Section 2 — Workplace Harassment ("All Reasonable Steps")
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Statutory anchor: Worker Protection Act 2023; Equality Act 2010 s.40A;
ERA 2025 ("all reasonable steps" + third-party liability, 1 Oct 2026).

EHRC eight-step framework status:
  1. Anti-harassment policy            ✓ current, signed by CEO 12 Jan 2026
  2. Engaged staff                     ✓ Workplace Risk Survey 14 Feb 2026 (78% RR)
  3. Risk assessment                   ⚠ Manchester site last reviewed 6 months ago
  4. Reporting channels                ✓ Multiple routes (manager, HR, anonymous form)
  5. Trained staff                     ✓ 82/92 staff completed core module
                                       ✓ 14/14 managers completed manager overlay
  6. Action when harassment happens    ✓ Investigation playbook current
  7. Third-party briefings             ⚠ 3 of 8 client briefings overdue
  8. Monitor and evaluate              ✓ Annual review due Q3 2026

Sector overlays applied:
  · Legal practice (12 min, 0.25 CPD hours) — assigned to all client-facing staff
  · Manager overlay (15 min) — assigned to 14 line managers

Risk assessment summary:
  · Sites:        London (Head Office, 62 staff), Manchester (Branch, 30 staff)
  · Third parties: 8 recurring clients, 4 contractors, 1 visitor cohort
  · Hotspots:     Late-night office (>20:00) — additional controls in place

Training records: see attached harassment-training-records.csv
Audit log:        see attached harassment-audit-log.csv (24 entries this quarter)
