Bystander Approaches to Sexual Harassment in the Workplace

Encourage. Support. Act!

Executive Summary

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• Back to Contents
• Foreword
• Executive summary
• Introduction
• Part 1: Sexual harassment: an overview
• Part 2: Sexual harassment from the perspective of bystanders
• Part 3: The motivations and actions of bystanders: theoretical perspectives on bystander intervention
• Part 4: Bystander interventions in violence prevention
• Part 5: Legal and organisational implications of bystander approaches for sexual harassment
• Part 6: Towards a prevention framework
• Conclusion
• Acknowledgements

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Executive summary

Sexual harassment in the workplace is a persistent and pervasive problem in Australia and elsewhere, demanding new and creative responses.^[1] One significant area that may inform prevention and response strategies is the area of ‘bystander approaches’. In examining the potential for bystander approaches to prevent and respond to workplace sexual harassment, this paper draws upon a range of theoretical and empirical research.

Who are bystanders?

Bystanders are individuals who observe sexual harassment firsthand, or are subsequently informed of the incident. This definition includes both ‘passive’ bystanders (those who take no action) and ‘active’ bystanders (those who take action to prevent or reduce the harm).

This inclusive definition of bystanders is not limited to people who have witnessed the event or incident. It also includes those who subsequently hear about the event.

In the context of sexual harassment, individuals often fail to distinguish their personal observations from the suggestions of others.^[2] Further, the impact of sexual harassment can extend from the observers to other co-workers who are not direct witnesses.^[3] For example, studies have shown that women working in an environment that is hostile to women and lax about harassment can experience similar negative impacts to those women who are actual targets of sexual harassment.^[4]

In the workplace, bystanders can include a range of people. They may include managers or supervisors, human resource employees, workplace ombudsmen and/or equity/harassment contact officers to whom sexual harassment is reported. Reporting can be either formally, where policies and grievance procedures are implemented, or informally,^[5] where targets seek support or request advice. Co-workers, who are informed of sexual harassment through the workplace grapevine or targets seeking emotional support and advice, are also bystanders.

What are bystander approaches?

Bystander approaches focus on the ways in which individuals who are not the targets of the conduct can intervene in violence, harassment or other anti-social behaviour in order to prevent and reduce harm to others.^[6]

Bystander approaches have a long history of being used in emergency situations. Increasingly, they have become part of efforts to prevent injustices, such as interpersonal violence, cyberbullying and race discrimination. For example, the Australian Human Rights Commission incorporated bystander approaches into initiatives aimed at empowering young people to take safe steps to respond to cyberbullying.^[7] The Victorian Health Promotion Foundation used bystander approaches to prevent and respond to race discrimination and violence against women in the community.^[8] A small body of recent work has also begun to address the potential for bystander interventions in workplace bullying.

There has been less emphasis, however, on bystander approaches in workplaces and in relation to sexual harassment specifically. Relative to the extensive literature that addresses the prevalence of sexual harassment, the way in which bystander approaches may be utilised to actively prevent or respond to sexual harassment is still a relatively new area.

One of the reasons that bystander approaches to sexual harassment in the workplace are under-utilised is because harassers tend to actively hide their sexually harassing behaviour.^[9] Further, relatively few targets report their experiences through formal organisational grievance procedures. Even fewer report the harassment to bodies outside the confines of the workplace or to a public hearing.^[10] For example, the Commission’s 2008 Prevalence Study on sexual harassment revealed that fewer than one in six respondents who reported sexual harassment had formally reported the incident(s). Predominantly this was because of fear of reprisals and/or an expectation that the response would be inadequate.^[11] Even when legal redress is sought, it is rare for direct eyewitness testimony to be available.^[12] Rather than anticipating the benefit of deterring potential harassers, a fear of bad publicity also means organisations rarely publicise cases.



Research suggests that, in some work environments and circumstances, the hidden nature of sexual harassment can be especially problematic. Deployment in Defence operations where the focus on the mission overshadows other concerns is one example.^[13] Off-site interactions with clients or customers where harassers may perceive less accountability, is another.^[14]



Despite these trends, the evidence of the success of bystander approaches in other areas suggests that they may also be highly effective in raising awareness of sexual harassment in the workplace. Accordingly they may also be effective in changing cultures of tolerance towards sexual harassment and, ultimately, eradicating the problem.

Why are bystander approaches relevant for addressing sexual harassment?

