ATTENTION EMPLOYERS
IMPORTANT UPDATE TO NYC SEXUAL HARASSMENT TRAINING REQUIREMENTS FOR ALL EMPLOYERS
As NFC previously reported, last year New York City enacted the “Stop Sexual Harassment in NYC Act” (the “Act”), which requires employers, among other things, to provide annual training on the protections against gender-based harassment. Recently, the New York City Commission on Human Rights (the “NYCCHR”) further revised its updated answers to Frequently Asked Questions about the training obligations under the Act.

Important points from the newly revised FAQs include:

  • Regardless of whether the employer or the employee is based in New York City, employers with 15 or more employees must train all employees who work or will work in New York City for more than 80 hours in a calendar year AND for at least 90 days. In addition, employers should train all employees who “regularly” interact with other employees in New York City, even if they are not physically present in the City. While there is no formal guidance on what “regularly” interact means, the NYCCHR has informally told NFC that the intent is to go beyond mere electronic communications to more significant interactions with NYC (for example, where an employee outside of NYC who regularly visits a NYC office, runs a project based in NYC, or leads a team based in NYC).

  • Employers are not required to train independent contractors. However, the NYCCHR “strongly advised” that independent contractors be trained if they are working on-site and interacting with employees, and are anticipated to work more than 80 hours in a calendar year and for at least 90 days in New York City.

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To assist employers in navigating the training requirements, which must be  interactive  and  legally complaint , NFC is offering instructor led training, provided by NFC's highly knowledgeable employment attorneys. Each training is customized to your organization and scheduled at your convenience.
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This publication/newsletter is for informational purposes only and does not contain or convey legal advice regarding any specific situation. This material may also be considered attorney advertising under court rules of certain jurisdictions.