Are You in Compliance With the Training and Notice Requirements Imposed by the Time’s Up Act?

Last June, Governor Lamont signed into law the “Time’s Up Act” (P.A. 19-16), which significantly expanded sexual harassment training and notice requirements for employers in Connecticut.  See our previous blog posts – here and here – for more detailed information about the Time’s Up Act.

While most of the provisions of the Time’s Up Act go into effect on October 1, 2020, there are a number of critical provisions that already went into effect on October 1, 2019:

Employers with three or more employees are required to provide to each  new employee a copy of information regarding the illegality of sexual harassment and remedies available to victims. Specifically, employers must provide this information to each employee by email, with a subject line that includes the words “Sexual Harassment Policy” (or words of similar import).   Employers must email this information to the employee, assuming that either (i) the employer has provided the employee an email account, or (ii) the employee has provided the employer with his or her personal email address.  If the employer has not provided all employees an email account, the employer must post the information concerning the illegality of sexual harassment and remedies available to victims of sexual harassment on the employer’s Internet web site, if the employer has one.  Alternatively, the employer could choose to provide its employees the information by email, text message, or in writing with the link to the page of the Connecticut Commission on Human Rights and Opportunities website that describes the illegality of sexual harassment and the remedies available to victims of sexual harassment.

Employers of three or more employees must provide two hours of training and education concerning sexual harassment to all employees by October 1, 2020, and to all new employees hired on or after October 1, 2019 within six months of their start date.  Accordingly, if you have at least three employees and you hired an employee on or after October 1, 2019, the clock is running for you to provide that employee with the requisite two hours of sexual harassment training, and must do so within six months of that employee’s start date.  Employers with fewer than three employees must provide the training to new supervisory employees within six months of their start date, and to existing supervisory employees by October 1, 2020.  All employers are also required to post notices concerning the illegality of sexual harassment and the remedies available to victims.

Has your company complied with these provisions?  If not, you should do so promptly to avoid the risk of being fined.   Pullman & Comley’s Labor & Employment practice group can assist you with compliance with the Time’s Up Act.

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