Key Activities was his subordinate employee. The petitionee had urged the petitioner to leave the company because she had rejected him. The petitionee told the petitioner that women are bound to quit their job because they have continuity issues when they start going out with someone or get married. However, if she were to go out with him, he would protect her. He was using his higher official rank to urge her to go out with him. When she rejected his offer, he said “get ready to quit,” which are comments that could have direct influence on her employment status. The petitioner ended up leaving the company. The Commission concluded that the petitionee made the petitioner quit her job, and his act is equivalent to giving a disadvantage in employment for reason that one does not accept sexual speech or sexual demands. Thus, it constitutes sexual harassment. Head of private educational institute demanding a female instructor to wear revealing clothing On November 19, the Commission recommended the petitionee, who is the director of a private educational institute, to take special human rights education sessions. The petitionee demanded a TOEIC instructor to wear a mini skirt, kill heels, coffee-colored stockings, and a lot of makeup, though such clothing had nothing to do with her performance as a TOEIC instructor. The petitionee insisted that he was coaching the petitioner on style so she can look like a professional TOEIC instructor, and that he had no sexual intention or implication. However, the Commission saw the required dress code to be a sort of sexual objectification, as it reveals certain parts of the body such as thighs and legs. The Commission also concluded that wearing a miniskirt against one’s will and putting up with excessive exposure not only gives women a sense of humiliation, but also creates a toxic work environment. Thus, the demand of the petitionee counts as sexual harassment. 100