Skip to main content

Encourage. Support. Act! - Executive summary

Encourage. Support. Act!

Bystander Approaches to Sexual Harassment in the Workplace


Sexual harassment in the workplace is a persistent and pervasive problem in
Australia and elsewhere, demanding new and creative
responses.[1] One significant area
that may inform prevention and response strategies is the area of
‘bystander approaches’. In examining the potential for bystander
approaches to prevent and respond to workplace sexual harassment, this paper
draws upon a range of theoretical and empirical research.

Who are bystanders?

Bystanders are individuals who observe sexual harassment firsthand, or are
subsequently informed of the incident. This definition includes both
‘passive’ bystanders (those who take no action) and
‘active’ bystanders (those who take action to prevent or reduce the

This inclusive definition of bystanders is not limited to people who have
witnessed the event or incident. It also includes those who subsequently hear
about the event.

In the context of sexual harassment, individuals often fail to distinguish
their personal observations from the suggestions of
others.[2] Further, the impact of
sexual harassment can extend from the observers to other co-workers who are not
direct witnesses.[3] For example,
studies have shown that women working in an environment that is hostile to women
and lax about harassment can experience similar negative impacts to those women
who are actual targets of sexual

In the workplace, bystanders can include a range of people. They may include
managers or supervisors, human resource employees, workplace ombudsmen and/or
equity/harassment contact officers to whom sexual harassment is reported.
Reporting can be either formally, where policies and grievance procedures are
implemented, or informally,[5] where
targets seek support or request advice. Co-workers, who are informed of sexual
harassment through the workplace grapevine or targets seeking emotional support
and advice, are also bystanders.

What are bystander approaches?

Bystander approaches focus on the ways in which individuals who are not the
targets of the conduct can intervene in violence, harassment or other
anti-social behaviour in order to prevent and reduce harm to

Bystander approaches have a long history of being used in emergency
situations. Increasingly, they have become part of efforts to prevent
injustices, such as interpersonal violence, cyberbullying and race
discrimination. For example, the Australian Human Rights Commission incorporated
bystander approaches into initiatives aimed at empowering young people to take
safe steps to respond to
cyberbullying.[7] The Victorian Health
Promotion Foundation used bystander approaches to prevent and respond to race
discrimination and violence against women in the
community.[8] A small body of recent
work has also begun to address the potential for bystander interventions in
workplace bullying.

There has been less emphasis, however, on bystander approaches in workplaces
and in relation to sexual harassment specifically. Relative to the extensive
literature that addresses the prevalence of sexual harassment, the way in which
bystander approaches may be utilised to actively prevent or respond to sexual
harassment is still a relatively new area.
One of the reasons that bystander
approaches to sexual harassment in the workplace are under-utilised is because
harassers tend to actively hide their sexually harassing
behaviour.[9] Further, relatively few
targets report their experiences through formal organisational grievance
procedures. Even fewer report the harassment to bodies outside the confines of
the workplace or to a public
hearing.[10] For example, the
Commission’s 2008 Prevalence Study on sexual harassment revealed that
fewer than one in six respondents who reported sexual harassment had formally
reported the incident(s). Predominantly this was because of fear of reprisals
and/or an expectation that the response would be
inadequate.[11] Even when legal
redress is sought, it is rare for direct eyewitness testimony to be
available.[12] Rather than
anticipating the benefit of deterring potential harassers, a fear of bad
publicity also means organisations rarely publicise cases.

suggests that, in some work environments and circumstances, the hidden nature of
sexual harassment can be especially problematic. Deployment in Defence
operations where the focus on the mission overshadows other concerns is one
example.[13] Off-site interactions
with clients or customers where harassers may perceive less accountability, is

Despite these
trends, the evidence of the success of bystander approaches in other areas
suggests that they may also be highly effective in raising awareness of sexual
harassment in the workplace. Accordingly they may also be effective in changing
cultures of tolerance towards sexual harassment and, ultimately, eradicating the

An example of a bystander intervention:

