When did your team last complete sexual harassment training? If the honest answer is “a while ago” or “I’d have to check”, you’re not alone. But that gap could be what leaves your people unprotected and your business exposed.
Too many organisations treat training as a box to tick. Run it once, file the certificates, move on. Two cases show exactly why that falls short and why we must keep on top of how our teams operate and the knowledge throughout the team.
The timing matters too. Since October 2024, employers have had a legal duty to take reasonable steps to prevent sexual harassment. From 30 October 2026, that rises to “all reasonable steps”. Meaning employers must ensure that all reasonable steps to prevent sexual harassment from the 30th of October is paramount within a business, these changes significantly raise employer duties compared with the previous reasonable steps standard. Tribunals won’t just ask whether you trained your staff. They’ll ask whether it worked.
What happened?
In December 2022, a woman staying alone at a Travelodge in Maidenhead woke to find a man sexually assaulting her in her bed. He had told reception he was her boyfriend, and staff handed him a key card. He was jailed for seven and a half years in January 2026.
The receptionist had received no training on key security. An independent review by Paul Greaney KC, published on 1 October 2026, found the policy was “seriously inadequate” and that staff were expected to learn on the job.
Here’s the part every employer should pause on. Since the assault became public, Travelodge has put all 12,000 guest-facing staff through new e-learning. Yet when testers visited five of it’s hotels, they got into a room at every single one. The review warned that e-learning has real limits unless managers check it has actually been understood.
The woman, called “Lily” in the review, was a guest rather than an employee, so this our usual employment case we like to highlight and discuss, but the rule remains as important for a business. It shows what tick-box training looks like in practice: everyone trained on paper, and the risk still there.
What claims were brought and the tribunal’s decision
Employment tribunals take the same view, and Allay (UK) Ltd v Gehlen is a clear example.
The Claimant, a senior data analyst, was regularly subjected to racist comments by a colleague, including being told he should go and work in a corner shop. Other staff, including managers, heard the remarks or were told about them and did nothing.
He brought claims of direct race discrimination and harassment related to race. The tribunal dismissed the direct discrimination claim but upheld the harassment claim.
The Company argued it had taken “all reasonable steps” to prevent harassment, so it shouldn’t be held responsible. It had policies. It had trained its staff, including the colleague who made the comments. On paper, it had done the right things.
The tribunal disagreed. The training had been delivered years earlier and was “clearly stale”. Staff had been told what to do if they heard unacceptable remarks, and none of them did it. That showed the training hadn’t stuck, and refreshing it would have been a reasonable step.
The Employment Appeal Tribunal (EAT) upheld the decision in 2021. It confirmed that tribunals can look at how effective training is likely to be, not just whether it happened.
What was the value, and why?
The tribunal awarded £6,000 for injury to feelings, at the top of the lowest band in the guidelines tribunals use for hurt feelings (known as the Vento bands). It cut this by 25% to £4,500 because the Claimant hadn’t raised a grievance at work. With interest, the total was £5,030.63.
That figure might look small. But the Company still lost its defence, spent time and money fighting the case all the way to appeal, and became a case other employers now learn from.
The stakes are higher today. Where a sexual harassment claim succeeds and the employer hasn’t met its preventative duty, a tribunal can increase compensation by up to 25%. Stale training is exactly the kind of gap that could trigger it.
Top 5 lessons for employers
- Treat training as ongoing, not one-off. Training your team completed years ago may not count as a reasonable step. Build regular refreshers into your calendar, and update content when the law changes, as it does again on 30 October 2026.
- Check it has landed. A completion certificate shows someone clicked through. It doesn’t show they understood. Follow up with team discussions, manager check-ins and real-life scenarios.
- Make it relevant to your workplace. Generic modules miss your real risks. Start with a sexual harassment risk assessment covering things like lone working, client-facing roles and work socials. In AB v Grafters Group Ltd, the EAT reminded tribunals that harassment away from the workplace can still be connected to work.
- Train people to act, not just to know. In Allay, staff knew the rules and still stayed silent. Give managers and colleagues the confidence to step in and report.
- Keep records. Be ready to show what training you delivered, when, why and how you checked it worked. Our blog on what’s changing and what employers need to do now explains what tribunals are likely to ask.
How can Thrive Law help?
We help organisations move from tick-box training to genuine prevention. Our team carries out sexual harassment risk assessments and policy reviews, and delivers bespoke, interactive training for managers and all staff, built around your workplace rather than an off-the-shelf module. Our Train the Trainer programme helps your own leaders keep training fresh between sessions, so it never goes stale.
Final thoughts and conclusion
Travelodge had a policy. Allay had trained its staff. In both cases, it wasn’t enough.
Training only protects people if it’s current, relevant and changes what actually happens on a busy shift or in a team meeting. With the bar rising on 30 October 2026, ask yourself honestly: when did your team last update their training, and would it stand up to scrutiny today?
Calls to action and references
Not sure your training would pass the test? We can review it with you. Email enquiries@thrivelaw.co.uk, call 0113 869 8101 or get in touch online. For more practical insight, watch Jodie Hill on YouTube.
More from Thrive Law
- Preventative Duty: One Year On
- Understanding the Worker Protection Act 2023: key questions answered
- Sexual harassment at the Christmas party
References
- Gehlen v Allay (UK) Ltd, Employment Tribunal judgment (2500144/2018)
- Allay (UK) Ltd v Gehlen, EAT judgment (UKEAT/0031/20/AT)
- AB v Grafters Group Ltd [2025] EAT 126
- Travelodge independent review by Paul Greaney KC
- The Independent: Travelodge treated woman who was sexually assaulted at hotel “disgracefully”, report finds
- Security Management (ASIS): UK independent review finds progress, but still problems, in Travelodge security
- Maidenhead Advertiser: Man jailed for sexually assaulting sleeping woman in Maidenhead hotel room