A focus on bystander interventions to address sexual harassment in the workplace is important because targets of sexual harassment often respond passively to the conduct. They often avoid the harasser, trivialise the behaviour or deny it altogether.^[16] This may be because, although targets want the behaviour to end, they must balance this objective with avoiding reprisals by the harasser and maintaining their status and reputation in the work environment.^[17] Therefore, organisational approaches which rely exclusively on individual complaints made by targets of harassment are unlikely to be successful.^[18]

In this regard, bystanders may provide effective assistance in extending efforts to eliminate sexual harassment at work. Their support could be enlisted to intervene during or following an actual event, or to report the behaviour through organisational channels.

This paper examines a range of existing bystander approaches in other areas to understand how they could be applied to address sexual harassment in the workplace. This includes examination of empirical work on sexual harassment, relevant legal cases and conceptual frameworks explaining bystander interventions as part of violence prevention.

Sexual harassment may overlap with other destructive workplace behaviours that may be characterised as gendered mistreatment. Some of the shared features of these phenomena include hierarchical power relations, a reduction in the quality of working life and an undermining of equal participation in employment.^[19] Examining the different forms of gendered mistreatment provides insights into organisational processes and dynamics that might not be possible with the use of a singular focus on sexual harassment. These insights are valuable for understanding what kind of bystander approaches could be effective in workplace settings.

Bystanders’ perceptions of sexual harassment

There is a large body of research that considers the ways in which behaviours that may constitute sexual harassment are perceived by bystanders.^[20] Research shows that in general, women are less accepting than men of sexual behaviour at work.^[21] Bystanders are also more likely to say the sexual harassment has occurred when the target responds assertively than when they acquiesce or do not communicate to the harasser that the behaviour is unwelcome. Understanding the different perceptions of sexual harassment can inform the type of bystander policies and procedures that need to be developed to address sexual harassment.

There is strong evidence that witnessing or otherwise hearing about sexual harassment is not only frequent in workplace contexts, but also causes a range of negative health and occupational outcomes similar to those experienced by the targets.^[22] These impacts have also been observed in individuals who witness or hear about other catastrophic or traumatic events in the community more broadly. This phenomenon is known as ‘bystander stress’.

Individually or collectively, bystanders have been found to respond to sexual harassment in a number of ways. Responses include reporting the problem on behalf of the target, supporting the target in making a complaint, offering advice to the target or confronting the harasser. Bystanders may provide social guidance which can influence whether targets report the problem or make a formal legal claim.^[23] They may initiate a formal organisational response themselves, intervene during an incident or later confront the harasser.^[24]

What can we learn from bystander approaches in other areas?

A number of explanations have emerged for the motivations and actions of bystanders. Early studies revealed the notion of ‘bystander apathy’, which described the behaviours of people who observed an assault or injustice but who did nothing. Other studies have affirmed that bystanders are influenced by the behaviour of other bystanders.^[25]

Some classifications of types of bystanders have been based on the type of actions taken, such as standing by and enjoying the victimisation, avoiding the behaviours or helping the target. Bystander intervention behaviours have also been categorised according to dimensions of immediacy (whether the intervention occurs as the sexual harassment event unfolds, or later) and the level or degree to which bystanders immerse themselves in the situation.^[26]

A recent model by Goldberg and colleagues explains the process by which a workplace observer will respond to a perceived injustice faced by a co-worker. This model suggests that

• first, when an observer perceives themselves to be similar to the target of the injustice, they will identify with them;
• second, when the observer identifies with the target, this increases the likelihood that an event will be noticed and perceived as an injustice;
• third, when an injustice is perceived, the decision of an observer to respond to or report the injustice will be influenced by the organisational environment;
• fourth and finally, an observer’s decision about whether to use individual or collective strategies will depend on the perceived benefits and costs of these options.^[27]

Such equity or justice theories are based on the idea that where an injustice occurs, people are motivated to behave in ways which restore equity. However, the extent to which bystanders are motivated to act can vary depending on various factors. These factors include the characteristics of the bystander, their relationship with the target, perceptions of the situation and/or conduct and norms within the workplace. The extent to which bystanders are motivated to act can also be influenced by the:

• level of personal threat or benefit to the workplace they perceive (eg male bystanders can also feel reluctant to take action for fear of being seen as weak, gay and/or unmasculine by their male peers);^[28]
• extent to which they perceive sexual harassment to be either an injustice or a socialisation behaviour; or
• extent to which the workplace supports people’s advocacy or responds once a complaint is made. (In workplaces without a credible system in place for voicing bystander responses, employees may resort to counterproductive behaviours and responses. These include reduced productivity, absenteeism and sabotage, which can incur significant costs to the organisation).^[29]

