INSIGHTS
From reactive to proactive: How game-based training can support anti-harassment policy

With new harassment legislation in effect in the UK, how can employers do more than tick a box when it comes to compliance?

What constitutes sexual harassment? Are members of your team at risk of it? Would they know what to do if they experienced or witnessed harassment? If you’re not sure about the answers to any of those questions, it’s time to get in the know.

Not just because of the extent of the problem of sexual harassment in UK workplaces (40% of women and 18% of men have experienced unwanted sexual behavior at work),¹ but because it’s now a legal requirement.

New legislation (under the Equality Act 2010) came into effect at the end of 2024 in the UK requiring employers to take ‘reasonable steps’ to prevent sexual harassment of employees.²

This has caused some of the businesses I’ve spoken to recently to be in a bit of a panic – mainly because the legislation doesn’t give much guidance when it comes to what those reasonable steps might look like.

Sure, you can put a company-wide policy in place. You can even get your team to read a document and complete some mandatory multiple-choice training to ‘prove’ they’ve taken in the information.

But if you want to demonstrate a more steadfast commitment to prevention, you might have to go a bit further.

The cost of compliance

The cost of compliance in general is growing in the UK. In the financial services sector alone, 76% of firms have increased compliance spending and their team members now spend an average of 18 hours per year in compliance training.⁴ But, in 2024 alone, the Financial Conduct Authority issues £160 million in fines for non-compliance.⁵

Clearly, throwing money and training hours at the problem isn’t enough – organizations need to think carefully about where they’re investing their time and money in 2025 to comply with new sexual harassment legislation on top of their other compliance initiatives.

What are ‘reasonable steps’?

There’s some general guidance, like from the Equality and Human Rights Commission and the Advisory, Conciliation and Arbitration Service (Acas), and some regulatory bodies have put out sector-specific guidance. But the truth is, no one really knows. As Acas put it in its guide, “What is reasonable depends on the situation. There’s no set list of steps that all employers must take.”⁶

For now, it’s up to employers to decide what they deem reasonable. And this isn’t a decision that should be taken lightly, considering that if an employee succeeds in a claim for sexual harassment, the employer could have to pay an additional 25% compensation if they’re found not to have complied with their preventative duty.⁷

Putting policy into practice

Perhaps the most obvious step an employer could take to prevent workplace sexual harassment would be to write an internal policy or update its existing one. But does that go far enough, and is simply having a policy enough to influence company culture?

Employers have to put the work in to make sure their teams have absorbed and understood the information. That means – you guessed it – training everyone from leaders to new starters on what the policy says and what it means for day-to-day life at that company.

What would strong preventative harassment training look like?

I bet you anything that a whole lot of quick and cheap training ‘solutions’ will be popping up as we speak in response to the legislation coming into effect.

But not all training was created equal, and many of them won’t actually make a difference to your team’s attitudes and behaviors, or your wider company culture.

Driven by data

It’s all well and good having your employees complete sexual harassment training. But how do you know the information has actually gone in? How can you tell who really gets it and who needs to revisit parts of their training to make it stick?

With AI-driven, data-based solutions, you can not only see where the strengths and knowledge gaps are in your team, but each person’s learning journey can be automatically personalized to strengthen their individual weaker areas.

Learning actively

Many e-learning solutions available provide reams of information and require participants to answer a few multiple-choice questions to make sure they’ve read it. The issue with that type of learning in this context is that the information is less likely to stick in real-world scenarios.

In contrast, active learning – where users are required to be more involved rather than passive in their learning journey – with realistic, simulated scenarios provides more context. It can provide a clearer framework for what behaviors you expect from them and equip learners with the tools they need to act in a way that’s consistent with your policy.

When legislation like this comes in, there’s naturally going to be some uncertainty around ‘what counts’ as reasonable steps towards preventing harassment.

But with a clear policy and the right kind of compliance training to back it up, you can feel more confident that your organization is doing what it can to not only comply but to actually drive a more positive culture for your teams.