If you want to discourage sexual harassment in your company, consider following these routinely prescribed steps:

* Adopt a sexual-harassment policy. Make a personal statement to your employees before distributing the policy. Build it around your company's values and the Equal Employment Opportunity Commission's definition of harassment. (See No. 05921461, May 1992.) Promise that grievances will be quickly and thoroughly investigated. Explain the disciplinary measures to be taken against those who harass and those who bring false charges.

* Provide employees with meaningful recourse. Find two neutral yet powerful people to whom employees can bring grievances. The person in charge of the company is one natural choice. For the other, pick someone from inside the company or a close outside adviser. Or give employees the option of complaining to the EEOC.

* Investigate promptly. Take all complaints seriously. That kind of action speaks louder than words to your employees, and it's also the best line of legal defense.

* Take appropriate action. Keep your policy's promise of disciplinary action, if appropriate. Above all, don't let the complaining employee feel he or she was treated perfunctorily.

Education is crucial in understanding the disparity between the ways men and women view certain kinds of behavior. (See this month's FaxPoll, "What Are You Doing About Sexual Harassment?" No. 05920231, May 1992.) Consider joining with other small companies to hire a training consultant. Or educate with videos, by reading (see No. 05921464, May 1992), and through discussion. Above all, remember that your visible commitment must underpin your program if it's to be taken seriously. -- Ellyn E. Spragins

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"Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature constitute sexual harassment when (1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment, (2) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or (3) such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile, or offensive working environment." -- EEOC's definition of sexual harassment

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