It’s the Monday after the Christmas party. Your office manager asks for ten minutes. Someone said something to a junior colleague on the dance floor, then followed it up with a message at midnight. The junior colleague hasn’t complained, but they’ve told a friend, and the friend has told your office manager.
You now know. And once you know, the clock is running.
What changed on 30 October
Employers already had a duty to take “reasonable steps” to prevent sexual harassment of their staff. Since 30 October 2026, that has become a duty to take “all reasonable steps”. It sounds like a small edit. In practice it raises the bar considerably, because “reasonable” no longer means you did a bit. It means you looked at the risk and did what a sensible employer could do.
The same package also makes employers liable for harassment of their staff by third parties. Customers, clients, suppliers, guests. If your team is hosting clients at a festive event, that’s directly relevant.
Does this really reach the Christmas party?
Yes. Employers can be responsible for what happens at work-related social events, including those held off site and outside normal hours. Tribunals have a long history of treating the office party as an extension of the workplace, particularly where the event is organised, paid for or encouraged by the employer.
Alcohol makes this worse, not because people are monsters but because judgement slips and hierarchy doesn’t. A senior leader’s “joke” at 11pm lands very differently from a peer’s.
What “all reasonable steps” looks like in practice
You don’t need a legal document the length of a novel. You need evidence that you thought about it and acted.
Start with the basics: a clear, up-to-date anti-harassment policy that people have actually seen, and a short reminder before the event that normal standards of conduct apply. A two-line message from the MD does more than a policy buried on the intranet.
Think about the event itself. Who is responsible for the room? Is there a named person staff can go to if something goes wrong? Is there a sensible plan for getting people home safely? Is the bar tab unlimited?
Think about who else is there. If clients or suppliers are attending, make sure your staff know what to do if a guest behaves badly, and that managers know they are expected to step in rather than laugh it off.
Train your managers. The most important step is often the least glamorous: make sure line managers know what to do if someone raises a concern, including informal comments like the one your office manager just heard.
What to do if it goes wrong
If a concern surfaces after the event, don’t wait for a formal complaint. Speak to the person affected, check what support they want, and consider whether you need to start an investigation. Keep notes of what you did and when. An employer who acts promptly and fairly is in a far stronger position than one who hoped it would go away.
Where an allegation involves someone senior, or where relationships are tangled, an independent investigator is often the cleanest route. It protects the person who raised the concern, the person accused, and the organisation.
Where we come in
King HR Advisory supports employers in Sheffield, South Yorkshire and across the UK with harassment policies, manager briefings and independent workplace investigations. If you’d like a quick review before your party, or you’re dealing with something after one, book a discovery call and we’ll work out the sensible next step.