Beyond the Policy: What "All Reasonable Steps" Actually Looks Like
The Employment Rights Act raises the bar from "reasonable steps" to "all reasonable steps", brings sexual harassment reports under whistleblowing protection, and makes employers directly liable for harassment by clients, customers and contractors, not just staff. Uncapped compensation, a 25% uplift, and sharper enforcement mean the cost of a paper policy that isn't lived is now much higher.
This conference is built around what changes in practice, not just in law. Two clear legal sessions cover the new threshold and the third-party liability now attached to remote work, digital tools and client-facing roles. Two case studies show how real organisations found and closed their gaps. A live scenario exercise then tests your own instincts against situations designed to uncover exactly the risks a compliant-looking policy misses.
What you'll take away:
- A precise, working definition of "all reasonable steps", and how to evidence it
- Clarity on your new liability for clients, contractors and remote/digital conduct
- Two real organisational case studies you can benchmark against
- Direct experience spotting the hidden risk signals most policies miss
- A 90-day action plan to close your own gaps before enforcement catches up
Why attend now:
This isn't a distant reform. The higher legal threshold, the whistleblowing alignment, and third-party liability are landing on a fixed timetable, and uncapped awards mean the financial exposure for getting it wrong has never been higher. Organisations that get ahead of this now don't just reduce tribunal risk: they build the kind of reporting culture that catches problems early, protects retention, and holds up client and public scrutiny in a way a dusty policy document never will. Getting it right is a genuine competitive advantage, not just box-ticking.
CPD eligible — certificate of attendance provided, with hours and content confirmed for your professional body.
The All Reasonable Steps Mandate – the new statutory threshold and how it will be tested
Whistleblowing Alignment – harassment reports as protected disclosures
Third-Party Liability – direct liability for clients, customers, suppliers and contractors
Remote and Digital Grey Areas – Teams, Slack, off-site events and client entertainment
Data-Led Risk Auditing – finding what generic policy reviews miss
Building Reporting Trust – multi-channel, anonymous-capable systems people actually use
The EHRC 8-Step System – embedding the framework into daily management
Investigation Practice – swift, fair, legally robust incident response
Scenario-Based Risk Recognition – applying all of the above under realistic pressure
09:30 - 09:50 Chair's Welcome and Live Poll: Where Are We Starting From?
A five-minute welcome and framework setting for the day
Live polling to establish the room's current understanding, confidence and exposure to the Act's harassment provisions, so today's content lands exactly where delegates need it
09:50 - 10:20 Legal Session One: The New Threshold
- The "All Reasonable Steps" Mandate: what distinguishes it from the old "reasonable steps" standard, and how tribunals are expected to test it
- Whistleblowing Alignment: sexual harassment reports as protected disclosures, and what that changes for detriment and dismissal risk
- The Cost of Failure: uncapped awards, the 25% uplift, and what enhanced enforcement powers mean for your risk register
10:20 - 10:50 Legal Session Two: The Third-Party and Remote Threat
The area of liability the Act introduces that catches most organisations by surprise.
- Statutory Liability: direct employer liability for harassment by clients, customers, suppliers and contractors
- The Grey Areas of Remote Work: governing conduct on Teams and Slack, off-site events, and client entertainment where the old rules don't clearly apply
- Commercial vs. Compliance: what to do when a valuable client relationship and a duty of care to junior staff pull in different directions
10:50 - 11:05 Comfort break
11:05 - 11:35 Case Study One: The Data-Led Audit
How one organisation moved beyond a generic policy review to a genuine risk audit, using turnover patterns and reporting-rate anomalies by department to find problems no one had reported yet, and what it changed as a result.
11:35 - 12:05 Case Study Two: Building a Reporting Culture People Actually Trust
How a second organisation closed the gap between having a reporting policy and having a reporting culture: multi-channel and anonymous routes, fair and fast investigation practice, and the EHRC 8-Step framework embedded into daily management, not left in a folder.
12:05 - 12:45 Live Scenario Exercise: What Would You Miss?
Delegates work through four short scenarios in breakout groups, then feed back what they'd flag, what they'd escalate, and what they'd do next. These scenarios are designed to reveal the risks a standard policy review typically misses.
- Scenario A: The Quiet Department
A regional team has unusually high turnover among younger women and almost no formal complaints. Nothing has been reported. Is there a problem, and how would you find out?
- Scenario B: The Valued Client
A long-standing client makes repeated inappropriate comments to a junior account handler during entertaining. The account is commercially significant. What does the new liability mean here, and what do you do?