This paper draws on a number of aligned areas to highlight how they may be useful for developing practical bystander interventions to address sexual harassment in the workplace. These areas include including whistle blowing, organisational ethics, workplace bullying and workplace health and safety. For instance, the research in whistle blowing shows that despite the existence of legislation that allows for whistle blowing, a greater determinant as to whether or not whistle-blowers will act is whether they anticipate anything will change.^[30] If there is a perception that there will be minimal change, then it is less likely that people will expose the conduct.

There is also a relatively established body of work that addresses bystander issues in relation to men’s violence towards women. These approaches have gained increasing traction as a way for men to prevent and respond to violence and for encouraging non-violent action by men. Their effectiveness is supported by a growing body of evidence.

The focus in this area of bystander action is on prevention by addressing the underlying causes of violence. The aim is to reduce its occurrence and, ultimately, to eliminate it altogether.

Approaches aimed at preventing and responding to violence are often classified according to when they occur:

• before the problem occurs (primary prevention);
• once the problem has begun (secondary prevention); and
• after the problem, extending into longer term responses (tertiary prevention).^[31]

Primary prevention strategies focus on the role of bystanders in challenging the attitudes and norms, behaviours, institutional environments and power inequalities that underpin acts of the violence against women.

The vast majority of existing violence prevention initiatives on bystander intervention rely on one or more of three streams of action to effect change: face-to-face education (eg mentors, buddy systems, public pledges), social marketing and communications (eg media) and policy and law.^[32]

There is a small but growing body of evidence that demonstrates that supporting bystander intervention strategies can increase the willingness of people to take action, their sense of efficacy in doing so and their actual participation in bystander behaviour.

Legal and organisational challenges for bystander approaches

There are a number of important legal and organisational challenges associated with the translation of bystander approaches from other areas of study to workplace sexual harassment. These include vicarious liability, victimisation and occupational health and safety.

Vicarious liability provisions exist in state and federal anti-discrimination legislation. Under these provisions, an employer will be liable for the discriminatory actions of her, his or its employee or agent unless the employer has taken reasonable steps to prevent the sexual harassment.

The involvement of bystanders, who may include co-workers as well as those in positions of organisational authority who have had sexual harassment reported to them, raises important questions about what an employer must do in order to have taken reasonable steps to prevent sexual harassment from occurring and thus to avoid liability for the conduct of their employees or agents. The related issues of victimisation of bystanders and aiding and abetting are also important in terms of organisational risk.

The way co-workers cooperate within a workplace health and safety framework to establish and maintain a safe and healthy work environment also plays a role in mobilising the support of bystanders. While the focus in this area has been on physical safety, there is increasing recognition of its capacity to also address psycho-social safety elements such as sexual harassment. Importantly, such workplace health and safety strategies have been found to be highly effective.^[33] Recent work has also indicated that the involvement of bystanders in workplace safety can lead to reshaping the traditional norms, which influence men’s and women’s behaviour and are associated with sexual harassment and other gendered forms of mistreatment at work.^[34]

Applying bystander approaches to sexual harassment in the workplace

Education about bystander intervention is a potentially invaluable element for preventing sexual harassment in the workforce. Bystander education can teach people to interrupt incidents of sexual harassment or the situations which lead to harassment. It can also teach them to challenge perpetrators and potential perpetrators, to provide support to potential and actual victims and to speak out against the social norms and inequalities supportive of sexual harassment. However, the effectiveness of education is dependent on its integration within a comprehensive framework of prevention.

Efforts to reduce and prevent workplace sexual harassment will only make real progress if they adopt the principles and strategies shown to constitute best practice in violence prevention. Effective interventions have five generic features, all of which are likely to have relevance for the development of bystander approaches to sexual harassment:

1. adopting multiple strategies to address the problem behaviour, in multiple settings and at multiple levels;^[35]
2. demonstrating a sound understanding of both the problem – of the workings and causes of sexual harassment itself – and of how it can be changed;^[36]
3. invoking educational, communication and other strategies known to create change – ensuring they focus on determinants of this behaviour, use effective teaching methods and have sufficient duration and intensity to produce change;^[37]
4. developing bystander interventions that have regard to the context (ie the social and structural constraints and the operating beliefs and norms);^[38] and
5. involving a comprehensive process of impact evaluation that is integrated into program design and implementation.^[39]

This paper provides a range of bystander strategies that could be implemented in workplaces to address sexual harassment.

