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

Decriminalize Sex Work (and Campaign to Decriminalize Sex Work)
Approved by both Boards of Directors on February 15, 2019

Decriminalize Sex Work and its sister organization, the Campaign to Decriminalize Sex Work, are herein referred to together as “DSW.” DSW is committed to providing for all its employees a safe environment that is 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 retaliated against for making such a complaint.

Definition of sexual harassment

Sexual harassment is considered to be unwelcome conduct of a sexual nature. 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 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, sexual orientation, gender identity, or sexual history of the worker
• Condescending or paternalistic remarks
• Sending sexually explicit messages (via email or other forms of communication)

Non-verbal conduct

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

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. What matters is that the sexual conduct was unwanted and unwelcome by the person against whom the conduct was directed. Anyone, including DSW employees found guilty of sexually harassment of 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 or possible 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 one of the Directors of DSW. 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.

The director receiving the complaint will ask the complainant if s/he would like to file a formal complaint. If they say “no”, the director should offer support and consultation on the issue. If they say yes, the director must conference with any second director, barring conflict of interest. If all other directors are conflicted out of the situation, the director should document this in a memo and move forward alone.

One director with consensus from a second director should hire an outside investigator within a reputable investigative agency or law office with experience investigating sexual harassment. This investigator should be retained within 7 business days. DSW funds are to be released to the investigator chosen by the two directors.

The two directors (or one director if everyone else is conflicted) should supervise the investigation and receive the results. All non-implicated, non-complainant directors shall convene and make a consensus decision on implementing the results of the investigation.Any employee who is found, after a thorough investigation, to have engaged in sexual or other harassment will be subjected to disciplinary action.

These may include: written warning, mediation, termination, demotion from supervisory position, or other acts of restorative justice.

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 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.

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 is effective.

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


FINANCIAL REPORTS for calendar year 2019

Coming no later than May 2020