SparkWell Anti-Harassment & Bullying Policy

1. About this Policy

1.1. Anti Entropy is committed to providing a working environment free from harassment and bullying and ensuring all staff are treated and treat others with dignity and respect.

1.2. This policy covers harassment or bullying at work and outside the workplace, such as on business trips, work-related events, or social functions.

1.3. This policy covers harassment and bullying by staff (including employees, consultants, contractors, and agency workers) and third parties such as SparkWell Project Leads, donors, suppliers, or visitors.

1.4. This policy does not form part of any employment or contractor agreement, and we may amend it at any time.

1.5. Important Note: Employees contracted under an Employer of Record (EOR), such as Deel, should also refer to the EOR's harassment policies, which may provide additional protections.

2. What is Harassment?

2.1. Harassment is any unwanted physical, verbal, or non-verbal conduct that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment for them. A single incident can amount to harassment.

2.2. It also includes treating someone less favorably because they have previously submitted or refused to submit to such behavior.

2.3. Protected Categories

2.3.1. Unlawful harassment may involve conduct related to:

• Sexual nature (sexual harassment)
• Age
• Disability
• Gender reassignment
• Marital or civil partner status
• Pregnancy or maternity
• Race, color, nationality, ethnic or national origin
• Religion or belief
• Sex or sexual orientation

2.3.2. Important: Harassment is unacceptable even if it does not fall within any of these categories.

2.4. Examples of Harassment

2.4.1. Harassment may include, for example:

• Unwanted physical conduct or "horseplay," including touching, pinching, pushing, and grabbing
• Unwelcome sexual advances or suggestive behavior (which the harasser may perceive as harmless)
• Offensive emails, text messages, or social media content
• Mocking, mimicking, or belittling a person's disability
• Displaying or sharing offensive images, jokes, or materials
• Intrusive questions about someone's personal life
• Spreading rumors or making derogatory comments

2.4.2. A person may be harassed even if they were not the intended "target." Harassment affects everyone who witnesses or is aware of it.

3. What Is Bullying?

3.1. Bullying is offensive, intimidating, malicious, or insulting behavior involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined, or threatened. Power does not always mean being in a position of authority but can include personal strength and the power to coerce through fear or intimidation.

3.2. Bullying can take the form of physical, verbal, and non-verbal conduct.

3.3. Examples of Bullying

3.3.1. Bullying may include, for example:

• Physical or psychological threats
• Overbearing and intimidating levels of supervision
• Inappropriate derogatory remarks about someone's performance
• Deliberately excluding someone from meetings, communications, or social events
• Setting unrealistic deadlines or excessive workloads designed to cause failure
• Persistent unjustified criticism
• Shouting, yelling, or using aggressive language
• Undermining someone's work or taking credit for their contributions

3.4. What Is NOT Considered Harassment or Bullying

3.4.1. The following actions, when conducted professionally and appropriately, do not constitute harassment or bullying:

• Providing constructive feedback on work performance
• Setting reasonable performance expectations and deadlines
• Addressing poor performance or misconduct through proper procedures
• Making legitimate business decisions about work assignments, scheduling, or resources
• Enforcing organizational policies consistently
• Having occasional disagreements or personality conflicts (unless they escalate to harassment)

3.4.2. However: If these legitimate actions are carried out in an unreasonable, aggressive, or humiliating manner, they may constitute bullying.

3.4.3. Important: Legitimate, reasonable, and constructive criticism of your performance or behavior, or reasonable instructions given during your employment, will not amount to bullying on their own.

4. Digital and Remote Workplace Conduct

4.1. Because Anti Entropy operates with remote staff, this policy explicitly covers:

4.1.1. Video meetings: Harassment or bullying during Zoom/video calls, including inappropriate comments, gestures, or backgrounds

4.1.2. Slack and messaging: Inappropriate messages, excluding people from channels, hostile communications, or excessive/intrusive messages

4.1.3. Email: Harassing, threatening, or demeaning emails

4.1.4. Social media: Harassment on platforms like LinkedIn, Twitter, or other social media, even on personal accounts, when it relates to work relationships

4.1.5. Virtual events: Harassment during online conferences, webinars, or virtual social events

4.2. The standards of professional conduct apply equally to digital and in-person interactions.

5. If You Are Being Harassed or Bullied

5.1. Informal Resolution

5.1.1. If you are being harassed or bullied, consider whether you feel able to raise the problem informally with the person responsible. You should explain clearly that their behavior is not welcome or makes you uncomfortable.

