3 FAM 1520: Anti-Harassment Program

The Department of State revised its sexual harassment policy, 3 FAM 1520, to separate internal investigations of sexual harassment under its Anti-Harassment Policy (AHP) and Equal Employment Opportunity (EEO) investigations in response to an EEO complaint. The policy clarifies that reporting harassment in an AHP investigation does not initiate the EEO process and that individuals who have initiated the EEO process are still required to participate in internal AHP investigations. The AHP policy also lowers the evidentiary bar for discipline and provides leadership with significant latitude to investigate employees for behavior that “may not meet the definition of harassment as stated in this policy but may become harassment if left unaddressed,” including issues of “professionalism” or “civility.” It also expands the category of supervisors who are strictly mandated to report any allegation of harassment or retaliation to include all “responsible department officials.”