Want to evaluate whether you need to improve your company’s sexual harassment and gender discrimination policies or get recommendations for potential improvements to those policies? A company can spend tens or hundreds of thousands of dollars to engage a large law firm to study the company’s policies and make recommendations for improvement. Alternatively, a company can piggyback on Microsoft’s investment in a publicly released, comprehensive report done by an outside, independent law firm on the effectiveness of its policies and recommendations to improve those policies and practices.
In January 2022, Microsoft retained an outside, independent law firm to review the effectiveness of the company’s sexual harassment and gender discrimination policies. In November 2022, the independent firm provided its final report to the Microsoft Board of Directors. Moreover, Microsoft just released the report to the world. While most companies cannot afford the significant investment Microsoft undertook in the audit of its policies and practices, here are the key takeaways from the report and recommendations that any company can consider implementing in its own policies.
Key Improvements Recommended in the Report
- Have the CEO sign the anti-discrimination and harassment policies
- Revise the anti-harassment and anti-discrimination policies to provide more examples and clarify expectations
- Require disclosure of certain consensual relations where a conflict of interest could develop and define inappropriate relationships
- Adopt a formal procedure to request reconsideration of an investigation’s findings that a party disagrees with
- Advise employees of the right to seek external relief
- Develop an effective tool to track and remind senior leaders that they need to take required training on gender discrimination and sexual harassment issues
- Ask complainants to complete surveys about their investigation experience
- Establish Credible Transparency around Remedial Efforts
- Take steps to minimize a perception that senior leaders are not held accountable
- Coordinate data among the various HR teams and groups that investigate allegations of misconduct
- Make improvements in the investigation process
- Continue efforts to increase the percentage of women in senior leadership positions.
The report is impressive in its thoroughness and comprehensiveness. More impressive is the fact that Microsoft released it publicly.
You can access the final report here.