The principles and strategies identified for developing and implementing bystander approaches to sexual harassment in the workplace include:

 

Overview and conclusion

Research shows that bystander approaches and interventions can be potent tools in raising awareness of sexual harassment and, ultimately, in eliminating this costly, damaging and increasingly pervasive problem in workplaces.

Part 1 of the paper examines definitions of sexual harassment. It also examines how sexual harassment overlaps with other destructive workplace behaviours which contribute to gender inequality.

Part 2 explores how sexual harassment is perceived by bystanders and the impacts on their psychological well-being and productivity.

Part 3 considers the motivations and actions of bystanders, drawing on other areas of research to understand what bystander responses are likely in different circumstances. These areas of research include whistle blowing, organisational ethics, workplace health and safety and workplace bullying.

Part 4 outlines existing bystander approaches, particularly as a prevention strategy for domestic and family violence, sexual violence and other forms of interpersonal violence.

Part 5 examines the legal and organisational implications of bystander involvement, referring to issues such as vicarious liability, victimisation and workplace health and safety.

Part 6 of the paper proposes an overarching framework that is based on the categorisation of primary, secondary and tertiary prevention in the area of interpersonal violence and incorporates a number of accepted general principles of bystander prevention approaches.

The paper concludes by canvassing a range of strategies relevant to workplace sexual harassment that may be practically employed in workplaces today.

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^[1] Sexual harassment is understood as both a specific and legally defined form of sex discrimination and as a manifestation of gender-based workplace violence and a broader ‘cultural misogyny’ or hostility towards women. J Gailey and A Prohaska, ‘Knocking off a fat girl: an explanation of hogging, male sexuality and neutralization’ (2006) 27 Deviant Behavior, pp. 31-49.

^[2] S Hekkanen and C McEvoy, ‘False memories and source-monitoring problems: criterion differences’ (2002) 16 Applied Cognitive Psychology, pp. 73-85.

^[3] K Miner-Rubino and L Cortina, ‘Beyond targets: consequences of vicarious exposure to misogyny at work’ (2007) 92(5) Journal of Applied Psychology, pp.1254-1269; J Raver and M Gelfand ‘Beyond the individual victim: linking sexual harassment, team processes and team performance’ (2005) 48 Academy of Management Journal, pp. 387-400.

^[4] T Glomb, W Tichman, C Hulin, F Drasgow, K Schneider and L Fitzgerald, ‘Ambient sexual harassment: an integrated model of antecedents and consequences (1997) 71 Organizational Behavior & Human Decision Processes, pp. 309-328; K Miner-Rubino and L Cortina, ‘Working in a context of hostility toward women: implications for employees’ well-being’ (2004) 9 Journal of Occupational Health Psychology, pp. 107-122; K Miner-Rubino and L Cortina, ‘Beyond targets: consequences of vicarious exposure to misogyny at work’ (2007) 92(5) Journal of Applied Psychology, pp.1254-1269.

^[5] The distinction between formal and informal reporting throws up legal and ethical concerns which are addressed in Part 4 of the paper.

^[6] A Powell, Review of bystander approaches in support of preventing violence against women, Victorian Health Promotion Foundation (2011), p. 8-10.

^[7] Australian Human Rights Commission, Cyberbullying, Human rights and bystanders (2010). At http://www.humanrights.gov.au/pdf/bullying/VHB_cyberbullying.pdf.

^[8] VicHealth, Review of bystander approaches in support of preventing race-based discrimination, Victorian Health Promotion Foundation (2010). VicHealth, More than ready:Bystander action to prevent violence against women in the Victorian community (2012). At: http://www.vichealth.vic.gov.au/en/Publications/Freedom-from-violence/Bystander-Research-Project.aspx (viewed 29 May 2012).

^[9] G Scott and B Martin, ‘Tactics against sexual harassment: the role of backfire’ (2006) 7(4) Journal of International Women’s Studies, pp. 111-125.

