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Worked example: harassment-duty checklist

This is a plain-English worked example for a fictional 40-cover pub called The Example Arms. It shows the kinds of points an employer might consider when taking reasonable steps to prevent sexual harassment of workers, under the duty introduced by the Worker Protection (Amendment of Equality Act 2010) Act 2023 (in force from 26 October 2024). The duty covers harassment by other workers and by third parties such as customers. From 30 October 2026, employers must not permit harassment of staff by customers and other third parties.

It is based only on that statutory duty and the Equality and Human Rights Commission’s published guidance (including its 8-step guide and hospitality-oriented checklist materials). It is not a complete policy, not a risk assessment, and not legal advice. Adapt any points to the real venue and seek appropriate advice.

Example only. Not legal advice.

Risk assessment notes (fictional)

The Example Arms is a small pub. Main risks considered: customer-facing bar and floor staff, presence of alcohol, occasional lone or late working, social events involving staff and customers, and power differences between managers and other workers. Steps below are the kinds of measures that might be noted as reasonable in this setting.

Before a shift

More than one person is involved in decisions about rotas or tips, so one individual cannot abuse that control. Staff are not routinely left alone in higher-risk situations (for example late closing or large groups) where this can reasonably be avoided. Clear ways to report concerns are in place, and more than one trusted contact is available on the shift. Anyone handling an incident (including temporary or agency staff) knows the basic response steps. Lighting, secluded areas and back-of-house spaces have been checked and adjusted where practical.

Start of a shift

Staff are reminded of the anti-harassment approach and of what sexual harassment means (unwanted conduct of a sexual nature that violates dignity or creates an intimidating, hostile, degrading or offensive environment). Zero tolerance is restated for behaviour by colleagues or by customers, and staff know who to tell if something happens. Any customer-facing notices or agreed responses (for example warning or asking a customer to leave) are confirmed. Staff working with large groups or in potentially isolated positions are paired or supported where possible.

During and end of shift

Staff have a straightforward way to raise something that happened, including anonymously if preferred. Any customer incident is logged so patterns can be seen and further steps considered. Staff are reminded that behaviour at staff social events connected with work is still treated seriously. A short note is made of whether the checklist points were used and whether anything needs adjusting for next time.

Ongoing points

A written anti-harassment policy (or clear section within a wider policy) exists, covers third-party behaviour, and is easy for staff to find. Training or briefings have been given so staff and managers recognise sexual harassment and know what to do. Complaints are handled promptly, confidentially where appropriate, and without victimising the person who raised them. Effectiveness is reviewed from time to time (for example by looking at any reports or staff feedback) and changes are made if needed.

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Example only. Not legal advice. Legal