Employ Respons Rights J (2007) 19:45–55 DOI 10.1007/s10672-006-9031-x
Parsing Work Environments Along the Dimensions of Sexual and Non-Sexual Harassment: Drawing Lines in Office Sand Bryan J. Pesta & Mary W. Hrivnak & Kenneth J. Dunegan
Published online: 6 January 2007 # Springer Science + Business Media, LLC 2007
Abstract Laws addressing harassment at work have evolved considerably since court systems first recognized that (sexual) harassment is illegal. Now, managers must worry about protected classes other than sex (e.g., race, age, etc.), and the effects of harassment on bystanders as well as victims (i.e., ambient harassment). Understanding these newer conceptualizations of workplace harassment is critical for mangers dealing with an increasingly complex array of possible work environments, only some of which are illegal. Toward this end, we present a taxonomy of eight possible work environments, created by parsing the legal definition of sexual harassment (i.e., the first-recognized type of hostile work environment). The taxonomy illustrates the evolution of law in this area, and highlights the multidimensional nature of workplace harassment. Also discussed are potential complications arising from how a reasonable person and a victim might interpret behavior. Managers using the taxonomy may better assess whether their work environments have crossed the line, or facilitate movement from less- to more-desirable work environments. Key words hostile work environment . sexual harassment . ambient harassment . employment discrimination law Surveys measuring the incidence of harassment at work yield mixed but consistently alarming results. In the United States, between 40 to 90% of women report having experienced sex-based harassment at work (see, e.g., United States Merit Systems Protection Board, 1995; Peirce, Rosen, & Hiller, 1997). European Commission data reveal a similar pattern, with between 40 to 50% of women (and 10% of men) reporting these experiences (Owens, Gomes, & Morgan, 2004). Equally alarming are reports attempting to quantify the economic and social costs of workplace harassment (see, e.g., Faley, Knapp, B. J. Pesta (*) : M. W. Hrivnak : K. J. Dunegan Department of Management and Labor Relations, Cleveland State University, 1860 East 18th Street, Cleveland, OH 44114, USA e-mail:
[email protected] M. W. Hrivnak e-mail:
[email protected] K. J. Dunegan e-mail:
[email protected]
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Kustis, & DuBois, 1999). The United States Department of Labor reports that American businesses lose $1 billion per year due just to sexual harassment, with legal fees for defending a single case averaging about $250,000 (Faley et al., 1999; Larson, 1996—for comparable figures in Australia, see, e.g., Equal Opportunity Commission data, Victoria, Australia, 2006). Many of these reports reflect the cost of harassment after victims have filed complaints, or sued in court. Behaviors leading to complaints of harassment, though, typically persist over time. More often than not, and unless the perpetrator’s behavior is blatant, harassment occurs (or at least becomes illegal) when separate, relatively less severe behaviors sum with time to poison the work environment. This fact requires managers to be vigilant in monitoring their current work environments. Acting proactively may serve to limit organizational liability, while fostering healthy and nondiscriminatory workplaces (see, e.g., Oppenheimer, 2004). Complicating the issue is the multifaceted nature of workplace harassment. Often it is difficult to know when work behaviors have “crossed the line,” or whether a given work environment is indeed illegal. Managers must consider issues from multiple perspectives, including those of the victim, the alleged harasser, and reasonable people within the context of the current work environment (see e.g., Raver & Gelfand, 2005). Also relevant are precedents set in case law, and guidelines issued by administrative agencies in the US and abroad (e.g., the United States Equal Employment Opportunity Commission, EEOC; the European Union Commission; the Japanese Ministry of Labor; the Equal Opportunity Commission of Australia). The above underscores the need for a comprehensive taxonomy that managers can use to audit the current status of their organization with regard to illegal harassment at work. Toward that end, we created such a taxonomy by parsing the legal definition of sexual harassment. We framed the taxonomy around sexual harassment, because it is the forerunner to the other types of illegal and potentially illegal work environments. Further, although we created the taxonomy by drawing primarily from experience with the legal system in the United States, we make parallels to the international community where relevant. In sum, we draw lines in office sand which help demarcate legal from illegal work environments. Like lines in sand, however, work environments can change rapidly— previously welcome behavior can become unwelcome, or relatively infrequent class-based acts can become pervasive. Because shifting work environments create more or less legal liability for the organization, the present taxonomy is also geared toward helping organizations foster proactive versus reactive policies against harassment at work.
