From “Reasonable Steps” to Real Prevention: A Board Level Roadmap to Comply and Lead on Sexual Harassment

Sexual harassment remains a persistent issue in workplaces across the UK, with surveys suggesting nearly a third of employees experience some form of harassment in a work-related setting each year. Yet only a small proportion report their experience formally. In other words, it could be happening in your workplace without ever reaching HR or leadership.

That under-reporting is part of the reason the legal approach has shifted. It is no longer enough for employers to be purely responsive once a complaint has been made. The expectation now is proactive: to identify risk, put effective preventative measures in place and reduce the likelihood of incidents occurring in the first place.

This article is based on our recent Level Up webinar, Preventing Sexual Harassment in the Workplace, hosted by Amy White, Head of Training and Wellbeing at Loch. In the session, Amy guided employers through what the legal duties mean in practice and shared a roadmap for moving from compliance to real prevention.

Why this is now firmly a board-level topic

From 26 October 2024, the Worker Protection (Amendment of Equality Act) Act 2023 introduced a new legal duty on employers: to take reasonable steps to prevent sexual harassment in the workplace.

Early signs suggest the duty is already influencing how employers and employees think about workplace behaviour and organisational responsibility. Acas reported a 39% increase in helpline calls about sexual harassment in the first half of 2025 compared with the previous year, from both employees and employers. This sharp rise reflects growing awareness among staff, and uncertainty among employers about their new obligations.

For boards, this is not only a legal compliance issue. It is also about governance and organisational resilience: how leaders create a workplace where people can do their best work, where concerns are handled early and fairly, and where the organisation is not exposed to avoidable cost, distraction and reputational risk.

The legal consequences are also sharper than before. While an individual cannot bring a standalone Tribunal claim purely for breach of the preventative duty, a tribunal can uplift compensation by up to 25% in a successful sexual harassment claim if it finds the employer breached that duty.

A board-ready roadmap: moving from compliance to real prevention

For many organisations, the new duty involves moving from policies that exist “on paper” to prevention that works in practice – supported by evidence, refreshed over time and clearly owned at leadership level.

In the webinar, Amy highlighted six prevention levers boards can expect to see in a credible, evidence-led plan. Here is how they fit together.

     1) Start with a living risk assessment

A risk assessment is the foundation. It helps you identify where risk is most likely to arise, who may be most exposed and which situations need additional controls – whether that is certain roles, work patterns, environments or power dynamics. It should be treated as a live document: workplaces change, and a plan that is not reviewed can drift out of date.

Board question: can we evidence that we understand our risks and have chosen proportionate actions that reduce them?

     2) Train for behaviour change

Training is one of the most visible “reasonable steps”, but its impact depends on quality and follow-through. Amy emphasised making training regular, relevant and practical – something that helps people make better decisions in real situations. A strong approach typically includes staff training (what sexual harassment can look like, expectations of behaviour, and how to raise a concern) and manager training (how to receive concerns, respond appropriately, escalate properly, and intervene early).

Trained managers reduce risk day-to-day through the tone they set and the confidence they bring to handling issues promptly and fairly.

     3) Refresh policies so they work in real situations

Policies only protect you if people can find them, understand them and trust the process behind them. A common gap is managers lacking confidence in applying the policy, which undermines consistency. Boards should expect policies that are accessible and clearly written, aligned with reporting routes, reinforced through ongoing communication (not a one-off announcement), and kept current with legal expectations and organisational learning.

The aim is predictability: employees know what to expect and managers know what “good” looks like when a concern is raised.

     4) Make reporting safe, clear and credible

A healthy reporting culture is not about encouraging more complaints. It is about ensuring people can raise concerns early, when issues are smaller and easier to address. Under-reporting means “we haven’t heard anything” is not a reliable indicator of low risk. Boards should look for multiple reporting options (not only “tell your manager”), clear escalation routes and responsibilities, and visible reassurance that concerns will be handled fairly, promptly and consistently.

When reporting feels credible, organisations can step in sooner, resolve issues appropriately, and protect teams.

     5) Build capability for fair, proportionate investigations

When an issue is raised, the organisation’s response is part of prevention. Investigations should be impartial and proportionate, handled as genuine fact-finding, and supported by confidentiality and sensitivity. Preparing capability in advance – whether that is training relevant leaders or ensuring access to specialist support – reduces inconsistency and builds trust in the process.

     6) Use feedback loops to keep improving

Effective prevention systems learn. Staff surveys, listening sessions, exit insights and themes from reports can all help you spot emerging risks and improve controls.

Amy highlighted the importance of turning insight into action – and documenting that improvement – so prevention remains active, credible and tailored to what is actually happening across the organisation.

“Reasonable steps” isn’t a template, it’s an individual approach

One of the most important takeaways from the webinar was that “reasonable steps” will not look identical from one organisation to another. What is reasonable depends on your context: the nature of your work, your workforce, your working patterns, your third-party relationships, your size and resources, and which measures will be most effective in your environment.

That is good news. It means boards can focus on building a prevention programme that is practical, proportionate and likely to work, rather than applying generic controls that do not land with employees or address the real risk points.

Looking ahead: further changes are coming this year

It is also worth planning beyond today’s requirements. Under the Employment Rights Act 2025, the prevention duty will tighten again: from October 2026, employers will need to take “all reasonable steps” to prevent sexual harassment in the workplace, raising the expected standard of prevention.

We cover this change – and the wider implications of the Employment Rights Act 2025 – in our recent webinar, The Employment Rights Act 2025: Your 2026–27 Action Plan. Click here to watch the webinar on demand.

How Loch supports you: tailored guidance, confidence and protection

Because the duty is context-specific, the strongest programmes are those shaped around the organisation’s real risks, not generic assumptions. Loch supports businesses to take that individual approach, with practical guidance boards can rely on: risk assessment, policy refresh, reporting route design, staff and manager training, and investigation capability – wrapped into a programme you can evidence and sustain.

If you are looking to strengthen your organisation’s culture and compliance, take a look at our Prevention of Sexual Harassment Support Packages, covering HR guidance and legal advice, and built for prevention that genuinely works.