^[10] J Firestone and R Harris, ‘Perceptions of effectiveness of responses to sexual harassment in the US military, 1988 and 1995’ (2003) 10(1) Gender, Work & Organization, pp. 42–64; R Illies, N Hauserman, S Schwochau and J Stibal, ‘Reported incidence rates of work-related sexual harassment in the United States: using meta-analysis to explain reported rate disparities’ (2003) 56(3) Personnel Psychology, pp. 607-618; D Wear, J Aultman and N Borgers, ‘Retheorising sexual harassment in medical education: women students’ perceptions at five US medical schools’ (2007) 19(1) Teaching and Learning in Medicine, pp. 20–29.

^[11] Australian Human Rights Commission (2008). Sexual Harassment: Serious Business. Results of the 2008 Sexual Harassment National Telephone Survey.

^[12] P McDonald, T Graham and B Martin, ‘Outrage management in cases of sexual harassment as revealed in judicial decisions’ (2010) 34(2) Psychology of Women Quarterly, pp.165-180.

^[13] United States Department of Defense, Report of the Defense Task Force on Sexual Assault in the Military Services (2009), Alexandra, VA: Defense Task Force. Available at http://www.dtic.mil/dtic/tr/fulltext/u2/a545871.pdf (viewed 7 June 2012).

^[14] H Gettman and M Gelfand, ‘When the customer shouldn’t be kind: antecedents and consequences of sexual harassment by clients and customers’ (2007) 92(3) Journal of Applied Psychology, pp. 757-770.

^[15] J Eveline and M Booth, ‘Gender and sexuality in discourse of managerial control: the case of women miners’ (2002) 9(5) Gender, Work & Organization, pp. 556-578.

^[16] L Bowes-Sperry L and A O’Leary-Kelly, ‘To act or not to act: the dilemma faced by sexual harassment observers’ (2005) 30 Academy of Management Review, pp. 288-306.

^[17] B Gutek, Sex and the workplace (1985); B Ragins and T Scandura, ‘Antecedents and work–related correlates of reported sexual harassment: an empirical investigation of competing hypotheses’ (1995) 32(7/8) Sex Roles, pp. 429–455; A O’Leary-Kelly, R Paetzold and R Griffin, ‘Sexual harassment as aggressive behavior: an actor based perspective’ (2000) 25 Academy of Management Review, pp. 372-388.

^[18] C Benavides-Espinoza and G Cunningham, ‘Bystanders’ reactions to sexual harassment’ (2010) 63 Sex Roles: A Journal of Research, pp. 201-213.

^[19] S Fredman, Women and the law (1997); D McCann, Sexual Harassment at Work: National and International Responses (2005); P McDonald, ‘Workplace sexual harassment 30 years on: a review of the literature’ (2011, in press) International Journal of Management Reviews; P Popovich and M Warren, ‘The role of power in sexual harassment as a counterproductive behavior in organizations’ (2010) 20 Human Resource Management Review, pp. 45-53.

^[20] The vast majority of this research is grounded in psychological theory and uses vignette-type studies where respondents are presented with written or verbal scenarios and stories describing sexual harassment and are asked for their perceptions. This body of work is also heavily reliant on the use of American undergraduate college student as samples.

^[21] J Berdahl and C Moore, ‘Workplace harassment: double jeopardy for minority women’ (2006) 91(2) Journal of Applied Psychology, pp. 426–436; C Gallivan, C Nelson, J Halpert and D Cellar, ‘Organizational responses for preventing and stopping sexual harassment: effective deterrents or continued endurance?’ (2007) 56(11/12) Sex Roles, pp. 811–822; M McCabe M and L Hardman, ‘Attitudes and perceptions of workers to sexual harassment’ (2005) 145(6) The Journal of Social Psychology, pp. 719–740; L Reese and K Lindenberg, Implementing sexual harassment policy: Challenges for the public sector workplace (1999); C Tang, M Yik, F Cheung, P Choi and K Au, ‘How do Chinese college students define sexual harassment?’ (1995) 10(4) Journal of Interpersonal Violence, pp. 503–515.

^[22] K Schneider, ‘Bystander Stress: Effects of Sexual Harassment on Victims’ Co-workers’. Paper presented at the 104^th Annual Convention of the American Psychological Association, Toronto, Ontario, Canada, August 9-13 (1996); K Miner-Rubino and L Cortina, ‘Beyond targets: consequences of vicarious exposure to misogyny at work’ (2007) 92(5) Journal of Applied Psychology, pp.1254-1269.

^[23] B Goldman, ‘Toward an understanding of employment discrimination claiming: an integration of organizational justice and social information processing theories’ (2001) 54 Personnel Psychology, pp. 361-386.