Parsing Sexual and Non-sexual Harassment According to the United States EEOC, sexual harassment occurs when work behaviors have “the purpose or effect of unreasonably interfering with an individual’s performance, or creating an intimidating, hostile, or offensive environment (EEOC, 1980, p. 74677).” Likewise, the European Union defines sexual harassment as existing when: any form of unwanted verbal, nonverbal or physical conduct of a sexual nature occurs, with the purpose or effect of violating the dignity of a person, in particular when creating an intimidating, hostile, degrading, humiliating or offensive environment (Owens et al., 2004, p. 4). Case law in the United States has further clarified the construct, finding that three elements must be present for sexual harassment to exist. First, the experienced behaviors
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must be unwelcome, both from the subjective point of view of the victim, and from the objective point of view of a reasonable person in the same situation as the victim. Second, the behaviors must be explicitly (i.e., sexually overt) or implicitly (i.e., directed toward one sex, but not the other) sex-based. Third, the behaviors must be so severe or pervasive that they alter the work environment (see e.g., US Circuit Court cases Mack v. Otis Elevator Company, 2d Cir. 2003; Mast v. IMCO Recycling of Ohio, 6th Cir. 2003; Quantock v. Shared Marketing Services, 2d Cir. 2002; for an international example, see Horne & McIntosh v. Press Clough Joint Venture, 1994). Harassment as a legal principle has evolved considerably since the 1980s. Newer issues surrounding workplace harassment have emerged, including constructs like “class based” and “ambient” harassment. The newer constructs, we believe, result from the logical evolution of the legal definition of sexual harassment—the first type of illegal work environment. As such, parsing the legal definition of sexual harassment illuminates how the newer constructs fit in with the overall scheme of general workplace harassment. Specifically, because three distinct elements comprise the legal definition of sexual harassment, there are logically two (welcome versus unwelcome) by two (sex-based versus non sex-based) by two (pervasive versus non-pervasive) possible work environments, as shown in Table 1. Because all three elements must be present for sexual harassment to exist, only the first cell in Table 1 can now be characterized as hostile work environment sexual harassment. This is the only environment where work behaviors are already unwelcome, sex-based and pervasive. The other cells in Table 1 illustrate different types of legal and illegal work environments, and follow from the evolution of case law regarding sexual harassment. Consider, for example, the second cell of the table, labeled non-sexual harassment. This cell covers harassment based on protected classes other than sex, and is illustrated by a recent US District Court case, Crawford v. Medina General Hospital (6th Cir. 1996). The plaintiff in this case was an older-adult female who claimed she was being harassed not because of her sex, but because of her age. Although Crawford failed to establish her case, the court nonetheless ruled that “class-based” harassment could potentially create an illegal work environment. The court also reasoned that the burden of proof in these types of cases would be the same as with sexual harassment cases. Namely, the victim must show that the behaviors were unwelcome, based on a protected class, and pervasive. Hence, if harassment is based on disability, age, religion, national origin, race, color, etc., it is also apt to be illegal, and thereby exposes the organization to prosecution. In sum, the first row of Table 1 identifies environments that are likely prima facie examples of harassment. In both scenarios, the behaviors are unwelcome, “class based” and Table 1 Possible work environments resulting from parsing the legal definition of sexual harassment. Unwelcome behavior Pervasive Non-pervasive
Sex-based Sexual harassment Unilaterally Lewda
Non-sex based Nonsexual harassment Unilaterally provocativea
Sex-based Ambient sexual harassment Bilaterally lewd
Non-sex based Ambient nonsexual Harassment Bilaterally provocative
Welcome behavior Pervasive Non-pervasive a
Powder keg environments
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pervasive. An organization falling in either scenario is obligated to take immediate and appropriate corrective action. Once management knows (or should have known) that harassment exists-even when the alleged harasser is not also a manager-the extent of the company’s liability depends on how it investigates and corrects the problem (see, e.g., US Supreme Court cases Burlington Industries, Inc. v. Ellerth, 1998; Faragher v. City of Boca Raton, 1998). Timely collection and documentation of facts from witnesses and victims, and appropriate remedial action would both serve to limit company liability. Oppenheimer (2004), for example, recently reviewed cases where employers either did or did not adequately investigate claims of harassment. In cases where the courts ruled against the company, management consistently failed to:
& & & & &
Promptly interview the accused. Promptly interview important witnesses. Corroborate allegations, when doing so would have been straightforward. Give sufficient weight to evidence in the victim’s favor. Take appropriate disciplinary action (Oppenheimer, 2004, pp. 56–57).
