As previously outlined in our Illinois employment law roundup, the deadline is fast approaching for completion of Chicago's additional sexual harassment and bystander training requirements. The new law requires employers to provide all Chicago employees with one hour of sexual harassment and bystander training and all managers of Chicago employees with an additional hour of sexual harassment prevention training. Completion of the training requirements under the Illinois Model Sexual Harassment Training Program does not fulfill the bystander training requirement nor the additional hour of training required of management-level personnel under the ordinance. Chicago has provided sample training materials for covered employers to consult in order to meet the additional training standards.
Recent guidance from the Chicago Commission on Human Relations (CCHR) has clarified what constitutes a covered employer under the ordinance. Previously, there had been some confusion as to whether employers without facilities in Chicago but with one or more remote employees located in the city must comply with the new requirements. An FAQ provided by CCHR has settled the issue, stating that "[t]he training requirement applies for all employees who work in Chicago, even if remote, and their managers or supervisors, even if the managers or supervisors work outside of Chicago." Employers should carefully review the locations of their employees and who oversees them, ensuring that all covered individuals receive the trainings on or before June 30, 2023.
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