Draft Sexual Harassment Manual


1.0     Preamble

Africa Centre of Excellence for Innovative and Transformative STEM Education (ACEITSE) as an Academic Centre in Lagos State University is committed to providing a safe and sound educational environment for all its Staff and Students free from discrimination on any ground and from harassment including sexual harassment. ACEITSE will operate a zero tolerance policy for any form of sexual harassment, treat all incidents seriously and promptly investigate all allegations of sexual harassment. Any person found to have sexually harassed another will face disciplinary action, up to and including dismissal. 

2.0     Definition of sexual harassment

Sexual harassment is unwelcome sexual advances, requests for sexual favours, and other verbal, non-verbal or physical conduct of a sexual nature when either:

  • The conduct is made as a term or condition of an individual’s employment, education, living environment or participation in a University community.
  • The acceptance or refusal of such conduct is used as the basis or a factor in decisions affecting an individual’s employment, education, living environment, or participation in a University community.
  • The conduct unreasonably impacts an individual’s employment or academic performance or creates an intimidating, hostile or offensive environment for that individual’s employment, education, living environment, or participation in a University community.

Anyone can be sexual harassed, regardless of their sex (male/female) and personality (Victim/Harasser). ACEITSE recognises that sexual harassment may also occur between people of the same sex. What matters is that the sexual conduct is unwanted and unwelcome by the person against whom the conduct is directed.

ACEITSE recognises that sexual harassment is a manifestation of power relationships and often occurs within unequal relationship. All sexual harassment is prohibited whether it takes place within ACEITSE premises or outside, including at social events, business trips, training sessions or conferences. 

The policy should apply to activities that are:

  • Conducted on the university campus or in a university facility;
  • Conducted as part of deployment on university business or as a representative of the university (such as field research and exchanges);
  • Affiliated with the university, such as student groups 

Table 7.1: Sample offence and sample sanctions

Offence Examples of unacceptable behavior Examples of sanctions
Sexual misconduct

Sexual intercourse or engaging in sexual act without consent

Attempting to engage in sexual intercourse or sexual act without consent

Sharing private sexual materials of another person without consent

Kissing without consent

Touching inappropriately without consent

Inappropriately showing sexual organs to another person

Repeatedly following another person without good reason

Making unwanted remarks of a sexual nature





Formal warning

Mandatory training session

Written or verbal apology

Abusive behavior

Threats to hurt another person

Abusive comments relating to an individual’s sex, race, pregnancy, maternity, gender, disability

Acting in an intimidating and hostile manner




False Allegation Obvious False Allegation

Verbal Warning

Formal Warning



3.0     Existing Policy

All complaints of sexual harassment will be taken seriously and treated with respect and in confidence. No one will be victimised for making such a complaint and if such complaint are false, the complaint will be appropriately sanctioned.

The University existing policy documents include, the staff handbook, undergraduate and post graduate student handbook and the Lagos State University MONITOR – Campus Safety Application on Google store, wherein sexual harassment complaints, procedures and punishment are well captured. 

4.0     Complaints Procedures

Anyone who is sexually harassed should, if possible, inform the alleged harasser that the conduct is unwanted and unwelcome. ACEITSE recognises that sexual harassment may occur in unequal relationships and that it may not be possible for the victim to inform the alleged harasser.

If a victim cannot directly approach an alleged harasser, he/she can approach one of the designated staff members responsible for receiving complaints of sexual harassment. This person could be another supervisor, a member of the human resources department, etc.

When an ACEITSE Officer receives a complaint of sexual harassment, he/she will:

  • immediately record the dates, times and facts of the incident(s)
  • ascertain the views of the victim as to what outcome he/she wants
  • ensure that the victim understands the Centre’s procedures for dealing with the complaint
  • discuss and agree the next steps: either informal or formal complaint, on the understanding that choosing to resolve the matter informally does not preclude the victim from pursuing a formal complaint if he/she is not satisfied with the outcome
  • keep a confidential record of all discussions
  • respect the choice of the victim
  • ensure that the victim knows that they can lodge the complaint outside of the Centre through the relevant country/legal framework.