In contrast, Oppenheimer (2004) found that adequate complaint investigations shielded the employer from liability in harassment and/or wrongful termination suits. Proper investigations were those that included the following management behaviors:
& & & & &
Using neutral investigators who have been trained in how to evaluate complaints. Making sure to interview the alleged harasser, victim, and all relevant witnesses. Documenting all steps in the investigation, and preparing a final written report. Communicating the results of the investigation confidentially to affected parties. Taking appropriate disciplinary action, when needed, while following-up to insure the victim is not retaliated against.
Clearly, how management reacts after a complaint has been filed is key in determining the extent of liability it will face. Turning back to Table 1, the remaining cells identify environments that are borderline with regard to whether they constitute illegal harassment. In the second row, for example, the environments are characterized by unwelcome, but non-pervasive behaviors. Because the behaviors are unwelcome (i.e., one-sided), we have labeled these environments unilaterally lewd, and unilaterally provocative, respectively. Examples might be environments where occasionally crude and unwelcome remarks are directed toward an employee’s sex or other protected class (age, race, religion, etc), respectively. We further characterize both these scenarios as powder keg environments, because the qualitative “feel” of harassment is present; the only thing lacking is quantity. With time, and more of the same behaviors, these scenarios will rise to the level of illegal harassment. Organizations falling in these environments should intervene immediately, perhaps by singling out the alleged harasser, while stating clearly (and in writing), that future incidents will not be tolerated. The key is preventive acts by management to insure the line between non-hostile and hostile work environment is not crossed. Bell, Quick and Cycyota (2002), for example, recommend the following acts as part of a “preventive management” strategy:
& & & &
Implementing zero tolerance polices. Regularly assessing the work environment. Having a clearly communicated procedure for victims to report allegations. Conducting both sensitivity and new-hire awareness training.
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In addition to limiting company liability, Bell et al. (2002) argue that preventative actions also positively influence the organization’s overall culture and climate. Row 3 of Table 1 identifies work environments where the behaviors are pervasive, but not unwelcome. These scenarios present a different problem from those of the powder keg environments above, as they illustrate ambient harassment.1 Here, the potential victim is not the person receiving the harasser’s attention, but an innocent third party. Ambient sexual harassment (i.e., the left cell) thus refers to the indirect exposure a worker might have to sexual behavior directed toward someone else (see, e.g., Glomb, Richman, Hulin, Schneider, & Fitzgerald, 1997). An example would be a coworker who sees or hears other employees engaged in sexual banter. Though the other parties might be willing participants, the neutral co-worker who experiences the acts would potentially be subject to hostile work environment harassment. To our knowledge, no one has yet won damages in these types of cases, either in the United States or abroad. Nonetheless, convincing data exist showing that exposure to ambient sexual harassment negatively impacts various job-related, psychological, and health-based outcomes (Glomb et al., 1997). As such, management inactivity in these environments exposes the organization to potential legal liability, losses in productivity, increased worker stress, etc. Also, Bowes-Sperry and O’Leary-Kelly (2005) discuss the reluctance of many victims of ambient harassment to intervene and or complain about their experiences. This finding again underscores the need for managers to proactively monitor the current work environment. Organizations waiting to act until employees complain may find they can then do little to avoid legal liability. The environment in Table 1 labeled ambient nonsexual harassment extends Glomb and colleagues’ work to protected classes other than sex. The logic, however, is the same as that for ambient sexual harassment. Examples might include racial or religious slurs overheard by a third-party coworker. Even if such utterances do not offend the person toward whom they were directed, they might nonetheless create a hostile work environment for other employees present when those slurs were uttered. Just as hostile work environment harassment evolved to include classes other than sex, the concept of ambient harassment could undergo a similar progression. The practical lesson here is that complaint investigators must consider work environments (and specific allegations of harassment) from both the perspective of the person toward whom the behaviors were targeted, and also of any bystanders/coworkers present when the incidents happened (see, e.g., Glomb et al., 1997; Oppenheimer, 2004). The last row in Table 1 describes non-pervasive behaviors that are “welcome” (or at least, non-offensive). These seem to be both the milder versions of the ambient harassment environments covered in Row 3 (milder, because the behaviors are non-pervasive), and the two-sided versions of the lewdness and provocation found in Row 2 (two-sided, because the behaviors are not unwelcome). Hence, we have labeled these cells bilaterally lewd and bilaterally provocative, respectively. Examples would include occasionally crude behaviors directed toward another employee’s sex or other protected class, respectively. However, since the behaviors are not unwelcome, these scenarios imply some degree of reciprocity–– either the “victim” is not offended by the remarks/behaviors, or indeed, the victim returns the remarks with more of the same.
