Harassment Prevention Training Program

Most organizations periodically train their personnel to recognize, avoid and report workplace discrimination, including harassment. To ensure that CPB-supported public media stations consistently follow this practice, beginning March 31, 2018, CPB is requiring annual harassment prevention training for all officers, employees and interns of each station as a condition of the grantee’s eligibility for a radio or television Community Service Grant (CSG). Grantees may satisfy this requirement through either of the following training options:

An interactive online harassment prevention training service from NAVEX Global, available free of charge through CPB, that instructs your personnel, individually on the following topics:
- What constitutes acceptable and unacceptable workplace behavior;
- How to recognize harassment when it occurs; and
- How to report and respond to violations.

A comparable harassment prevention training program of your choice. The program will be considered “comparable” if it instructs your personnel individually, either in person or online, on the three topics (listed above) that are included in the CPB-provided training service.

If you elect to use the Navex Global service provided by CPB, then each station must register for licenses to train its personnel using this Online Form. When we receive the completed form, CPB will send your station contact person the NAVEX Global login and system usage instructions. When your personnel complete the training program, the system will provide a record of those who were trained to demonstrate compliance. If you use a different training program, you must keep records of all personnel who were trained each year to demonstrate compliance.

Grantees must certify their compliance with this new requirement in the next CSG Agreement and Certification of Eligibility which you will receive in early November. This means that you must complete this year’s training no later than October 1, 2018 so your station can certify compliance in the FY 2019 CSG Agreement.

We know you share our commitment to maintaining a work environment that is free from all forms of discrimination and harassment. CPB appreciates your cooperation with the measures we are taking to enforce that commitment. For additional information, please see the FAQ below. If you still have questions, please contact us.

Frequently Asked Questions

Who must take the Harassment Prevention Training?

All officers, employees and interns of each grantee.

Will each participant need a login to access CPB’s online interactive training service?

Yes. For the Navex Global training, each person will need a login. CPB will provide information about logins under separate cover.

Who should I designate as my station’s contact on the Online Form?

The station contact person should be responsible for ensuring that all personnel are trained annually, such as your HR professional. If you don’t have an HR professional at your station, another option is your CPB ISIS Grants Administrator.

What is meant by "grantee's officers?"

Officers include executives and senior staff of your station. This includes titles such as President/CEO, General Manager, Chief Operating Officer, Chief Financial Officer and Vice Presidents.

Are my University administrators required to take the training?

People who do not work directly for the station are not subject to this CSG requirement. Examples include: University administrators; Board of Regents members; Community Licensee Board members; School Board members; and members of your Community Advisory Board (CAB).

What if all the people on my staff haven’t taken the training by October 1, 2018?

Your station will not be able to certify compliance in your FY 2019 CSG Agreement and Certification of Eligibility until all officers, employees and interns have taken the CPB or comparable training program.

Will every intern, including those who may only be in the station for a few weeks or months, be required to take the training?

Yes. All interns employed by the station are required to take the training. We encourage stations to provide harassment prevention training as part of your orientation protocol.

My station uses a lot of students, but they aren’t interns. Some are paid an hourly wage by the station and some are paid through Work-Study. Do students who aren’t “interns” have to take the training?

Yes.

My University makes harassment prevention training available on a voluntary basis. Will that suffice?

No. If you are going to use comparable training, the training must be taken by your grantee’s officers, employees and interns and you must keep records of all personnel who complete the training.

I am wondering how grantees will be expected to track this requirement? It covers literally every employee and intern – in our case, this will be over 200 people some of whom come and go throughout the year.

The CPB-provided training service from NAVEX Global automatically tracks use of the program so your station will know who has taken and completed the training. Stations that use alternative comparable training programs must maintain adequate documentation of compliance.

My University is requiring all faculty and staff but not students and interns to take training. Does that count?

If University faculty and staff work as officers or employees of the station, and if the training program is comparable to CPB’s, it will count for those station personnel. Others, such as interns not included in the University’s requirement, must complete the CPB or comparable training program.

How do you define employee? Are volunteers who work on-air considered employees? What about volunteers who come to my station to answer phones for pledge or work putting together our annual on-air auction?

Employees are defined as those paid a salary or hourly wage and who regularly work at your station, whether full- or part-time.

My state requires harassment prevention training every two years. Will all CSG grantees in my state have to certify annually?

Yes. CPB requires all CSG grantees to certify annually that their officers, employees, and interns have taken harassment prevention training in the past year.

Each person on our staff has already taken Harassment Prevention Training from a vendor during our FY 2018, will this count for CPB’s FY 2019?

Yes, if it is comparable to the CPB training.

How do I know if the training that my station employees have taken is the equivalent of the CPB-provided training? Also, will CPB review and approve comparable Harassment Prevention Training programs?

To be comparable to the CPB-provided training, the training for your grantee’s officers, employees and interns must cover the following topics:

What constitutes acceptable and unacceptable workplace behavior;
How to recognize harassment when it occurs; and
How to report and respond to violations.

CPB will not evaluate alternative training programs. Station management will need to decide if the training you provide is comparable.

Will the CPB-provided training cover sexual harassment only, or other kinds of workplace harassment and bullying?

The training will address all forms of harassment.

Is the harassment prevention training requirement in lieu of the requirement that at least one person on our staff must annually complete at least one CPB-sponsored compliance training?

No. This training requirement is in addition to your annual CSG compliance training requirement.

For State University Licensees who do Title IX training already, what will we need to do to verify that our training meets all requirements (if we use our current training, rather than the option CPB is offering)?

You must determine whether the Title IX training is comparable to the CPB-provided training, as explained above.