Office Manager's Guide to Handling a Harassment Complaint
An employee just told you that a coworker, or worse, a manager, has been harassing them. They came to you because you are the person they trust, the person who handles personnel matters, or simply the person who was available. You did not ask for this responsibility, but you have it.
What you do in the next 24 to 48 hours matters enormously, both for the employee who reported and for your organization's legal exposure. Here is how to handle it.
Your First Response: Listen and Take It Seriously
The moment an employee reports harassment, your job is to listen without minimizing, dismissing, or immediately problem-solving. Do not say 'Are you sure that's what they meant?' or 'That doesn't sound like [accused person].' Do not speculate about motives or suggest the employee may have misunderstood.
Listen. Take notes. Thank the employee for coming to you. Tell them you take this seriously and will address it. Do not promise a specific outcome, but do promise a process.
What to Document Immediately
Before you do anything else, write down:
• The date and time the complaint was made to you
• What the employee said, as specifically as possible: their words, not your summary. Direct quotes are your friend.
• The name of the person accused and their relationship to the complainant (coworker, manager, vendor, customer)
• The dates, locations, and nature of the conduct described
• Whether there were any witnesses
• Whether the employee has any documentation (messages, emails, photos)
This contemporaneous record is critical. It establishes what was reported, when, and to whom. If this matter ever becomes a legal or regulatory proceeding, that record is your foundation.
Escalate Immediately
A harassment complaint is not something an office manager should handle alone, regardless of how minor it may seem. Escalate to the business owner, a senior leader, or legal counsel today, not next week. Time is of the essence.
Why immediately: your organization's legal obligation to investigate begins the moment a complaint is made. Delays in investigation are themselves a liability. Courts and the EEOC look unfavorably on employers who sat on a complaint while the conduct continued. Knowing in advance which complaints require formal investigation versus which are interpersonal friction is a distinction worth understanding. Employee Keeps Complaining About a Coworker: When Is It an HR Issue? draws that line clearly.
Interim Protection for the Complainant
While the investigation is being organized, consider whether there are steps needed to protect the complainant from further contact with the accused. This does not mean automatically separating them or assuming the complaint is valid. It means asking whether the current working situation creates ongoing risk while the matter is investigated.
Options depending on the situation: temporarily adjusting schedules, reassigning a project, or moving workspaces. The goal is to avoid a situation where the complainant has to continue working in close proximity to the accused while the complaint is unresolved.
Do not automatically tell the accused about the complaint before the investigation begins. The complainant's identity should be protected to the extent possible.
The Investigation: What It Requires
A proper harassment investigation involves:
• Interviewing the complainant: get the full account in their words, documented
• Interviewing the accused: give them a fair opportunity to respond to the specific allegations
• Interviewing any witnesses identified by either party
• Reviewing any documentary evidence (messages, emails, records)
• Making a finding based on the preponderance of evidence
• Taking corrective action based on the finding
• Following up with the complainant
For a small organization without dedicated HR, this investigation may need to involve an outside HR consultant or employment attorney, particularly if the complaint involves a manager or owner, or if the alleged conduct is serious.
The Retaliation Prohibition Is Non-Negotiable
From the moment a complaint is made, any adverse action against the complainant like a schedule change, demotion, exclusion, or termination, can be characterized as retaliation, which is its own separate legal violation that can succeed even if the underlying harassment complaint does not.
Make sure everyone who knows about the complaint understands this. The complainant's work situation should not change in any negative way as a result of having made the report. If the complaint involves a romantic relationship that went sideways, the dynamics are more complicated. My Employees Are Dating: How Do I Handle It? covers what you should have had in place before it got here.
Why a Written Policy Matters Before This Happens
Every step described above is harder without a written harassment policy that defines the process. A policy tells employees how to report, tells you what to do when they do, and tells everyone what the investigation and corrective action process looks like. Without it, you are improvising a legal process in real time under pressure. That is exactly when mistakes get made.
Get an Anti-Harassment Policy Template
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Questions about this or other HR topics? Visit pragmatichrgroup.com for more resources.
