1 Core obligations

All organisations should have a policy relating to sexual harassment to demonstrate that the organisation has a system in place to address sexual harassment. This can be contained in a Code of Conduct and/or a stand-alone policy. 

This template is provided for you to customise for your organisation.

Code of conduct

1 Core obligations

All organisations should have a policy relating to sexual harassment to demonstrate that the organisation has a system in place to address sexual harassment. This can be contained in a Code of Conduct and/or a stand-alone policy. 

2 What to focus on 

A Code of Conduct sets out the rules, values, ethical principles and vision that provides workers and those dealing with the organisation with a clear understanding of the standards and expectations expected of those working within and dealing with the organisation (client, customers, other third parties).

An organisation’s Code of Conduct should: 

  • State the organisation’s commitment to providing workers with a safe working environment
  • Contain a strong statement that the organisation does not tolerate sexual harassment 
  • Define sexual harassment, with behavioural examples 
  • State that sexual harassment is against the law 
  • Set clear expectations about safe, respectful and inclusive behaviour and language, (including from third parties such as clients or customers) 
  • Set out workers’ obligations in relation to attending sexual harassment training 
  • Encourage workers to report sexual harassment
  • Indicate the organisation’s commitment to raising awareness of sexual harassment, including who may be impacted by sexual harassment and the effects of sexual harassment 
  • Outline how the organisation will support complainants and those who support them (including those who may witness and report harassment) 
  • Set out the process for raising a concern or complaint (informally, formally and externally) 
  • Contain a clear statement that the safety and wellbeing of the person disclosing sexual harassment is the employer’s priority 
  • State what will happen to perpetrators and if the Code of Conduct is not complied with (for example, that disciplinary action may be taken by the organisation or where a criminal offence is alleged, that the matter [may / will] be reported to the police) 

Codes of Conduct are frequently supported by stand-alone policies. A Code of Conduct could address the points above at a high level, supplemented by a harassment policy.

3 Example wording

Example policies and templates are available from: 

 
This document is intended to provide general guidance only. The contents should not be relied upon as legal advice.  Specific legal advice should be sought in particular matters.

We need to set the tone and lead from the top. With this in mind, here is an example of some things we should never say or accept from others:

  • A bullying and harassment policy should be enough to deal with sexual harassment.
  • We have low report rates of sexual harassment, so it’s not a problem at this organisation.
  • We have a reporting hotline which is well publicised, but we don’t get many calls about sexual harassment, so it’s not an issue here.
  • I have been in this industry for decades and I have never seen it, so it mustn’t be happening.
  • That’s the remit of our HR team. If there was ever a big issue, they would escalate it to us.
  • Our staff engagement scores are terrific and there is no indication of there being a sexual harassment problem here. That means we’re doing enough.


Most cultural issues aren’t hiding in plain sight. Often it’s the things that aren’t being talked about that we need to be concerned about. Research tells us that sexual harassment is common and that it’s significantly under reported. We need to be proactive to prevent sexual harassment, and not wait for a complaint before we act.

We need to ensure our people feel safe to come forward and report instances of sexual harassment or discrimination in the workplace. The only way they’ll do this is if they can see that leadership takes this issue seriously.

Can I suggest we create a board paper for the next meeting to outline how we plan to do this?

We take the health and wellbeing of our people very seriously. We work hard to improve our safety outcomes and reduce injuries, and overall we do a good job preventing physical harm to our people.

As we have seen in many other organisations, sexual harassment is more prevalent than a lot of people think. This represents a real risk to keeping people safe in the workplace, and to our people’s wellbeing and productivity.

It can also cause significant damage to our reputation, our brand as an employer of choice, lost business, and to our corporate standing.

We need to make it crystal clear to everyone in the organisation that we have zero tolerance for sexual harassment. Our objective is to prevent it. We need to ensure all our systems, processes and practices enforce this commitment.

We need to treat sexual harassment risks as we would any other physical or psychological risk in the workplace. We already have existing systems and processes in place for identifying and mitigating workplace health and safety risks and hazards, and for defining our desired culture.

We need to embed these into our sexual harassment response frameworks, reporting practices and organisational culture so sexual harassment is eradicated.

We can’t afford to wait on this; we need to act urgently.

Sexual harassment is any unwelcome sexual advance, request for sexual favours or other conduct of a sexual nature. It’s not only a human rights issue, which is unlawful under the Sex Discrimination Act, but also a workplace health and safety (WHS) risk which can cause significant psychological, physical, reputational and financial harm.

Existing systems and processes for managing WHS risks and hazards should be used to eliminate the risks and control the likelihood of sexual harassment occurring in the workplace.

Board members and senior executives have a duty to address this. Everyone deserves to work in a safe, respectful and inclusive environment. Respect is everyone’s business.

Sexual harassment is any unwelcome sexual advance, request for sexual favours or other conduct of a sexual nature. It’s not only a human rights issue, which is unlawful under the Sex Discrimination Act, but also a workplace health and safety (WHS) risk which can cause significant psychological, physical, reputational and financial harm.

Existing systems and processes for managing WHS risks and hazards should be used to eliminate the risks and control the likelihood of sexual harassment occurring in the workplace.

Board members and senior executives have a duty to address this. Everyone deserves to work in a safe, respectful and inclusive environment. Respect is everyone’s business.