Ms. Smith's supervisor subjected her to a barrage of threats and gender-based insults while she was under his supervision. This is a direct quote from the old EEOC guidelines, and is identical to the language of most companies' harassment policies. The employer's policy did not mention discrimination on the basis of gender, as required by the new EEOC guidelines. The court recognized that a woman's work environment can be hostile even if she isn't subjected to sexual advances or propositions. For a Harassment Policy that meets the new requirements, go here .
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