In a large gem mine in remote Australia women were being systematically
subjected to a range of offensive behaviours, predominantly the display of
pornographic pictures. A group of women organised and advertised a series of
women-only meetings, which were held at the mine itself. They formed an
‘Offensive Materials Committee’ to negotiate a broad-based agreement
for the removal of the pin-ups. They also collectively approached their
state’s Equal Opportunity Commissioner who subsequently visited the
mine-site, providing advice about sexual harassment, pin-ups and sex
discrimination. The Equal Opportunity Commission also ensured that programs on
sexism and sexual harassment were

Why are bystander approaches relevant for addressing sexual

A focus on bystander interventions to address sexual harassment in the
workplace is important because targets of sexual harassment often respond
passively to the conduct. They often avoid the harasser, trivialise the
behaviour or deny it altogether.[16] This may be because, although targets want the behaviour to end, they must
balance this objective with avoiding reprisals by the harasser and maintaining
their status and reputation in the work
environment.[17] Therefore,
organisational approaches which rely exclusively on individual complaints made
by targets of harassment are unlikely to be

In this regard, bystanders may provide effective assistance in extending
efforts to eliminate sexual harassment at work. Their support could be enlisted
to intervene during or following an actual event, or to report the behaviour
through organisational channels.

This paper examines a range of existing bystander approaches in other areas
to understand how they could be applied to address sexual harassment in the
workplace. This includes examination of empirical work on sexual harassment,
relevant legal cases and conceptual frameworks explaining bystander
interventions as part of violence prevention.

Sexual harassment may overlap with other destructive workplace behaviours
that may be characterised as gendered mistreatment. Some of the shared features
of these phenomena include hierarchical power relations, a reduction in the
quality of working life and an undermining of equal participation in
employment.[19] Examining the
different forms of gendered mistreatment provides insights into organisational
processes and dynamics that might not be possible with the use of a singular
focus on sexual harassment. These insights are valuable for understanding what
kind of bystander approaches could be effective in workplace settings.

Bystanders’ perceptions of sexual harassment

There is a large body of research that considers the ways in which behaviours
that may constitute sexual harassment are perceived by
bystanders.[20] Research shows that
in general, women are less accepting than men of sexual behaviour at
work.[21] Bystanders are also more
likely to say the sexual harassment has occurred when the target responds
assertively than when they acquiesce or do not communicate to the harasser that
the behaviour is unwelcome. Understanding the different perceptions of sexual
harassment can inform the type of bystander policies and procedures that need to
be developed to address sexual harassment.

There is strong evidence that witnessing or otherwise hearing about sexual
harassment is not only frequent in workplace contexts, but also causes a range
of negative health and occupational outcomes similar to those experienced by the
targets.[22] These impacts have also
been observed in individuals who witness or hear about other catastrophic or
traumatic events in the community more broadly. This phenomenon is known as
‘bystander stress’.

Individually or collectively, bystanders have been found to respond to sexual
harassment in a number of ways. Responses include reporting the problem on
behalf of the target, supporting the target in making a complaint, offering
advice to the target or confronting the harasser. Bystanders may provide social
guidance which can influence whether targets report the problem or make a formal
legal claim.[23] They may initiate a
formal organisational response themselves, intervene during an incident or later
confront the harasser.[24]

What can we learn from bystander approaches in other areas?

A number of explanations have emerged for the motivations and actions of
bystanders. Early studies revealed the notion of ‘bystander apathy’,
which described the behaviours of people who observed an assault or injustice
but who did nothing. Other studies have affirmed that bystanders are influenced
by the behaviour of other

Some classifications of types of bystanders have been based on the type of
actions taken, such as standing by and enjoying the victimisation, avoiding the
behaviours or helping the target. Bystander intervention behaviours have also
been categorised according to dimensions of immediacy (whether the
intervention occurs as the sexual harassment event unfolds, or later) and the level or degree to which bystanders immerse themselves in the

A recent model by Goldberg and colleagues explains the process by which a
workplace observer will respond to a perceived injustice faced by a co-worker.
This model suggests that

