Anti-Harassment & Anti-Discrimination Policy
Anti-Harassment & Anti-Discrimination Policy template for defining prohibited conduct, reporting channels, investigations, anti-retaliation protections, and training expectations. Use it to document a clear complaint process and meet EEOC and state training requirements.
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Overview
This Anti-Harassment & Anti-Discrimination Policy template sets out what conduct is prohibited, how employees report concerns, how the company investigates, and what happens when a complaint is substantiated. It is built for employers that need a policy holder document employees can read, managers can enforce, and HR can use as the starting point for a documented warning, corrective action, or escalation path when needed.
Use this template when you need a formal policy for harassment, discrimination, and retaliation complaints under Title VII, the ADA, the ADEA, and EEOC guidance, with room for state-specific training and notice requirements. It is especially useful for multi-state employers that need one core policy with carve-outs for California, New York, Illinois, and other jurisdictions. It also helps when you want a consistent reporting procedure for in-person, remote, and third-party complaints.
Do not use this template as a substitute for a case-specific investigation plan or as a standalone legal memo. If your workplace has union issues, public-sector rules, or local notice obligations, add those details before rollout. If you need a policy for leave, accommodation, or wage issues, use the matching template instead of stretching this one beyond harassment and discrimination.
Standards & compliance context
- Align the policy with Title VII, the ADA, the ADEA, and EEOC harassment guidance so protected-class complaints and retaliation claims are handled consistently.
- Include NLRA-aware language so employees do not read the policy as restricting concerted activity, workplace discussions, or protected complaints about terms and conditions of employment.
- Add state-specific training and notice carve-outs where required, including California harassment prevention rules, New York anti-harassment training expectations, and Illinois training requirements where applicable.
- If the investigation process collects employee data, limit access and retention consistent with GDPR or CCPA principles where those laws apply.
- Use the compliance / discipline section to explain corrective action, up to and including termination, and avoid language that suggests discipline is automatic or predetermined.
General regulatory context for orientation only — verify current requirements with counsel or the relevant agency before relying on this template for compliance.
What's inside this template
Purpose
Explains why the policy exists and what employee behavior and management actions it is meant to control.
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This policy establishes the organization's commitment to a workplace free from harassment, discrimination, and retaliation. It is designed to comply with applicable federal, state, and local employment laws, including **Title VII of the Civil Rights Act of 1964**, EEOC guidance on harassment, and state-specific requirements in California, New York, and Illinois. The policy provides clear standards of conduct, reporting channels, investigation procedures, and corrective action expectations. It also supports a respectful workplace and helps ensure that all employees understand their rights and responsibilities.
Scope
Defines who and what the policy applies to, including employees, managers, contractors, applicants, and third parties where relevant.
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This policy applies to all employees, applicants, interns, contractors, temporary workers, volunteers, managers, supervisors, and anyone else conducting business on behalf of the organization. It applies to conduct that occurs: - In the workplace - During work-related travel or events - In virtual meetings, messaging platforms, email, and other electronic communications - Off-site when the conduct affects the workplace or employment relationship **California employees:** Additional training, notice, and complaint-handling requirements may apply under the California Fair Employment and Housing Act (FEHA) and related regulations. **New York employees:** Harassment prevention training and policy distribution requirements may apply under the New York State Human Rights Law. **Illinois employees:** Harassment prevention training requirements may apply under the Illinois Human Rights Act and related state rules.
Definitions
Clarifies key terms so employees and investigators use the same standard for harassment, discrimination, retaliation, and protected classes.
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For purposes of this policy: - **Protected class** means a characteristic protected by law, including race, color, religion, sex, pregnancy, sexual orientation, gender identity or expression, national origin, ancestry, age, disability, genetic information, marital status, military or veteran status, citizenship status, or any other status protected by applicable law. - **Harassment** means unwelcome conduct based on a protected class that is severe or pervasive enough to create a hostile work environment, or that results in an adverse employment action. - **Quid pro quo harassment** means a request for sexual favors or other conduct tied to employment benefits, threats, or decisions. - **Hostile work environment** means unwelcome conduct that unreasonably interferes with work performance or creates an intimidating, hostile, or offensive work environment. - **Discrimination** means unfavorable treatment in hiring, compensation, promotion, discipline, termination, assignments, or other terms and conditions of employment because of a protected class. - **Retaliation** means any adverse action taken because a person reported a concern, participated in an investigation, requested a reasonable accommodation, or opposed conduct they reasonably believed violated this policy. - **Good-faith report** means a report made honestly, even if the concern is not ultimately substantiated. - **Bad-faith report** means a knowingly false report made to harm another person or to evade accountability.
Policy Statement
States the company’s rule against harassment and discrimination and sets the expectation for respectful conduct.
