Harassment & Discrimination Policy Woodstock Farm Sanctuary is committed to providing a safe working environment for all its employees, free from discrimination and harassment, including sexual harassment. In addition to complying with federal and state nondiscrimination laws, the goal of this policy is to (a) protect employees from discrimination and harassment, including employees not covered by existing law, and (b) create a culture where every individual is treated with respect. Woodstock Farm Sanctuary will operate a zero tolerance policy for discrimination or harassment in the workplace by investigating any complaint made by or about an employee. Any employee found to have harassed or discriminated against another will face corrective and disciplinary action, up to and including dismissal from employment. All allegations of discrimination or harassment will be taken seriously, promptly investigated, and there will be no retaliation for making such allegations. Any attempt of retaliation for making such allegations in good faith may constitute grounds for dismissal. Complaints will be confidential and records will be kept in a confidential file, not in the complainant’s personnel file. Limited disclosure may be required in order to conduct an investigation, or in the case of imminent danger to the employee. Woodstock Farm Sanctuary recognizes that sexual harassment can occur between people of the same sex or gender, including those who don’t identify with a specific gender. During business travel, no employee will be required to share a bedroom with a person of a different sex or gender, or any other person that would result in their feeling vulnerable or unsafe. The employee must inform their supervisor if they’re uncomfortable rooming with a particular sex, gender, or person. No policy can prescribe what should be done on every occasion because circumstances vary. If employees need help or advice about a particular situation or circumstance, employees are encouraged to contact their supervisor or a Designated Person. The following are Designated Persons: A direct supervisor, any manager, the Managing Director and the Executive Director. Definitions Discrimination is the differential treatment of an employee on the basis of race, color, religion, sex (including pregnancy), national origin, age, disability, genetic information, gender presentation, or any other factor that is legislatively protected in the country in which you work (“Protected Classes”). Per federal law, discrimination is illegal in work-related decisions including hiring, firing, pay, job assignments, promotions, layoff, training, fringe benefits, and any other term or condition of employment. Harassment is unwelcome conduct including physical, verbal, and nonverbal behaviors, and results in a hostile environment. Per federal law, harassment is illegal when unwelcome conduct is related to any of the Protected Classes and when enduring the conduct becomes a condition of continued employment, or the conduct is so severe or pervasive that a reasonable person would consider the working environment intimidating, hostile, or abusive. Woodstock Sanctuary recognizes that existing federal and state nondiscrimination laws cannot cover all types of behavior or groups of people. Woodstock Sanctuary therefore further defines discrimination as differential treatment of any person with regard to work-related decisions based on any characteristics outside of professional qualifications, and harassment as unwelcome conduct against any person where they feel threatened, publicly humiliated, or intimidated. Examples of harassment include, but are not limited to: Humiliation in front of coworkers Repeated unwelcome remarks or jokes Exercising, attempting to exercise, or threatening to exercise physical force against an employee in the workplace that causes or could cause physical injury to the employee Comments that promote stereotyping of any of the Protected Classes Comments related to an employee’s ethnic, racial, or religious affiliation, or their sexual orientation, gender, or age, that are publicly humiliating, offensive, threatening, or that undermine the employee’s role in a professional environment Sexual harassment is unwanted conduct that is sexual in nature. Examples of sexual harassment include, but are not limited to: Unwelcome physical contact including touching, patting, pinching, stroking, kissing, hugging Sexual comments, stories, and jokes, including bragging about sexual prowess Repeated and unwanted social invitations for dates or physical intimacy The use of job-related threats or rewards to solicit sexual favors Comments on an employee’s appearance or private life Display of sexually explicit or suggestive material Insults based on the sex or gender identity of the worker Physical violence, including sexual assault Sending sexually explicit messages Sexually-suggestive gestures Whistling in the context of “cat-calling” Leering Implementation Woodstock Sanctuary will provide this policy to paid staff, interns, volunteers and board members. Recipients of the policy will sign it to demonstrate that they have read and understood it. Woodstock Sanctuary will include this policy in the staff handbook. It is the responsibility of every supervisor to ensure that all of their employees are aware of this policy. Complaints Procedure Self-Help Employees are encouraged to keep a written record of the date, time, details of the incident(s), and witnesses, if any. Where employees are comfortable doing so, they can attempt to resolve their concerns by directly communicating disapproval to the person whose conduct is offensive. Initial Complaint If an employee doesn’t feel comfortable approaching the alleged harasser to ask them to stop their behavior, or if