  • first, when an observer perceives themselves to be similar to the target of
    the injustice, they will identify with them;
  • second, when the observer identifies with the target, this increases the
    likelihood that an event will be noticed and perceived as an injustice;
  • third, when an injustice is perceived, the decision of an observer to
    respond to or report the injustice will be influenced by the organisational
  • fourth and finally, an observer’s decision about whether to use
    individual or collective strategies will depend on the perceived benefits and
    of these options.[27]

Such equity or justice theories are based on the idea that where an
injustice occurs, people are motivated to behave in ways which restore equity.
However, the extent to which bystanders are motivated to act can vary depending
on various factors. These factors include the characteristics of the bystander,
their relationship with the target, perceptions of the situation and/or conduct
and norms within the workplace. The extent to which bystanders are motivated to
act can also be influenced by the:

  • level of personal threat or benefit to the workplace they perceive (eg male
    bystanders can also feel reluctant to take action for fear of being seen as
    weak, gay and/or unmasculine by their male
  • extent to which they perceive sexual harassment to be either an injustice or
    a socialisation behaviour; or
  • extent to which the workplace supports people’s advocacy or responds
    once a complaint is made. (In workplaces without a credible system in place for
    voicing bystander responses, employees may resort to counterproductive
    behaviours and responses. These include reduced productivity, absenteeism and
    sabotage, which can incur significant costs to the

paper draws on a number of aligned areas to highlight how they may be useful for
developing practical bystander interventions to address sexual harassment in the
workplace. These areas include including whistle blowing, organisational ethics,
workplace bullying and workplace health and safety. For instance, the research
in whistle blowing shows that despite the existence of legislation that allows
for whistle blowing, a greater determinant as to whether or not whistle-blowers
will act is whether they anticipate anything will
change.[30] If there is a perception
that there will be minimal change, then it is less likely that people will
expose the conduct.

There is also a relatively established body of work that addresses bystander
issues in relation to men’s violence towards women. These approaches have
gained increasing traction as a way for men to prevent and respond to violence
and for encouraging non-violent action by men. Their effectiveness is supported
by a growing body of evidence.

The focus in this area of bystander action is on prevention by addressing the
underlying causes of violence. The aim is to reduce its occurrence and,
ultimately, to eliminate it altogether.

Approaches aimed at preventing and responding to violence are often
classified according to when they occur:

  • before the problem occurs (primary prevention);
  • once the problem has begun (secondary prevention); and
  • after the problem, extending into longer term responses (tertiary

Primary prevention strategies focus on the role of bystanders in
challenging the attitudes and norms, behaviours, institutional environments and
power inequalities that underpin acts of the violence against women.

The vast majority of existing violence prevention initiatives on bystander
intervention rely on one or more of three streams of action to effect change:
face-to-face education (eg mentors, buddy systems, public pledges), social
marketing and communications (eg media) and policy and

There is a small but growing body of evidence that demonstrates that
supporting bystander intervention strategies can increase the willingness of
people to take action, their sense of efficacy in doing so and their actual
participation in bystander behaviour.

Legal and organisational challenges for bystander

There are a number of important legal and organisational challenges
associated with the translation of bystander approaches from other areas of
study to workplace sexual harassment. These include vicarious liability,
victimisation and occupational health and safety.

Vicarious liability provisions exist in state and federal anti-discrimination
legislation. Under these provisions, an employer will be liable for the
discriminatory actions of her, his or its employee or agent unless the employer
has taken reasonable steps to prevent the sexual harassment.

The involvement of bystanders, who may include co-workers as well as those in
positions of organisational authority who have had sexual harassment reported to
them, raises important questions about what an employer must do in order to have
taken reasonable steps to prevent sexual harassment from occurring and thus to
avoid liability for the conduct of their employees or agents. The related issues
of victimisation of bystanders and aiding and abetting are also important in
terms of organisational risk.

