Running head: WORKPLACE SEXUAL HARASSMENT 1

Workplace Sexual Harassment: The Deterioration of the Work Environment

Nadia B. Farashahi

First Colonial High School

WORKPLACE SEXUAL HARASSMENT 2

Abstract

This paper looks at the occurrence of workplace sexual harassment that has

created a setback for a functioning work environment. The author begins by introducing what

sexual harassment in the workplace is as well as the different types. Information on how a victim

can take steps to make a claim and what consequences the perpetrator can receive are discussed.

The author then addresses the legalities that surround workplace sexual harassment on the

federal and states levels, including court cases. Connections are made to sexual harassment

occurring on a global scale to see the impact of this issue with more perception. Finally, the

author talks about recent trends in workplace sexual harassment and possible solutions to take for

prevention.
WORKPLACE SEXUAL HARASSMENT 3

Workplace Sexual Harassment: The Deterioration of the Work Environment

One in five American adults have reported being a victim to sexual harassment in the

workplace (Lee, 2017). This means that one in five American adults, the majority being women,

have experienced sexual comments, obscene gestures, and inappropriate touching in their place

of employment. This type of action can take a toll on the work environment, the employees

involved, and the image that the company portrays. The occurrence of sexual harassment in the

workplace obstructs the functioning of an effective work environment through creating a

demoralizing and hostile place of work.

Types of Sexual Harassment in the Workplace

The Equal Employment Opportunity Commission (EEOC) established two main types of

sexual harassment in the workplace, which also establishes the the two types of sexual

harassment claims: quid pro quo and hostile work environment. Both types of harassment

involve unwelcome conduct of a sexual nature, but there are different factors that go into

classifying which type occurred in a situation ("EEO: Sexual," 2018).

Quid Pro Quo

Quid pro quo sexual harassment occurs when someone with power, such as a supervisor,

makes a condition that if a worker under them wants to keep their job/job benefits, they have to

comply to sexual harassment ("Sexual Harassment," n.d.). Through quid pro quo, actions like

promotions, hiring, or firing are dependent on the employee involved giving sexual favors or

taking part in sexual conduct by the will of the employer. An example is a higher up demanding

sexual favors and either threatening an employee with termination for not taking part in it or

promising a promotion for agreeing (Berlin, 2018). If a person wants to claim sexual harassment
WORKPLACE SEXUAL HARASSMENT 4

under quid pro quo, there are certain elements they must be able to prove to a jury. These

elements are:

1. Plaintiff was an employee of, or applied for a job with, company X (the defendant).

2. The alleged harasser, an officer or employee of company X, made unwanted sexual

advance to the plaintiff, or engaged in other unwanted verbal or physical conduct of a

sexual nature.

3. Certain job benefits were conditioned, by words or conduct, on the plaintiff's

acceptance of the alleged harasser’s sexual advances or conduct; or that employment

decisions affecting the plaintiff were made based on his or her acceptance or rejection of

the alleged conduct.

4. At the time of the alleged conduct, the alleged harasser was a supervisor or agent for

company X.

5. The plaintiff was harmed by the alleged conduct.

6. The alleged harasser's conduct was a substantial factor in causing the plaintiff's harm

("What Is Quid," 2018).

This process is just for compensation for a quid pro quo harassment claim. So, if an employee

wants full justice they will need to take the complaint to a federal labor protection agency like

the EEOC. If a quid pro quo case is filed as a lawsuit, even if it is proven that no employment

opportunity was taken away as well as the salary/benefits, the plaintiff could still get

compensation. In addition, the employer could still be held liable (Wilner, Mckenna, Burritt, &

Tilles LLp, n.d.).

