All reasonable steps in practice: what tribunals will expect to see
Safecall
52:07
October 2026 is closer than it feels. From that point, UK employers must be able to demonstrate that they have taken all reasonable steps to prevent sexual harassment. Yet many organisations are still unclear what that standard looks like in practice – and what evidence they will need to have available.
This challenge is compounded by the fact that statutory guidance on the duty is not expected until 2027, after the obligation is already live. Organisations therefore need to focus on preparing based on what is already clear, rather than waiting for further clarification.
What is well understood is that scrutiny will focus on whether arrangements are working in practice. It is not enough for measures to exist on paper; organisations need to be able to show that they are embedded, used and reviewed.
This session shares practical insight into how organisations are approaching this challenge across five key areas that commonly come under scrutiny:
- Prevention – training that is current, role‑appropriate, tracked and reviewed for effectiveness
- Reporting routes – channels that are accessible, trusted and supported by evidence of awareness and use
- Case management – clear, consistent and documented handling of concerns from receipt through to outcome
- Investigations – fair, thorough processes delivered with appropriate capability and independence
- Board oversight – meaningful visibility of themes, trends and outcomes to support effective governance
What you will learn
- How organisations are interpreting “all reasonable steps” in practical, evidential terms
- The areas that are most commonly examined when concerns are challenged, and what good practice looks like across each
- Where organisations often identify gaps in their arrangements, and the operational steps taken to strengthen them ahead of October 2026
- How to build a framework that is not just compliant, but demonstrable and sustainable
Who should attend
This session is relevant to anyone with responsibility for preventing, reporting, investigating or overseeing workplace concerns. It will be of particular value to HR Directors and People Leaders, General Counsel and legal teams, compliance and risk professionals, and board members with responsibility for organisational culture and conduct.
Speakers
Joanna Lewis
Managing Director, Safecall
Joanna is the Managing Director of Safecall. She leads the Safecall business teams in delivering confidential whistleblowing services, training, and independent investigations on behalf of organisations around the world. As part of that role, Joanna sees the effect that whistleblowing reporting has on promoting positive working cultures and preventing or mitigating damage to business reputations.
Kate Dodd
Partner - Employment and Equality Law at Pinsent Masons
Kate is an employment expert who advises household name employers across the UK. Having extensive experience in a specialist diversity and inclusion role, Kate is particularly known for her specialism in equality and discrimination law.
All reasonable steps in practice: what tribunals will expect to see
52:07