From the EEOC: 5 Culture Changing Ideas to Prevent Harassment

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Nov 6, 2018

Last week the EEOC held a public meeting on “Steps to Transform Workplace Culture to Prevent Harassment.” The consensus was that employers best accomplish this through  a “holistic approach.”

Those are fancy words. But what precisely can you do to address harassment?

I’ve got five big takeaways from the meeting:

1. Create a culture assessment

David Bowman, a partner at the law firm of Morgan, Lewis & Bockius, testified about the importance of “routine culture assessments” and training as a best practice for employers to combat workplace harassment and discrimination.

What goes into conducting a culture assessment?

  • Identify the organization’s goal(s) and specific issue(s) that the organization seeks to address;
  • Develop a set of focused interview questions;
  • Ask the question in one-on-one interviews and/or focus groups;
  • Analyze the results to yield key themes or other vulnerable areas; and
  • Fashion recommendations designed to remediate organizational problems.

2. The three levels of prevention

Rob Buelow, vice president, EVERFI, addressed the “public health model.” According to Mr. Buelow, this involves three levels of prevention, all of which can be applied to address workplace issues like harassment and discrimination:

  • Primary prevention strategies are focused on addressing root causes and deterring the onset of risky or harmful behaviors.
  • Secondary prevention strategies are focused on reducing exposure to and effectively responding in risky or harmful situations.
  • Tertiary prevention strategies are focused on mitigating the impact of harmful behavior after it has occurred and preventing future recurrence.

Mr. Buelow stressed that “organizations should be actively shifting the balance to prioritize primary prevention (or stopping concerning behavior before individuals are harmed).”

3. Focus on ‘civility training’ to address and prevent harassment

Christine Porath, associate professor, Georgetown University, McDonough School of Business, was asked to offer “information on civility, how it’s tied to harassment, how training in civility can be used to address and prevent harassment, and how social networking analysis can be used as a tool to assess civility.”

Concluding that there is a direct correlation between an increase in workplace civility and a decrease in harassment, Professor Porath explained that civility training “tends to focus on the positive – what employees and managers should do to build a workplace where people feel respected and valued (rather than on what they should not do).”

4. ‘Ya Basta’

SEIU United Service Workers West is a union that represents subcontracted security officers, airport workers and over 25,00 janitors throughout the state of California. At the public meeting, Alejandra Valles, secretary-treasurer of USWW, shared how “for the last three years, immigrant women janitors have been breaking their silence and saying Ya basta to End Rape on the Night Shift by changing the culture of the industry from the bottom up.”

This prompted a “look within” and a six-part plan:

  1. Change the culture of the janitorial industry from the bottom up by altering human behavior on the spot.
  2. Prevention as a goal; liability and compliance as a tactic. Both and, not either or.
  3. Work to create mandates for in-person sexual violence and harassment training for the janitorial industry through policy, union contracts and our own union as an employer.
  4. Build a Ya Basta coalition and partner with organizations who value worker centered and survivor centered solutions.
  5. Create curriculum designed and delivered by janitors, in their language, style and expertise
  6. Build trust.

5. Organizational policies and proper CEO oversight

Finally,  Anne Wallestad, president & CEO, BoardSource, shared her experience with an eye towards strengthening nonprofit leadership at the highest level – the board of directors. She stressed that “the board has not only an opportunity, but a responsibility, to ensure that the organization treats employees fairly and appropriately, that it is in compliance with all relevant laws, and that issues of harassment are being addressed.”

To address workplace harassment, Ms. Wallestad suggested focusing on “two levers: organizational policies and proper CEO oversight.”

Regarding policy-setting, the board must be comfortable with the organization’s policies and practices related to:

  • hiring and references,
  • reporting, investigation, and consequences, and
  • communications and accountability.

She noted that the board should proactively ask questions like:

  • If faced with a situation of sexual misconduct by someone affiliated with our organization, how will we demonstrate accountability?
  • Do we have clear policies about who is empowered to serve as a spokesperson for our organization?
  • In what circumstances would we err on the side of more (or less) transparency in our communications?

Finally, she recommended that boards implement an “evaluation process” that includes some or all of the following inputs:

  • Direct, 360 feedback: BoardSource recommends that each CEO review include feedback from — at a minimum — those employees who report directly to the CEO. This is one of the only opportunities boards have to invite staff feedback in a way that is respectful of the CEO and does not signal a lack of confidence from the board. It also encourages honest feedback by protecting staff members’ confidentiality.
  • Staff surveys: Staff surveys can be a helpful window into the CEO’s leadership of the team as well as the overall health of the organization.
  • Staff retention metrics: Boards should pay attention to any spikes in attrition or significant variances within different demographic categories of staff, which could be a signal of challenges.
  • Publicly available commentary and feedback: Boards can take advantage of publicly available commentary on sites like, which enable employees (and former employees) to share candid feedback about the organization’s work environment.

What do you think?

Hopefully, some of these ideas either resonate or complement efforts that your business has taken to combat workplace harassment. If you’d like to learn more, here is a link to more from the EEOC public hearing, including witness testimony, bios, and (eventually) a video from the hearing.

This article originally appeared on The Employer Handbook blog.

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