Workplace Harassment: How to Build a Prevention Policy and Safe Reporting Channels

How can workplace harassment be prevented? Employer legal duties, the features of an effective reporting channel and what to watch for during an investigation.

An employee often speaks up about a complaint months after the harassment began. The reason for the delay is usually not that the incident was minor; it is that they do not know whom to tell, fear not being believed, worry about losing their job and dread that "it will blow up and everyone will find out". Workplace harassment, whether psychological or sexual, damages not only the victim's sense of safety but the whole team's, and exposes the organisation to serious legal risk. The good news is that preventing harassment depends largely on the system an organisation puts in place. In this article I look at the forms harassment takes, the employer's legal responsibilities, how to design a trustworthy reporting channel and the steps to take when a complaint arrives.

What Is Workplace Harassment? Its Forms and Boundaries

Harassment is the general name for unwanted behaviour that damages a person's dignity, frightens or humiliates them, or creates a hostile environment. The main forms we encounter in working life are:

• Sexual harassment: Unwanted physical contact, sexual innuendo, sending messages or images with sexual content, persistent invitations, expecting sexual closeness in return for work-related benefits.
• Psychological harassment (mobbing): Systematically excluding, humiliating or obstructing a person, constantly criticising them, making baseless accusations.
• Verbal and written harassment: Insults, demeaning nicknames, mockery based on gender, age, origin, belief or disability.
• Digital harassment: Singling someone out in messaging groups, disturbing messages outside working hours, exposure or unauthorised sharing on social media.

There is an important distinction here: in legal practice, the concept of psychological harassment generally refers to behaviour that is systematic, continuous and intentional. Sexual harassment, however, can occur through a single incident. An organisation's policy must not leave room for the mistaken impression that "it must be repeated to be taken seriously". I have also covered mobbing in detail in the article on workplace mobbing and employer obligations.

How Common Is Harassment and Why Does It Stay Invisible?

According to the ILO's 2026 report, 23% of employees worldwide have experienced violence or harassment at work at least once, and the most common form is psychological violence, at 18% (ILO, 2026). In the European OSH Pulse survey, 7% of employees reported having recently experienced harassment or bullying (EU-OSHA, 2022). However, these figures reflect only the experiences that were spoken about.

The main reasons harassment stays invisible are:

• Power imbalance: The person harassing is often a manager, a senior employee or an important client.
• Career concerns: In the same survey, 50% of employees think that disclosing a mental health problem would harm their career (EU-OSHA, 2022). Raising a more sensitive subject such as harassment increases this worry still further.
• An unclear channel: The employee does not know whom to tell or how, or the only channel is the manager to whom the harasser reports.
• Shame and guilt: The victim may play down what they have experienced or blame themselves.
• Organisational culture: Reactions such as "we were only joking" or "that is just how he is, don't mind it" normalise silence.

The price of silence is high. Employees who experience harassment at work commonly develop anxiety, sleep problems, constant hypervigilance, avoidance of going to work and loss of self-confidence. Over time this can turn into absenteeism, coming to work but being unable to be productive, and eventually leaving the job. Employees who witness harassment are affected too: the thought that "one day it could be my turn" weakens trust and cooperation in the team. Moreover, employees who see that the person who harassed faced no sanction stop believing in the values the organisation declares.

The ESENER 2024 survey of European workplaces confirms this: the greatest difficulty workplaces face in managing psychosocial risks, at 59%, is reluctance to talk openly about these issues (EU-OSHA, 2025).

