New York §201-g Sexual Harassment Training Addendum

NY Labor Law §201-g sexual harassment training addendum — annual interactive training for ALL employees (no employer-size threshold).

Purpose

• This addendum establishes the company’s New York sexual harassment prevention training requirements under **New York Labor Law §201-g**. The policy holder must ensure that all covered workers complete **annual interactive training** and that completion is documented. This addendum is intended to supplement, not replace, the company’s broader anti-harassment policy and reporting procedures.

Scope

• This addendum applies to: - **All employees** working in New York, regardless of employer size - Supervisors and managers - Temporary workers and interns, where applicable to the company’s training program - Any employee transferred into New York work locations or assigned to perform work in New York **New York employees:** training is required on an annual basis and must be interactive. This addendum does not limit any rights or remedies available under federal, state, or local law, including Title VII of the Civil Rights Act and applicable New York City Human Rights Law requirements where applicable.

Definitions

• For purposes of this addendum: - **Interactive training** means training that includes participant engagement, such as questions and answers, scenarios, quizzes, or live discussion. - **Sexual harassment** means unwelcome conduct of a sexual nature or conduct based on sex that creates a hostile work environment, affects employment conditions, or is otherwise prohibited by law. - **Covered employee** means any employee required to complete the New York training under this addendum. - **Completion record** means documentation showing the date, format, attendee, and completion status of the training.

Policy Statement

• The company will provide sexual harassment prevention training to all covered employees at least once every 12 months. Training must be interactive and must cover the company’s reporting channels, anti-retaliation protections, and the standards of conduct expected in the workplace. The company will not retaliate against any employee who raises a concern, participates in an investigation, or requests a reasonable accommodation related to training access or delivery.

Required Training Content

• The training program must, at a minimum, include: 1. A clear explanation of prohibited sexual harassment conduct 2. Examples of conduct that may violate policy 3. Reporting options, including how to report to HR or a designated manager 4. The company’s investigation process and confidentiality expectations to the extent practicable 5. Anti-retaliation protections 6. Supervisor responsibilities to escalate complaints promptly 7. Bystander intervention or practical prevention guidance, where included in the company curriculum 8. Any additional content required by applicable New York state or local law The training should be tailored to the workplace and should use examples relevant to the employee’s work environment.

Training Delivery and Timing

• Training may be delivered in person, live virtual, or another interactive format approved by HR, provided it allows employee participation. The company will: - Assign training upon hire or assignment to New York work, if the employee has not completed a current-cycle training - Require annual retraining every 12 months - Provide make-up sessions for employees who miss the scheduled training - Offer reasonable accommodation or alternative delivery methods when needed to support access, consistent with the ADA interactive process Employees are expected to complete training by the assigned deadline and to participate in good faith.

Roles and Responsibilities

• **HR / Compliance** - Maintain the training program and update it for legal changes - Track completion records and send reminders - Coordinate make-up sessions and accommodations **Managers and Supervisors** - Ensure team members complete training on time - Escalate missed deadlines to HR - Model respectful workplace behavior **Employees** - Complete training by the deadline - Participate actively and answer required prompts or assessments - Report any issues accessing the training **Policy holder / Employer** - Approve the training content, vendor, and recordkeeping process - Ensure the program remains compliant with New York law

Compliance, Recordkeeping, and Consequences

• The company will retain training completion records, attendance logs, and course materials for compliance purposes according to the company’s record retention schedule and applicable law. Failure to complete required training may result in corrective action, which may include a documented warning, removal from scheduling until training is completed, or placement on a performance improvement plan (PIP), subject to applicable law and company practice. Nothing in this addendum limits employee rights under the NLRA, FLSA, FMLA, ADA, or applicable anti-discrimination laws.

Review and Revision

• This addendum will be reviewed at least annually and whenever New York, local, or federal law changes affect training requirements. Updates must be approved by HR, Legal, or the designated compliance owner before publication. If a conflict exists between this addendum and applicable law, the law will control.