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For example, studies have linked sexual harassment to negative effects on a firm's ability to attract employees. Even behavior that doesn't rise to the level of harassment can adversely affect the ability of employers to attract talent. The ability of a firm to retain customers and clients, or attract new ones, could also be affected. Studies demonstrate that perceived sexual harassment in the workplace has a negative effect on attitudes toward the brand and brand image.

In this sense, internal brand strategies are critical for overall business success. Again, even behavior that does not rise to the level of harassment can adversely affect a brand. A majority of respondents in the Level Playing Field Institute's study replied that "unfairness" they had suffered in the workplace led them "to some degree" to discourage others from purchasing products or services from their employer.

Finally, an often competing economic consideration bears discussion. Employers may find themselves in a position where the harasser is a workplace "superstar.

Often, however, superstars are privileged with higher income, better accommodations, and different expectations. When the superstar misbehaves, employers may perceive themselves in a quandary. They may be tempted to ignore the misconduct because, the thinking goes, losing the superstar would be too costly. They may wager that the likelihood or cost of a complaint of misbehavior is relatively low and outweighed by the superstar's productivity.

Some employers may even use this type of rationale to cover or retaliate for a harasser. Employers should avoid the trap of binary thinking that weighs the productivity of a harasser solely against the costs of his or her being reported. As a recent Harvard Business School study found, the profit consequences of so-called "toxic workers" - specifically including those who are "top performers" - is a net negative.

Indeed, the reputational costs alone can have serious consequences, particularly where it is revealed that managers for years "looked the other way" at a so-called "superstar" harasser. Our efforts over the past year with the Select Task Force focused broadly on unwelcome conduct in the workplace based on characteristics protected under anti-discrimination statutes.

We wanted to find ways to help employers and employees prevent such conduct before it rose to the level of illegal harassment. Several members of the Select Task Force suggested that we identify elements in a workplace that might put a workplace more at risk for harassment. The thought was that if we could identify "risk factors," that might give employers a roadmap for taking proactive measures to reduce harassment in their workplaces.

Indeed, as we delved into the question, we found that academic research and practical knowledge gained on the ground by investigators, trainers, diversity leaders, and human resources personnel have identified a number of such risk factors. Some of the findings around risk factors both from academic work and practical work look at the characteristics of those who might be more prone to engage in harassment or to be the victims of harassment.

We decided to focus instead on a number of environmental risk factors - organizational factors or conditions that may increase the likelihood of harassment. Indeed, numerous studies have shown that organizational conditions are the most powerful predictors of whether harassment will happen. Most if not every workplace will contain at least some of the risk factors we describe below. In that light, to be clear, we note that the existence of risk factors in a workplace does not mean that harassment is occurring in that workplace.

Rather, the presence of one or more risk factors suggests that there may be fertile ground for harassment to occur, and that an employer may wish to pay extra attention in these situations, or at the very least be cognizant that certain risk factors may exist. Finally, we stress that the list below is neither exclusive nor exhaustive, but rather a number of factors we felt were readily identifiable.

Perhaps not surprisingly, harassment is more likely to occur where there is a lack of diversity in the workplace. Conversely, workers in the majority might feel threatened by those they perceive as "different" or "other. Harassment is more likely to occur where a minority of workers does not conform to workplace norms based on societal stereotypes. It might seem ironic given the first risk factor of homogenous workforces that workplaces that are extremely diverse also pose a risk factor for harassment.

The Select Task Force heard testimony from one expert who discussed how language and linguistic characteristics can play a role in cases of harassment or discrimination. In both homogenous and diverse workforces, events and coarse social discourse that happen outside the workplace may make harassment inside a workplace more likely or perceived as more acceptable.

Thus, events outside a workplace may pose a risk factor that employers need to consider and proactively address, as appropriate. Workplaces with many teenagers and young adults may raise the risk for harassment. As noted in the discussion regarding the business case, there are workforces in which some employees are perceived to be particularly valuable to the employer - the "rainmaking" partner or prized, grant-winning researcher.

The reality is that there are significant power disparities between different groups of workers in most workplaces. But such significant power disparities can be a risk factor. Low-status workers may be particularly susceptible to harassment, as high-status workers may feel emboldened to exploit them.

