Harassment prevention: using the 2023 preparation year well

A duty with time to prepare

The Act established a duty for employers to take reasonable steps to prevent sexual harassment of employees and provided for a potential compensation uplift in relevant tribunal cases. The timing mattered: October 2023 was the Act’s passage, while the new duty took effect on 26 October 2024.

Later reforms strengthened the law again in October 2026. This retrospective does not treat that later wording as if it had applied in 2023. The operational lesson from the Act’s passage was to prepare a prevention process, with legal and HR owners responsible for identifying what the employer needed to do.

A concern needs a route beyond the desk

A concern may first reach a recruiter rather than an employee’s line manager. It might be raised during an interview, through a candidate message or after a placement begins. An unclear response path can leave the person repeating sensitive information while each recipient assumes someone else has taken responsibility.

A useful preparation exercise is to map those routes and identify who can receive a confidential escalation. The process should explain what routine administrators may record, where sensitive material belongs and when urgent action is required. A general customer-service inbox is unlikely to be an adequate substitute for a properly agreed reporting route.

Testing a sample report route with the responsible manager can reveal an outdated contact before a real concern depends on it.

Support the route while retaining accountability

Key Med Solutions can help a client document approved escalation contacts, add the correct reporting information to onboarding material and maintain training-completion administration where that work is agreed. The content and adequacy of prevention measures should be determined by the employer with appropriate professional advice.

For staffing businesses, a placement handover can record that the worker has received the relevant contact details and that the client’s responsible manager is identified. The record should avoid implying that signing a form proves a workplace is safe. Concerns still need timely handling by people authorised and trained to respond.

The preparation year offered space to test whether policies were usable in practice. Key Med can support the coordination and recordkeeping around an approved process; investigations, risk assessments requiring specialist judgement and decisions about legal duties remain with the employer and qualified advisers.