Adopt, communicate, and consistently enforce a written policy prohibiting all forms of harassment. This policy should:
Use the EEOC definition of harassment; or use plainer language and include examples of various kinds of harassment. It is wise to include a prohibition of harassment based on other criteria, such as religion, age, race, or disability (covered by Title VII).
Communicate a “zero-tolerance” stance to harassment.
Avoid having employees assume that a manager’s actions are implicitly approved or known by the nonprofit.
All employees are expected to report any harassment that they observe, have heard about, or believe may be occurring.
The level of discipline will depend on the severity and frequency of the harassment. Choices range from documented verbal counseling or a written warning to probation or even termination. In any harassment investigation, it is wise to seek legal advice.
The policy should require all individuals who believe they have been the victims of harassment, or who have observed or heard about harassment, to report it.
The complaint can be handled in a discreet manner and information can be kept on a need-to-know basis; it can’t be held strictly confidential if investigation and discipline are to follow.
Encourage employees to report harassment to any supervisor, as well as to specific, named, male and female managers. List names and phone numbers of specific persons to contact when the employee feels the complaint was not adequately addressed. Provide a hot-line number or name of person to contact at headquarters office, if the nonprofit is a large multi-location entity with centralized headquarters offices.
Specifically assure that employees who, in good faith, report what they believe to be harassment, or who cooperate in any investigation, will not suffer any retaliation. The policy should also state that any employee who believes he or she has been the victim of retaliation for reporting harassment should immediately report the retaliatory acts and include a name and phone number.
Provide separate acknowledgment forms for supervisors (who can be held personally liable for engaging in sexual harassment) and non-supervisory employees to sign after reading the policy.