the alleged harasser continues the behavior after being asked to stop, the employee should approach a designated staff member responsible for receiving discrimination and harassment complaints. When the Designated Person receives a complaint, they will: Record the dates, times, and facts of the incident(s). Ensure that the complainant understands the procedure for resolving the complaint. Identify the outcome wanted by the complainant. Discuss and agree on next steps: either an informal or formal complaint, with the understanding that resolving the matter informally will not prevent the complainant from pursuing a formal complaint if they are not satisfied with the outcome. Inform the complainant that they have the right to contact legal counsel, such as the U.S. Equal Employment Opportunity Commission (EEOC) or other legal counsel, if they think this is necessary. Respect the choice of the complainant Keep a confidential record of all discussions. Ensure that the above is completed within 5 days of initial discussion of the complaint. Informal Complaint If the employee decides to resolve the matter informally, the Designated Person will: Give the alleged harasser an opportunity to respond to the complaint. Ensure the alleged harasser understands the procedure for resolving the complaint. If the complainant is comfortable, facilitate discussion between both parties to achieve an informal resolution that is acceptable to the complainant. If the complainant is not comfortable, achieve an informal resolution by speaking with the complainant and alleged harasser separately. If the Designated Person is unable to achieve an informal solution that is acceptable to the complainant, consult the Executive Director, who may refer the matter to a mediator. Keep a confidential record of all actions taken to resolve the complaint. Inform the Executive Director of the complaint, maintaining the anonymity of the parties to the fullest extent possible; in the case where the Executive Director is the alleged victim or harasser, inform a member of the board of directors. Ensure that the above is completed within 10 days of receiving the complaint. In the case where the Designated Person has difficulty completing these items within 7 days, they may work with another Designated Person to complete their duties. Follow up 2 weeks after the discussion to ensure that the behavior has stopped. Formal Complaint If the employee wants to make a formal complaint, or if the informal complaint mechanism does not lead to a satisfactory outcome for the complainant, a formal complaint should be made. At the time of the formal complaint, the Designated Person who initially received the complaint will form a committee comprised of themself, the Managing Director and the Executive Director. In the case that a committee member has a conflict of interest due to their relationship with the complainant or alleged harasser, or for another reason, they will excuse themselves from the investigation. This committee will proceed to investigate the complaint, or refer the matter to an outside investigator. Note: The steps below are written assuming the committee is carrying out the investigation. An investigation will be carried out: In the case where the Executive Director is the victim or alleged harasser, inform a member of the board of directors. Interview the employee and their alleged harasser separately. Interview other relevant third parties, such as witnesses, separately. Produce a report detailing the investigations, findings, and any recommendations. The committee may not be able to determine whether the incident(s) of harassment took place. For this reason, the committee will focus on a remedy that is appropriate to the alleged incident and ensures proper functioning of the workplace. The remedy may involve disciplinary action up to and including dismissal for the harasser, and may involve reparations for the complainant. Note: Complaints must be made in good faith; in the case where an employee makes multiple complaints against the same alleged harasser, and the Designated Person(s) believes the complaints may be a form of harassment, the complainant may face disciplinary action. Witnessing Discrimination and Harassment Any employee who becomes aware of discrimination or harassment in the workplace, even if they are not directly involved, is expected to report the incident to a Designated Person. The Designated Person will document the incident and consult with the alleged victim to determine if the victim would like to file a complaint. Complaints Against Third Parties Woodstock Sanctuary recognizes that an employee can be subject to harassment from a non-employee who supports or conducts business with the organization, such as a donor, overnight host, contractor, consultant, or volunteer (“third party”). An employee who believes that they have been harassed by a third party is encouraged to file a complaint with a Designated Person. The Designated Person will document the complaint and take whatever action is appropriate in the circumstances. For example, if a fundraiser files a complaint about a donor, the Designated Person may, with the permission of the employee, recommend to their supervisor that the employee no longer be required to work with that donor. Complaints By Third Parties Woodstock Sanctuary recognizes that a non-employee can be subject to harassment from Sanctuary employees, such as a volunteer being harassed by an employee at a work-related conference. If a non-employee believes that they have been harassed by an employee and reports the conduct to an employee, contractor, or board member, the third party will be referred to a Designated Person. The Designated Person will follow the procedure for informal and formal complaints above.