WORKPLACE SEXUAL HARASSMENT 5

Hostile Work Environment

To qualify for a hostile work environment sexual harassment claim, there usually has to

be a reoccurring action and has to show a pattern. If it occurs once, it is usually not classified as a

hostile work environment. This type of sexual harassment means there is some sort of action

taking place that is not wanted, based on sex, and has the magnitude to make a work

environment that is abusive. It occurs if an employee is subject by another employer, who can

also be an employer, to unwelcome sexual conduct. This can include advances, gestures,

demands, or comments of a sexual nature. No employment benefit has to be at risk for a hostile

work environment claim. Hostile work environment sexual harassment can affect the work

environment for the other employees even though they were not directly involved in the

harassment. If sexual harassment occurs between employees, the employer can be liable for

hostile work environment harassment as long as certain things are proven. The employer had to

have had knowledge about the situation and it be proven that he/she did not take any action to

prevent or stop it (Miller, 2018).

Guidelines for its Occurrence and Making Claims

There are certain standards that have to be met in order for someone to claim they are a

victim to sexual harassment in the workplace. The term is defined by the law as, “unwelcome

verbal, visual, non-verbal or physical conduct of a sexual nature or based on someone’s sex that

is severe or pervasive and affects working conditions or creates a hostile work environment”

(Equal Rights Advocate, n.d.). Workplace sexual harassment can be the cause of a antagonistic

or offensive environment at work. Victims who claim sexual harassment have to meet a

subjective and objective standard- “he/she subjectively believed the conduct was hostile,
WORKPLACE SEXUAL HARASSMENT 6

abusive, or offensive; and a reasonable person in the plaintiff's position would objectively

believe the conduct was hostile, abusive, or offensive” (Sexual harassment at work, 2018).

Sexual harassment in the workplace can take the form of making inappropriate sexual comments,

sharing sexual images online or in person, making unwanted physical contact with another

employee, etc (Doyle, 2018). If a person has or believes they have been subject to sexual

harassment in the workplace, there are different ways for them to take action. Certain companies

might already have a process in place that deals with sexual harassment complaints, so an

employee can first take their situation through their superiors. This can include having an

employer delegated to be the person who receives and handles any complaints or allegations.

("Sexual Harassment," n.d.). If the situation can not be fully handled within the company, the

victim can try to file the complaint through their state. If the state does not have a law to address

it, then the person should take it federally which has a 300 day range of when a complaint can be

reported. If an employee has any sort of concerns or inquiries about sexual harassment in the

workplace they can reach out to the Office of Civil Rights, under the U.S. Department of State,

who can take action though investigating any allegations. Persons wanting to make a claim for

sexual harassment in the workplace, for either type of sexual harassment claim, can also file a

complaint with the Department of State through the EEOC (U.S. Department of State, n.d.). This

agency enforces Title VII of the Civil Rights Act of 1964. They take action through an

investigation once this occurs the victim can formally file a Title VII lawsuit, also assuming

there is no settlement that would occur ("Sexual Harassment," n.d.). Through the EEOC, making

a complaint requires a process involving contacting an agency counselor within 45 days of the

act that took place. This contact will allow the claim victim to be informed of what actions
WORKPLACE SEXUAL HARASSMENT 7

he/she can to take in order to legally deal with the issue. There are lots of different options to be

taken once a claim victim gets to this point including taking the case to court, mitigating

damages, and that in order for a complaint to be official filed with the agency, it must have been

noted in the pre-complaint counseling (EEOC, n.d.).

Liability and Punishments

Employees can be liable for compensatory and punitive damages if quid pro or hostile

work environment harassment is proven. Liability can depend on the position of person who

committed the act and how the company acted to fix it. If committed by a superior and there is

solid employment action like demoting or firing, the employer is liable. If committed by a

superior and the harassment is a hostile work environment, employer is liable. “The employer's

defense to liability is that it 1) exercised reasonable care to prevent the harassment and took

prompt corrective action to stop it once made aware, and 2) the employee unreasonably refused

to take advantage of the corrective measures” ("Sexual Harassment," n.d.). If committed by a

coworker, the employer is liable if they knew/should have known about the harassment;

however, they aren’t liable if its shown that they immediately did something to address the

situation ("Sexual Harassment," n.d.).

