Sally Strither is the HR director at SouthParkHospital in Fort Smith, Texas, the only hospital in Fort Smith. The closest city is Austin, which is about 100 miles away. You are the new compliance officer for the hospital. Sally asked to meet with you because of the ongoing claims of sexual harassment made by the nursing staff against some of the physicians and residents. Although several complaints have been made to the HR department over the past few years, no lawsuits have been filed yet.

Sally indicated to you that it is really just a matter of time before a lawsuit is filed. The main reason why this has not already occurred is that the nurses are fearful of losing their jobs and there really are not a lot of alternative employment opportunities for nurses in Fort Smith. It is inevitable; however, that a nurse who has been harassed and finds work in another city will not be so reticent about filing a suit.

You are shocked to hear this and are a little concerned about the competence and independence of the HR department as well. You immediately call the CEO and discuss the matter. The CEO is surprisingly noncommittal, but he does suggest that you draft a policy addressing what "proactive" measures can be taken to minimize the risk of a sexual harassment suit. You are surprised again at the lack of outrage or concern by the CEO. You begin to suspect that the physicians really run the hospital; nevertheless, you feel it is your obligation to establish policies to reduce the likelihood of a lawsuit (before you start your employment search in Austin).

Draft a policy that describes at least six (6) proactive measures that the hospital can take to reduce the likelihood of a lawsuit. Include a legal argument and defense(with case citation) in support of this policy that may help convince the CEO that these measures are necessary.