As we discussed in our previous posts – see here and here – in April 2018, New York passed legislation intended to combat workplace sexual harassment. Under this new law, employers are required to implement and distribute to employees a written policy prohibiting sexual harassment by October 9, 2018. To assist employers in complying, in April 2018, the New York State Department of Labor (“NYSDOL”) released a package of draft model policies for employers and state contractors to provide guidance to employers on how to implement their new sexual harassment prevention policies. At that time, the NYSDOL proposed that all covered New York employers be required to provide employees with sexual harassment training no later than January 1, 2019. However, in early October 2018, after considering comments from the public, New York released its finalized model materials, in which, among other things, it changed the deadline for training from January 1, 2019 to October 9, 2019, giving employers a full year from the date implementation is required under the law to complete the required employee training. Although the deadline has been extended, it is important for New York employers to begin thinking about how they will comply with the training requirements by the October 9, 2019 deadline. Squire Patton Boggs can assist with this – please see Training and Beyond in the #MeToo Era – as well as other issues raised by but not fully addressed, and that remain unanswered, in the NYSDOL’s final materials.
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