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The organization prohibits harassment, discrimination, and retaliation in any form. All employment decisions must be based on legitimate business reasons and job-related criteria, consistent with applicable law. Prohibited conduct includes, but is not limited to: - Offensive jokes, slurs, epithets, or insults - Unwanted touching, blocking movement, or physical intimidation - Displaying or sharing offensive images, memes, or messages - Repeated unwanted comments about appearance, body, identity, or personal life - Sexual advances, requests for sexual favors, or suggestive conduct - Misgendering, deadnaming, or mocking a person's protected status - Excluding or isolating a person because of a protected characteristic - Retaliating against a person for making a complaint or participating in an investigation This policy applies to conduct by coworkers, supervisors, managers, customers, vendors, clients, and other third parties when the conduct affects the workplace.
Reporting Procedure
Shows employees exactly how to raise concerns and who receives the complaint first.
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Employees are encouraged to report concerns as soon as possible. Reports may be made verbally or in writing through any of the following channels: - Direct manager or supervisor - Human Resources - Compliance Officer or designated ethics hotline - Any manager in the reporting chain A report should include, when possible: - The names of the people involved - A description of the conduct - Dates, times, and locations - Any witnesses or supporting documents If the complaint involves the employee's direct supervisor, the employee may report to HR, another manager, or the Compliance Officer. Employees are not required to confront the person involved before reporting. The organization will make reasonable efforts to keep reports confidential to the extent possible while still conducting a prompt and thorough investigation. **California employees:** The organization will provide information about available state complaint channels and any required notices. **New York employees:** The organization will distribute the required anti-harassment policy and training materials as applicable. **Illinois employees:** The organization will provide required training and complaint information as applicable.
Investigation Procedure
Lays out the steps HR or the investigator follows from intake through findings and resolution.
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The organization will promptly review all complaints and determine the appropriate investigative steps. Investigations will be conducted in a fair, impartial, and documented manner. Investigation steps may include: - Initial intake and risk assessment - Interim protective measures, when necessary - Interviews with the complainant, respondent, and witnesses - Review of documents, messages, recordings, or other evidence - Credibility assessment based on the totality of the facts - Written findings and recommended corrective action Investigations should be completed as quickly as practicable, consistent with the need for a thorough review. The organization may place employees on administrative leave or implement temporary separation measures when appropriate and lawful. The organization will maintain investigation records in accordance with its retention schedule and applicable privacy requirements.
Anti-Retaliation Protections
Explains that good-faith complaints and participation in an investigation cannot be punished.
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Retaliation is strictly prohibited. No employee will be disciplined, demoted, denied opportunities, harassed, or otherwise adversely treated for: - Making a good-faith complaint - Participating in an investigation - Opposing conduct reasonably believed to violate this policy - Requesting a reasonable accommodation - Supporting another employee's complaint Any employee who believes they have experienced retaliation should report it immediately using the reporting channels above. Retaliation may result in disciplinary action up to and including termination.
Training and Prevention
Describes how the company teaches the policy, reinforces expectations, and tracks completion.
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Managers and supervisors are responsible for maintaining a respectful workplace and escalating concerns promptly. They must not ignore, minimize, or retaliate against complaints. The organization will provide harassment prevention training to employees and supervisors as required by applicable law. Training content may include: - Recognizing prohibited conduct - Reporting obligations and escalation paths - Supervisor duties and response expectations - Anti-retaliation protections - Bystander intervention and respectful workplace behaviors **California employees:** Supervisor and employee training must comply with California FEHA training requirements, including timing and frequency where applicable. **New York employees:** Training must comply with New York State Human Rights Law requirements, including annual training where applicable. **Illinois employees:** Training must comply with Illinois Human Rights Act requirements and any applicable annual training standards.
Compliance / Discipline
Connects policy violations to corrective action and makes enforcement consistent across cases.
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Violations of this policy may result in corrective action up to and including termination of employment, removal from assignments, suspension of access, or other appropriate measures. Discipline will be based on the severity of the conduct, prior history, credibility findings, and the need to prevent recurrence. The organization may also require coaching, counseling, training, a documented warning, or a performance improvement plan (PIP) where appropriate. False or bad-faith reports may also result in discipline. However, a report made in good faith will not be treated as false merely because the allegation is not substantiated.
Roles & Responsibilities
Assigns ownership so employees, managers, HR, and legal know their duties in the process.
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**Employees** must treat others respectfully, comply with this policy, and report concerns promptly. **Managers and supervisors** must model compliant behavior, respond immediately to complaints, preserve evidence, and escalate issues to HR or Compliance without delay. **Human Resources** is responsible for intake, investigation coordination, documentation, corrective action support, and policy administration. **Compliance Officer / Legal / Designated Investigator** is responsible for oversight of serious or sensitive matters, trend review, and ensuring consistent application of the policy. **Policy holder** is responsible for maintaining the policy, coordinating training, and ensuring periodic review for legal updates.
