Manager harassment training gap raises legal risk

Manager harassment training gap raises legal risk

Manager training gaps are increasing employers’ harassment compliance exposure now. VinciWorks found that 21% provide no specific manager preparation before stronger preventative duties take effect in October.


One in five UK managers receives no specific training on responding to workplace sexual harassment, despite managers often being the first people approached by employees, new research has found.

The survey by compliance training provider VinciWorks questioned 985 UK-based HR and compliance professionals during July 2026.

Only 30% of respondents said managers received dedicated training on handling sexual harassment. Another 32% included manager guidance within general employee sessions, while 21% provided managers with no specific preparation.

The findings precede a planned strengthening of employers’ legal duties. From October 2026, organisations will be required to take “all reasonable steps” to prevent sexual harassment, replacing the existing requirement to take “reasonable steps”.

What constitutes sufficient action will depend on an employer’s size, sector, workforce, risks, and operating environment. Government guidance identifies risk assessment, clear policies, staff engagement, reporting channels, training, monitoring, and protection from third-party harassment among the relevant measures.

Nick Henderson-Mayo, head of compliance at VinciWorks, said: “The first hour after someone discloses harassment to a manager is where trust is built or lost. If that manager is not equipped for the moment, then neither is the business standing behind them. A lack of proper, role-specific training is one of the clearest risks.”

Weaknesses also appear before a complaint reaches a manager. More than a third of employers, 34%, said they had never conducted a sexual harassment risk assessment, while 17% had not completed one during the past year.

Another 14% provided no sexual harassment training at all. Only 7% rated their provision as excellent, and 47% believed that it required improvement.

An employee cannot bring a standalone tribunal claim solely for breach of the preventative duty, but compensation can be increased by up to 25% where a sexual harassment claim succeeds and the employer has failed to comply. The Equality and Human Rights Commission also has enforcement powers.

Changing the duty from “reasonable” to “all reasonable” steps will place greater emphasis on the measures that were considered but not adopted. A policy and annual online module may not be sufficient where known risks require more targeted action.

Exposure varies significantly between workplaces. Hospitality and retail employees may encounter harassment from customers, while site-based and mobile workers can have limited access to reporting channels. In founder-led, commission-based, or heavily hierarchical organisations, power imbalances may discourage complaints or make employees doubt whether a senior person will be challenged.

Remote work has created additional routes for misconduct through messaging platforms, video calls, informal digital channels, and online social activity connected to work. A risk assessment based only on physical premises will overlook a substantial part of the working environment.

An effective review should examine how work is actually carried out, including lone working, travel, alcohol, social events, customer interaction, accommodation, recruitment, probation, reporting lines, and the concentration of authority in particular roles.

Manager preparation has to address the first response. A person receiving a disclosure needs to know how to listen without prejudging the outcome, protect confidentiality within appropriate limits, prevent retaliation, record essential information, escalate correctly, and explain what will happen next.

Poor handling can create further harm. Dismissing a concern, promising absolute secrecy, carrying out an unauthorised informal investigation, or relocating the complainant rather than addressing the alleged conduct may weaken trust and increase legal exposure.

Receiving a report is also distinct from determining an outcome. Managers will not always be suitable investigators, particularly where they know the parties, report to one of them, or have another conflict of interest. Clear escalation routes and access to trained investigators are therefore necessary.

Boards and senior teams will need evidence that prevention measures are operating in practice. Attendance records demonstrate that training took place, but not whether managers can apply it under pressure.

Useful indicators may include reporting confidence, investigation times, repeat allegations, case outcomes, employee surveys, exit feedback, and whether higher-risk teams receive additional support. Patterns in grievance, absence, turnover, and settlement data may also reveal problems that have not reached a formal harassment process.

Third-party harassment creates another operational demand. Employers may need arrangements covering customers, contractors, suppliers, patients, guests, and other people encountered during work. Contract terms, site rules, escalation procedures, and the ability to withdraw service can all form part of prevention.

Smaller organisations may lack dedicated employee relations or compliance teams, but size does not remove the duty. Proportionate measures can include named reporting contacts, external investigation support, documented risk reviews, and practical manager guidance designed around the workplace.

The October change leaves a limited period in which to test policies, reporting channels, training, risk assessments, and investigation procedures as one connected system. A weakness in any part can undermine the organisation’s ability to show that preventative action was credible.

Formal procedures often begin with an informal human interaction. How a manager handles that first conversation can determine whether an employee trusts the process and whether the employer’s written commitments have any force beyond the intranet.



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