1. Identify your workplace risks and sexual harassment history including potential sexual harassment problems
looming in the horizon. Do not limit your analysis to potential sexual harassment problems, but include inappropriate sexual and gender conduct, and
other forms of harassment, including racial, national origin, religion, disability, etc. Also include what employees,
not only are at risk in your organization.

2. Identify your budget constraints. Decide how im-
portant it is to provide a quality training program given the risks identified in the above analysis. This decision may prove pivotal to either winning or losing a potential lawsuit. If you find you have a high
potential risk, then you must find a way to fund a high quality training program and training expert.

3. Review the content used during prior sexual harassment prevention training programs.

4. If the prior training content is exactly what the new law requires (specific content required by AB 1825 training included) then you need not train the same supervisors you trained during 2003 and 2004
until 2006. You will only have to provide training to newly hired or promoted supervisors

5. Identify how many employees fit The Fair Em-
ployment and Housing Act’s (FEHA) definition of a
supervisory employee*. Include newly promoted
supervisors or those whose responsibilities change to
include supervisory duties in your training schedule.

6. Identify how much time you have left to schedule
and deliver the training before the end of 2005. Consider your training options and your consultant’s availability.

7. Define the training cohorts. You may want to provide a combination of the following:
• Executive suite training
• Supervisory training by rank or department
• General employee training

8. Decide if you want to offer live training or online-training or combination of both depending

on the cohort as shown above.If you choose an expert trainer consider documenting what makes this It specifically requires the training must be presented by trainers or educators with "knowledge and expertise" in the preven-
tion of harassment, discrimination, and retaliation.
For instance, is the person experienced with performing sexual harassment investigations in the
requirement mandated by AB 1825.

9. Identify the scope of the training. For instance, define topics and the timing allocated to the training. The law requires a minimum two hours of sexual
harassment training covering specific topics. By lengthening the training program by one half an hour you can add harassment the subject of prevention based on the other categories protected under federal and state law (for instance, race, age, and disability). If you extend the training to these topics you will
create a stronger defense against liability or damages
in case of future litigation.

10. Devise a training schedule. You must consider that you need to train eligible supervisors by the end
of 2005 and every two years thereafter.

11. Create a record that proves which supervisors took the training program by having sign-in sheets and by asking your consultant to provide Certificates of Attendance to your trainees.

12. Maintain good records of the participants who complete the training. You may be able to diligently train all your supervisors with the required content in a timely manner, but if you cannot produce the
physical evidence to establish that the training took place you may lose your case in court. Corporate records constitute credible evidence. So, you may wonder: what is your obligation if you have fewer than 50 employees in your organization? Even though employers with fewer than 50 employees (or contractors) are not required to comply with
AB 1825, when you are faced with a claim of sexual harassment in your workplace, everybody is potentially affected, both supervisors and employees alike. Your pocketbook is likely to suffer the most. Either you pay lawyers for legal assistance, pay the victim a settlement or you pay a judgment to the
victim if you lose your case in court.