Most employers would like to think sexual harassment simply won’t happen in their workplace.

That’s understandable. But relying on a policy sitting on the shared drive and hoping you never need to use it isn’t enough and from October, the expectations on employers are getting tougher.

The real question businesses need to be asking is:

“If you were challenged tomorrow, could you demonstrate what you have actually done to prevent sexual harassment from happening?”

Because that’s where the law is heading.

What’s changing with sexual harassment prevention?

• Since October 2024, employers have been under a legal duty to take reasonable steps to prevent sexual harassment of their workers. 
• From 30 October 2026, that duty strengthens. Employers will be expected to take all reasonable steps to prevent sexual harassment. 
• The Employment Rights Act 2025 also introduces greater protection from harassment by third parties including customers, clients, contractors and other people employees come into contact with through their work. 

This is important for all businesses but particularly important for sectors such as hospitality, retail, leisure and healthcare. Think about employees attending client sites, conferences, networking events, travelling for work or dealing with customers and suppliers. Third-party risk can exist in almost any organisation.

There has also already been another important change. Since 6 April 2026, disclosures about sexual harassment can qualify for protection under whistleblowing legislation, subject to the usual legal requirements.

Put simply, this is an area employers need to take seriously.

A sexual harassment policy alone won’t be enough

This is probably the biggest message for employers. 

You can have a beautifully written sexual harassment policy, but if nobody has read it, managers don’t know what to do when somebody raises a concern, training happened three years ago and you’ve never considered where the risks actually sit within your business, how effective is that policy really? 

The strengthened duty is about prevention, and not simply responding appropriately once something has already happened. 

Employers should therefore be thinking much more broadly about: 

• where sexual harassment risks could arise within their organisation 

• who might be particularly exposed to those risks 

• interactions with customers, clients and other third parties 

• whether employees and managers have received appropriate training 

• whether people genuinely know how to raise a concern 

• how concerns and complaints are handled 

• whether senior leaders demonstrate the behaviours expected of everybody else 

• what evidence exists to demonstrate the preventative steps the organisation has taken 

This isn’t just another compliance exercise. Done properly, it is part of creating a workplace where people feel safe, respected and confident enough to speak up when something isn’t right. 

Not sure whether your current approach goes far enough?

Omny Group can review your existing policy and preventative measures, identify any gaps and give you a practical action plan aligned with the October changes, simply get in touch.

What does sexual harassment actually mean? 

Under the Equality Act 2010, sexual harassment involves unwanted conduct of a sexual nature which has the purpose or effect of violating someone’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment. 

That can include obvious behaviours such as unwanted sexual advances or inappropriate physical contact, but it can also include sexual comments or jokes, messages, images, gestures and behaviour online or through social media and it can happen to anyone, regardless of gender, sexual orientation, role or seniority. 

That’s why practical examples are so important in employee and manager training. People need to understand what inappropriate behaviour can look like in real workplace situations, not simply be told to read a definition in a policy. 

So, what should employers be doing now?

Start by looking at what happens in your business in practice rather than just reviewing the wording of your policy. Consider where the risks are. Do employees work alone with customers? Attend conferences or networking events? Travel or stay away for work? Work late? Socialise with clients? Communicate through WhatsApp or social media? Attend work parties where alcohol is involved? 

Your preventative approach should reflect your actual workplace and your actual risks. 

Your policy should then support that approach by clearly setting out: 

• what sexual harassment is, with practical examples 

• the standards of behaviour expected 

• individual, management and leadership responsibilities 

• how employees can raise concerns 

• how complaints will be handled 

• protection from victimisation 

• expectations around customers, clients and other third parties 

• expectations at work events, during business travel and online 

• where employees can access additional support 

• how and when training will take place 

• when your arrangements will be reviewed 

But don’t stop there… 

• Would your managers know what to do? 

This is one of the areas businesses often overlook. 

The first sign of a problem isn’t always a formal grievance landing in HR’s inbox. 

It might be an employee quietly telling their manager that somebody made them uncomfortable. It might be something a manager witnesses themselves. Or it might initially sound like workplace banter or a personality clash. Managers need to know how to recognise those moments and what to do next. 

Training should help them understand how to listen without judgement, take concerns seriously, maintain appropriate confidentiality, escalate issues correctly and avoid saying or doing something that could make the situation worse.  They also need to understand that their role isn’t to decide immediately whether harassment has occurred. 

Their role is to make sure concerns are recognised and handled appropriately.

If your managers haven’t received practical training recently, now is the best time to address it. 

Our Sexual Harassment Prevention: Employer Obligations training gives employers and managers practical guidance on their responsibilities; the changing legal requirements and the steps they can take to demonstrate prevention in practice. 

Training: Sexual Harassment Prevention: Employer Obligations

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Check how prepared your organisation really is 

A useful exercise is to ask yourself “If somebody raised a sexual harassment concern tomorrow…” 

• Would they know who to speak to? 

• Would their manager know what to do? 

• Would the concern be escalated appropriately? 

• Could you demonstrate the training employees and managers have received? 

• Have you assessed the risks specific to your workplace? 

• Have you considered customers, clients and other third parties? 

• Could you evidence the preventative action your organisation has taken? 

If the answer to some of those questions is “I’m not sure”, that will be the best place to start.

Sexual harassment prevention is ultimately about culture 

Policies and training matter, but neither works particularly well in isolation. Creating a respectful workplace depends on what leaders and managers tolerate, challenge and role-model every day. 

Employees need to see that inappropriate behaviour will be challenged regardless of who is involved, whether that’s a colleague, senior leader, important client or customer. 

They also need to trust that raising a concern won’t negatively affect their career or how they are treated at work. That takes more than a policy. It requires clear expectations, capable managers, accessible reporting routes, appropriate training and leadership that demonstrates the right behaviours. 

What should you do before the October changes come into place? 

It’s important to stress that you shouldn’t wait until the legislation changes to start reviewing your arrangements. 

Use the next few months to understand where your risks are and whether the preventative measures you already have are actually working. Review your policy, assess your workplace risks, check your reporting routes, train your managers and employees, and importantly, keep evidence of what you have done. 

The question shouldn’t be: 

“Do we have a sexual harassment policy?” 

It should now be: 

“Can we demonstrate that we have taken all reasonable steps to prevent sexual harassment?” 

That’s a much higher bar, and one that employers need to start preparing for in advance. 

How Omny Group can help 

You don’t need to wait until you have a problem to ask for advice or support. Omny Group can work with you now to understand where you are, identify any gaps and put practical measures in place, including: 

• sexual harassment prevention risk assessments 

• policy reviews and updates 

• employee awareness training 

• manager and leadership training 

• reporting and escalation processes 

• support with complaints and investigations 

• ongoing HR and employment law support. 

Whether you need a full review or simply want someone to sense-check what you already have, we can help you understand what needs to change before October 2026. 

Want to know how prepared your organisation really is? We’ll be more than happy to review your current approach. Already aware that training is your major gap? Register your interest in our Sexual Harassment Prevention Training today.