In today's global workplace, managing sexual harassment complaints is no longer a matter confined to a single jurisdiction. As companies expand across borders...

Worldwide Employment and HR

Matthew Banham Your Author LinkedIn Connections

In today's global workplace, managing sexual harassment complaints is no longer a matter confined to a single jurisdiction. As companies expand across borders, their legal obligations become increasingly complex. A recent Seyfarth Shaw webinar brought together employment law experts from the US, UK, France, Spain, Italy, and Latin America to explore the challenges of conducting cross-border investigations into sexual harassment.

The key takeaway? There is no universal playbook. Each jurisdiction brings its own legal framework, cultural expectations, and procedural nuances. For multinational employers, understanding these differences is not just helpful—it's essential to managing risk and ensuring fairness.

A Patchwork of Legal Duties and Definitions

Across jurisdictions, the legal duty to prevent harassment varies significantly. The UK has recently introduced a positive duty on employers to prevent sexual harassment, requiring proactive risk assessments and preventative measures, much like health and safety obligations. This marks a move from reactive compliance to active prevention.

In Italy, Mexico, and Brazil, the obligation is framed within broader duties to take all necessary measures to protect employee health and safety. France...

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