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compliance

New York §201-g Sexual Harassment Training Addendum

New York §201-g sexual harassment training addendum for annual, interactive training of all employees. Use it to document required content, delivery, recordkeeping, and enforcement for New York workplaces.

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Overview

This New York §201-g Sexual Harassment Training Addendum is the training-specific companion to an anti-harassment policy. It sets out who must be trained, what the training must cover, how often it must occur, how completion is documented, and who is responsible for follow-through. Use it when you need a New York-focused addendum that can be attached to a handbook, onboarding packet, or LMS assignment record.

The template is a good fit for employers with New York employees who need a clear annual training process for all staff, including remote and hybrid workers. It is especially useful when you want to standardize live sessions, virtual sessions, or vendor-led modules while keeping a paper trail for audits and complaints. It also helps managers understand their role in escalation, anti-retaliation, and attendance enforcement.

Do not use this addendum as a substitute for a full anti-harassment policy, complaint procedure, or investigation protocol. It is also not the right place for broad culture statements without operational steps. If your organization has no New York employees, or if you need a global harassment policy, this template should be localized rather than used as-is. It should be paired with your broader EEO, anti-retaliation, and reporting policies so employees know both the standard and the process.

Standards & compliance context

  • This addendum should align with Title VII and EEOC harassment principles, including anti-retaliation and prompt reporting expectations.
  • New York employers should keep the training annual and document completion, because the addendum is meant to operationalize state training obligations rather than restate general policy language.
  • If the training covers complaint handling or retaliation, it should be consistent with NLRA protections for concerted activity and avoid discouraging protected workplace complaints.
  • Where employees are also covered by other state overlays, such as California, Washington, or Illinois rules, the addendum should be localized rather than treated as a one-size-fits-all document.
  • Recordkeeping should be handled in a way that respects privacy and data minimization principles, especially if training records are stored in HR systems subject to GDPR or CCPA-style controls.

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 supports the broader anti-harassment policy.

  • 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

Defines which employees, locations, and work arrangements are covered by the training requirement.

  • 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

Clarifies the terms used in the addendum so training obligations and reporting steps are interpreted consistently.

  • 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

States the employer’s commitment to annual sexual harassment training and non-retaliation.

  • 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

Lists the topics that must be covered so the training is complete and not just a generic awareness session.

  • 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

Sets the cadence, format, and completion expectations for annual and new-hire training.

  • 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

Assigns ownership for scheduling, delivering, tracking, and escalating training issues.

  • 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

Explains how completion is documented and what happens when employees or managers miss the requirement.

  • 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

Ensures the addendum stays current when laws, reporting channels, or internal processes change.

  • 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.

How to use this template

  1. 1. Insert the effective_date, version, review_frequency, applicable_jurisdictions, and applicable_roles fields so the addendum is tied to the correct New York employee population.
  2. 2. Link the addendum to your existing anti-harassment policy and complaint procedure so the training content matches the reporting and investigation process employees will actually use.
  3. 3. Assign the annual training to all employees, including supervisors, remote staff, and new hires, and specify whether completion is through live instruction, virtual delivery, or an LMS module.
  4. 4. Document attendance, acknowledgments, questions raised, and completion dates, then retain the records in the HR or compliance file for audit and dispute support.
  5. 5. Review the addendum after each training cycle, update it for legal or process changes, and issue a new version when reporting channels, vendors, or required content changes.

Best practices

  • Use interactive training that allows employees to ask questions and receive answers in real time or through a documented follow-up channel.
  • State clearly that the addendum applies to all employees in New York, including supervisors, temporary staff, and remote workers where applicable.
  • Tie the training content to your actual complaint intake path so employees hear the same reporting steps they will use later.
  • Keep a version-controlled attendance log that shows the training date, trainer, topic outline, and completion status for each employee.
  • Train managers separately on escalation, anti-retaliation, and how to avoid informal handling of complaints that should be reported.
  • Update the addendum whenever your policy holder changes reporting contacts, vendor platforms, or investigation procedures.
  • Use plain language for examples and prohibited conduct so employees can recognize conduct problems without legal jargon.