Low-status workers may be less likely to understand internal complaint channels, and may also be particularly concerned about the ramifications of reporting harassment e. Few employers would say that their business does not rely on excellent customer service and client satisfaction. As a risk factor, we are specifically speaking about those workplaces where an employee's compensation may be directly tied to customer satisfaction or client service.

For example, a tipped worker may feel compelled to tolerate inappropriate and harassing behavior rather than suffer the financial loss of a good tip.

Finally, in order to ensure customer happiness, management may, consciously or subconsciously, tolerate harassing behavior rather than intervene on the workers' behalf. We heard that workplaces where workers are engaged in monotonous or low-intensity tasks may be more likely to see workplace harassment. In jobs where workers are not actively engaged or have "time on their hands," harassing or bullying behavior may become a way to vent frustration or avoid boredom. Harassment is also more likely to occur in isolated workspaces, where the workers are physically isolated or have few opportunities to work with others.

Alcohol reduces social inhibitions and impairs judgment. Not surprisingly, then, workplace cultures that tolerate alcohol consumption during and around work hours provide a greater opportunity for harassment. In other workplaces, particularly those where social interaction or client entertainment is a central component of the job sales, for example , alcohol use may be more ritualized and thus present more of a potential risk factor.

Decentralized workplaces, marked by limited communication between organizational levels, may foster a climate in which harassment may go unchecked. In such workplaces, some managers may feel or may actually be unaccountable for their behavior and may act outside the bounds of workplace rules.

Others may simply be unaware of how to address workplace harassment issues, or for a variety of reasons may choose not to "call headquarters" for direction. We close this section by observing once more that, obviously, every workplace has some of these risk factors, and some workplaces have many of them. But the instinct of our Select Task Force members that we should devote time and resources to exploring and categorizing possible risk factors is borne out by what we have learned.

The objective of identifying risk factors is not to suggest that having these risk factors will necessarily result in harassment in the workplace. A single risk factor may make a particular workplace more susceptible to harassment; more broadly, industries with numerous risk factors may be at greater risk of harassment in their workplaces and greater risk of the harassment not being identified and remedied. The objective of identifying and describing these risk factors is to provide a roadmap for employers that wish to take proactive actions to ensure that harassment will not happen in their workplaces.

We stress that employers need to maintain "situational awareness" - an employer noting surprise that women were being sexually assaulted on the night shift when they worked in isolation and their schedules were controlled by men is cold comfort to the victims of these assaults.

The next Part of our report describes a number of actions that employers can take to prevent harassment, including an assessment of these risk factors. In addition, Appendix C includes a chart with suggestions for addressing each of these risk factors in a proactive manner. Harassment in the workplace can sometimes feel like an intractable problem. The question is whether there is anything we can do to prevent harassment to a significant degree.

We believe the answer to that is "yes. We also believe that it will not be easy to achieve this goal. If it were easy, it would have happened a long time ago. The following sections lay out our analysis, based on what we have learned over the past year, for achieving what some may see as a quixotic goal, but which we see as a moral and legal imperative.

Over and over again, during the course of our study, we heard that workplace culture has the greatest impact on allowing harassment to flourish, or conversely, in preventing harassment.

We heard this from academics who testified to the Select Task Force; we heard it from trainers and organizational psychologists on the ground; and we read about it during the course of our literature review.

Two things - perhaps two faces of the same coin - became clear to us. First, across the board, we heard that leadership and commitment to a diverse, inclusive, and respectful workplace in which harassment is simply not acceptable is paramount.

And we heard that this leadership must come from the very top of the organization. Second, we heard that a commitment even from the top for a diverse, inclusive, and respectful workplace is not enough. These 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, directly or indirectly, are rewarded for doing that job well, or penalized for failing to do so.

An organization's culture is set by the values of an organization. To achieve a workplace without harassment, the values of the organization must put a premium on diversity and inclusion, must include a belief that all employees in a workplace deserve to be respected, regardless of their race, religion, national origin, sex including pregnancy, sexual orientation, or gender identity , age, disability, or genetic information, and must make clear that part of respect means not harassing an individual on any of those bases.

In short, an organization's commitment to a harassment-free workplace must not be based on a compliance mindset, and instead must be part of an overall diversity and inclusion strategy. Organizational culture manifests itself in the specific behaviors that are expected and formally and informally rewarded in the workplace.

