Sexual Harassment Training - Do I have to train 1099 employees/independent contractors?

Sexual Harassment Training - Do I have to train 1099 employees/independent contractors?

https://www.ny.gov/combating-sexual-harassment-workplace/combating-sexual-harassment-frequently-asked-questions

Q4. What policy, if any, must be provided to contractors, subcontractors, vendors and consultants?

A4. Employers do not have to provide any policy to independent contractors, vendors or consultants as such individuals are not employees of the employer. However, the State Human Rights Law imposes liability on the employer for their actions, and you are encouraged to provide the policy and training to anyone providing services in the workplace.


NYC does have the independent contractor training requirement: https://www1.nyc.gov/site/cchr/law/sexual-harassment-training-faqs.page

4.  Are employers required to have their independent contractors complete annual sexual harassment prevention training?
Yes. Similar to employees and interns, if an independent contractor works for an employer of 15 or more people and works (a) more than 80 hours in a calendar year AND (b) for at least 90 days (does not need to be consecutive), then the independent contractor must be trained. If an independent contractor worked less than 90 days, or less than 80 hours in a calendar year, they do not need to be trained.

Individuals who must be trained do not need to take the training at each workplace where they work over the course of a year. Independent contractors and freelancers may provide proof of completion of one sexual harassment prevention training to multiple workplaces and need not repeat the training at multiple workplaces.