If a complaint or claim is made through the Department of State and this incident is

proven to have occurred, the harasser will receive some sort of management action. “Discipline

will be appropriate to the circumstances, ranging from a letter of reprimand through suspensions

without pay of varying lengths to separation for cause. A verbal or written admonishment, while

not considered formal discipline, may also be considered” (U.S. Department of State, n.d.)
WORKPLACE SEXUAL HARASSMENT 8

Legalities

There are different levels of laws and codes that govern sexual harassment in the

workplace. This includes local policies, state codes, federal laws, and case laws. These laws are

set in place to stop the occurrence of sexual harassment and try to deter it.

Laws Addressing Sexual Harassment in the Workplace

Federal laws. ​Sexual harassment in the workplace is considered a violation of Title VII

of the Civil Rights Act of 1964. Under this federal law, sex, race, color, national origin, and

religion can not be used as the base for discrimination in employment. “The law also makes it

illegal to retaliate against a person because the person complained about discrimination, filed a

charge of discrimination, or participated in an employment discrimination investigation or

lawsuit” (American Association of University Women, 2018).

State laws. ​In Virginia Code § 30-129.4, sexual harassment training is required for all

employees of the legislative branch for Virginia. This required training applies specifically to a

General Assembly member, a General Assembly member's legislative assistant or other

legislative staff compensated by the state who work full time, and all other full-time employees

of each legislative branch agency of the Commonwealth. The Code of Virginia defines sexual

harassment as “unwelcome sexual advances, requests for sexual favors… when such conduct

explicitly or implicitly affects an individual's employment, unreasonably interferes with an

individual's work performance, or creates an intimidating, hostile, or offensive work

environment” (Sexual Harassment, 2018). Different states have various sexual harassment laws

and policies. Certain states have fair employment laws which deal with the issue, requiring that

the complaint be filed 180 days after the incident occurred.Companies with less than 15 workers
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are governed by state laws while those with 15 or more follow Title VI’s standards ("Sexual

Harassment," n.d.).

Court Cases

When sexual harassment cases have gone to court, they have helped to set precedent and

establish case laws for the issue. Workplace sexual harassment cases have been occurring for

many years. One significant case took place during the 1980’s known as ​Harris v. Forklift

Systems, Inc. ​Tessa Harris worked as a rental manager for Forklift Systems Inc, and she claimed

from 1985 to 1987 that her employer, Charles Hardy, created a abusive and hostile work

environment with offensive/vulgar comments and actions of sexual nature. She claimed he

called her a “dumb ass woman” and even made suggestions of going to a nearby hotel to

negotiate her raise. Harris quit then filed the suit on the grounds of being a victim of sexual

harassment under Title VII. The federal district court ruled in favor of of Forklift Systems

because a hostile work environment was not created by Hardy’s actions, and the harassment was

not to the magnitude that it could affect Harris’s psychological well being. The decision was

affirmed by a Sixth Circuit Court of Appeals. The case was then taken to the Supreme Court.

The question raised by this case was “Must sexual harassment ‘seriously affect [an employee's]

psychological well being’ in order to create an ‘abusive work environment’ that violates Title

VII of the Civil Rights Act of 1964?” (Oyez, n.d.). In an unanimous decision in 1993, the

Supreme Court ruled favor of the petitioner, saying plaintiffs in Title VII workplace-harassment

don’t have to prove psychological injury. However, the court acknowledged that an offensive

joke or comment is unlikely to be grounds for sexual-harassment suits (Encyclopedia Britannica,

2015). This case set a precedent involving whether psychological injury has to be proven in order
WORKPLACE SEXUAL HARASSMENT 10

for it to be a workplace sexual harassment lawsuit. It also helped to analyze the legalities behind

sexual harassment in the workplace and helped make the public more aware of this issue,

especially during those years. A more recent example of sexual harassment case is ​Ashley Alford

vs. Aaron’s Rents.​ In 2008, Ashley Alford filed a lawsuit with the EEOC under Title VII against