As one of our witnesses explained, "[O]rganizational climate is an important driver of harassment because it is the norms of the workplace; it basically guides employees. Organizational cultures that tolerate harassment have more of it, and workplaces that are not tolerant of harassment have less of it. This common-sense assumption has been demonstrated repeatedly in research studies. What steps can an organization's leadership take to ensure that its organizational culture reflects the leadership's values of not tolerating harassment and promoting civility and respect?

First, leadership must establish a sense of urgency about preventing harassment. That means taking a visible role in stating the importance of having a diverse and inclusive workplace that is free of harassment, articulating clearly the specific behaviors that will not be acceptable in the workplace, setting the foundation for employees throughout the organization to make change if change is needed , and, once an organizational culture is achieved that reflects the values of the leadership, commit to ensuring that the culture is maintained.

One way to effectuate and convey a sense of urgency and commitment is to assess whether the workplace has one or more of the risk factors we describe above and take proactive steps to address those. For example, if employees tend to work in isolated workspaces, an employer may want to explore whether it is possible for the work to get done as effectively if individuals worked in teams. In a workplace where an employee's compensation is directly tied to customer satisfaction or client service, the employer may wish to emphasize that harassing conduct should be brought immediately to a manager's attention and that the worker will be protected from retaliation.

In workplaces with many teenagers and young adults entering the workforce, the employer may wish to have an orientation in which conduct that is not acceptable is clearly described and workers are encouraged to come forward quickly with any concerns. Another way to communicate a sense of urgency is to conduct a climate survey of employees to determine whether employees feel that harassment exists in the workplace and is tolerated.

Several researchers have developed such climate surveys, and the military has adopted them on a widespread scale in recent years. Second, an organization must have effective policies and procedures and must conduct effective trainings on those policies and procedures. Anti-harassment policies must be communicated and adhered to, and reporting systems must be implemented consistently, safely, and in a timely fashion. Trainings must ensure that employees are aware of, and understand, the employer's policy and reporting systems.

Such systems must be periodically tested to ensure that they are effective. Our detailed recommendations concerning these policies and trainings are discussed in the following sections. Third, leadership must back up its statement of urgency about preventing harassment with two of the most important commodities in a workplace: money and time.

Employees must believe that their leaders are authentic in demanding a workplace free of harassment. Nothing speaks to that credibility more than what gets paid for in a budget and what gets scheduled on a calendar. For example, complaint procedures must be adequately funded in the organization's budget and sufficient time must be allocated from employee schedules to ensure appropriate investigations.

Similarly, sufficient resources must be allotted to procure training, trainings must be provided frequently, and sufficient time must be allocated from employee schedules so that all employees can attend these trainings. Moreover, if an organization has a budget for diversity and inclusion efforts, harassment prevention should be part of that budget. Finally, in working to create change, the leadership must ensure that any team or coalition leading the effort to create a workplace free of harassment is vested with enough power and authority to make such change happen.

Because organizational culture is manifested by what behaviors are formally and informally rewarded, it all comes down to accountability - and accountability must be demonstrated.

An employer that has an effective anti-harassment program, including an effective and safe reporting system, a thorough workplace investigation system, and proportionate corrective actions, communicates to employees by those measures that the employer takes harassment seriously.

This in turn means that more employees will be likely to complain if they experience harassment or report harassment they observe, such that the employer may deal with such incidents more effectively. With regard to individuals who engage in harassment , accountability means being held responsible for those actions.

We heard from investigators on the ground, and we read in the academic literature, that sanctions are often not proportionate to the inappropriate conduct that had been substantiated. With regard to mid-level managers and front-line supervisors , accountability means that such individuals are held responsible for monitoring and stopping harassment by those they supervise and manage.

For example, if a supervisor fails to respond to a report of harassment in a prompt and appropriate fashion, or if a supervisor fails to protect from retaliation the individual who reports harassment, that supervisor must be held accountable for those actions. Similarly, if those responsible for investigations and corrective actions do not commence or conclude an investigation promptly, do not engage in a thorough or fair investigation, or do not take appropriate action when offending conduct is found, that person must be held accountable.

Accountability also includes reward systems. If leadership incentivizes and rewards responsiveness to anti-harassment efforts by managers, that speaks volumes. For example, a number of witnesses noted that companies who were successful in creating a culture of non-harassment were those that acknowledged and "owned" its well-handled complaints, instead of burying the fact that there had been a complaint and that discipline had been taken.

Perhaps counter-intuitively, rewards can also be given to managers when - at least initially - there is an increase in complaints in their division.

