Can only a supervisor engage in “hostile work environment” harassment?
A. No. Unlike tangible employment action harassment, “hostile work environment” harassment can be committed by a supervisor, co-worker or non-employee (e.g., contractor, etc.). In contrast to a claim of harassment that results in a tangible employment action, a “hostile work environment” harassment claim does not require a showing that the victim was fired, denied a promotion, or otherwise penalized in a tangible way as a result of the harassment.