The Employer's Legal Obligations

Turkish legislation places on the employer a clear duty of prevention and protection with regard to harassment:

• Turkish Code of Obligations No. 6098 (TBK), art. 417/1: The employer is obliged to protect and respect the employee's personality, to maintain an order in the workplace consistent with the principles of good faith, and in particular to take the necessary measures so that employees are not subjected to psychological and sexual harassment and so that those who have been harassed are not harmed further.
• TBK art. 417/3: Where personality rights are violated through a breach of these obligations, compensation is subject to the provisions on liability arising from breach of contract.
• Labour Law No. 4857, art. 24/II: Among the situations that give the employee the right to terminate immediately for just cause are the employer's sexual harassment (b), provocation, intimidation and baseless serious accusations (c), and the employee being sexually harassed by another employee or third parties and the necessary measures not being taken despite their informing the employer (d).
• Prime Ministry Circular No. 2011/2: Treats the prevention of psychological harassment in the workplace first and foremost as the employer's duty and provides for psychologist support on the ALO 170 line (Turkey's labour hotline).

Within this framework, sub-paragraph 24/II-d is especially noteworthy: legal risk arises not only from the harassment taking place but from failing to act once it has been reported. For this reason, a functioning reporting and investigation system is not an option for the employer but the basic means of protection. A prevention policy, training records and a complaint procedure are the documents that show the employer took the necessary measures. In specific cases, the opinion of an employment lawyer should always be sought.

How Do You Write a Workplace Harassment Prevention Policy?

An effective policy does not have to be long or full of legal terms. A simple, firm text that an employee can understand when they read it is more functional. The core elements it should contain are:

1. A clear commitment: That the organisation will not turn a blind eye to any form of harassment and that the rule applies to everyone regardless of title or performance.
2. Definitions and examples: What psychological, sexual, verbal and digital harassment mean, with concrete examples.
3. Scope: Employees, managers, interns, subcontracted staff, customers and suppliers; the workplace, shuttle vehicles, business trips, business meals and digital channels.
4. Reporting routes: At least two different channels and how each is to be used.
5. Protection against retaliation: That any adverse treatment of those who report in good faith or give testimony will itself be a disciplinary matter.
6. Process and timeframes: How soon a complaint will be dealt with, who will investigate it and how the parties will be informed.
7. Confidentiality: That information will be shared only with those the investigation requires.
8. Support: The psychological support and temporary arrangements that will be offered to the victim.

According to ESENER 2024, 55% of workplaces in Europe with 20 or more employees have a procedure for cases of bullying and harassment (EU-OSHA, 2025). In other words, having a procedure is becoming an ordinary part of corporate life.

Features of a Trustworthy Reporting Channel

Having a complaints box or an email address on paper does not mean the channel works. A channel that employees will genuinely use should have these features:

• More than one route: The direct manager, HR, an ethics committee or an external independent consultant. If the person harassing is the manager themselves, there must always be a route that lets the employee bypass them.
• Accessibility: Employees who work shifts, do not use computers or work in the field must also be able to reach the channel. In factories, an email route alone is not enough.
• An option for anonymous initial reports: Some employees want to give information anonymously first and see how the organisation responds. This option can open the way to a formal complaint.
• Quick feedback: Confirming within a short time that the report has been received and explaining the next steps increases trust.
• Trained contacts: The person who first listens to a complaint should be a listener and an informer, not an interrogator.

The role of managers and team leaders

However well a reporting channel is designed, the person employees turn to first is often still their direct manager. For this reason every manager must know what to do when they are told about harassment: listen, not belittle the matter, not try to "sort it out between them" on their own, and immediately pass the process to the authorised channel. A manager saying "don't exaggerate, that's just how he is" can undo the entire effect of the organisation's written policy in a single sentence.

Harassment in hybrid and remote work

Remote work does not eliminate harassment; it changes its form. Inappropriate comments in video calls, persistent approaches through private messages, or the systematic exclusion of one person in team chat groups should also be explicitly within the scope of the policy. Employees should be reminded that incidents in digital channels can be recorded with screenshots.

Employees trust a reporting channel after they have seen how the first report was received.

What Should You Do When a Complaint Arrives?

