Sexual and Other Unlawful Harassment


The Foundation seeks a collegial, productive, supportive, and appreciative culture and workplace in which all individuals can benefit equitably. The work environment is expected to be conducive to these goals and respectful interactions among staff are necessary to achieve the goals. Harassment of any kind by anybody is antithetical to the goals. This policy addresses the Foundation’s approach to preventing, addressing, and mitigating any behavior that could constitute sexual or other unlawful harassment.

Policy Statement

The Foundation strongly disapproves of and will not tolerate the sexual harassment of any of its employees by anyone, including, but not limited to, any supervisor, coworker, visitor, vendor, or grantee of the Foundation. The Foundation also strongly disapproves of and will not tolerate the harassment of any of its employees on the basis of their gender, race, color, religion, national origin, age, sexual orientation or disability. The Foundation is committed to maintaining a work environment that is free of harassment of any kind. The Foundation believes it is the responsibility of all employees to assist the Foundation in providing a workplace that is free from sexual and other unlawful harassment at all times by not engaging in offensive or inappropriate harassing behavior and by reporting incidents of such behavior.

Prohibited Conduct

Foundation policy prohibits any conduct which has the effect of adversely affecting an employee's job performance or which creates a hostile, intimidating, or offensive working environment. Prohibited conduct can be verbal, physical or visual. Examples of prohibited conduct are cited below. Such conduct may constitute sexual or other unlawful harassment even if it is not directed at any one individual employee. Sexual or other harassment is unacceptable in the workplace and in other work-related settings, such as business meetings, grantee sites, or business-related social events.

Specific Examples of Prohibited Conduct

Some examples of conduct which may constitute prohibited harassment include but are not limited to the following:

  • Lewd or sexually suggestive comments, gestures or actions;
  • Unwelcome sexual advances;
  • Explicit sexual propositions;
  • Sexual innuendo;
  • Requests for sexual acts or favors (with or without accompanying promises or threats of reciprocal favors or actions);
  • Foul or obscene language or gestures;
  • Sexually oriented "kidding," "teasing," or "practical jokes;"
  • Jokes or slurs about gender-specific traits;
  • Display of foul, obscene, or sexually explicit printed or visual material, including pictures, greeting cards, articles, books, magazines, photos, or cartoons;
  • Physical contact such as patting, pinching, or intentionally brushing against another's body; or
  • Slurs, jokes or degrading comments concerning gender, age, race, color, national origin, religion, sexual orientation or disability.

Reporting Sexual and Other Unlawful Harassment

Employees who believe that they have encountered or witnessed inappropriate behavior are strongly encouraged to promptly notify the offender that his or her behavior is unwelcome. If such notifications are unsuccessful or the employee prefers not to deal directly with the offender, the employee should report the behavior to People and Culture, or any member of the Executive Leadership Team. An employee may also use any of the reporting avenues described in the Policy on Reporting Illegal or Unethical Conduct. In addition, supervisors are required to report any incidents of inappropriate behavior of which they are aware to one of the above-mentioned individuals. Every effort will be made to treat all complaints as confidential consistent with the need to investigate and take corrective action.

Investigation of Sexual and Other Unlawful Harassment Complaints

The Foundation will promptly investigate all reported complaints of sexual or other unlawful harassment. Because sexual harassment covers a wide spectrum of conduct, the precise nature of an investigation and who will conduct it will depend on the circumstances and the Foundation may involve outside investigators or counsel. In all events, any investigation will be thorough, fair, and complete as possible.

Resolution of Sexual and Any Other Unlawful Harassment Complaints

If an investigation confirms that sexual harassment or other inappropriate behavior has occurred, appropriate corrective action, up to and including termination of the offender, will be taken. Disciplinary action will correlate with the nature and gravity of the offense.

Policy Against Retaliation

The Foundation also prohibits retaliation against an employee who complains about alleged inappropriate behavior, even if sufficient evidence is not found to substantiate the complaint. Similarly, the Foundation prohibits retaliation against employees who participate in an investigation of a harassment complaint. Any incidents of retaliation also should be reported to the individuals identified in Reporting Sexual and Other Unlawful Harassment above.


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