In Fiol v. Doellstedt (1996) 50 Cal.App.4th 1318, the Court rejected the extension of liability to a supervisor for the alleged failure to investigate, control, monitor, discipline, or restrain a harassing employee. The court concluded that, while a supervisor is personally liable for his or her own actions, the supervisor is not liable for the mere failure to prevent the conduct of another employee, either directly or as an aider and abettor. (Id. at p. 1331.) The Court stated that in considering the aiding and abetting liability of a person under section 12940, subdivision (i), the statements in Fiol, supra, 50 Cal.App.4th 1318, must be read in light of its statement of the rule that "the FEHA provides that an employer is strictly liable for the harassment of an employee by an agent or supervisor, while the employer is only liable for harassment of an employee by nonagents or nonsupervisors if the employer, its agents or supervisors know or should know of the harassing conduct and the employer fails to take immediate and appropriate corrective action. " (Id. at p. 1328, ) Also in Fiol, supra, 50 Cal.App.4th 1318, the court referred to the decision in Janken v. GM Hughes Electronics (1996), as stating that "'it was the intent of the Legislature to place individual supervisory employees at risk of personal liability for personal conduct constituting harassment, but that it was not the intent of the Legislature to place individual supervisory employees at risk of personal liability for personnel management decisions later considered to be discriminatory. We conclude that the Legislature's differential treatment of harassment and discrimination is based on the fundamental distinction between harassment as a type of conduct not necessary to a supervisor's job performance, as contrasted with business or personnel management decisions -which might later be considered discriminatory-as inherently necessary to performance of a supervisor's job.' While the Janken court considered the distinction between harassment and discrimination, its analysis is equally relevant to the distinction between harassing and nonharassing supervisors. A nonharassing supervisor who fails to take action on a sexual harassment complaint by a subordinate has not engaged in personal conduct constituting harassment, but rather has made a personnel management decision which in retrospect may be considered to be inadequate or improper." (Fiol, supra, 50 Cal.App.4th at pp. 1330-1331.)