Suppose a female operator at a production site reports to HR that her shift supervisor constantly makes sexual innuendos and sends her messages outside working hours. The steps taken at this point are decisive both for the employee's wellbeing and for the organisation's legal position:

1. Listen and put it on record: Listen to the employee without judging. Note what happened, when, the witnesses and any evidence such as messages. Avoid questions like "Are you sure?" or "Could you have misunderstood?"
2. Ensure safety: If necessary, temporarily change the direct working relationship between the parties. However, this change must not be such as to punish the victim; their shift, pay or duties must not be altered to their disadvantage.
3. Begin an impartial investigation: The investigation should be carried out by people with no hierarchical or personal link to the parties. If necessary, obtain external expert support.
4. Hear both sides: Give the person complained about the opportunity to express themselves too; the process must be fair.
5. Decide and implement: Take proportionate disciplinary measures according to the outcome of the investigation and communicate the result to the relevant parties appropriately.
6. Monitor for retaliation: In the weeks after the process ends, make sure the victim and witnesses are not excluded and that their duties and evaluations are not adversely affected.
7. Offer psychological support: Harassment can leave effects such as anxiety, sleep problems, avoidance of going to work and loss of self-confidence. Offering the employee confidential one-to-one support makes it easier for them to recover and to trust the job again.

Documentation matters throughout all of these steps. Meeting dates, temporary measures taken, the people heard and the decision given should be kept in writing. Well-kept records show that the process was conducted fairly, and, if a workplace harassment claim is later taken to court, show that the organisation took measures.

If an employee talks about thoughts of harming themselves, or if there is immediate danger, the situation should not be left waiting and 112 (emergency services) should be called.

How Do You Get Started in Your Organisation?

Needs analysis: First you need to see the current situation. Existing policies and procedures are reviewed, how past complaints were concluded is examined, and how far employees trust the reporting channels is measured through anonymous employee surveys and focus groups. This work can be carried out together with the "social relations" dimension of the psychosocial risk assessment. For our analysis approach, you can look at the organisational analysis section.

Programme: Based on the analysis, the policy is written or updated and the reporting channels are reorganised. All employees are told what harassment is and how to report it; managers and those who will first listen to complaints also receive "first conversation" training. How witnesses can intervene (stepping in, supporting the victim, reporting) should also be part of the training. You can find how the programme can be structured for your organisation's scale on the corporate services page.

Measurement: Report numbers, the time from report to decision, retaliation complaints, the rate of agreement in employee surveys with the statement "if I report, I will be supported" and turnover data are monitored. After a policy is published, an increase in reports is often not a negative sign but a sign that silence is being broken.

Frequently Asked Questions

Should anonymous complaints be taken into account?

Yes. Anonymous reports may not on their own be enough for a disciplinary decision; however, they point to the existence of a problem and should be investigated through observation, team interviews or a climate survey. An anonymous channel can pave the way for the employee to make a formal complaint later.

What happens if a harassment complaint turns out to be unfounded?

A lack of evidence does not mean the complaint was made in bad faith. The policy should state clearly that reports made in good faith will not be punished under any circumstances. Only reports knowingly made falsely and with the aim of causing harm can be assessed separately.

Does a small business also need a written policy?

Yes. In small businesses employees have fewer channel options, and the person harassing is often the boss directly or someone close to them. A short written policy and an independent external point of contact provide an important safeguard even on a small scale.

What should an employee who witnesses harassment do?

If it is safe, the most valuable steps a witness can take are to step in and stop the behaviour, to talk to the victim afterwards and let them know they are not alone, and to pass the incident to the reporting channel. Teaching these skills to witnesses in an organisation's training programme can mobilise the silent majority.

• #workplace harassment
• #sexual harassment
• #reporting channel
• #human resources

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Eda Erkan Alapala

Klinik Psikolog. İstanbul Kent Üniversitesi Klinik Psikoloji Tezli Yüksek Lisans mezunu; bilişsel davranışçı terapi, çocuk merkezli oyun terapisi ve çocuk-ergen psikoterapisi alanlarında eğitimlerini tamamlamıştır.

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