How employee feedback can support harassment prevention
What does taking “all reasonable steps” to prevent harassment look like in practice? Part of the answer is understanding whether people feel able to raise concerns, and recording what you did in response.

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The quarterly EHS results are in! Most comments are about workload. One, though, is different: a junior associate writes that one of the firm’s biggest clients “always gets a bit much” after a few drinks, and that they weren’t sure if it was worth mentioning.
This is an illustrative situation, but a familiar one. Nothing has been formally reported, but something has been said. The practical question is how feedback like this can help prevent harm, not only record it.
The client is a third party and from 30th October 2026, that matters. A business can be liable if a client harasses one of its people and it has not taken all reasonable steps to prevent it. The same applies to harassment related to any protected characteristic, not only sexual harassment. This article is general guidance, not legal advice.
Use feedback to understand where risk sits
The EHRC’s technical guidance says an employer “is unlikely to be able to comply with the preventative duty unless they carry out a risk assessment”. Feedback can make that assessment more accurate. It shows where people feel uncomfortable or unsure, not only where incidents have been reported.
Risks are rarely spread evenly. Ask about the settings where it tends to gather:
- Third partiesClient meetings, site visits and secondments, and behaviour people may feel they have to tolerate from a valued client.
- Late working and busy periodsEvenings before a deadline or during busy season, with fewer colleagues around.
- DependenceTrainees, juniors and anyone whose progress or qualifications rests with one partner or supervisor.
- Capacity and disruptionClient entertainment, networking events and conferences, where the usual boundaries can blur.
EHS department views show how the score and feedback differ across teams. A different experience in one place can be otherwise lost in an organisation-wide average. Treat a difference as a prompt to look closer, not a diagnosis.
Listen for early signs, not only formal reports
Formal reports matter, but they are rare and often arrive late. In the Government Equalities Office’s 2020 Sexual Harassment Survey, 29% of people in employment had experienced workplace sexual harassment in the previous 12 months. Only 15% of those reported it formally.
Regular feedback can surface what sits below that threshold: comments about disrespect, “banter” that has started to grate, or a sense that some behaviour is tolerated. Those are starting questions, not findings. They show where to look and who to talk to, before something becomes a formal complaint.
This does not need a survey about harassment. The EHS headline question asks how people feel about working at the organisation, with room to explain why. Asked every quarter, it gives people a regular, low-key moment to mention what is bothering them, as the associate in the opening did.
Ask whether people feel able to speak up
Prevention relies on people raising concerns early. Acas suggests employers regularly check whether their “policies and procedures for preventing sexual harassment and handling complaints are working”. Asking your people is one of the most direct ways to find out.
Three questions are worth asking regularly:
- Would you know where to go? That includes behaviour from clients, not just colleagues.
- Would you expect it to be taken seriously? People need to believe a concern will be handled fairly.
- Would you feel comfortable raising it? People may worry about the effect on themselves, their team, or a valued client relationship.
EHS Check-ins include questions on raising concerns, so a short Check-in is one way to ask them. Lower confidence is not proof of a problem there. It is a reason to ask a better question.
Use what you hear to shape the steps you take
Feedback is most useful when it changes what you do. EHS groups recurring topics from written feedback, so a theme raised in several comments is easier to see.
Themes can then inform:
- TrainingThe situations people actually describe, such as stepping in when a client crosses a line.
- Guidance for managersWhat to do when a concern is raised informally
- Expectations for third partiesHow clients are told what behaviour is expected, for example in engagement terms or event invitations.
- Staffing and allocationWho works late, travels or is placed with a client, and with what support.
Then, tell people what you heard and what will change. Visible follow-through can make people more willing to speak next time. The organisation still owns the interpretation, decisions, and communication.
Keep a short record of what you heard and did
A short record helps leaders follow through. It also keeps the reasoning behind each step visible when prevention is reviewed.
Here is another illustrative situation. A mid-sized accountancy practice runs a Check-in at the end of the financial year. Several comments describe behaviour from one client during on-site audit visits. The team records:
- What we heard: junior staff on the client audit are unsure whether the client’s behaviour ‘counts’ as something to report.
- What it may mean: the firm’s policy covers this, but people are not confident it applies to clients. It does not tell us how often incidents happen.
- What we will do: brief engagement partners on stepping in, and add client behaviour to the reporting guidance
- Owner and date.
- How we will tell people.
- When we will listen: next EHS Check-in or Cycle
A quarterly EHS rhythm, with 30 days to collect feedback and around 60 days to act, gives that record a regular review point.
A later change in feedback alone does not prove that a particular action caused it. It does give you a better question for the next conversation. Prevention needs clear steps. Listening shows where to take them and whether they’re working.
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