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Completion rate is not evidence of understanding.

That is the gap we see most often in harassment training
ahead of 30 October.

The training exists.
The dashboard is green.
The question a tribunal is likely to ask is a different one:
could the people involved act on it?

We recently asked five employees at a client business
where they would report harassment.

Five different answers.
One could not say.

Anonymised, details changed.

What is unlikely to count as a reasonable step:

- An induction slide.
- An all-staff email with the policy attached.
- An e-learning module from 2022 with no record of
who did not complete it.
- Anything nobody can recall doing.

What we would expect to carry weight:

- Evidence: dated, with an attendance record.
- Currency: recent, with annual as the working standard.
- Fit: role-specific, because managers and frontline staff
carry different responsibilities.
- Substance: what to do when it happens, not only what not to do.
- Scope: third parties covered explicitly.
- Clarity: your actual reporting routes named.
- Culture: bystander guidance, which tends to separate
a serious programme from a box-ticking one.

The detailed regulations setting out "reasonable steps"
are still to come, so this reflects EHRC guidance and
what we expect a tribunal to look for.

The five-employee test: ask five employees at random
where they would report harassment and what would happen next.

If they cannot tell you, you have delivered training.
You have not achieved it.

Practical HR, without the jargon. MA HR Services Ltd. | St Albans

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