City of London councillors have approved a new policy aimed at preventing sexual harassment, which will come into effect from October 1, 2026. This proactive measure anticipates the Employment Rights Act 2025, which will strengthen employers' duty to prevent sexual harassment.
The new policy shifts the focus from reacting to incidents to actively preventing them. It includes enhanced provisions for third-party harassment and places a greater emphasis on the role of managers in taking preventative action. The policy has been developed in consultation with various stakeholders, including recognised Trade Unions, Senior Employee Representatives, HR colleagues, and the Equality, Equity, Diversity and Inclusion team.
Key changes in the policy include explicit reference to the employer's duty, a focus on prevention, stronger third-party harassment provisions, and a greater emphasis on managers' roles in taking preventative action. The policy introduces a better reporting framework, improved victim support, and incorporates risk assessment as a formal control measure.
Reporting and Support
The new policy introduces a 'better reporting framework' that differs from the previous system by focusing on prevention rather than reaction. It includes both informal and formal procedures. The informal procedure encourages employees to raise concerns with their Line Manager within five working days. The formal procedure requires completing a Sexual Harassment Reporting Form and proceeding to a formal hearing conducted by a Grievance Hearing Officer. The previous procedure was primarily focused on responding to incidents after they occurred and did not contain the preventative controls, training expectations, management guidance, or risk assessment arrangements necessary to demonstrate compliance with the duty to take all reasonable steps to prevent sexual harassment.
Victim support has also been enhanced. Resources available include the Employee Assistance Programme (EAP), Occupational Health Services for counselling, and Trade Union support to act as a representative in Disciplinary Actions. Additionally, any adjustments for employees affected by sexual harassment, such as time off for sickness or appointments for specialist support, will not be counted towards sickness trigger points and will be reviewed periodically.
Managerial Responsibilities and Training
Under the new policy, managers will receive additional training on their responsibilities in preventing and addressing sexual harassment, including by third parties. The City Corporation is also working with the Learning & Organisational Development Team on mandatory training for all staff, with specific information on manager responsibilities for manager training.
Third-Party Harassment
The policy addresses inappropriate behaviour by individuals who are not employed by the City Corporation, such as visitors or contractors. If a visitor or third-party commits a breach of the policy, they will be asked to leave the premises, their employer will be informed if they represent another company, and they may be banned from City Corporation premises. A Human Resources' representative must be informed of any allegations of sexual harassment by a third-party.
Risk Assessment
Risk assessment is now a formal control measure within the policy. Managers are encouraged to undertake regular risk assessments to identify all reasonable measures to minimize the risk of exposure to sexual harassment, including from third parties. These assessments should be reviewed periodically and following any incident, complaint, workplace change, or identified risk.
Consequences of Non-Compliance
Failure to adopt the revised policy increases the risk of the organization failing to take all reasonable steps in line with the Employment Rights Act 2025. For individuals, sexual harassment can lead to disciplinary action, including dismissal without notice for gross misconduct. The Equality Act 2010 defines sexual harassment as unwanted conduct of a sexual nature that violates dignity or creates a hostile environment, and the Employment Rights Act 2025 strengthens the duty on employers to prevent sexual harassment.
This updated policy aims to create a more structured, supportive, and procedurally robust framework for addressing sexual harassment concerns, aligning with ACAS recommendations for employers to have specific policies, provide training, and foster the right workplace culture. The policy is also developed in preparation for the implementation of the Employment Rights Act 2025, which will strengthen the duty on employers to take 'all reasonable steps' to prevent sexual harassment and introduces employer liability for third-party harassment. The policy also references the Equality Act 2010 definition of sexual harassment.
Further details can be found in the Public reports pack for the Corporate Services Committee meeting on 9th September 2026.