What this template typically catches

Issues teams running this template most often surface in practice:

No proof that the training was completed by all covered employees.
A one-time training event is used instead of an annual cadence.
The training content does not match the employer’s actual complaint process or reporting contacts.
Managers are not trained on escalation, anti-retaliation, or their duty to route complaints promptly.
Attendance records do not identify the trainer, date, or version of the materials used.
Remote employees are left out because the employer relies only on onsite sessions.
The addendum is attached to the handbook but never updated after policy changes or legal revisions.

Common use cases

Retail district manager rollout
A retail chain uses this addendum to assign annual harassment training to store associates, assistant managers, and district leaders across New York locations. The template helps the company document attendance, track completion, and keep supervisors aligned on escalation duties.
Healthcare onboarding for new hires
A healthcare employer adds this training addendum to onboarding for nurses, aides, and administrative staff in New York facilities. It gives HR a repeatable way to deliver the required content and retain proof of completion in personnel files.
Professional services virtual training
A consulting firm with hybrid staff uses the template to run live virtual harassment training and capture questions, acknowledgments, and completion records. The addendum helps ensure remote employees receive the same content and reporting instructions as onsite staff.
Multi-state compliance overlay
A multi-state employer uses this as the New York-specific addendum attached to a broader handbook. It keeps the New York training requirement separate from other state rules while preserving a consistent company policy structure.

Frequently asked questions

Who does this addendum apply to?

This addendum is written for New York workplaces that need annual sexual harassment training for all employees, regardless of employer size. It is designed to sit alongside an existing handbook or anti-harassment policy and fill the training-specific requirements. If you have employees working in New York, this template helps you document the training obligation, delivery method, and records. You should still tailor it to your organization’s reporting channels and policy holder structure.

How often should the training be completed?

Use this addendum for annual training, with a cadence that is easy to track and repeat each year. Many employers set a fixed training window tied to hire date, calendar year, or a company-wide rollout date. The key is consistency and proof of completion, not an informal reminder. If you use a learning platform, the addendum should match the system’s assignment and retraining schedule.

Who should run the training and track completion?

HR, compliance, or a designated policy holder should own the process, with managers helping ensure attendance and completion. The trainer can be an internal facilitator or an outside vendor, but the organization should keep records showing who attended, when the training occurred, and what content was covered. If managers are involved, they should know how to escalate complaints and avoid handling them informally. This template includes roles and responsibilities so ownership is clear.

What makes this different from a general anti-harassment policy?

A general policy explains expectations and reporting channels, while this addendum focuses on the required training content, timing, and documentation. It is meant to make the training obligation operational, not just aspirational. The addendum should reference the policy’s complaint process, investigation path, and anti-retaliation rules. If your handbook already covers conduct standards, this template adds the New York-specific training layer.

Does this template address federal law too?

Yes, it is designed to align with Title VII and EEOC anti-harassment principles, while also supporting New York’s training requirements. It should be used together with your broader equal employment opportunity and anti-retaliation policies. If your workforce includes supervisors, the training should also reinforce reporting obligations and prompt escalation. For multi-state employers, you may need state-specific addenda for other jurisdictions as well.

What are the most common mistakes employers make with this addendum?

The most common mistakes are treating the training as a one-time event, failing to document attendance, and using content that is too generic to meet New York expectations. Another frequent gap is not explaining how employees can report concerns without retaliation. Employers also miss the need to update the addendum when complaint channels, vendor platforms, or legal requirements change. This template helps prevent those gaps by separating content, delivery, and recordkeeping.

Can this be customized for remote or hybrid employees?

Yes, and it should be. Remote employees still need a training method that is interactive and trackable, such as live virtual training or a platform that records completion and questions. The addendum should spell out how employees ask questions, receive acknowledgments, and confirm completion when they are not onsite. If you have field staff, you can also add mobile-friendly delivery and manager follow-up steps.

What records should be kept after training?

Keep attendance records, completion confirmations, training dates, trainer names, and the version of the addendum or training materials used. If employees ask questions during the session, it is also helpful to retain the agenda or slide deck that shows the topics covered. These records support compliance reviews and help defend against claims that training was missing or inconsistent. The template’s recordkeeping section is built to support that audit trail.

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