Full testimony below on EVERFI’s evidence-based approach in transforming workplace culture.

EVERFI is a leading provider of online education that addresses some of the most pressing challenges facing our nation’s corporations and schools. EVERFI is unique in that we utilize a prevention-based, public health approach to address workplace harassment and other critical social issues.

I recognize that people are often unclear about what public health is. Whereas the field of medicine is about treating individuals after they’ve gotten sick or injured, public health is about preventing populations from getting sick or injured to begin with.

Too often, workplace harassment initiatives focus on how to define and respond to illegal behavior. EVERFI believes that organizations should shift the balance to prioritize prevention—stopping concerning behavior before individuals are harmed. Prevention programs that use a positive, values-based approach can be far more effective in shaping behavior than the consequence-avoidance focus of traditional anti-harassment training.

Telling employees about actions that violate policy places focus on what not to do. Behaviors that are often only perpetuated by a small subset of employees. It is much more effective to say, “our organization is a great place to work. Here is how we respect and support each other so that we can all do our very best.” This action-oriented message engages and empowers all employees to create a safe and respectful workplace culture.

This engagement of the healthy majority of employees is central to the evidence-based approach of bystander intervention.

When it comes to bystander intervention, many employees can identify situations of blatant harassment, but they may not recognize some of the less egregious, precursor behaviors that lead to those situations. They also may not know what to say or do or may worry that getting involved won’t be supported by their peers. Thus, good bystander intervention training will present a range of inappropriate behaviors and encourage employees to take action across this spectrum. It will provide many different options for taking action that can vary based on employees’ unique styles and strengths, the setting of the incident, and the positions of the individuals involved. And lastly, it will include messages that help individuals know that intervening is socially acceptable and encouraged.

Organizations are increasingly using online training to complement or replace the in-person programs that have been traditionally utilized to address workplace harassment. While both approaches have merit, especially together, I have been asked to talk about unique advantages of online training that can be difficult to achieve via in-person programming. These fall into the categories of: 

  • Compliance
  • Content
  • Design
  • Administration
  • Data

While all five of these areas are critical and addressed in my full written statement, I will focus on design and data in these remarks. To maximize impact, training must be designed to meet employees where they are, with a degree of personalization that can be challenging for in-person programming. This can include personalized feedback to attitudinal questions; customized content based on employee characteristics, like culturally appropriate messages based on geographic region; and unique pathways through skill-building scenarios.

Further, because this training requires discussion of sensitive topics, reflections about personal values, and practicing new skills, some employees may feel uncomfortable doing this work in an in-person group setting.

Finally, online courses allow organizations to provide this type of personalized experience at scale, which is particularly useful if your workplace is dispersed or in locations that make in-person training difficult—like construction sites, warehouses, and retail stores.

Turning to data, online training can include pre- and post- surveys to monitor changes and employees’ knowledge, attitudes, and behaviors and provide real-time insights on workplace culture. This data can be invaluable in informing resource allocation and strengthening ongoing initiatives. For example, if employees’ survey responses indicate a lack of confidence around intervening if they witness harassment, the employer could then launch a focused communication campaign to address this gap and encourage actions that protect workplace culture. Or, if HR is made aware of harassment within a particular division but they’re not receiving reports, climate surveys can help uncover whether this is simply the result of lack of awareness, of reporting resources, or something more complex—like fears of retaliation.

I’d like to conclude by noting that training is just the tip of the iceberg in our efforts to address workplace harassment. Training must be supported by other crucial elements of a comprehensive prevention strategy, like organization-wide commitment including visible leadership and meaningful investment; robust policies and procedures that are strongly and consistently enforced; and rigorous intentionality, like data collection, goal setting, and strategic planning.

Thank you for allowing me to share my perspective and for the EEOC’s ongoing leadership and commitment in this area.

Question from EEOC’s Chair, Victoria A. Lipnic: 

Because I’ve long been fascinated with public health and so your public health-based approach, one of the things that has always fascinated me about public health is the concept of patient 0 and the idea that things can be traced down to the person who originates whatever the Public Health crisis may be. If you could address that a little bit in terms of the context of both training but also approaches of employers trying to get at one person or collective group.

Answer from EVERFI’s Rob Buelow:

Around addressing one person versus addressing groups of individuals, research has shown that things like offender management programs, addressing individuals that are engaging in the most problematic behavior is a long-term investment and it takes time, and change is absolutely possible. But a quicker lever for making behavior change is changing the culture and the surrounding climate of accountability within peer groups about behaviors that are unacceptable and inappropriate—people will be much quicker to change behaviors when peers are holding them accountable. 

But to the broader public health approach of the question, I think it’s really important for us to think about how we define the question: 

What is prevention? 

Public Health lays it out into three categories: primary, secondary, and tertiary.

Primary prevention is really about root causes and deterring the onset of problematic behaviors before they occur.

Secondary prevention is around reducing exposure to and effectively responding in risky and harmful situations.

Tertiary prevention is around mitigating impact and preventing recurrence. 

And I think that when we ask particularly leadership around how they think about prevention, it tends to be focused on the secondary and tertiary categories. But the greatest return on investment of prevention work is keeping harassment from happening to begin with, rather than continually responding to it when reports are made

So I think that fundamentally reshifting the way that we prioritize our efforts, all three of those categories are critical. But really shifting the balance to prioritize primary prevention is where we’re truly going to make change.