Earlier this week, New York State published the final versions of its Model Sexual Harassment Policy and Model Sexual Harassment Training Program. One of the changes that was made after the comment period was that the date for the initial round of training has been pushed to October 9, 2019 (had been January 1). After the initial training, employees will also be required to received training on an annual basis. Please note, that you need to have your policy up-to-date (in accordance with the regulations), posted and distributed to your employees by this coming Tuesday, October 9. We recommend using the model policy provided by the state. For your Union employees, please note this passage from the State's FAQ section: Q6. What are the obligations of employment agencies? What about employees who received the same training from another employer within the past year? A6. The law requires that employers provide a sexual harassment prevention policy and training on an annual basis to all employees. An employer may choose to deem the training requirement satisfied if a new employee can verify completion through a previous employer or through a temporary help firm. An agency or any other worker organization (e.g. labor union) may choose to provide training to workers, however, the employer may still be liable for the employee's conduct and understanding of policies and should train the employee on any nuances and processes specific to the company or industry. We will provide more information on training options, including when the Unions will be offering training, when it becomes available. The state's website has additional information, including model policy language and model training programs, which can be found by clicking here. Please note that NYC has its own sexual harassment laws which include additional requirements. Click here for more information on NYC's requirements.