Aaron Rents, Inc. and her supervisor through the company, Richard Moore through quid pro quo

sexual harassment. Alford brought to court claims that Moore had made inappropriate comments

of a sexual nature, exposed himself to her, and requested for sexual favors from her. She said that

these favors Moore sought were in return for her employment and benefits like longer lunch

hours and more vacation days. Eventually, Alford said that she was sexual assaulted by him in

the store’s warehouse. When she started working, Alford was informed of policies against sex

discrimination and harassment as well as a hotline to call if there were any complaints of this

regard. After she started working for the company, Moore started to touch her and talk to her in

unwelcome, inappropriate, ways of a sexual nature. Alford called the hotline to complain of his

behavior and talked to another manager of the store, but nothing came out of these actions.

Moore sexually assaulted her in the security room in which he locked them in, and after this she

called the hotline once again. On top of this she also talked to another manager about what was

occurring but no immediate action was taken. Alford filed a claim with the EEOC, and they

investigated the situation, ending with Moore being suspended immediately. .(Ashley Alford v.

Aaron Rents, 2011, slip op. at [Page #]).

WORKPLACE SEXUAL HARASSMENT 11

Sexual Harassment in the Workplace in India

Workplace sexual harassment is a global issue; it is not confined to the boundaries of the

United States. It occurs everywhere, and in some countries, like India, it is a even bigger threat

especially to females.

Overview of Occurrence

India is still currently a developing country, with higher poverty rates, less policies

targeting gender inequality, and a big labor force. In regards to sexual harassment in the

workplace, women workers are more vulnerable to be victims. This is because of job insecurity,

economic dependence on the job for their livelihood, social perception of obeying the superiors,

or male bias in work environment. Women fear retribution if they report conduct like sexual

harassment, and it can also be difficult to come up with enough evidence for a charge. On top of

all this is the embarrassment and attention that comes with making a claim (Padmini, 2017). This

takes place all over world, in different cultures, including the United States. In India, their

culture is different from other nations in the way that for a long time it has been a patriarchal

society and women have been seen as inferior to males. This system puts women in more

vulnerable positions already in society, especially in the workplace which alters men mindsets to

act on their “dominance” and the powerless position of the woman. This is not always the case in

other nations, but in India it is how society has functioned for a long time, the males are always

on top; although this is changing in recent years because of economic and social advances among

the genders. However, it is still a big problem (Padmini, 2017). The occurrence of sexual

harassment is not confined to one country; it is on a global scale. Women for years have been the

main target of sexual harassment in the United States and other countries, especially those where
WORKPLACE SEXUAL HARASSMENT 12

there are greater rates of gender inequality in society. 79% of women in India have experience

some form of sexual harassment as of a report in 2015 (Senthilingam, 2017).

India Laws on Workplace Sexual Harassment

Sexual harassment in the workplace is an illegal act defined by the Supreme Court of

India, in a similar wording as the United States, as any sort of unwelcome action of a sexual

nature, “whether directly or by implication such as physical conduct and advances, a demand or

request for sexual favors, sexually colored remarks, showing pornography, [and] any unwelcome

physical, verbal or non-verbal conduct of sexual nature” (Padmini, 2017). The Indian law is

similar to the components of the United States law, with an emphasis on the act being

unwelcome. This law was enacted after a gang rape of a social worker in India in the late 1990’s.

It was this event that the Indian Supreme Court took notice on the lack of legalities on sexual

harassment in the workplace, especially for women (Padmini, 2017).

Significance and Solutions to this Issue

Workplace sexual harassment occurs at such a large scale, that it will never be

completely ended. It can have great effects on the victims, who are usually women. However, in

recent times more and more awareness has been growing in retaliation against workplace sexual

harassment. On top of that, more and more steps are being taken within workplaces to counter it.

The best method is to spread awareness and try to address every aspect of it through policies and

regulations.

