Employers may be liable for sexual harassment under the FARAGHER case when the employer has not taken affirmative steps to deter harassment or failed to have a structure in place to enforce sexual harassment policies, such as a system for deterring and reporting sexual harassment.

Assume you are a manager at cleaning inc. (as in the theory to practice problem) and you receive the following e-mail from the company's vice president of operation: i just read an article about a company that was sued under the sexual harassment law. i know we have a good policy, but we need a system in place for claims and compliance. Draft a two-to three page memorandum that outlines how to implement a system that will

1) Help deter sexual harassment,

2) Ensure that our policy is well known by the employees, and

(3) Provide a procedure for initiating and investigating complaints.