fortune 100 company. I taught dozens of people to facilitate sexual harassment prevention training. I received and managed sexual harassment complaints as an HR manager. I’ve investigated sexual harassment and “disrespectful treatment” allegations. And, not for nothing, I’ve been sexually harassed as an employee dozens of times. Sad.

    IMHO, first and foremost, leadership must model taking complaints seriously and managing what they observe, in the moment if possible. Leadership must support consequences commensurate with the situation. You have no idea what sh!t I took when I insisted on putting an employee on probation, thus blocking his “expected” promotion that year.

    We incorporated training for bystanders in the latest version of employee training. Employees wanted NOTHING to do with that. They wanted to know just how they were on the hook. “Can I be disciplined for doing nothing? That’s what we were up against there. I found I had to do a lot of talking in training sessions and offline to help people understand, and help them talk through their fears.

    Unless they see leadership actively calling out public behavior, they will not take what they consider is a risk. The two brave men who helped the Stanford woman give me hope.

    I look forward to reviewing the full report you mention in your final paragraph.