Consequences
Ensure consequences for individuals found liable of sexual harassment align with the seriousness of the misconduct.
Table of Penalties
Consider expanding the use of tables of penalties or other tools or framework to ensure that disciplinary action is consistently applied for like or similar misconduct.
No Entry for Harasser
To the extent legally supportable and feasible, implement policies to prohibit hiring those who have previously engaged in sexual harassment or other serious misconduct (including procedures to ensure due diligence in hiring), or establish procedures to safeguard employees if the law prohibits such actions.
Risk Assessment
Assess whether any aversion to risk, including litigation risk, associated with taking adverse personnel actions unduly impacts addressing sexual harassment or other serious misconduct in a manner that aligns with organizational values.
Remove Bonus Opportunity
Update policies to prohibit the payment of bonuses to any individual found to have committed sexual harassment and to delay bonuses for any employee being investigated for sexual harassment or other serious misconduct, until cleared of any wrongdoing. Determine whether other actions are appropriate for individuals found to have engaged in sexual harassment (e.g., demotion, restricting promotion opportunities).