We heard that using the metric of the number of complaints lodged within a particular division, with rewards given to those with the fewest number of complaints, might have the counterproductive effect of managers suppressing the filing of complaints through formal and informal pressure. In contrast, if employees are filing complaints of harassment, that means the employees have faith in the system. Thus, using the metric of the number of complaints must be nuanced. Positive organizational change can be reflected in an initial increase of complaints, followed by a decrease in complaints and information about the lack of harassment derived from climate surveys.

Before moving on to detailed recommendations, we pause to highlight a radically different accountability mechanism that we find intriguing, and solicited testimony regarding at one of our public meetings. A number of large companies, such as McDonald's and Wal-Mart, have begun to hold their tomato growers accountable by buying tomatoes only from those growers who abide by a human rights based Code of Conduct, which, among other elements, prohibits sexual harassment and sexual assault of farmworkers.

The companies agreed to the program because of consumer-driven market pressures, and most of the agricultural companies that entered the program did so because of the resulting financial pressures. As part of the program, the CIW conducts worker-to-worker education programs.

There is also a worker-triggered complaint resolution mechanism, which can result in investigations, corrective action plans, and if necessary, suspension of a farm's "participating grower" status, which means the farm could lose its ability to sell to participating buyers. The most important lesson we learned from our study is that employers must have a holistic approach for creating an organizational culture that will prevent harassment. If employers put a metric in a manager's performance plan about responding appropriately to harassment complaints, but then do nothing else to create an environment in which employees know the employer cares about stopping harassment and punishing those who engage in it - it is doubtful that the metric on its own will have much effect.

If an employer has a policy clearly prohibiting harassment that is mentioned consistently at every possible employee gathering, but does not have a system that protects those who complain about harassment from retaliation, the policy itself will do little good. It is not that policies and metrics are not important.

To the contrary, they are essential components of a harassment prevention effort. But holistic refers to the whole system. Every activity must come together in an integrated manner to create an organizational culture that will prevent harassment. Policies, reporting procedures, investigations, and corrective actions are essential components of the holistic effort that employers must engage in to prevent harassment.

In this section, we set forth what we have learned about how to make each of these components as successful as possible. An organization needs a stated policy against harassment that sets forth the behaviors that will not be accepted in the workplace and the procedures to follow in reporting and responding to harassment.

Employees in workplaces without policies report the highest levels of harassment. EEOC's position, which after our study we believe remains sound, is that employers should adopt a robust anti-harassment policy, regularly train each employee on its contents, and vigorously follow and enforce the policy.

An employer's policy should be written in clear, simple words, in all the languages used in the workplace. The points we note above describe the content of an effective policy, but the words of the policy itself should be simple and easy to understand.

Similarly, an effective policy should make clear that harassment on the basis of any protected characteristic will not be tolerated. Itis also not sufficient simply to have a written policy, even one written in the most user-friendly fashion.

The policy must be communicated on a regular basis to employees, particularly information about how to file a complaint or how to report harassment that one observes, and how an employee who files a complaint or an employee who reports harassment or participates in an investigation of alleged harassment will be protected from retaliation. Finally, we urge employers whomay read this and conclude that their policies are currently effective and in line with EEOC's recommendations to consider this report as an opportunity to take a fresh and critical look at their current processes and consider whether a "reboot" is necessary or valuable.

Appendix B includes a checklist for an effective harassment prevention policy. An additional wrinkle for employers to consider, as they write and update anti-harassment policies, is the proliferation of employees' social media use. Arguably, the use of social media among employees in a workplace can be a net positive. As noted by a witness at the Commission's meeting on social media, social media use in the workplace can create a space for "less formal and more frequent communications.

Unfortunately, social media can also foster toxic interactions. Nearly daily, news reports reflect that, for whatever reasons, many use social media to attack and harass others. For example, an anti-harassment policy should make clear that mistreatment on social media carries the weight of any other workplace interaction. Supervisors and others with anti-harassment responsibilities should be wary of their social media connections with employees. And, procedures for investigating harassment should carefully delineate how to access an employee's social media content when warranted.

In context, social media - specifically its use in the workplace - is relatively new. Plus, it seemingly changes at an exponential pace. For now, however, the constant for employers is that social media platforms are potential vehicles for workplace-related interactions. And wherever that exists, employers must be aware that harassment may occur.