1
Ambient harassment probably also occurs in the first row of Table 1. For clarity, however, we focused our discussion there on just the direct victim of the target’s behavior.
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Though these environments appear mild relative to the others, they should nonetheless be monitored for change. Both scenarios have the potential for ambient harassment, and even worse, if welcome behaviors become unwelcome, or uncommon occurrences become ordinary, these environments will reclassify into one of the other, more severe categories. Also, because the behaviors are currently “welcome,” it is unlikely the “victim” will complain about them until and unless they cross the line. As such, reactive managers (see e.g., Bell et al., 2002) who fail to monitor these environments for change will not know there is a problem until the change into a harassing environment has occurred. By then it may be too late to act. Finally, we note that the elements constituting harassment in Table 1 are dichotomized, implying that they are all or none. In practice, people deciding on these issues will likely treat them initially as continuums (e.g., work behaviors likely fall on a continuum ranging from not at all sex-based to blatantly sex-based). Recognizing that shades of grey exist, nonetheless, does not remove the burden of ultimately deciding yes or no for whether each element is present in the current environment. If the organization is not able to do this, a judge or jury eventually might.
Which Perspective: Victim, or Reasonable Person? Having reviewed the eight possible scenarios in Table 1, a complicating factor arises with regard to the legal definition of harassment. Specifically, the American courts use two separate standards for deciding if behaviors are indeed unwelcome. The first standard is whether the victim found the behaviors to be subjectively offensive. In general, the courts will rely on just the victim’s testimony for establishing this, although when the victim claims to have merely “blown off” the incident(s), the courts will then not find them offensive (see, e.g., US Circuit Court case Mast v. IMCO Recycling of Ohio, 6th Cir. 2003). The second standard is that the behaviors must be objectively offensive to a reasonable person in the same work environment as the victim. For example, a pat on the buttocks from the football coach might not offend a reasonable person; whereas, the same action from a floor manager in a department store might. Our focus is on what complaint investigators should do when the two standards seem to conflict (i.e., a reasonable person would not be offended, even though the victim was, or vice versa). Logically, either the complaint investigator playing the role of the “reasonable person” agrees with the victim that the behaviors are offensive, or the investigator does not agree. When there is agreement, the work environments we described in Table 1 still hold. The top half of Table 1 then identifies work environments where both the victim and the reasonable person are offended by the behaviors. And, the bottom half of Table 1 covers work environments where neither the victim nor the reasonable person found the behaviors offensive. Where there is disagreement between the reasonable person and the victim, things get complicated. The investigator might feel that the behaviors described in a given complaint are relatively benign, and do not rise to the level of harassment, even though the victim indeed complained about them. Conversely, the investigator may observe an incident that he or she finds offensive, even though the target of the incident reported not being offended. From the organization’s point of view, the danger inherent in either case is committing one of two possible mistakes, which we have labeled false alarms and false negatives. A false alarm would occur when the investigator concludes that harassment exists, even though ultimately a court would find for the organization. False alarms could result from
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management over-reacting to a situation, or perhaps from an organization’s interpretation of a zero-tolerance policy with regard to harassment at work. On the other hand, a false negative would occur when a complaint investigator concludes that harassment does not exist, even though ultimately a court would find for the victim. False negatives could be caused by many factors, including vague or poorly defined policies with regard to harassment at work, insufficient training of investigators on how to handle incidents of this nature, or even perceptual differences between the complaint investigator (i.e., the “reasonable person”) and the victim. In the interest of avoiding either type of error, it is important to highlight what might be going on when the perspective of the victim differs from that of the investigator. To illustrate, Table 2 crosses the elements of agreement/disagreement between the victim and a reasonable person; whether the behaviors were or were not sex based; and whether the behaviors were or were not pervasive. Because the legal decision on whether an environment is harassing rests with the courts, whether each cell in the table constitutes a correct classification or a mistake depends on whether a judge or jury down the road would side with the victim, or with the organization. The first row of Table 2 covers scenarios where the behaviors are pervasive, and offensive to a reasonable person, but not to the victim. Respective examples might be coworkers engaged in consensual sex at work, or racial slurs that seem tolerated by the person toward whom they were directed. These scenarios are further examples of ambient harassment. Even though the “victim” is not offended by the behaviors, other reasonable people are. As such, any coworker or organizational member present when the incident(s) occurred would be subject to offensive and pervasive behaviors. Again, however, if the conclusion the complaint investigator reached playing the role of a reasonable person differs from that of some court in the future, the investigator’s decision would instead constitute a false alarm. The second row of Table 2 also contains scenarios where the behaviors are offensive only to the reasonable person, but here the acts are non-pervasive. These seem to be further examples of powder keg environments, because although not yet pervasive, reasonable people find the behaviors offensive. Given this, we have labeled the sex-based environment as salacious, and the non sex-based environment as uncivil. These scenarios differ from those that rise to the level of harassment (ambient or otherwise) only because the alleged harasser’s behaviors do not yet cross the legal line of being pervasive. Nonetheless, Lim Table 2 Descriptive labels for work environments where the victim and reasonable person disagree on whether the behaviors are offensive. Reasonable person is offended/victim is not (possible false alarmsa) Pervasive Non-pervasive