The way co-workers cooperate within a workplace health and safety framework
to establish and maintain a safe and healthy work environment also plays a role
in mobilising the support of bystanders. While the focus in this area has been
on physical safety, there is increasing recognition of its capacity to also
address psycho-social safety elements such as sexual harassment. Importantly,
such workplace health and safety strategies have been found to be highly
effective.[33] Recent work has also
indicated that the involvement of bystanders in workplace safety can lead to
reshaping the traditional norms, which influence men’s and women’s
behaviour and are associated with sexual harassment and other gendered forms of
mistreatment at work.[34]

Applying bystander approaches to sexual harassment in the

Education about bystander intervention is a potentially invaluable element
for preventing sexual harassment in the workforce. Bystander education can teach
people to interrupt incidents of sexual harassment or the situations which lead
to harassment. It can also teach them to challenge perpetrators and potential
perpetrators, to provide support to potential and actual victims and to speak
out against the social norms and inequalities supportive of sexual harassment.
However, the effectiveness of education is dependent on its integration within a
comprehensive framework of prevention.

Efforts to reduce and prevent workplace sexual harassment will only make real
progress if they adopt the principles and strategies shown to constitute best
practice in violence prevention. Effective interventions have five generic
features, all of which are likely to have relevance for the development of
bystander approaches to sexual harassment:

  1. adopting multiple strategies to address the problem behaviour, in multiple
    settings and at multiple
  2. demonstrating a sound understanding of both the problem – of the
    workings and causes of sexual harassment itself – and of how it can be
  3. invoking educational, communication and other strategies known to create
    change – ensuring they focus on determinants of this behaviour, use
    effective teaching methods and have sufficient duration and intensity to produce
  4. developing bystander interventions that have regard to the context (ie the
    social and structural constraints and the operating beliefs and
    norms);[38] and
  5. involving a comprehensive process of impact evaluation that is integrated
    into program design and

This paper provides a range of bystander strategies that could be
implemented in workplaces to address sexual harassment.

The principles and strategies identified for developing and implementing
bystander approaches to sexual harassment in the workplace include:

Principles informing the strategies
Primary Prevention – training
Secondary Prevention – reporting and
Tertiary Prevention – supporting
Design comprehensive programs, using multiple strategies, settings and
Design training to:

  • increase recognition of sexual harassment
  • include content which addresses different forms of bystander involvement
    and challenge myths of sexual harassment
  • address the links between sexual harassment and other forms of gender
  • define sexual harassment by focusing on the behavior rather than the

Make social responsibility norms evident in the
workplace; acknowledge bystanders can be individuals or respond

Use modeling in training modules to demonstrate how bystanders can

Deliver training to all employees

Respond and investigate complaints in a timely way

Allow employees to participate in the design of complaints procedures

Establish what constitutes sexual harassment in the organisation

Create a workplace environment that allows for reporting sexual

Give management credit for taking action to encourage reporting

Preserve the anonymity of bystanders who disclose

Address the risks of victimisation to the bystander

Implement appropriate penalties for harassment when it occurs

Provide multiple communication channels for bystanders and targets

Acknowledge that some organisational actors are more vulnerable

Support bystanders who may have experienced the negative impacts of sexual

Enlist the support of bystanders to assist targets of sexual harassment in
the longer term

Implement ongoing monitoring and evaluation of bystander strategies

Develop an appropriate theoretical framework
Incorporate educational, communication and other change strategies
Locate bystander approaches in the relevant context
Include impact evaluation in the bystander approach

Overview and conclusion

Research shows that bystander approaches and interventions can be potent
tools in raising awareness of sexual harassment and, ultimately, in eliminating
this costly, damaging and increasingly pervasive problem in workplaces.

Part 1 of the paper examines definitions of sexual harassment. It also
examines how sexual harassment overlaps with other destructive workplace
behaviours which contribute to gender inequality.

Part 2 explores how sexual harassment is perceived by bystanders and the
impacts on their psychological well-being and productivity.

Part 3 considers the motivations and actions of bystanders, drawing on other
areas of research to understand what bystander responses are likely in different
circumstances. These areas of research include whistle blowing, organisational
ethics, workplace health and safety and workplace bullying.