Impact of Workplace Sexual Harassment

A majority of women in the United States who have been sexually harassed have

experienced some sort of mental and/or physical problems due to this harassment. These victims
WORKPLACE SEXUAL HARASSMENT 13

are also susceptible to lose wages and hours in unpaid leave. These occurrences have a

significant impact on the work environment and the employees, especially if the perpetrator was

a male and the victim a female. “Sexual harassment has a cumulative, demoralizing effect that

discourages women from asserting themselves within the workplace, while among men it

reinforces stereotypes of women employees as sex objects” (University of Minnesota, n.d.).

There is a demoralizing effect that accompanies sexual harassment that takes a toll on all

employees, even if they are not directly involved. This altered work environment could cause

employees, especially women to try to find a new place of work, leaving the company or

business with a permanent negative image (University of Minnesota, n.d.).

Current Action on Workplace Sexual Harassment

#MeToo movement. ​In recent years there has been a bigger stand taken on sexual

harassment in the workplace, seen through a specific movement known as #MeToo. This was

initiated when The New York Times published an expose alleging that Harvey Weinstein

committed sexual harassment, causing others to come out with claims against other

executives/superiors. As a result of the movement, New York state and New York City created

new stricter workplace sexual harassment laws which begin October 16, 2018. The new laws

require all New York state employees to take part in training for sexual harassment by October 9,

2019, and new employees have to take part in it as soon as possible or within 90 days. There are

other states that have required harassment training, like California, yet New York is different

because of its rigor. The training is going to be annually, focusing on prevention, and will be a

requirement of every employee. It will also focus on discrimination. Among its provisions, there

is no requirement for the state to check if every business is taking part in the provisions of it, but
WORKPLACE SEXUAL HARASSMENT 14

there are the possibility of consequences if they don’t. A human resources consultant, Frank

Cania, talks on the new development saying “the training has to somehow accommodate

questions, including [a] live trainer made available during that training session to answer those

questions. And it also requires the employer to solicit feedback from employees about the

training and the materials presented.” There has been a change in workplace harassment cases,

showing a great business risk for employers now that more employees are coming out with

allegations (Noguchi & McKeon, 2018). There has also been an increase in the amount of sexual

harassment workplace claims filed with the EEOC in correlation with the momentum of the

#MeToo movement. There was a 12% increase in sexual harassment claims filed with EEOC.

There was also 50% increase in lawsuits for allegations of sexual harassment, they filed

41.However, there is skepticism to the vast amount of complaints being filed to the EEOC, and

they believe they do not truly represent the actual amount of sexual harassment taking place in

the work environment.As many as 70% of people who are harassed never file a complaint with

their employer, based on a report by the EEOC in 2016 (Horowitz, 2018).

Required training. ​As seen with the policy implemented for required training for

New York state employees after the Harvey Weinstein controversy, required training is a strong

solution to target sexual harassment in the workplace. A bill introduced to the Senate in

November of 2017 titled Senate Training on Prevention of Sexual Harassment Resolution is

pending approval. It is a resolution “requiring sexual harassment training for Members, officers,

employees, interns, and fellows of the Senate and a periodic survey of the Senate” (Senate

Training, 2017). This process that would take place in the Senate not only requires training for

preventing sexual harassment, but surveys would also be given periodically that will constantly
WORKPLACE SEXUAL HARASSMENT 15

reinstate zero tolerance for and aim at detering it (Senate Training, 2017). A similar bill was

actually passed in the House of Representatives that requires all employees and members of the

House to take part in anti-discrimination and anti-harassment training. It would occur during

each one-year session of each two-year Congress ("Should Members," n.d.). Direct initiatives

like these, involving the government of the United States addressing the problem in their own

work environment is very influential.

Implementing Sexual Harassment Policies within Places of Work

There are laws that govern sexual harassment in the workplace, and these will

always be in place. However, a more effective way to prevent and spread awareness on this issue

is to target it on a smaller scale. Certain companies and businesses already have sexual

harassment policies or some sort of training in place, however they can be made more important

and effective. Many steps can be taken in to take these preventive steps like making sure there is

a clear policy on sexual harassment that is known to all employees. This policy should define

sexual harassment, address the zero tolerance on it, list any consequences, promise protection for

anyone who wants to make a complaint, etc. On top of this, there should be some sort of training

that all employees, even supervisors take part it. The US government is already taking steps in

their own place of work to combat sexual harassment, which shows the importance of it being

incorporated throughout the country. There are already some states that have requirements for

training like Connecticut and Maine, and recently New York has done the same (Barreiro, n.d.).

