Workplace Conduct & Complaints
Overview
California law prohibits harassment, discrimination, and retaliation in the workplace.
Employers must take reasonable steps to prevent, investigate, and address workplace misconduct.
Misconduct may involve coworkers, supervisors, managers, or third parties such as clients or vendors.
Protected Characteristics
Workplace misconduct is unlawful when based on a protected characteristic, including:
Race, color, sex, gender identity or expression, sexual orientation, religion, disability, medical condition, marital status, national origin, ancestry, military or veteran status, and age (40+).
Key Definitions
Harassment
Unwelcome conduct based on a protected characteristic that creates an intimidating, hostile, or offensive work environment.
Example: Repeated jokes about an employee’s age.
Discrimination
Making job-related decisions—such as hiring, pay, discipline, promotion, or termination—based on a protected characteristic instead of job performance or qualifications.
Example: Refusing to hire a qualified applicant because she is pregnant.
Retaliation
Taking negative action against someone for reporting misconduct, participating in an investigation, or exercising workplace rights.
Example: Cutting an employee’s hours after they file a complaint.
What to Watch For
Offensive comments, jokes, or slurs
Unwanted physical contact or threatening behavior
Excluding or isolating an employee
Harassing emails, texts, or messages
Offensive images or displays
Unequal discipline, pay, or scheduling
Complaints—formal or informal—about feeling targeted or uncomfortable
Important: All complaints must be taken seriously, even if informal.
Workplace Complaint Response Checklist
Step 1: Receive the Complaint
Have the employee complete the Complaint Form provided in The Guide
Respond promptly (same day or next business day when possible)
Do not promise confidentiality or outcomes
Step 2: Acknowledge the Complaint
Confirm receipt in writing
Explain that the complaint will be reviewed fairly
Clearly state that retaliation is prohibited
Step 3: Assign a Neutral Investigator
Select someone impartial and unbiased
The employer may act as investigator if necessary
Step 4: Investigate
Use the “Investigation Questionnaire” provided in The Guide to:
Interview the complaining party
Interview the accused employee
Interview relevant witnesses
Review documents, messages, video, or other evidence
Treat all parties respectfully and avoid assumptions.
Step 5: Reach Findings
Complete the “Investigation Report” provided in The Guide
Make findings using a “more likely than not” standard
Inform the complaining party that the investigation is complete
Step 6: Take Appropriate Action
If misconduct is found, take corrective action based on severity:
Minor misconduct: coaching, written warning, refresher training
Serious misconduct: corrective action up to and including termination
For termination-related steps, refer to the Termination & Resignation section of this Manual.
Step 7: Follow Up
Check in with the complaining party
Monitor for retaliation
Document follow-up steps
Remedial Measures After an Investigation
Once an investigation is complete, the employer must take appropriate remedial action if misconduct is substantiated. The response should be proportional to the severity of the conduct.
Remedial Measures for “Minor Misconduct”
Minor misconduct generally includes isolated, non-violent, or non-threatening behavior that does not rise to severe or pervasive misconduct.
Examples may include:
Offhand or inappropriate comments
Minor policy violations
Unprofessional behavior that stops once addressed
Available Remedial Tools
1. Written Corrective Action (Infraction)
Use the Employee Corrective Action Notice to document:
The misconduct
The policy or expectation violated
Clear expectations going forward
The employee should acknowledge receipt, and the document should be retained in the personnel file.
2. Refresher Training
Require additional training to reinforce company policies and expected behavior.
Training must occur during paid working time and completion should be documented.
3. Coaching or Counseling
Informal corrective discussions may be appropriate for very minor issues, but should still be documented internally.
Remedial Measures for “Serious Misconduct”
Serious misconduct generally includes conduct that is severe, repeated, threatening, or unlawful.
Examples may include:
Physical harassment or threats
Repeated harassment after prior warnings
Retaliation
Serious policy violations
Available Remedial Tools
1. Performance Improvement Plan (PIP)
Use the Performance Improvement Plan (PIP) when continued employment is appropriate but requires structured correction.
A PIP should:
Clearly describe the issue
Set measurable expectations
Identify a defined review period (e.g., 30, 60, or 90 days)
Be signed by the employee and employer
2. Last-Chance or Final Corrective Action
In appropriate cases, a final written warning or last-chance agreement may be used before termination.
3. Coaching or Counseling
Informal corrective discussions may be appropriate for very minor issues, but should still be documented internally.
Documentation Is Critical
For every investigation and remedial action, employers should retain:
Complaint Form
Investigation Questionnaire
Investigation Report
Corrective Action or PIP (if issued)
Proper documentation protects the business in the event of a claim or audit.
Retaliation Is Strictly Prohibited
Retaliation against anyone who reports misconduct, participates in an investigation, or assists as a witness is illegal.
Watch for Signs of Retaliation
Sudden discipline or negative reviews
Schedule or duty changes
Isolation or exclusion
Increased scrutiny or micromanagement
Termination shortly after a complaint
Address retaliation immediately.
Investigation Best Practices
Stay neutral and fact-focused
Ask open-ended questions
Document all steps taken
Share information only on a “need to know” basis
Do not promise full confidentiality
Manager Do’s & Don’ts
DO
Listen calmly and respectfully
Take every complaint seriously
Escalate complaints immediately
Document what was reported
Maintain professionalism
Report retaliation concerns right away
DON’T
Ignore or minimize complaints
Investigate on your own without guidance
Promise confidentiality or specific outcomes
Take sides or assume guilt
Delay action
Retaliate or allow retaliation
Reminder: Even subtle retaliation can create legal liability.
Key Takeaways
Investigate promptly and fairly
Document every step
Retaliation is illegal
Use The Guide’s templates to stay consistent and compliant
When in doubt, pause and consult counsel before taking disciplinary action.