From 6 April 2026, a first wave of reforms under the Employment Rights Act 2025 took effect. The change most worth pausing on, for anyone responsible for culture, is the one that explicitly added sexual harassment to the list of protected disclosures for whistleblowing purposes. A worker who raises a concern in the reasonable belief that doing so is in the public interest now sits inside the full whistleblower-protection regime. Confidentiality clauses that try to prevent a worker from making such an allegation are, in the words of the new provisions, void.
This is the part that most boards have already discussed with their employment lawyers. It is not the part most boards have discussed with their managers.
The legal change is real. The behavioural change is harder. A speak-up channel exists in almost every UK organisation already. The question the new rules quietly sharpen is whether anyone is actually using it.
Why Policy Without Behaviour Does Not Move the Number
What the academic literature on this topic has been saying for twenty-five years is that speak-up is a behavioural property of a team, not a policy property of a company. Amy Edmondson's 1999 paper in Administrative Science Quarterly, the foundational work on psychological safety, framed it as "a shared belief that the team is safe for interpersonal risk-taking". The word that does the work in that sentence is shared. Policies are written. Beliefs are observed.
Google's Project Aristotle, the multi-year internal study of what made some Google teams effective and others not, ranked psychological safety first of the five team dynamics that distinguished high-performing teams from the rest. The mechanism in both findings is the same. People do not raise difficult things based on whether a policy says they may. They raise difficult things based on what they have seen happen to the last person who did.
This is the part that the 6 April changes do not, and cannot, fix. Voiding a confidentiality clause does not change what happens in the meeting after the disclosure.
What Most Organisations Do (And Why It Stays Quiet)
The default response to any tightening of the harassment rules is recognisable. The policy is rewritten. An e-learning module is rolled out. Managers click through 18 minutes of scenarios while answering email in a second tab. Sign-off is tracked. The policy folder is updated.
The problem is the gap between knowing and doing. Roediger and Karpicke (2006), writing in Psychological Science, showed that being tested on material increases long-term retention by around 50% compared with re-reading the same content. Watching a compliance video falls in the second category. Eight weeks later, the manager who is approached quietly in the corridor by a worried colleague is operating on whatever instinct they had before the module, plus a vague memory of a video.
What the reformulated rules need from line managers is specific behaviour, in the moment. Listening without minimising. Holding space without rushing to "fix it". Not promising secrecy when secrecy is not theirs to promise. Escalating without rendering the colleague invisible. None of those are policy clauses. All of them are skills.
What Actually Builds Speak-Up
The organisations whose disclosure numbers have moved upward, and whose engagement scores held while their peers' fell, tend to share three features.
First, they distinguish between what the policy says and what behaviour they are asking managers to perform. They name the behaviours, and they ask their managers to practise them.
Second, they put the difficult conversation in front of managers in a low-stakes setting before the real one arrives. Building on academic behaviour-change work from UCL, Cambridge and Bocconi, our own research found that immersive role-play with professional actors was around 20% more effective than passive modalities such as slide-show or video e-learning at moving real skill. The same study found that participants overestimated their skill level before measurement: they thought they would handle it well, until they had to.
Third, they re-measure. Not policy distribution. Behaviour observed.
This is the work behind our Speak-Up Lab and our wider immersive simulations. We stage the conversation that the new rules will eventually surface, with the help of professional actors trained in the dynamics, before the real version of it arrives in the manager's diary unannounced.
The honest test for any UK organisation this quarter is not whether the harassment policy now reflects the 6 April changes. It almost certainly does. The harder test is whether a worker who has just witnessed something would, today, walk into their line manager's office and say so. If your culture survey suggests the answer is no, the new rules have not made anything worse. They have just made it harder to ignore.
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