One of China’s “big five” state-owned banks and the world’s largest asset lender is turning heads with an anti-sexual harassment guideline issued to some employees at its Beijing headquarters, according to domestic media.

In an internal email that was shared online Tuesday, the Industrial and Commercial Bank of China, or ICBC, outlined 10 scenarios staff may find themselves in with a colleague of the opposite sex, as well as appropriate, questionable, and inappropriate ways of handling them, as indicated by a green, orange, or red lightbulb, respectively. The guideline stressed that healthy professional relationships between men and women are beneficial to careers and “family happiness.”

Most of the 10 scenarios — which included driving a colleague home, sending GIFs in a chat, giving gifts, and drinking socially — focused on maintaining a safe and respectful distance or sticking to neutral conversation topics. According to the guideline, it would never be appropriate for a woman to ask her male colleague’s opinion of her underwear, for example, or for a man to bid farewell to his female colleague by patting her on the head.

According to domestic media, the internal email said the anti-sexual harassment guideline was a response to “profound lessons” learned from “previous relevant cases.” Though no further details were provided, this cryptic wording raised concerns among netizens about the possible prevalence of sexual harassment at ICBC.

An ICBC employee working in Shanghai’s Changning District, surnamed Liu, told Sixth Tone that the anti-sexual harassment guideline was only circulated within a research center at ICBC’s headquarters and not through the whole company. This may be a sign that “there are some problems” in that particular department, he said, adding that employers should consider distributing such materials when the personal affairs of a few staff members reflect badly on the entire company.

Another ICBC staff member based in Shanghai’s suburban Songjiang District said she hasn’t experienced or observed sexual harassment in her workplace, which she described as “quite safe.”

“I don’t have to consciously set and maintain boundaries when interacting with co-workers of the opposite sex, because there’s typically some physical distance between us,” the employee, surnamed Zhang, told Sixth Tone.

A staff member who answered ICBC’s customer service hotline did not respond to Sixth Tone’s interview request by time of publication, and a spokesperson for an ICBC branch in Shanghai said she could not comment on the matter.

The memo went viral after being leaked online, sparking wide discussion among people who either identified with the common workplace scenarios depicted or were simply curious.

As of Thursday afternoon, a related hashtag had been viewed over 200 million times on Weibo. Some users of the microblogging platform appreciated the bank giving attention to the serious issue of workplace sexual harassment — rare among large Chinese firms — but others argued that the guideline didn’t seem to have much faith in the goodness of people, or took issue with the implication that harassment can only happen between a man and a woman.

Wang Xiaozhe, the co-founder of EnGender, a volunteer feminist group and UN Women project winner, told Sixth Tone that although the guideline is aimed at curbing “inappropriate” relationships at work, some of its contents are problematic.

“The memo is a case of lazy paternalism. Its premise involves a kind of ‘sexual gaze’ and imposes a paranoia of sexual tension overshadowing what can just be plain, normal workplace relationships,” said Wang, whose organization drafted China’s first free anti-sexual harassment toolkit for local companies. “It obviously has neither a candid imagining of interpersonal relationships between the opposite sexes nor an enforceable plan for the management team to detect and curb actual workplace sexual harassment.”

In the absence of an authoritative guideline from the government, workplace sexual harassment often goes unchecked in China. In a 2018 commentary for Sixth Tone, a management analyst at a Chinese bank described her own experiences with such conduct, which she said was rampant in the country’s banking industry.

Other incidents of inappropriate behavior have involved managers requiring their subordinates to accompany them for evening entertainment, outside of regular work hours.

According to China’s new civil code, which came into effect in January, employers must take responsibility for investigating and adjudicating incidents of sexual harassment that happen under their watch. The code does not, however, recommend specific punishments for violators.

Additional reporting: Zhang Chaoyan; contributions: Chen Qi’an; editor: David Paulk.

(Header image: People Visual)