PURPOSE OF THE STUDY The purpose of the study was to determine how many school divisions in the Commonwealth of Virginia had adequate policies which addressed sexual harassment specifically and to determine why school divisions had either developed or failed to develop such policies. An additional purpose was the development of a paradigm to guide school divisions in the construction of policy governing sexual harassment. PROCEDURE All 133 superintendents in Virginia were identified and 119 superintendents participated in the study. Data were collected using a survey questionnaire and copies of policies were requested. All survey data were analyzed using crosstabulation commands on the App-Stat statistical package. Policies which were returned were analyzed in comparison to evaluation criteria taken from the Equal Employment Opportunity Commission (EEOC) Guidelines that prohibit sexual harassment and from the research of sample policies from the public and private sectors. CONCLUSIONS 1. Sixty-eight percent of the school divisions in the Commonwealth indicated they did not have policies and/or administrative regulations which specifically prohibit sexual harassment. 2. Thirty-four of the 81 school divisions in Virginia which did not have sexual harassment policies indicated they were aware of the need for such policy. Twenty of the respondents indicated they had other policies which they believed adequately addressed sexual harassment, and fourteen of the respondents indicated they were developing such policy. 3. Most school divisions that had developed policies had done so because they were aware of their liability or the possibility of litigation. 4. Most policies were inadequate in that they failed to communicate that employers were serious about sexual harassment or they failed to indicate that employees would be made aware of sexually harassing behaviors through awareness training. / Ed. D.