We recently decided that just telling our general managers and supervisors how we felt about harassment was not enough. In the past, we had included brief statements on harassment at departmental meetings and new employee orientations.

We were being clear that harassment of any type would not be tolerated and that anyone who felt they were subject to it could go to any level of the company to report it. However, we recently decided that our verbal system was insufficient and that a formal policy needed to be developed and implemented. 

Unfortunately, the rules have changed and all employers need to be able to demonstrate and document all of its policies and that they were communicated to employees. The realities of the workplace and our litigious society necessitate being very clear on where an employer stands on these issues. What is included here is our recently issued policy we circulated to all our general managers:

No Harassment Policy - American Hospitality Management Company and Hospitality Employees, Inc., are committed to providing our employees with a work environment that is free of unlawful discrimination. As part of that commitment, we do not and will not tolerate harassment of out employees.

"Harassment" includes, but is not limited to verbal, graphic, or physical conduct relating to an individual's race, color, gender, sexual preference, religion, national origin, citizenship, age or disability.

"Sexual Harassment" in specific may take a number of forms all of which are prohibited by this policy. Sexual harassment may include, but is in no way limited to, the following:

Unwelcome sexual flirtations, sexual advances or propositions, requests for sexual favors, unwelcome or offensive touching, explicit, degrading or demeaning comments about another individual or his/her appearance, the display of sexually suggestive pictures or objects, telling suggestive jokes or making sexually suggestive comments or gestures or other offensive verbal, graphic or physical conduct of a sexual nature. Taking or the refusal to take any personnel action based on an employee's submission to or refusal of sexual overtures. No employee should ever imply or even joke that an individual's "cooperation" with sexual overtures will have any effect on the individual's employment, assignment, compensation, advancement, career development or any other condition of employment. 

A sample Sexual Harrassment Policy

VIOLATION OF THIS POLICY PROHIBITING HARASSMENT WHICH AFFECTS THE WORKPLACE WILL SUBJECT AN EMPLOYEE TO DISCIPLINARY ACTION UP TO AND INCLUDING IMMEDIATE DISCHARGE

All employees must avoid behavior which may even raise the implication of harassment. If your question whether or not something you do could be deemed harassment, the best choice would be not to perform that behavior.

1. If possible, tell the harasser that his or her actions are unwelcome and that they should stop.

2. Immediately notify your supervisor or corporate personnel director if you feel you cannot go to your supervisor. Supervisors must immediately report all incidents of suspected or reported incidents to their supervisors and corporate personnel director.

3. If additional incidents occur, immediately report them to the same individuals to whom you reported all prior incidents.

4. If you feel that a supervisor or member of management has acted inconsistently with this policy or if you feel that your complaint has not been handled to your satisfaction, please contact the corporate office immediately.

All reported incidents will be thoroughly investigated. Although neither American Hospitality Management Company no Hospitality Employees, Inc., can guarantee confidentiality, your complaint and the actions taken to resolve the complaint will be handled as discreetly as possible. This commitment, however, will always be weighted against our obligation to investigate and act upon reports of harassment.

No employee will be retaliated against for reporting an incident of harassment and immediate action will be taken should the alleged harasser engage in retaliation or any adverse treatment against the individual reporting the incident.

You should never assume that the organization is aware of your problem. It is your responsibility to bring your complaints and concerns to our attention so that we can help resolve them.

Implementation of No Harassment Policy Enclosed is a new Communication Bulletin to be included in your policy manual, the Communications Bulletin Binder. Although this company has always had an underwritten policy regarding harassment, we feel it is necessary to put the policy in writing.

You are to Immediately:

Read this policy very carefully. Place it in the Communications Bulletins Binder in the appropriate place. Hold departmental meetings specifically to give all employees a copy of this policy and to discuss the contents of the bulletin. If you are planning to hold departmental meetings within the next week, you may distribute and discuss it at that time. If your meetings are not scheduled in the immediate future, you must schedule one to discuss this policy. Write a memo to us at the corporate offices documenting when and where you discussed this policy with all employees. List the names of the employees in attendance at each meeting. If any employee is absent, you must give them a copy and discuss the policy individually. This, too, must be documented. This memo must be received in our office no later than one week following your receipt of this bulletin. 

Disclaimer: If you need to develop and implement a formal harassment policy, and I think you do, no matter how small your operation is and what the demographic makeup of your workforce is, you should consult with your attorney before implementing such a policy. 

Do not just copy this one because circumstances vary from company to company. If your attorney is not very experienced and knowledgeable in labor relations, you need to find someone more appropriate to assist you. If you need a referral to such an attorney call me and I'll give you the names of two or three excellent ones.