Finally, we have a caution to offer with regard to use of the phrase "a 'zero tolerance' anti-harassment policy. Accountability requires that discipline for harassment be proportionate to the offensiveness of the conduct. For example, sexual assault or a demand for sexual favors in return for a promotion should presumably result in termination of an employee; the continued use of derogatory gender-based language after an initial warning might result in a suspension; and the first instance of telling a sexist joke may warrant a warning.

Although not intended as such, the use of the term "zero tolerance" may inappropriately convey a one-size-fits-all approach, in which every instance of harassment brings the same level of discipline. This, in turn, may contribute to employee under-reporting of harassment, particularly where they do not want a colleague or co-worker to lose their job over relatively minor harassing behavior - they simply want the harassment to stop.

Thus, while it is important for employers to communicate that absolutely no harassment will be permitted in the workplace, we do not endorse the term "zero tolerance" to convey that message.

Effective reporting systems for allegations of harassment are among the most critical elements of aholistic anti-harassment effort. A reporting system includes a means by which individuals who have experienced harassment can report the harassment and file a complaint, as well as a means by which employeeswho have observed harassment can report that to the employer.

Ultimately, how an employee who reports harassment either directly experienced or observed fares under the employer's process will depend on how management and its representatives act during the process. If the process does not work well, it can make the overall situation in the workplace worse. If one employee reports harassment and has a badexperience using the system, one can presume that the next employee who experiences harassment will think twice before doing the same.

For employers that have a unionized workplace, the role of the union in the employer's reporting system is significant. If union representatives take reports of harassment seriously, and support complainants and witnesses during the process, that will make a difference in how employees who are union members view the system. Similarly, because unions have obligations towards all union members, the union must work with the employer to have a system that works in a fair manner for any individual accused of harassment.

There is a significant body of research establishing the many concerns that employees have with current reporting systems in their workplaces. In other situations, the employer may need to do an immediate intervention and begin a thorough investigation. Of course, the operational needs and resources of small businesses, start-up ventures, and the like, will differ significantly from large, established employers with dedicated human capital systems or "C Suites" of senior leadership.

But the principle of offering an accessible and well-running reporting system remains the same. As noted in the previous section, a safe and timely reporting system that operates well also communicates to employees the leadership's commitment to the words it has set forth in its anti-harassment policy.

We heard some innovative ideas for making that commitment clear. One witness described a company that established a small internal group of key "C-Suite" personnel who were informed immediately regarding any harassment complaint unless a conflict of interest existed.

The small group of senior leaders was then regularly updated regarding investigation outcomes and prevention analysis. In a smaller business, this "group of senior leaders" may be the business's owner or the highest-ranking members of management. We heard strong support for the proposition that workplace investigations should be kept as confidential as is possible, consistent with conducting a thorough and effective investigation.

We heard also, however, that an employer's ability to maintain confidentiality - specifically, to request that witnesses and others involved in a harassment investigation keep all information confidential - has been limited in some instances by decisions of the National Labor Relations Board "NLRB" relating to the rights of employees to engage in concerted, protected activity under the National Labor Relations Act "NLRA".

Based on what we have learned over the last year, we believe there are several elements that will make reporting systems work well and will provide employees with faith in the system. These are largely consistent with the recommendations made above regarding the content of an effective anti-harassment policy:.

The bottom line, however, is that we need better empirical evidence on what type of reporting systems are effective. Many witnesses told us it would be extraordinarily valuable for employers to allow researchers into their workplaces to conduct empirical studies to determine what makes a reporting system effective. We agree with that suggestion, although we are cognizant of the concerns that employers may have in welcoming researchers into their domains. For example, we recognize that employers will want to have control over how data derived from its workplace will be used, and equally important, not used.

There are many reasons why employers offer anti-harassment trainings. Employers who care deeply about stopping harassment use training as a mechanism to do so. After EEOC's guidelines suggested methods for preventing sexual harassment, many employers started to offer training as one of those methods.

California and Connecticut have mandated such training for employers with 50 or more supervisors, and Maine has mandated such training for employers with 15 or more supervisors. Given the amount of resources employers devote to training, and the fact that training is one of the primary mechanisms used to prevent harassment, we explored whether training is effective in preventing harassment, and if so, whether there are some forms of training that have better outcomes than others.