Conclusion

As long as sexual harassment is occurring, there can not be a fully functioning or safe

work environment. Even with the protections that have been implemented including federal laws
WORKPLACE SEXUAL HARASSMENT 16

like Title VII, the problem still occurs. Taking legal action against workplace sexual harassment

is not an easy process either, with lots of processes and standards that have to be met. A victim

no longer feels welcoming or relaxed in their place of work, and the work environment as a

whole is completely disrupted. There have been court cases from decades ago to ones that have

taken place in recent years, which is just evidence of the continuance problem. However, today,

there has been bigger steps to raise awareness and address workplace sexual harassment. There is

no set solution to completely end it, but tight enforcement and more preparation for prevention

can help to get on the right path.

References

American Association of University Women. (2018). Know your rights at work. Retrieved

December 6, 2018, from AAUW.org website:

https://www.aauw.org/what-we-do/legal-resources/know-your-rights-at-work/workplace-

sexual-harassment/

Ashley Alford v. Aaron Rents, No. 08-cv-0683-MJR (May 3, 2011). Retrieved from

https://casetext.com/case/alford-v-aaron-rents-7

Barreiro, S. (n.d.). Preventing sexual harassment in the workplace. Retrieved December 14,

2018, from Nolo website:

https://www.nolo.com/legal-encyclopedia/preventing-sexual-harassment-workplace-2985

1.html

Berlin, R. (2018). Sexual harassment in the workplace defined. Retrieved November 26, 2018,

from AllLaw website: https://www.alllaw.com/articles/employment/article37.asp

Bertini, L. (2018, October 19). [Telephone interview by the author].

WORKPLACE SEXUAL HARASSMENT 17

Doyle, A. (2018, November 6). Examples of sexual and non-sexual harassment. Retrieved

November 26, 2018, from The Balance Careers website:

https://www.thebalancecareers.com/examples-of-sexual-and-non-sexual-harassment-206

0884

EEOC. (n.d.). Federal EEO complaint processing procedures. Retrieved November 26, 2018,

from U.S. Equal Employment Opportunity Commission website:

https://www.eeoc.gov/eeoc/publications/fedprocess.cfm

EEO: sexual harassment: what are the different types of sexual harassment? (2018, January 12).

Retrieved November 26, 2018, from Society for Human Resource Management website:

https://www.shrm.org/resourcesandtools/tools-and-samples/hr-qa/pages/typesofsexualhar

assment.aspx

Encyclopedia Britannica. (2015, September 23). Harris v. forklift systems. Retrieved October 9,

2018, from Britannica.com website:

https://www.britannica.com/topic/Harris-v-Forklift-Systems

Equal Rights Advocate. (n.d.). ​Sexual harassment at work​ [Fact sheet]. Retrieved November 20,

2018, from Equal Rights website:

https://www.equalrights.org/legal-help/know-your-rights/sexual-harassment-at-work/

Harris v. Forklift Systems, Inc. (n.d.). Oyez. Retrieved October 9, 2018, from

https://www.oyez.org/cases/1993/92-1168

Harris v. Forklift Systems. (23 Sep, 2014). Encyclopedia Britannica. Retrieved October 9, 2019,

from https://www.britannica.com/topic/Harris-v-Forklift-Systems
WORKPLACE SEXUAL HARASSMENT 18

Horowitz, J. (2018, Oct 5). Workplace sexual harassment claims have spiked in #MeToo Era.