Sex-based Ambient sexual harassment Salaciousb
Non-sex based Ambient nonsexual harassment Uncivilb
Victim is offended/reasonable person is not (possible false negativesa) Pervasive Non-pervasive a
Sex-based Pseudo-sexual harassment Mumpish
Non-sex based Pseudo-nonsexual harassment Petulant
These environments result in false alarms or false negatives when the complaint investigator, playing the role of a reasonable person, reaches a conclusion different from what a court would ultimately decide.
b
Powder keg environments.
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and Cortina (2005) discovered that uncivil (but not necessarily illegal) workplace behavior in general predicts whether or not employees also experience illegal, class-based harassment. Further, Andersson and Pearson (1999) argue that incivility typically increases over time, which leads to more intense, and then ultimately illegal, aggressive behaviors. In sum, uncivil but legal work behavior may be a precursor to an illegal, hostile work environment (if the incivility eventually gets directed toward a protected class). As with the powder keg environments of Table 1, organizations in these environments should intervene immediately to avoid liability. Interventions could take the form of adopting zero tolerance harassment policies, together with training and/or disciplining proven harassers (or any of the proactive acts outlined by Bell et al., 2002). Underscoring the importance of employee training in these environments is an article by Reese and Lindenberg (2003). These authors used case studies and survey methodology to explore the relationship between employee training and the overall effectiveness of an employer’s sexual harassment policy. Reese and Lindenberg (2003) found that sexual harassment training increased the effectiveness of a company’s harassment policy by increasing the employee’s (1) confidence that an adequate remedy for harassment exists, and (2) willingness to use such a policy were harassment to occur. The remaining cells in Table 2 include environments where the victim is offended, but the reasonable person is not. Recall that these are potential false negatives (i.e., the complaint investigator risks concluding that harassment does not exist, when ultimately a court would find for the victim). In Row 3, the behaviors are pervasive and either sex-based (left side) or non-sex based (right side). These environments are perhaps least intuitive, and we have labeled them pseudo-sexual and pseudo-non-sexual harassment, respectively. Here, victims report pervasive and unwanted attention, but the reasonable person concludes that even the totality of the experienced behaviors do not seem offensive. Examples might include employees overreacting to (relatively benign) teasing based on sex or some other protected class, respectively. Independent of the potential for making a false negative here, organizations should monitor these forms of quasi-harassment for change as well. The courts consider both the quality and the quantity of the experienced behaviors when deciding on severity. A seemingly minor but common annoyance now might indeed become harassment later, if that annoyance persists, especially after the victim complains about it. Finally, the bottom row of Table 2 describes environments where the behaviors are nonpervasive and offensive to the victim, but not to a reasonable person. It is unlikely these environments would rise to the level of harassment. Not only do the behaviors fail the “reasonable person” test, they are also neither severe nor pervasive. Thus, we have labeled the scenarios mumpish in the sex-based cell, and petulant in the non-sex based cell. The aim is not to denigrate with these labels, but by definition (i.e., by virtue of the scenarios falling in these cells) the victims here would be hypersensitive to the alleged harasser’s behavior. Examples might include over-reaction to occasional flattery from a coworker, or perhaps over-reaction to mild and innocuous teasing from other organizational members. Though people have the right to work in environments free from unwanted behavior of any sort, the reality––especially with today’s diverse work environments—is that not all co-workers will get along. Moreover, some claims of harassment (as ultimately decided by the courts) will describe behaviors that simply do not rise to the level of a hostile work environment. Organizations faced with these last two scenarios should consider meeting with the victim and the alleged harasser, in an attempt to reach a compromise where both can work in environments neither overly restrictive, nor overly offensive (recognizing that what
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constitutes “restrictive” or “offensive” is partly subjective, and varies person by person). It is also in these scenarios where training might be particularly valuable, by instilling the company’s frame of reference for what behaviors it considers offensive. In this regard, Berry (2004) offers suggestions for how management can foster better workplace relationships, including actions that support employee communication, and those allowing employees to question/report illegal or unethical practices within the organization (see also Gross-Schaefer, Florsheim, & Pannetier, 2003).
