1. A clear policy is needed - harassment does not need to be specifically prohibited by law (such as sexual harassment) in order for an employer to be able to forbid such conduct - "sexual harassment" includes any unwelcome conduct of a sexual nature that tends to creates adverse or hostile working conditions for an employee.

  2. Provide for education and training of all employees regarding the policy.

  3. It is especially important for all management and supervisory personnel to be fully committed to the anti-harassment policy and procedures.

  4. Essential in light of 1998 Supreme Court rulings on sexual harassment: to the greatest extent possible, limit supervisors' authority to adversely affect the terms and conditions of employment for their subordinates, i.e., firing, suspension, demotion, pay cuts, adverse changes in shifts, work locations, or duties, or similar tangible job actions - make it clear to all employees that the most their supervisors can do is recommend changes, but that any changes must be approved and carried out by specifically-designated individuals.

  5. Prompt investigation and remedial action are needed - results on a "need to know" basis - documentation should be maintained in a separate grievance and investigation file.

  6. Uniform application of policy is important.

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