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OneSource HR

Sexual Harassment Consultancy

The legal bar for preventing sexual harassment is rising sharply.

Since October 2024, employers have had a legal duty to take reasonable steps to prevent sexual harassment. From October 2026 that duty becomes materially harder to meet. OneSource HR helps organisations move from policy to practice, and from minimum compliance to a genuine, defensible standard of prevention.

What is changing, and what it means for you

The law is moving quickly, and the direction is only one way.

1

The duty is becoming "all reasonable steps."

The current duty requires employers to take reasonable steps to prevent sexual harassment. From October 2026, that standard rises to all reasonable steps. If a step could reasonably have been taken and was not, the standard will not be met. Organisations that comfortably satisfy today's duty will not automatically satisfy the upgraded one.

2

Employers are becoming liable for third-party harassment.

Also from October 2026, employers will be directly liable where an employee is harassed by a customer, client, patient, contractor, or supplier, and the employer has not taken all reasonable steps to prevent it. For any organisation with public-facing or lone-working staff, this significantly widens the risk.

3

Reporting sexual harassment is now a protected disclosure.

Since April 2026, a disclosure relating to sexual harassment automatically qualifies as a protected disclosure under whistleblowing law. Sexual harassment policy and whistleblowing policy can no longer sit in separate silos. They need to be aligned.

Taken together, these changes mean the same thing. Reacting is no longer enough. Organisations need to anticipate risk, plan for it, document what they have done, and be able to demonstrate it.

Not sure where your organisation stands?

Take our free, five-minute All Reasonable Steps Checker and get a readiness band and a traffic-light picture across ten areas of prevention.

How we help

Our consultancy covers

Most organisations come to us for a specific piece of work. A risk assessment. A policy review. A framework for a particular site. We are always happy to help with a single, well-defined engagement, but the organisations that get the most value are the ones that let us look at the whole picture.

Sexual harassment risk assessments, tailored to your sector, workforce, and working patterns, including front-line, lone-worker, and third-party exposure

Policy design and review, ensuring your sexual harassment, anti-harassment, and whistleblowing policies are aligned and fit for the 2026 standard

Reporting routes and complaints procedures that people actually trust and use

Worker Protection Act and Employment Rights Act compliance, with the documentary trail the all reasonable steps standard demands

Evaluation and measurement, including anonymous staff pulse surveys that test the culture of your organisation and give you real data on whether your prevention work is landing

Full CEASE Framework® implementation, for organisations that want the gold standard

The CEASE Framework®

The gold standard for demonstrating all reasonable steps.

For organisations that want to do this properly, the CEASE Framework® is the most robust approach available.

CEASE treats sexual harassment prevention the way the best organisations already treat quality, health, and safety. It follows the same plan, do, check, act cycle that underpins ISO management standards, which means it produces exactly the kind of structured, continuous, documented evidence that the all reasonable steps standard requires.

This framing does something else important. By approaching sexual harassment as a quality, health, safety, and environment issue rather than a purely emotional or political one, CEASE removes the polarisation that so often derails this work.

Organisations that engage us to assess and build out their full framework can work towards becoming CEASE certified, a clear, credible, and renewable way to demonstrate the standard of their prevention work to their people, their board, their clients, and, if it ever comes to it, a tribunal.

The CEASE Framework emblem, five interlocking rings representing the five stages: Call it out culture, Educate, Assess your risk, Strengthen systems, and Evaluate and evolve.

Questions

Frequently asked questions

What are "all reasonable steps"?
It is the legal standard employers must meet to prevent sexual harassment from October 2026, replacing the current “reasonable steps” duty. The word “all” raises the bar considerably. In practice it means an employer must be able to show they have taken every step that could reasonably have been expected of them, taking into account their size, resources, and sector. If a reasonable step was available and not taken, the standard is unlikely to be met. The government is expected to set out specific expected steps in regulations, likely to include risk assessments, clear policies, and robust reporting procedures.
Does my organisation need a sexual harassment risk assessment?
Almost certainly. The EHRC has been clear that an employer is unlikely to be able to comply with the preventative duty unless they carry out a risk assessment. It should be treated as a live document, reviewed regularly, and should consider factors such as power imbalances, lone and night working, public-facing roles, travel, and events involving alcohol.
What counts as third-party harassment?
Harassment of your employee by someone who is not you or another of your employees. That includes customers, clients, patients, service users, contractors, and suppliers. From October 2026, employers can be directly liable for failing to take all reasonable steps to prevent it, across all protected characteristics.
We already did training last year. Is that enough?
Almost certainly not. A one-off or annual e-learning module is widely regarded as insufficient to meet the all reasonable steps standard. Training needs to be tailored to the real risks in your environment, delivered in a way that changes behaviour, refreshed regularly, and documented. It is one part of a wider system, not a standalone solution.
How does the CEASE Framework® help with compliance?
CEASE Framework® gives you a structured, continuous, documented approach to prevention that maps directly onto what the all reasonable steps standard requires. Because it produces evidence at every stage, risk assessments, tailored training records, policy reviews, reporting data, and regular evaluation, it creates exactly the documentary trail an organisation needs to demonstrate it has met its duty.
Do you only work with certain sectors?
No. We are sector-agnostic and we tailor every engagement. The CEASE Framework® translates particularly well into environments already driven by quality and health and safety thinking, but the principles apply anywhere.

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Get ahead of the 2026 changes

The organisations that act now will meet the new duty with confidence. Talk to our team about where your organisation stands and what the right next step looks like.