Document 30: Alan K. Campbell, Director, U.S. Office of Personnel Management, "Memorandum to Heads of Departments and Independent Agencies," and "Policy Statement and Definition of Sexual Harassment," appended, 12 December 1979. 2 pp.


   On December 12, 1979, Alan Campbell, The Director of Office of Personnel Management, issued a model policy statement and training materials on sexual harassment, which he sent to all heads of departments and independent agencies of the executive branch of the federal government. Campbell's model policy strongly opposed sexual harassment, clearly prohibiting coercive sexual demands by supervisors, but the policy was ambiguous about whether it prohibited environmental harassment and harassment by co-workers. In addition, Campbell's policy did not provide penalties for sexual harassment.

[p. 98]

December 12, 1979


SUBJECT: Policy Statement and Definition on Sexual Harassment

This memorandum transmits the Office of Personnel Management's policy statement on sexual harassment which is applicable to each Federal agency and department. The policy statement also includes the specific definition of sexual harassment which should be utilized in addressing this issue.

The Subcommittee on Investigations of the Committee on Post Office and Civil Service has held hearings on the problem of sexual harassment within the Federal sector. The Office of Personnel Management was requested by Chairman James M. Hanley to assist in the effort to curtail sexual harassment by issuing a policy statement which made clear that sexual harassment undermines the integrity of the Federal Government and will not be condoned. Merit system principles require that all employees be allowed to work in an environment free from sexual harassment.

I am recommending that each of you take a leadership role by initiating the following actions:

  1. Issue a very strong management statement clearly defining the policy of the Federal Government as an employer with regard to sexual harassment;

  2. Emphasize this policy as part of new employee orientation covering the merit principles and the code of conduct; and

  3. Make employees aware of the avenues for seeking redress, and the actions that will be taken against employees violating the policy.



[p. 99]


   Federal employees have a grave responsibility under the Federal code of conduct and ethics for maintaining high standards of honesty, integrity, impartiality and conduct to assure proper performance of the Government's business and the maintenance of confidence of the American people. Any employee conduct which violates this code cannot be condoned.

   Sexual harassment is a form of employee misconduct which undermines the integrity of the employment relationship. All employees must be allowed to work in an environment free from unsolicited and unwelcome sexual overtures. Sexual harassment debilitates morale and interferes in the work productivity of its victims and co-workers.

   Sexual harassment is a prohibited personnel practice when it results in discrimination for or against an employee on the basis of conduct not related to performance, such as the taking or refusal to take a personnel action, including promotion of employees who submit to sexual advances or refusal to promote employees who resist or protest sexual overtures.

   Specifically, sexual harassment is deliberate or repeated unsolicited verbal comments, gestures, or physical contact of sexual nature which are unwelcome.

   Within the Federal Government, a supervisor who uses implicit or explicit coercive sexual behavior to control, influence, or affect the career, salary, or job of an employee is engaging in sexual harassment. Similarly, an employee of an agency who behaves in this manner in the process of conducting agency business is engaging in sexual harassment.

   Finally, any employee who participates in deliberate or repeated unsolicited verbal comments, gestures, or physical contact of a sexual nature which are unwelcome and interfere in work productivity is also engaging in sexual harassment.

   It is the policy of the Office of Personnel Management (OPM) that sexual harassment is unacceptable conduct in the workplace and will not be condoned. Personnel management within the Federal sector shall be implemented free from prohibited personnel practices and consistent with merit system principles, as outlined in the provisions of the Civil Service Reform Act of 1978. All Federal employees should avoid conduct which undermines these merit principles. At the same time, it is not the intent of OPM to regulate the social interaction or relationships freely entered into by Federal employees.

   Complaints of harassment should be examined impartially and resolved promptly. The Equal Employment Opportunity Commission will be issuing a directive that will define sexual harassment prohibited by Title VII of the Civil Rights Act and distinguish it from related behavior which does not violate Title VII.


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