Conclusion An organization should not be in the position of classifying work environments retroactively, as part of a post hoc complaint investigation into whether harassment has occurred. To prevent illegal harassment in the future, managers must obtain a realistic assessment of the potential for harassment now. As such, we hope the taxonomy provided here clarifies—on a logical/legal basis—which behaviors do and do not constitute hostile work environment harassment. By using the templates provided here, managers can (1) attempt the proactive classification of their current work environment, (2) monitor that environment for change, and (3) take preemptive corrective action (perhaps aimed at moving to a more neutral environment) if needed. Also clear is the need for management to have an effective policy against harassment already in place. Effective policies are those that clearly demarcate acceptable from non acceptable work behaviors; include provisions for monitoring the work environment; foster respect among co-workers, and provide specific remedies for employees who feel they are victims of harassment (see e.g., Bell et al., 2002; Cortina & Wasti, 2005; Oppenheimer, 2004). It is also important that the policy be clearly communicated to employees, and that management act in a timely and fair manner whenever complaints are filed. An additional potential benefit of using the taxonomy is that it may help organizations deal with disagreement over whether a given complaint constitutes illegal harassment. When people—for example, the victim and the complaint investigator—disagree, the decision making outcomes are clear: Either management will correctly classify and take appropriate action, or management will make one of two possible mistakes (i.e., a false alarm or a false negative). When management makes mistakes, the tendency seems to be a preference for false alarms, as evidenced by strict interpretations of zero tolerance policies. With constant changes in workgroups (new employees added, employee turnover, etc.), though, it behooves an organization to train all employees regarding specific harassment policies (Oppenheimer, 2004). Such training may both illuminate where the organization draws the lines, and promote tolerance and civil behavior among employees. We also add a note of caution, as much of our taxonomy is based on case law arising in the United States. What may be considered harassment in one culture may be acceptable in another (Gee & Norton, 1999). Further complicating the issue is the presence of multinational corporations bound by laws of the parent country, but operating in the culture of the host country (Hardman & Heidelberg, 1996; Luthar & Luthar, 2002). More research is needed on the cultural relativity of sexual harassment (see, e.g., Gee & Norton, 1999). In any culture, however, lines will be drawn demarcating acceptable from nonacceptable behavior with regard to sexual harassment at work. We hope the taxonomy presented here is flexible enough to accommodate these differences internationally, while still allowing managers to accurately assess the status of their current work environments.
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Finally, investigating harassment complaints is perhaps best characterized as a skill involving complex information processing. At the very least, the exercise is inherently a decision making activity. The investigator must sort through relevant and irrelevant information, arrive at reasoned, accurate conclusions, and decide on appropriate corrective actions, where necessary. Although much is at stake, both from a legal and a work morale point of view, social science provides many examples of humans as less-than-optimal decision makers (see e.g., Bazerman, 1997), and characterizes them as severely limited in their ability to hold and process information in consciousness (Miller, 1956; Simon 1979). In this regard, the templates provided here might lessen the manager’s informationprocessing burden, by helping define where in the sand the lines are currently drawn.
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