A suggestion for Anti Harassment Policy

(first published on Medium on 11 July 2017)

Being the pragmatic, here is the anti harrassment policy I thought would be useful and relevant for a HR handbook for companies of any size:

1) Anti harrassment (zero tolerance) is a stated belief and policy in the company’s HR handbook and a clause specifically highlighted during both the employment letter signing process and new employee orientation.

2) HR is the de facto department to handle all complaints the company receives, and a cross function department committee (involving at least 1 senior management) will be formed to investigate serious complaints brought against staff and decide on punishments/penalties if any. The committee’s decision will be presented to senior management team for comment and concurrence prior to execution.

2a) HR is to handle all complaints within 3 days of receiving the complaint. HR will interview the complaint originator to get full understanding of the incident. HR will then interview and share the complaint with the “deemed aggressor” to get the other side of story. HR will NOT divulge the identity of the complaining party in any circumstances to the deemed aggressor. The Company undertakes to reach reasonable closure within 4 weeks of receiving complaint.

2b) All complaints given / received will become an record in both parties’ employee records. In the event the company decideds to terminate the deemed aggressor’s employment, the reason for the termination will not be shared in the individual’s future employment reference check requests, unless specific evidence were gathered.

3) For individuals who have more than 3 complaints (from different individuals), an discipline committee will be formed to investigate the complaints. For individuals receiving multiple similar complaints from different parties, they may be asked to resign or have their employments terminated immediately by the company for misconduct, even if no concrete evidence could be gathered. As an employer, the company is obligated by law to provide a safe working environment. If a person is deemed harassing by multiple co-workers, the person is deemed to be a threat to the safe working environment that the company has built up.

4) If there is no HR functions in the firm, a whistle blowing system should be set up. Eg could be a dedicated email that’s received by 2–3 senior members of the company.

5) A similar structure could be set up for harrassment complaints for external parties, say suppliers or investee firms. Key is there should be multiple internal parties to receive this complaints jointly, so there is no risk of “cover up”.

— -

But yes I can’t think of a good way to communicate to external parties of such a system, other than inserting this information during an “onboarding program” say vendor registration form etc. Am not sure if VCs have a similar onboaring process in the start up talent scouting?? If no, are they willing to put such in place??

Point being, after the decency pledge, concrete actions should happen — I hope to see it soon in all work places.

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