^[24] L Bowes-Sperry and A O’Leary-Kelly, ‘To act or not to act: the dilemma faced by sexual harassment observers’ (2005) 30 Academy of Management Review, pp. 288-306.

^[25] K Van Heugten, ‘Theorizing active bystanders as change agents in workplace bullying of social workers’ (2011) 92(2) Families in Society: The Journal of Contemporary Social Services, pp. 219-224.

^[26] L Bowes-Sperry and A O’Leary-Kelly, ‘To act or not to act: the dilemma faced by sexual harassment observers’ (2005) 30 Academy of Management Review, pp. 288-306.

^[27] C Goldberg, M Clark and A Henley, ‘Speaking up: a conceptual model of voice responses following the unfair treatment of others in non-union settings’ (2011) 50(1) Human Resource Management, pp. 75-94.

^[28] M Carlson, ‘I’d rather go along and be considered a man: masculinity and bystander intervention’ (2008) 16(1) Journal of Men’s Studies, pp. 3-17.

^[29] M Ambrose, M Seabright and M Schminke, ‘Sabotage in the workplace: The role of organizational injustice’, (2002) 89(1) Organizational Behavior and Human Decision Processes, pp. 947-965; E De Boer, A Bakker, J Syroit and W Schaufeli, ‘Unfairness at work as a predictor of absenteeism’ (2002) 23(2) Journal of Organizational Behavior, pp. 181-197; B Klaas, ‘Determinants of grievance activity and the grievance system’s impact on employee behavior: an integrative perspective’ (1989) 14(3) Academy of Management Review, pp. 445-458; R Moorman, B Niehoff and D Organ, ‘Treating employees fairly and organizational citizenship behavior: sorting the effects of job satisfaction, organizational commitment and procedural justice’ (1993) 6(3) Employee Responsibilities and Rights Journal, pp. 209-225.

^[30] J Near, T Morehead Dworkin and M Miceli, ‘Explaining the whistle-blowing process: suggestions from power theory and justice theory’ (1993) 4(3) Organization Science, pp. 393-411; A Trimmer, ‘Whistleblowing: what it is and what it might mean for incorporated legal practices’ (2004) February Law Society Journal, p. 69.

^[31] This summary combines and modifies the accounts given by the CDC (2004: 3) and Chamberlain (2008: 3).

^[32] M Flood, ‘Involving men in efforts to end violence against women’ (2011) 14(3) Men and Masculinities.

^[33] T MacDermott, ‘The duty to provide a harassment-free work environment’ (1995) 37(4) Journal of Industrial Relations, pp. 495-523.

^[34] R Ely and D Meyerson, ‘An organizational approach to undoing gender: The unlikely case of offshore oil platforms’ (2010) 30 Research in Organizational Behavior, pp., 3-34.

^[35] E Casey and T Lindhorst, ‘Toward a multi-level, ecological approach to the primary prevention of sexual assault: prevention in peer and community contexts’ (2009) 10(2) Trauma, Violence & Abuse, pp. 91-114; M Nation, C Crusto, A Wandersman, K Kumpfer, D Seybolt, E Morrissey-Kane and K Davino, ‘What works in prevention: principles of effective prevention programs’ (2003) 58(6/7) American Psychologist, pp. 449-56.

^[36] M Flood, L Fergus and M Heenan, Respectful Relationships Education: Violence prevention and respectful relationships education in Victorian secondary schools, Department of Education and Early Childhood Development, State of Victoria, (2009), pp. 33-35.

^[37] M Flood, L Fergus and M Heenan, Respectful Relationships Education: Violence prevention and respectful relationships education in Victorian secondary schools, Department of Education and Early Childhood Development, State of Victoria, (2009), pp. 35-54.

^[38] E Casey and T Lindhorst, ‘Toward a multi-level, ecological approach to the primary prevention of sexual assault: prevention in peer and community contexts’ (2009) 10(2) Trauma, Violence & Abuse, pp. 91-114; M Flood, L Fergus and M Heenan, Respectful Relationships Education: Violence prevention and respectful relationships education in Victorian secondary schools, Department of Education and Early Childhood Development, State of Victoria, (2009), pp. 55-56.

^[39] M Flood, L Fergus and M Heenan, Respectful Relationships Education: Violence prevention and respectful relationships education in Victorian secondary schools, Department of Education and Early Childhood Development, State of Victoria, (2009), pp. 57-58.