Part 4 outlines existing bystander approaches, particularly as a prevention
strategy for domestic and family violence, sexual violence and other forms of
interpersonal violence.

Part 5 examines the legal and organisational implications of bystander
involvement, referring to issues such as vicarious liability, victimisation and
workplace health and safety.

Part 6 of the paper proposes an overarching framework that is based on the
categorisation of primary, secondary and tertiary prevention in the area of
interpersonal violence and incorporates a number of accepted general principles
of bystander prevention approaches.

The paper concludes by canvassing a range of strategies relevant to workplace
sexual harassment that may be practically employed in workplaces today.

[1] Sexual harassment is understood
as both a specific and legally defined form of sex discrimination and as a
manifestation of gender-based workplace violence and a broader ‘cultural
misogyny’ or hostility towards women. J Gailey and A Prohaska,
‘Knocking off a fat girl: an explanation of hogging, male sexuality and
neutralization’ (2006) 27 Deviant Behavior, pp. 31-49.

[2] S Hekkanen and C McEvoy,
‘False memories and source-monitoring problems: criterion
differences’ (2002) 16 Applied Cognitive Psychology, pp. 73-85.

[3] K Miner-Rubino and L Cortina,
‘Beyond targets: consequences of vicarious exposure to misogyny at
work’ (2007) 92(5) Journal of Applied Psychology, pp.1254-1269; J
Raver and M Gelfand ‘Beyond the individual victim: linking sexual
harassment, team processes and team performance’ (2005) 48 Academy of
Management Journal
, pp. 387-400.

[4] T Glomb, W Tichman, C Hulin, F
Drasgow, K Schneider and L Fitzgerald, ‘Ambient sexual harassment: an
integrated model of antecedents and consequences (1997) 71 Organizational
Behavior & Human Decision Processes,
pp. 309-328; K Miner-Rubino and L
Cortina, ‘Working in a context of hostility toward women: implications for
employees’ well-being’ (2004) 9 Journal of Occupational Health
, pp. 107-122; K Miner-Rubino and L Cortina, ‘Beyond
targets: consequences of vicarious exposure to misogyny at work’ (2007)
92(5) Journal of Applied Psychology, pp.1254-1269.

[5] The distinction between formal
and informal reporting throws up legal and ethical concerns which are addressed
in Part 4 of the paper.

[6] A Powell, Review of
bystander approaches in support of preventing violence against women
Victorian Health Promotion Foundation (2011), p. 8-10.

[7] Australian Human Rights
Commission, Cyberbullying, Human rights and bystanders (2010). At

[8] VicHealth, Review of
bystander approaches in support of preventing race-based discrimination,
Victorian Health Promotion Foundation (2010). VicHealth, More than
ready:Bystander action to prevent violence against women in the Victorian
(2012). At: (viewed 29 May 2012).

[9] G Scott and B Martin,
‘Tactics against sexual harassment: the role of backfire’ (2006)
7(4) Journal of International Women’s Studies, pp. 111-125.

[10] J Firestone and R Harris,
‘Perceptions of effectiveness of responses to sexual harassment in the US
military, 1988 and 1995’ (2003) 10(1) Gender, Work & Organization, pp. 42–64; R Illies, N Hauserman, S Schwochau and J Stibal,
‘Reported incidence rates of work-related sexual harassment in the United
States: using meta-analysis to explain reported rate disparities’ (2003)
56(3) Personnel Psychology, pp. 607-618; D Wear, J Aultman and N Borgers,
‘Retheorising sexual harassment in medical education: women
students’ perceptions at five US medical schools’ (2007) 19(1) Teaching and Learning in Medicine, pp. 20–29.

[11] Australian Human Rights
Commission (2008). Sexual Harassment: Serious Business. Results of the 2008
Sexual Harassment National Telephone Survey

[12] P McDonald, T Graham and B
Martin, ‘Outrage management in cases of sexual harassment as revealed in
judicial decisions’ (2010) 34(2) Psychology of Women Quarterly, pp.165-180.

