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New York State Model Sexual Harassment Policy, Complaint Form, and Training Program Made Available for Public Comment

On August 23, 2018, in accordance with the recent amendments to the New York Labor Law regarding sexual harassment in the workplace, New York State published draft versions of the Model Sexual Harassment Policy and Model Complaint Form, as well as a Model Sexual Harassment Prevention Training script.

While many employers already have sexual harassment policies in place, the amendments to the Labor Law require that such policies meet minimum standards set by New York State. Employers’ sexual harassment policies must meet or exceed these standards. These new and updated policies must be implemented by each employer operating in New York State by October 9, 2018.

The Labor Law amendments also require interactive sexual harassment prevention training to be provided to all employees on an annual basis. This training must also meet certain minimum standards established by the State. Once finalized, in addition to the script published by the State, it appears that the Model Sexual Harassment Training will also be available in other formats, including PowerPoint and video. As it currently stands, the model training document requires that all employees complete sexual harassment prevention training before January 1, 2019.

All three documents discussed herein are draft documents. As such, employers and other members of the public are encouraged to provide public comments on all of the policies proposed therein. Comments can be submitted on or before September 12, 2018.

However, as the October 9, 2018 deadline for the implementation of sexual harassment policies that are compliance with the Labor Law amendments is quickly approaching, employers may want to begin examining their current policies and updating them to conform with the current draft Model Sexual Harassment Policy.

For assistance reviewing these newly published documents, submitting public comments with respect to the same, and/or updating your company’s sexual harassment policy and training to ensure compliance with New York State Law, contact Jennifer Kavney Harvey or Madeline W. Goralski.