From anti-harassment protocols to verifiable corporate due diligence: A labour-law framework for workplace sexual harassment in the European Union

European labour law prohibits workplace sexual harassment, but the existence of a policy cannot demonstrate effective protection. This article reconstructs a verifiable standard of organisational due diligence from EU equality law, ILO Convention No 190, occupational safety and health, protection against victimisation and effective remedies. It distinguishes formal, procedural and material compliance through six pillars: governance; risk prevention; accessible reporting; independent investigation and evidence preservation; protection, reparation and non-repetition; and monitoring and learning. The framework connects the integrative contribution of Convention No 190 with the distinct requirements of equality and occupational safety remedies. Spanish and Italian illustrations show how prevention can be embedded in interacting legal duties. Digital evidence and algorithmic management receive particular attention, and a hypothetical case-sequence test illustrates how cumulative post-report disadvantage can be examined. The proposal is an analytical method, not an autonomous cause of action or a compliance safe harbour. Its central claim is that diligence should be assessed through evidence of the performance of applicable duties before, during and after a complaint.