[13] United States Department of
Defense, Report of the Defense Task Force on Sexual Assault in the Military
(2009), Alexandra, VA: Defense Task Force. Available at (viewed 7 June 2012).

[14] H Gettman and M Gelfand,
‘When the customer shouldn’t be kind: antecedents and consequences
of sexual harassment by clients and customers’ (2007) 92(3) Journal of
Applied Psychology
, pp. 757-770.

[15] J Eveline and M Booth,
‘Gender and sexuality in discourse of managerial control: the case of
women miners’ (2002) 9(5) Gender, Work & Organization, pp.

[16] L Bowes-Sperry L and A
O’Leary-Kelly, ‘To act or not to act: the dilemma faced by sexual
harassment observers’ (2005) 30 Academy of Management Review, pp.

[17] B Gutek, Sex and the
(1985); B Ragins and T Scandura, ‘Antecedents and
work–related correlates of reported sexual harassment: an empirical
investigation of competing hypotheses’ (1995) 32(7/8) Sex Roles, pp. 429–455; A O’Leary-Kelly, R Paetzold and R Griffin,
‘Sexual harassment as aggressive behavior: an actor based
perspective’ (2000) 25 Academy of Management Review, pp.

[18] C Benavides-Espinoza and G
Cunningham, ‘Bystanders’ reactions to sexual harassment’
(2010) 63 Sex Roles: A Journal of Research, pp. 201-213.

[19] S Fredman, Women and the
(1997); D McCann, Sexual Harassment at Work: National and
International Responses
(2005); P McDonald, ‘Workplace sexual
harassment 30 years on: a review of the literature’ (2011, in press) International Journal of Management Reviews; P Popovich and M Warren,
‘The role of power in sexual harassment as a counterproductive behavior in
organizations’ (2010) 20 Human Resource Management Review, pp.

[20] The vast majority of this
research is grounded in psychological theory and uses vignette-type studies
where respondents are presented with written or verbal scenarios and stories
describing sexual harassment and are asked for their perceptions. This body of
work is also heavily reliant on the use of American undergraduate college
student as samples.

[21] J Berdahl and C Moore,
‘Workplace harassment: double jeopardy for minority women’ (2006)
91(2) Journal of Applied Psychology, pp. 426–436; C Gallivan, C
Nelson, J Halpert and D Cellar, ‘Organizational responses for preventing
and stopping sexual harassment: effective deterrents or continued
endurance?’ (2007) 56(11/12) Sex Roles, pp. 811–822; M
McCabe M and L Hardman, ‘Attitudes and perceptions of workers to sexual
harassment’ (2005) 145(6) The Journal of Social Psychology, pp.
719–740; L Reese and K Lindenberg, Implementing sexual harassment
policy: Challenges for the public sector workplace
(1999); C Tang, M Yik, F
Cheung, P Choi and K Au, ‘How do Chinese college students define sexual
harassment?’ (1995) 10(4) Journal of Interpersonal Violence,
pp. 503–515.

[22] K Schneider,
Bystander Stress: Effects of Sexual Harassment on Victims’
. Paper presented at the 104th Annual Convention
of the American Psychological Association, Toronto, Ontario, Canada, August 9-13
(1996); K Miner-Rubino and L Cortina, ‘Beyond targets: consequences of
vicarious exposure to misogyny at work’ (2007) 92(5) Journal of Applied
, pp.1254-1269.

[23] B Goldman, ‘Toward an
understanding of employment discrimination claiming: an integration of
organizational justice and social information processing theories’ (2001)
54 Personnel Psychology, pp. 361-386.

[24] L Bowes-Sperry and A
O’Leary-Kelly, ‘To act or not to act: the dilemma faced by sexual
harassment observers’ (2005) 30 Academy of Management Review, pp.

[25] K Van Heugten,
‘Theorizing active bystanders as change agents in workplace bullying of
social workers’ (2011) 92(2) Families in Society: The Journal of
Contemporary Social Services
, pp. 219-224.