Review & Revision
Sets the cadence for updates, version control, and jurisdiction-specific changes.
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This policy will be reviewed at least annually and updated as needed to reflect changes in law, regulatory guidance, or organizational practices. Any material revisions should be communicated to affected employees, and acknowledgement may be required upon update. Jurisdiction-specific addenda may be issued for California, New York, Illinois, or other locations where local law imposes additional requirements.
How to use this template
- 1. Fill in the policy holder name, effective_date, version, applicable_jurisdictions, applicable_roles, and review_frequency before publishing the policy.
- 2. Customize the definitions section to match your workplace, including protected classes, harassment examples, reporting channels, and any jurisdiction-specific carve-outs.
- 3. Assign named roles for HR, legal, managers, and investigators so every complaint has a clear intake path and escalation owner.
- 4. Publish the reporting and investigation procedures with concrete steps for intake, interim measures, interviews, findings, and corrective action.
- 5. Train managers and employees on the policy, then collect acknowledgments and keep investigation records in the same system you use for compliance tracking.
- 6. Review the policy after each substantiated complaint, training cycle, or legal update and revise the version history accordingly.
Best practices
- Define multiple reporting channels so employees can bypass a direct supervisor when the supervisor is involved in the complaint.
- State that complaints will be reviewed promptly and in good faith, then describe who decides interim measures and final corrective action.
- Use examples of conduct in the definitions section, but avoid limiting the policy to a closed list that leaves out new forms of harassment.
- Tell managers to escalate every complaint immediately, even if the employee asks for secrecy or says they just want the behavior to stop.
- Document witness interviews, evidence review, and outcome notices so the investigation can be reconstructed later.
- Separate anti-retaliation language from general conduct rules so employees understand that retaliation is prohibited even when the original complaint is unsubstantiated.
- Add state-specific training cadence and notice language in the training section instead of burying it in a footnote.
- Keep confidentiality language accurate by promising limited disclosure only to the extent necessary for a good-faith investigation.
What this template typically catches
Issues teams running this template most often surface in practice:
Common use cases
Frequently asked questions
What does this anti-harassment and anti-discrimination policy template cover?
It covers prohibited conduct, protected classes, reporting channels, investigation steps, anti-retaliation protections, training, and discipline. The template is designed to document how complaints are received, reviewed, and resolved. It also gives you a place to add state-specific training or notice requirements. Use it as the policy holder document employees can actually follow.
Who should own and administer this policy?
HR usually owns the policy holder version, with legal review and manager support for enforcement. A designated investigator, HR business partner, or employee relations lead should handle complaints under the investigation procedure. Managers need to know how to escalate issues immediately and avoid informal side deals. The policy should name the applicable roles and responsibilities clearly.
How often should this policy be reviewed?
Review it at least annually, and sooner if the company expands into a new jurisdiction, changes reporting channels, or updates training requirements. Annual review helps keep the policy aligned with EEOC guidance and state overlays such as California, New York, and Illinois rules. It also helps you catch outdated definitions or missing escalation steps. Include an effective_date and version so employees know which policy controls.
What laws or standards does this template need to align with?
At a minimum, align it with Title VII, the ADA, the ADEA, and EEOC guidance on harassment and discrimination. Also account for NLRA issues when complaints involve concerted activity, and add state-specific training or notice rules where required. California, New York, and Illinois often have extra requirements that should be called out explicitly. If you handle employee data in the process, add GDPR or CCPA language for records and confidentiality.
What are the most common mistakes companies make with this policy?
The biggest mistake is having a policy that says harassment is prohibited but never explains how to report it or what happens next. Another common gap is failing to include anti-retaliation language that is specific enough for managers to follow. Companies also miss jurisdiction carve-outs, especially for training cadence and notice rules. Finally, vague confidentiality promises can create problems if the investigation requires limited disclosure.
Can this template be customized for different locations or employee groups?
Yes. You can add location-specific reporting contacts, state law carve-outs, and separate language for remote workers, supervisors, and contractors. Many employers also customize the policy for unionized sites, multilingual workforces, or locations with mandatory training rules. Keep the core complaint and investigation process consistent so employees get the same experience everywhere. Then layer in local requirements under the compliance section.
How does this compare with handling complaints informally?
Informal handling often leaves gaps in documentation, timing, and escalation, which makes it harder to show a good-faith response. This template gives you a repeatable process for intake, investigation, findings, and corrective action. It also helps managers avoid promising outcomes they cannot control. Use the policy as the standard path, even if some issues are resolved quickly.
What should be integrated with this policy when rolling it out?
Pair it with your employee handbook, onboarding acknowledgments, training records, complaint intake forms, and investigation logs. If you use an HRIS or case management tool, link the policy to the workflow so reports are tracked consistently. You should also connect it to manager training and annual compliance refreshers. That makes the policy easier to enforce and audit.
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