In the area of sexual harassment, quid pro quo describes a form of sexual blackmail. Quid pro quo sexual harassment is the conditioning of employment benefits on an employee's sub-mission to unwelcome sexual conduct. Title VII of the civil rights act (42 . § 2000 (e)-2 ) provides a remedy for quid pro quo sexual harassment. Most courts follow the Equal Employment Opportunity Commission's guidelines and hold that the necessary quid pro quo exists if submission to unwelcome sexual advances "is made either explicitly or implicitly a term or condition of an individual's employment" or if submission to unwelcome sexual advances "is used as the basis for employment decisions affecting such individual" (29 . § (a)(1)-(2) ).