[26] L Bowes-Sperry and A
O’Leary-Kelly, ‘To act or not to act: the dilemma faced by sexual
harassment observers’ (2005) 30 Academy of Management Review, pp.

[27] C Goldberg, M Clark and A
Henley, ‘Speaking up: a conceptual model of voice responses following the
unfair treatment of others in non-union settings’ (2011) 50(1) Human
Resource Management
, pp. 75-94.

[28] M Carlson, ‘I’d
rather go along and be considered a man: masculinity and bystander
intervention’ (2008) 16(1) Journal of Men’s Studies, pp.

[29] M Ambrose, M Seabright and M
Schminke, ‘Sabotage in the workplace: The role of organizational
injustice’, (2002) 89(1) Organizational Behavior and Human Decision
pp. 947-965; E De Boer, A Bakker, J Syroit and W
Schaufeli, ‘Unfairness at work as a predictor of absenteeism’ (2002)
23(2) Journal of Organizational Behavior, pp. 181-197; B Klaas,
‘Determinants of grievance activity and the grievance system’s
impact on employee behavior: an integrative perspective’ (1989) 14(3) Academy of Management Review, pp. 445-458; R Moorman, B Niehoff and D
Organ, ‘Treating employees fairly and organizational citizenship behavior:
sorting the effects of job satisfaction, organizational commitment and
procedural justice’ (1993) 6(3) Employee Responsibilities and Rights
, pp. 209-225.

[30] J Near, T Morehead Dworkin
and M Miceli, ‘Explaining the whistle-blowing process: suggestions from
power theory and justice theory’ (1993) 4(3) Organization Science,
pp. 393-411; A Trimmer, ‘Whistleblowing: what it is and what it might mean
for incorporated legal practices’ (2004) February Law Society
, p. 69.

[31] This summary combines and
modifies the accounts given by the CDC (2004: 3) and Chamberlain (2008: 3).

[32] M Flood, ‘Involving
men in efforts to end violence against women’ (2011) 14(3) Men and

[33] T MacDermott, ‘The
duty to provide a harassment-free work environment’ (1995) 37(4) Journal of Industrial Relations, pp. 495-523.

[34] R Ely and D Meyerson,
‘An organizational approach to undoing gender: The unlikey case of
offshore oil platforms’ (2010) 30 Research in Organizational
, pp., 3-34.

[35] E Casey and T Lindhorst,
‘Toward a multi-level, ecological approach to the primary prevention of
sexual assault: prevention in peer and community contexts’ (2009) 10(2) Trauma, Violence & Abuse, pp. 91-114; M Nation, C Crusto, A
Wandersman, K Kumpfer, D Seybolt, E Morrissey-Kane and K Davino, ‘What
works in prevention: principles of effective prevention programs’ (2003)
58(6/7) American Psychologist, pp. 449-56.

[36] M Flood, L Fergus and M
Heenan, Respectful Relationships Education: Violence prevention and
respectful relationships education in Victorian secondary schools,
Department of Education and Early Childhood Development, State of Victoria,
(2009), pp. 33-35.

[37] M Flood, L Fergus and M
Heenan, Respectful Relationships Education: Violence prevention and
respectful relationships education in Victorian secondary schools,
Department of Education and Early Childhood Development, State of Victoria,
(2009), pp. 35-54.

[38] E Casey and T Lindhorst,
‘Toward a multi-level, ecological approach to the primary prevention of
sexual assault: prevention in peer and community contexts’ (2009) 10(2) Trauma, Violence & Abuse, pp. 91-114; M Flood, L Fergus and M Heenan, Respectful Relationships Education: Violence prevention and respectful
relationships education in Victorian secondary schools,
Department of
Education and Early Childhood Development, State of Victoria, (2009), pp.

[39] M Flood, L Fergus and M
Heenan, Respectful Relationships Education: Violence prevention and
respectful relationships education in Victorian secondary schools,
Department of Education and Early Childhood Development, State of Victoria,
(2009), pp. 57-58.