I don't know if I can really answer that. I'd really have to look at the whole policy and see.
I think, ultimately, resolving sexual harassment as a problem in the workplace is not really about crime and punishment. It's about trying to create healthy workplaces, where justice and equality are values. I don't know if labelling somebody a harasser is necessarily going to help resolve the broader issue. I would say that I can't really comment on the specific policy.