DSW’s and the Coalition to Decriminalize Sex Work’s (CDSW’s) organizational Conflict of Interest policy reads as follows:

1. Act with honesty and transparency

I agree to bring to light any conflicts or benefits of interest that I might have with any decision being made at DSW/CDSW.

DSW may require staff and stakeholders to submit written accounts of potential conflicting interests, which might include (1) formal or former affiliations with similar or relevant organizations, or (2) a profit motive relating to DSW/CDSW transactions.

2. Act in DSW’s/CDSW's interests

In all dealings with DSW/CDSW, I agree to act appropriately regarding conflicts of interest, including recusing myself from discussions in which I have a personal financial stake.

I agree to consider always what impact any transactions — whether they are conflicts of interest or benefits of interest — could have on how DSW/CDSW is perceived by the news media, government agencies, the organization’s donors, the organization’s staff and volunteers, other stakeholders, and the public generally.


Sexual Harassment Policy

DSW is committed to providing for all its employees a safe environment that’s free from discrimination and harassment, including sexual harassment. DSW will operate a zero-tolerance policy for any form of sexual harassment in the workplace and with work-related activities regardless of the location, promptly investigating all allegations of sexual harassment. Any person found to have sexually harassed another will face disciplinary action, up to and including dismissal from employment.

All complaints of sexual harassment will be taken seriously and treated with respect and in confidence. No one will be victimized for making such a complaint.

Definition of sexual harassment

Sexual harassment is considered to be unwelcome conduct of a sexual nature that makes a person feel offended, humiliated, and/or intimidated. This includes situations where a person is asked to engage in sexual activity as a condition of the person’s employment, as well as situations which create an environment that is hostile, intimidating, or humiliating.

Sexual harassment can involve one or more incidents and actions, which could be physical, verbal, or non-verbal in nature. Examples of conduct or behavior that constitute sexual harassment include, but are not limited to, the following:

Physical conduct

• Unwelcome physical contact, including patting, pinching, stroking, kissing, hugging, fondling, or inappropriate touching
• Physical violence, including sexual assault
• The use of job-related threats or rewards to solicit sexual favors

Verbal conduct

• Comments about a worker’s appearance, age, private life, etc.
• Sexual comments, stories, and jokes
Sexual advances
Repeated and unwanted social invitations for dates or physical intimacy
Insults based on the sex of the worker
Condescending or paternalistic remarks
• Sending sexually explicit messages (via email or other forms of communication)

Non-verbal conduct

• Leering
• Displaying sexually explicit or suggestive material
• Sexually suggestive gestures
• Whistling

Anyone can be a victim of sexual harassment, regardless of their sex and the sex of the harasser, including two people of the same sex or other gender combinations. What matters is that the sexual conduct was unwanted and unwelcome by the person against whom the conduct was directed.

DSW recognizes that sexual harassment is a manifestation of power relationships and often occurs within unequal relationships in the workplace—for example, between a manager or supervisor and their employee.

Anyone, including DSW employees, clients, customers, contractors, or visitors who sexually harass another will be reprimanded in accordance with this organizational policy.

All sexual harassment is prohibited, whether it takes place during social events, business trips, training sessions, or conferences that may or may not be sponsored by DSW.

Reporting sexual or other unlawful harassment

Anyone who is subjected to sexual harassment should, if possible, inform the alleged harasser that the conduct is unwanted and unwelcome. That said, DSW recognizes that sexual harassment may occur in unequal relationships (between a supervisor and their employee), and therefore it might not be practicable for the aggrieved person to inform the alleged harasser.

Any employee who believes they have been subjected to or have witnessed any form of unlawful harassment by a manager, coworker, vendor, or contractor should report the situation immediately to their department head, to any other department head, or to the executive director. Employees may be asked to provide an initial report (either in writing or orally) that includes details of the incident(s), the names of the individuals involved, the names of any witnesses, direct quotes when relevant, and any documentary evidence.

DSW will conduct a prompt and thorough investigation following any report of harassment. (The executive director will manage the investigation; if the executive director faces harassment allegations, the board of directors and/or an outside attorney will manage the investigation instead.)  To the extent possible, confidentiality will be maintained in order to ensure a thorough investigation. Any employee who is found, after a thorough investigation, to have engaged in sexual or other harassment will be subjected to disciplinary action.

Sanctions and disciplinary measures

Anyone who has been found to have sexually harassed another person under the terms of this policy may be subjected to any of the following sanctions:

• verbal or written warning
• adverse performance evaluation
reduction in wages
• demotion
• suspension
• dismissal

The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable deterrent sanctions will be applied in order to ensure that incidents of sexual harassment aren’t treated as trivial. Certain serious cases, including physical violence, will result in the immediate dismissal of the harasser.

Retaliation prohibited

DSW will not retaliate—and prohibits retaliation—against any employee or other aggrieved party for making a good-faith complaint of harassment and/or for providing good-faith assistance with an investigation. If any employee or other party feels they’ve been the subject of retaliation, they should report such concerns to their department head, any other department head, or the executive director immediately.

Implementation of this policy

DSW will ensure that this organizational policy is shared with all relevant people, including but not limited to being included in the staff’s manual of organizational policies. In addition, all new employees must be trained on the content of this policy as part of their induction into the company.

Every year, DSW will conduct a refresher training course or discussion about the content of this policy.

Monitoring and evaluation

DSW recognizes the importance of monitoring this sexual harassment policy and will collect information anonymously on how the policy is being used and whether it’s effective.

Supervisors, managers, and those responsible for addressing sexual-harassment allegations will report annually on compliance with this policy to the executive director and the board of directors, including the number of incidents, how they were dealt with, and any recommendations made. As a result of these annual reports, the organization will evaluate the effectiveness of this policy and periodically make any changes that are needed.



[The organizations’ pair of federal tax forms (the Form 990) for calendar year 2018 will be posted here by May 2019.]