ARTICLE
5 December 2025

Navigating Festivities—an Employer's Guide To Preventing Sexual Harassment

AO
A&O Shearman

Contributor

A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength. Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations. Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
As the office playlists veer towards Mariah and the novelty jumpers are dusted off, this is a timely reminder about the proactive duty to take reasonable steps to prevent sexual harassment in the workplace, and how that looks in a festive context.
United Kingdom Employment and HR
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As the office playlists veer towards Mariah and the novelty jumpers are dusted off, this is a timely reminder about the proactive duty to take reasonable steps to prevent sexual harassment in the workplace, and how that looks in a festive context.

This blog focuses on what reasonable steps look like in December, and how to comply without turning your party into a policy seminar. It comprises a handy checklist to assist with compliance and risk management.

For a deeper dive into background, scope and third-party risk, see our earlier blogs:Employers' positive duty to take reasonable steps to prevent sexual harassment — a new era beginsandOne year on: are your "reasonable steps" still reasonable?

Your December action plan

Reasonableness is fact-specific, but the direction of travel is clear. Tribunals and the EHRC will look for visible, embedded measures proportionate to your size, risk profile, resources, the nature and frequency of your work-related social events and the steps you take to mitigate foreseeable risks.

Employers should be able to demonstrate the reasonable risk-based steps they have taken. For a seasonal and socially heavy period like December, that translates into actions before, during and after events—a glossy policy that no one has read since last year will no longer cut it.

Clickhereto access your seasonal checklist.

Final word: prevention is cultural, not seasonal

The duty is a year‑round requirement. December is simply a stress test of your culture and systems.

Employers who invest in clear expectations, credible training, confident managers and accessible reporting will not only meet their legal obligations, but also ensure safer, more inclusive celebrations.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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