'Hear no evil, see no evil' is a manager's worst possible anti-harassment strategy.

Make sure your supervisors know that they have a direct obligation--both legally and for company policy reasons--to pass along to HR any complaints of harassing or discriminatory behavior that they hear about from their employees.

As the EEOC recently said, "Employers must understand that even lower-level managers have a duty to report and stop sexual harassment when they become aware of it ... Companies should bear this in mind when they select and train management candidates."

Recent case: A female employee at a home improvement store received pornographic video clips and photos via text message from the male manager of the hardware department. She showed some of the messages to a co-worker, who reported the texts to the store manager.

The store manager, however, chose neither to investigate the issue nor discipline the manager. The texts continued.

About a year later, a different employee complained about the same harassing behavior to the store manager. The manager again did nothing. But this time, the worker took the complaint up another level in the org chart. This time, the hardware department manager was investigated and terminated.

After failing to mediate a resolution, the EEOC sued the store for allowing the sexual harassment to continue. The store eventually settled the case, agreeing to pay the employee $25,000. The store must also agree to do live anti-harassment training for managers. (EEOC v. Menards, ED MI)

5-part plan to prevent & address sexual harassment

1. Create a policy prohibiting sexual harassment of any kind. Write your policy broadly, in gender-neutral terms, so it applies to everyone, regardless of the sex of the alleged harasser and the victim. Communicate the policy to all employees.

2. Establish complaint procedures. Provide the names and...