- Scenario C: The Teams Channel
Borderline banter has been running on an informal Teams channel for months. No one has complained, but several people have quietly muted it. Where does this sit legally, and what should have happened sooner?
- Scenario D: The Manager Who Handled It Quietly
A line manager deals with a disclosure informally and never escalates it. They believe they've resolved it. What's the actual risk exposure, and what should the organisation have in place to prevent this?
Groups are assigned one scenario each and asked to identify: the legal exposure, the signal that was missed or nearly missed, and what "all reasonable steps" would have looked like in that case.
12:45 - 13:00 Open Forum Q&A & Chair's Closing Summary
The 90-Day Action Plan: a summary checklist of immediate priorities before the statutory deadlines land
A final opportunity for delegates to put questions to the day's speakers
13:00 End of conference
This course is designed for:
- HR Directors and HR Managers
- Employee Relations and ER Case specialists
- In-house legal teams
- DEI and People leads
- Senior managers and line managers with people responsibility
Particularly relevant for organisations with public-facing, client-facing, or remote/hybrid workforces, where the new third-party and digital liability bites hardest.
By the end of the course, delegates will be able to:
- Explain the "all reasonable steps" threshold precisely enough to evidence compliance, not just describe it
- Identify their organisation's direct liability for third parties, remote work and digital conduct
- Apply a data-led audit approach to surface risks that go unreported
- Recognise the early signals a compliant-looking policy typically misses
- Benchmark their own reporting and investigation practice against two real organisational case studies
- Leave with a concrete 90-day action plan rather than a general awareness of the law
What does BFI specialise in?
BFI provides expert-led training in HR compliance, employment law, immigration for employers, union relations, workplace inclusion, and AI and talent solutions.
Who typically attends your courses?
Attendees include HR managers, legal teams, compliance officers, operations leaders, and public sector employers.
Are your trainers practitioners?
Yes. All trainers are experienced specialists; we feature practitioners from the public and private sectors as well as lawyers, policy advisers, former regulators, and consultants.
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Choose an event on the website and click Register. You can pay online with a credit card or request an invoice.
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Yes. Public and private-sector organisations may use PO numbers. These can be added during the registration process, or can be retrospectively added to am invoice if the place has been booked already.
We need to set you up as a Supplier, can you complete a form or send me over your company information?
Yes, we can do either; please contact us via info@bfi.co.uk
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Do you offer group discounts?
Yes. Discounts for multiple bookings are automatically applied at checkout. For groups of over ten, it may be more cost-effective to run the course in-house. Call 01983 861133 for details
Can I transfer my place to another date or colleague?
Yes. Substitutions are free, and transfers are typically allowed within a set timeframe.
What is your cancellation policy?
BFI follows standard UK training-industry cancellation terms.
How are online courses delivered?
Training is delivered live via Zoom with interactive Q\&A and case-based discussion.
Will I receive slides and supporting materials?
Yes. Attendees receive slides, templates (where relevant), and many other useful documents and links.
Will I receive a copy of the event recording?
Our monthly subscription and webinar clients receive recordings of the live sessions; otherwise we do not record our courses to encourage confidential discussion and questions under the Chatham House Rule
What time zone are online events delivered in?
All events are delivered in UTC / London time unless otherwise stated
What is included in in-person events?
Full-day training includes refreshments, full documentation which is emailed prior to the event and networking opportunities.
Are your venues accessible?
Yes. All venues are fully accessible.
Is your training CPD certified?
All our courses are either CPD accredited or CPD eligible, so every certificate of attendance can count towards your CPD requirements. Look out for the CPD badge on each course page to see which applies.
Can I ask questions about my organisation’s situation?
Yes. Trainers answer questions during the session and can respond afterward.
Will the training help us prepare for an audit?
Yes, on our audit courses you will learn what triggers visits, what officers look for, and how to evidence compliance.
Will I receive a certificate?
Yes. All attendees receive a digital certificate of course completion.
Do you offer private or in-house training?
Yes. All courses can be tailored for your team. Visit https://bfi.co.uk/team-training/
Can I ask questions about my organisation's situation?
Yes. Our trainers answer questions live during sessions and can follow up briefly afterwards, but we don't offer ongoing case-by-case advice by email. If you need dedicated support on a specific situation, we offer paid consultancy - contact us to find out more.
Do you offer consultancy?
Yes. BFI offers policy reviews, audit preparation, HR compliance support, and workforce advisory services.