CNN. Retrieved from

https://www.cnn.com/2018/10/04/business/eeoc-sexual-harassment

-reports/index.html

Miller, B. (2018, September 3). Sexual harassment in the workplace: Quid pro quo versus hostile

work environment. Retrieved November 28, 2018, from HR Daily Advisor website:

https://hrdailyadvisor.blr.com/2014/09/03/sexual-harassment-in-the-workplace-quid-pro-

quo-versus-hostile-work-environment/

Noguchi, Y., & McKeon, S. (2018, Oct 9). Amid #MeToo, New York employers face strict new

sexual harassment laws. National Public Radio. Retrieved from

https://www.npr.org/2018/10/09/654537942/amid-metoo-new-york-employers-face-strict

-new-sexual-harassment-laws

Oyez. (n.d.). Harris v. forklift systems, inc. Retrieved October 9, 2018, from Oyez.org website:

https://www.oyez.org/cases/1993/92-1168

Padmini, K. (2017). Sexual Harassment of Women at the Workplace. Indian Social Science

Journal, 6(2), 27-36. Retrieved from

https://search.proquest.com/docview/2002968973?accountid=3785

Requiring Each Member, Officer, and Employee of the House of Representatives to Complete a

Program of Training in Workplace Rights and Responsibilities Each Session of Each

Congress, and for Other Purposes, H.R. 630, 115th Cong. (Nov. 29, 2017). Retrieved

from

https://www.countable.us/bills/hres630-115-requiring-each-member-officer-and-employe
WORKPLACE SEXUAL HARASSMENT 19

e-of-the-house-of-representatives-to-complete-a-program-of-training-in-workplace-rights

-and-responsibilitie

Senate training on prevention of sexual harassment resolution, S. Res. 323, 115th Cong. (as

introduced, Nov. 6, 2017). Retrieved from

https://www.countable.us/bills/sres323-115-senate-training-on-prevention-of-sexual-hara

ssment-resolution

Senthilingam, M. (2017, November 29). Sexual harassment: How it stands around the globe

(S.-G. Mankarious, Ed.). Retrieved December 10, 2018, from CNN.com website:

https://www-m.cnn.com/2017/11/25/health/sexual-harassment-violence-abuse-global-lev

els/index.html?r=https%3A%2F%2Fwww.google.com%2F

Sexual harassment: actions you can take. (n.d.). Retrieved from FindLaw website:

https://employment.findlaw.com/employment-discrimination/sexual-harassment-actions-

you-can-take.html

Sexual harassment at work. (n.d.). Retrieved from FindLaw website:

https://employment.findlaw.com/employment-discrimination/sexual-harassment-at-work.

html

Sexual harassment training required; legislative branch., Va. Code Ann. § 30-129.4 (2018).

Retrieved from https://law.lis.virginia.gov/vacode/title30/chapter13.1/section30-129.4/

Should members and employees of the house of representatives have to undergo anti-harassment

and anti-discrimination training? (n.d.). Retrieved December 12, 2018, from Countable.us

website:

https://www.countable.us/bills/hres630-115-requiring-each-member-officer-and-employe
WORKPLACE SEXUAL HARASSMENT 20

e-of-the-house-of-representatives-to-complete-a-program-of-training-in-workplace-rights

-and-responsibilitie

University of Minnesota. (n.d.). Sexual harassment- effects of sexual harassment. Retrieved

December 18, 2018, from Human Rights Library website:

http://hrlibrary.umn.edu/svaw/harassment/explore/4effects.htm

U.S. Department of State. (n.d.). Sexual harassment policy. Retrieved November 20, 2018, from

U.S. Department of State Diplomacy Action website:

https://www.state.gov/s/ocr/c14800.htm

What is quid pro quo harassment? (2018). Retrieved November 26, 2018, from FindLaw

website:

https://employment.findlaw.com/employment-discrimination/what-is-quid-pro-quo-haras

sment.html

Wilner, Mckenna, Burritt, & Tilles LLp. (n.d.). Quid pro quo sexual harassment definition.

Retrieved November 30, 2018, from WMlawyers.com website:

https://www.wmlawyers.com/sexual-harassment/definitions/eeoc-harassment-definition/q

uid-pro-quo-harassment/
WORKPLACE SEXUAL HARASSMENT 21