Update Details: The harassment risk assessment and the harassment, equality and behaviour policies have been updated to work to all reasonable steps to prevent harassment, including harassment by third parties such as customers, clients, suppliers and members of the public.
From 30 October 2026 the duty to prevent sexual harassment at work rises from taking reasonable steps to taking all reasonable steps. On the same date employers become liable when their staff are harassed by customers, clients, suppliers or the public, unless they took all reasonable steps to prevent it. That covers sexual harassment and harassment related to a protected characteristic, and a single incident is enough.
All reasonable steps is not defined in the law itself, which puts the weight on being able to show what was assessed, what was put in place and how it was followed through. The risk assessment and policies below now carry that through from the risk to the reporting route.
Third-Party Harassment in the Harassment Risk Assessment
The worked example business risk assessment for harassment has been updated to match:
- All reasonable steps - the wording used throughout the risks and controls
- Third-party harassment - the risk now covers harassment related to any protected characteristic, and a single incident with no earlier warning
- Assessed by role, location and situation - so the controls sit where staff actually deal with customers, clients, suppliers or the public
- Conduct standards for third parties - set through terms of business, contracts and notices, with service refused or ended where needed
- Withdrawing from a situation - staff can step away without penalty, and reports are acted on with support given
- Policy references - a reference line to the sexual harassment and anti-bullying and harassment policies
Harassment Risk Assessment and Policies Updated:
| RA-BR20 Harassment | Worked example business risk assessment, with third-party harassment assessed by role, location and situation, and conduct standards set for customers and suppliers |
| P-121 Sexual Harassment Policy | All reasonable steps to prevent sexual harassment, including by third parties, prevention steps including risk assessment, and reporting to a named person |
| P-73 Anti Bullying and Harassment Policy | All reasonable steps including third parties, with new sections on reporting and investigation, third parties, and prevention and review |
Equality and Behaviour Policies Updated:
Each of these now commits to all reasonable steps to prevent harassment, including harassment by third parties.
P-6 Equal Opportunities and Diversity Policy
P-44 Diversity and Inclusion Policy
P-97 Equality and Diversity Policy
P-123 Behavioural Management Policy
Further guidance on preventing harassment is available in our knowledge base;
Bullying and Harassment at Work
Managing Staff and Workers