Witnesses who provided testimony to the Select Task Force, and our own reading of the literature, exposed the problems of the empirical evidence to date regarding the effectiveness of training programs standing alone. First, most of the studies use researcher-designed training, and each of those trainings has different content, lengths, and leaders.

It is hard to know if something works when the "what" that you are studying is not the same. Second, our research which was thorough, if admittedly not an exhaustive review of all literature over the past three decades discovered only two studies based on large-scale evaluations of anti-harassment training designed by employers not researchers that were given to a significant number of employees who were taking the trainings in their actual workplaces.

A set of studies, conducted in the late s by Professor Magley and her colleagues, evaluated trainings at two large employers - a large regulated utility with one location and a large agribusiness with several worksites. Third, because it is difficult for researchers to gain access to workplaces to study which is why there are so few research studies of this kind , many researchers design experiments using student-volunteer samples or other small volunteer samples in organizational settings.

In many studies, the researchers survey participants pre- and post-training and evaluate the effectiveness of the training based on self-reported answers immediately following the training. These studies are not to be discounted, but their limitations must be acknowledged.

Finally, all of the evidence regarding the effectiveness of training is based on studies of sexual harassment training, not general harassment training.

First, it appears that training can increase the ability of attendees to understand the type of conduct that is considered harassment and hence unacceptable in the workplace.

The most interesting study in this regard was of federal employees. Rather than conducting a large-scale evaluation of a particular training, researchers compared results from the three surveys done by the Merit Systems Protection Board of federal employees over the course of a decade and a half - in , , and The training seemed particularly successful in clarifying for men that unwanted sexual behavior from co-workers, and not just from supervisors, can be a form of sexual harassment.

Ensuring that employees know what an employer considers to be harassment is obviously an essential element for effective implementation of an employer's anti-harassment policy. In the study by Professors Bingham and Scherer of a minute training, participants demonstrated more knowledge about sexual harassment than those who had not participated in the training. Given that Hispanic employees in that study did not evidence increased knowledge, the researchers observed that culturally-appropriate training might have made a difference.

Second, it is less probable that training programs, on their own, will have a significant impact on changing employees' attitudes, and they may sometimes have the opposite effect. The study by Professors Bingham and Scherer evaluated a minute training focused on sensitizing attendees to sexual harassment. Men who completed the training were more likely to say that sexual behavior at work was wrong, but they were also more likely to believe that both parties contribute to inappropriate sexual behavior.

In the study conducted by Professor Magley and her colleagues, there was no evidence of any backlash to the trainings. However, the personal attitudes of participants toward sexual harassment were minimally changed or completely unchanged. Third, in the study by Professor Magley and her colleagues the only study to test for this result , there was no evidence that the training affected the frequency of sexual harassment experienced by the women in the workplace or the perception by women that certain sexual conduct was sexual harassment.

However, on the positive side, complaints to the human resources department did increase after the training. The researchers postulated that the increase was the result of a multi-faceted approach taken by the employer and not the result of the training alone. For example, prior to the training, the employer had provided employees with a number of additional resources to lodge complaints including hotlines and had begun improving its procedures for complaint follow-up.

As Professor Magley and her colleagues have pointed out, a common theme among the research studies is that effective training does not occur within a vacuum. Researchers have suggested a range of ideas for creating harassment-free and supportive work environments in which non-training factors are included together with training.

In sum, the existing empirical evidence is conflicting and sometimes surprising. It leaves us with a few conclusions:. We cautioned above, and we caution again, that the results of these studies implicate only the effectiveness of the specific trainings that were evaluated.

The data cannot be extrapolated to support general conclusions about the effectiveness of training. Indeed, our most important conclusion is that we need better empirical evidence on what types of training are effective and what components, beyond training, are needed to make the training itself most effective.

As we noted above, many witnesses told us that it would be extraordinarily valuable for employers to allow researchers into their workplaces to conduct empirical studies to determine what makes training effective.

We agree with that suggestion, although as we noted above, we are cognizant of the concerns that employers may have in welcoming researchers into their domains. For example, we recognize that employers will want to have control over how data derived from their workplaces will be used, and equally important, not used.

Regardless of the empirical data from research studies, we heard from practitioners with decades of experience that training - especially compliance training - is a key component of any harassment prevention effort. We provide below the insights we learned from these practitioners. Compliance training is training that helps employers comply with the legal requirements of employment non-discrimination laws by educating employees about what forms of conduct are not acceptable in the workplace and about which they have the right to complain.

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