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Though it would be relatively easier to prove that a manager or supervisor to the recipient could be guilty of harassing "during the course of employment", it may require more proof if the harasser is in a subordinate position. Employers can avoid liability for discrimatory harassment if they can prove that they took such steps that were reasonably practical to prevent harassment from occurring. However, employers cannot use this defence to a claim of harassment under the Protection from Harassment Actunder which they will have vicarious liability for the actions of their employees.