Throughout the complaints procedure, a victim is entitled to be helped by a counsellor within the University Counsellor Unit. ACEITSE recognises that because sexual harassment often occurs in unequal relationships, victims often feel that they cannot come forward. ACEITSE understands the need to support victims in making complaints. 

5.0     Informal complaints mechanism

If the victim wishes to deal with the matter informally, the ACEITSE, Human Resources Officer will:

  • give an opportunity to the alleged harasser to respond to the complaint;
  • ensure that the alleged harasser understands the complaints mechanism;
  • facilitate discussion between both parties to achieve an informal resolution which is acceptable to the complainant, or refer the matter to Head, Human Resources within the Centre to resolve the matter;
  • ensure that a confidential record is kept of what happens;
  • follow up after the outcome of the complaints mechanism to ensure that the behaviour has stopped; and
  • ensure that the above is done speedily and within 3days of the complaint being made. 

6.0     Formal complaints mechanism

If the victim wants to make a formal complaint or if the informal complaint mechanism has not led to a satisfactory outcome for the victim, the formal complaint mechanism should be used to resolve the matter.

The ACEITSE, Human Resources Officer who initially received the complaint will refer the matter to Head, Human Resources within the Centre instigate a formal investigation. Head, Human Resources within the Centre may deal with the matter him/herself, refer the matter to an internal or external investigator or refer it to a committee of three others made up of ACEITSE staff members.

The person carrying out the investigation will:

  • interview the victim and the alleged harasser separately;
  • interview other relevant third parties separately;
  • decide whether or not the incident(s) of sexual harassment took place;
  • produce a report detailing the investigations, findings and any recommendations;
  • if the harassment took place, decide what the appropriate remedy for the victim is, in
  • consultation with the victim (i.e.- an apology, a change to working arrangements, a promotion
  • if the victim was demoted as a result of the harassment, training for the harasser, discipline,
  • suspension, dismissal);
  • follow up to ensure that the recommendations are implemented, that the behaviour has
  • stopped and that the victim is satisfied with the outcome;
  • if it cannot determine that the harassment took place, he/she may still make
  • recommendations to ensure proper functioning of the workplace;
  • keep a record of all actions taken;
  • ensure that the all records concerning the matter are kept confidential; and
  • ensure that the process is done as quickly as possible and in any event within three days of the complaint being made. 

7.0     Outside complaints mechanisms

A person who has been subject to sexual harassment can also make a complaint outside of the

company. They can do so through [insert mechanism depending on country/legal framework – i.e. employment tribunal, ombudsperson, etc]. 

8.0     Sanctions and disciplinary measures

Anyone who has been found to have sexually harassed another person under the terms of this policy is liable to any of the following sanctions:

  • verbal or written warning
  • adverse performance evaluation
  • reduction in wages
  • transfer
  • demotion
  • suspension
  • dismissal

The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable

deterrent sanctions will be applied to ensure that incidents of sexual harassment are not treated as trivial. Certain serious cases, including physical violence, will result in the immediate dismissal of the harasser. 

9.0     Implementation of this policy

ACEITSE will ensure that this policy is widely disseminated to all relevant persons. It will be included in the staff handbook. All new employees must be trained on the content of this policy as part of their induction into the company.

Every year, members of LASU ACEITSE, Human Resources sub-unit will attend a refresher training course on the content of this policy. It is the responsibility of every manager to ensure that all his/her employees are aware of the policy. 

10.0   Monitoring and Evaluation

ACEITSE recognises the importance of monitoring this sexual harassment policy and will ensure that it anonymously collects statistics and data as to how it is used and whether or not it is effective.

Supervisors, managers and those responsible for dealing with sexual harassment cases will report on compliance with this policy, including the number of incidents, how they were dealt with, and any recommendations made. This will be done on a yearly basis. As a result of this report, the company will evaluate the effectiveness of this policy and make any changes needed.