The New York Division of Human Rights has released an updated Sexual Harassment Prevention Policy. The state requires that employers of all sizes use the model policy or one that is equivalent to it. The updated model policy is considerably longer than the last version and includes additional definitions and examples. It also includes a new section on bystander intervention.

Given the length (11 pages) and complexity of the updated policy, we recommend using it essentially as-is—with customization where indicated—rather than trying to modify a more generic policy to meet New York’s minimum required standards. Employers that don’t include the policy in their employee handbook should ensure that it’s given to each employee as part of the onboarding materials.

Action Item
Make any necessary changes to the new model policy and distribute it to employees as soon as possible, but no later than during your next round of sexual harassment prevention training. The new model policy, as well as other required forms and notices, is available here.