Illinois Sexual Harassment Training Addendum (PA 101-0221)
This Illinois sexual harassment training addendum sets the annual training requirement, required content, delivery timing, and recordkeeping rules for Illinois employees. Use it to attach a clear, state-specific training obligation to your existing harassment policy.
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Overview
This Illinois Sexual Harassment Training Addendum (PA 101-0221) is a policy attachment that tells employees and managers what training is required, when it must happen, and how the employer will document completion. It is designed to sit alongside your main anti-harassment policy, not replace it, and it is especially useful for employers with Illinois-based staff, remote workers assigned to Illinois, or multi-state teams that need a state-specific compliance layer.
Use this template when you need a clear annual training rule, a defined content outline, and a recordkeeping process that can stand up to internal review. It is also useful when you want to standardize onboarding for new hires and make sure supervisors understand their reporting and escalation duties. The template is not meant to be a generic diversity statement or a broad conduct policy; it is focused on the Illinois training obligation and the operational steps needed to meet it.
Do not use this addendum as your only harassment document. It should not be the place where you first define prohibited conduct, complaint intake, investigation steps, or discipline. It also should be reviewed carefully if you operate in multiple jurisdictions, because state and local rules can differ on training cadence, supervisor content, notice language, and record retention. If your workforce includes union employees, remote employees, or multilingual teams, customize the delivery and acknowledgment process so the policy matches how training is actually assigned and completed.
Standards & compliance context
- This addendum supports compliance with Illinois Public Act 101-0221 and the Workplace Transparency Act by making annual sexual harassment training explicit for Illinois employees.
- The training content should align with Title VII and EEOC harassment principles, including protected-class harassment, reporting, investigation, and anti-retaliation expectations.
- If your training touches leave, accommodations, or disability-related conduct, keep the content consistent with ADA interactive process obligations and FMLA leave administration.
- Supervisory content should reinforce NLRA-safe reporting and avoid language that could chill protected concerted activity while still requiring prompt escalation of complaints.
- For employees in other jurisdictions, check state and local overlays before reusing this addendum, because training cadence, supervisor requirements, and notice rules can vary.
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 addendum exists and how it connects Illinois training obligations to the broader harassment policy.
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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
Defines which employees, locations, and worker categories are covered so the requirement is applied consistently.
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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
Clarifies key terms used in the addendum so employees and managers interpret the training requirement the same way.
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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
States the employer’s commitment to annual Illinois sexual harassment training and sets the baseline obligation.
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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
Lists the topics the training must cover so the course is not generic or incomplete.
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The training must, at a minimum, include the following topics:
- An explanation of sexual harassment consistent with Illinois law.
- Examples of conduct that constitute unlawful sexual harassment.
- A summary of relevant federal and state statutory provisions concerning sexual harassment, including employee remedies.
- A summary of the employer’s internal complaint process, including how to report concerns.
- Information on how complaints are investigated and resolved.
- A statement that retaliation for reporting harassment or participating in an investigation is prohibited.
- 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
Sets the cadence, format, and completion deadlines that make the requirement operational.
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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
Assigns ownership for scheduling, delivery, tracking, and escalation so the policy can actually be administered.
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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
Explains how completion will be documented and what happens when someone misses or refuses training.
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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
Creates a review cycle so the addendum stays aligned with law changes, vendor updates, and internal process changes.
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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.
How to use this template
- Add this addendum to your existing harassment policy or handbook and replace bracketed fields with your company name, effective date, applicable jurisdictions, version, review frequency, and policy holder.
- Assign HR, compliance, or another designated owner to schedule annual Illinois training, track new-hire completion, and coordinate any manager-only module.
- Load the required content into your LMS, vendor course, or live session so the training covers prohibited conduct, reporting channels, retaliation, and the complaint process used by your organization.
- Notify Illinois employees of the training deadline, provide access instructions, and document completion with attendance logs, certificates, or LMS exports.
- Review overdue completions, issue documented warnings or other discipline for noncompliance where appropriate, and update the addendum whenever Illinois law, your reporting process, or your training vendor changes.
Best practices
- Tie the addendum to a single policy holder so one person owns scheduling, reminders, and recordkeeping.
- Use the same reporting contacts and complaint steps in the training that appear in your handbook so employees are not given conflicting instructions.
- Train supervisors separately on duty to report, no-retaliation rules, and how to escalate complaints without investigating on their own.
- Document completion immediately after each session and keep the training version with the attendance record.
- Provide the training in a format employees can actually access, including captions, translations, or alternate formats where needed.
- Separate Illinois requirements from other state modules so multi-state employees receive the correct jurisdiction-specific content.
- Escalate missed training the same way you would other policy violations, using a documented warning and follow-up deadline.
What this template typically catches
Issues teams running this template most often surface in practice:
Common use cases
Frequently asked questions
Who does this addendum apply to?
It is written for Illinois employees and should be attached to your broader harassment policy or handbook. Use it for any employee who works in Illinois, including remote employees assigned to Illinois, unless your legal review says a narrower or broader application is needed. If you have multi-state staff, keep the Illinois-specific requirements separate from your general anti-harassment policy so the obligations are easy to administer.
How often does the training need to be completed?
This addendum is built around annual training, which is the standard cadence for Illinois compliance programs under the Workplace Transparency Act framework. New hires should be trained on your onboarding schedule and then folded into the annual cycle. If you use role-based modules, make sure the Illinois module still meets the yearly requirement for every covered employee.
Who should run the training and track completion?
HR, compliance, or a designated policy holder should own the program, with managers helping ensure attendance and follow-up. The training can be delivered by an internal facilitator or an outside vendor, but the employer remains responsible for content, timing, and records. Assign one person or team to monitor completions, send reminders, and escalate overdue training.
What content has to be included in the training?
The addendum should require training on prohibited conduct, reporting channels, bystander response, and the employer’s complaint process. It should also cover examples of sexual harassment, how investigations work, and the consequences of policy violations. If you use a vendor course, confirm it aligns with Illinois requirements rather than relying on a generic harassment module.
Does this replace our general anti-harassment policy?
No. This is an addendum that supports your broader policy by adding Illinois-specific training rules, not a full standalone harassment policy. Keep your main policy for definitions, complaint procedures, and discipline, then use this addendum to make the annual training obligation explicit. That separation helps avoid confusion when other states have different requirements.
What are common mistakes employers make with Illinois harassment training?
A common mistake is treating the training as optional for remote or non-supervisory staff in Illinois. Another is using a generic national course that does not match the employer’s reporting process or Illinois-specific expectations. Employers also get flagged when they cannot prove completion dates, attendee lists, or the version of the training used.
How should this be customized for different workplaces?
Customize the reporting contacts, investigation timeline references, and any union or site-specific escalation steps. If you have supervisors, add a manager track that explains duty to report, no-retaliation obligations, and how to respond to complaints. If your workforce includes multiple languages, consider translated materials or subtitles so the training is actually understood.
What records should we keep to show compliance?
Keep attendance logs, completion certificates, training dates, the version of the module used, and any acknowledgments signed by employees. Retain records in a way that lets you prove who was trained and when, especially for new hires and annual refreshers. If training is delivered through an LMS, make sure exports are available for audits or investigations.
How is this different from handling complaints ad hoc?
Ad hoc reminders do not create a reliable compliance record or ensure every Illinois employee receives the same baseline information. This addendum turns training into a repeatable policy obligation with defined timing, ownership, and documentation. That consistency matters if a complaint later raises questions about notice, prevention, or employer response.
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