Illinois Sexual Harassment Training Addendum (PA 101-0221)

Illinois Workplace Transparency Act / Public Act 101-0221 requires annual sexual-harassment training for ALL Illinois employees.

Purpose

• This addendum establishes the company's Illinois-specific sexual harassment prevention training requirements for all employees working in Illinois. It is intended to support compliance with the **Illinois Workplace Transparency Act (Public Act 101-0221)** and the **Illinois Department of Human Rights (IDHR) Minimum Training Standards for All Employers**.

Scope

• This policy applies to **all employees working in Illinois**, including full-time, part-time, temporary, seasonal, and remote employees whose work location is Illinois. It also applies to supervisors and managers. **Illinois employees:** annual training is required regardless of employer size. If a broader company anti-harassment policy exists, this addendum supplements that policy and controls for Illinois-specific training requirements.

Definitions

• For purposes of this addendum: - **Sexual harassment** means unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature when submission to or rejection of such conduct is used as the basis for employment decisions, or when the conduct has the purpose or effect of unreasonably interfering with work performance or creating an intimidating, hostile, or offensive work environment. - **Annual training** means training completed at least once every 12 months. - **Policy holder** means the company department or designated leader responsible for maintaining this policy and training records. - **Interactive process** means a good-faith, individualized discussion used to evaluate concerns, accommodations, or reporting barriers when relevant to training access or workplace issues.

Policy Statement

• The company requires every Illinois employee to complete sexual harassment prevention training **annually**. Training must be provided in a manner that is accessible to employees and must cover the minimum topics required by Illinois law and IDHR standards. Completion of training is a condition of continued employment to the extent permitted by law and company procedure.

Required Training Content

• The training must, at a minimum, include the following topics: 1. An explanation of sexual harassment consistent with Illinois law. 2. Examples of conduct that constitute unlawful sexual harassment. 3. A summary of relevant federal and state statutory provisions concerning sexual harassment, including employee remedies. 4. A summary of the employer's internal complaint process, including how to report concerns. 5. Information on how complaints are investigated and resolved. 6. A statement that retaliation for reporting harassment or participating in an investigation is prohibited. 7. Any additional content required by the IDHR minimum training standards or applicable local law. Training content must be updated when legal requirements change.

Training Delivery and Timing

• The company will provide training: - Within the first year of employment for new Illinois employees, and - At least once every 12 months thereafter. Training may be delivered in person, live virtual, or approved e-learning format, provided it satisfies Illinois requirements and is reasonably accessible to the employee. Managers are responsible for ensuring new hires are scheduled promptly and that employees do not miss their annual deadline.

Roles and Responsibilities

• **Human Resources / Compliance** - Maintain the approved training curriculum. - Track completion dates and issue reminders. - Retain training records. - Coordinate updates when Illinois law or IDHR standards change. **Managers** - Ensure employees complete training on time. - Escalate missed completions to HR. - Support scheduling and attendance. **Employees** - Complete required training by the assigned deadline. - Follow reporting procedures if they experience or witness harassment. - Cooperate in good-faith with any investigation.

Compliance, Recordkeeping, and Consequences

• The company will maintain records of training completion, including the employee name, training date, and training method, for the period required by law or company retention standards. Failure to complete required training may result in documented warning, removal from scheduling until training is completed, or other corrective action consistent with company policy and applicable law. Nothing in this policy limits rights protected by the **NLRA Section 7**, the **FLSA**, the **FMLA**, the **ADA interactive process**, or **EEOC Title VII** protections.

Review and Revision

• This addendum will be reviewed at least annually and whenever Illinois law, IDHR standards, or related company policies change. The policy holder is responsible for coordinating revisions and re-approval.