5.1.2. If this is too difficult or embarrassing, you should speak to your supervisor, who can provide confidential advice and assistance in resolving the issue formally or informally.

5.1.3. Note: For most employees and contractors at Anti Entropy, your supervisor is Jeffrey Poche (Board President). If unclear who to contact, email support@antientropy.org.

5.2. Formal Complaint

5.2.1. If informal steps are inappropriate or have not been successful, you should raise the matter formally under our Grievance policy.

6. How to Report

6.1. If you experience or witness harassment or bullying:

6.1.1. Informal resolution: If comfortable, address the issue directly with the person or speak to your supervisor

6.1.2. Formal complaint: Contact your supervisor or Jeffrey Poche (Board President)

6.1.3. If your supervisor is involved: Contact Jeffrey Poche (Board President) or another board member

6.1.4. Anonymous reporting: You may submit concerns to support@antientropy.org

6.2. All reports will be taken seriously and investigated promptly and confidentially.

7. Investigation Process

7.1. We will investigate complaints in a timely and confidential manner, typically completing investigations within 30 days of receiving a complaint. Where possible, the investigation will be conducted by someone with appropriate experience and no prior involvement in the complaint.

7.2. Details of the investigation, the names of the person making the complaint, and the person accused must only be disclosed on a "need to know" basis.

7.3. We will consider whether steps are necessary to manage any ongoing relationship between you and the person accused during the investigation, such as:

• Temporary work arrangement changes
• Limited contact protocols
• Interim safety measures

8. Investigation Outcomes

8.1. Once the investigation is complete, we will inform you of our decision.

8.2. If Harassment or Bullying is Substantiated

8.2.1. If the harasser or bully is an employee or contractor, the matter will be dealt with under our Misconduct & Discipline policy as a case of possible misconduct or gross misconduct

8.2.2. If the harasser or bully is a third party, such as a SparkWell Project Lead, donor, customer, or other visitor, we will consider appropriate action to deal with the problem

8.3. Ongoing Relationship Management

8.3.1. Whether or not your complaint is upheld, we will consider how best to manage any ongoing working relationship between you and the person concerned.

9. If You Witness Harassment or Bullying

9.1. If you witness harassment or bullying of a colleague:

9.1.1. Intervene safely: If you feel safe doing so, speak up or redirect the conversation

9.1.2. Support the person: Check in with them privately and ask how you can help

9.1.3. Report it: Even if the person affected hasn't reported it, you may report what you witnessed

9.1.4. Don't ignore it: Silence can enable harmful behavior to continue

9.2. You will not face retaliation for reporting harassment or bullying you witness in good faith.

10. Protection and Support for Those Involved

10.1. Staff who make complaints or participate in good faith in any investigation must not suffer any form of retaliation or victimization. Anyone found to have retaliated against or victimized someone in this way will be subject to disciplinary action under our Misconduct & Discipline policy.

10.2. False or Malicious Complaints

10.2.1. Making a complaint in good faith, even if it is not upheld, will not result in disciplinary action. However, making a complaint that you know to be untrue, or providing false information during an investigation, is a serious matter that may result in disciplinary action under our Misconduct & Discipline policy.

11. Support and Resources

11.1. If you are affected by harassment or bullying, support is available:

11.2. Internal Support

11.2.1. Confidential discussion: Contact Jeffrey Poche (Board President) or support@antientropy.org

11.2.2. Employee Assistance Program: If available through your benefits (Deel), contact them for counseling support

11.3. External Resources

11.3.1. National Domestic Violence Hotline: 1-800-799-7233 (available 24/7)

11.3.2. RAINN (Sexual Assault Hotline): 1-800-656-4673 (available 24/7)

11.3.3. Crisis Text Line: Text HOME to 741741

11.3.4. National Suicide Prevention Lifeline: 988 (available 24/7)

11.4. Taking care of your wellbeing is important. We encourage you to seek support if you need it.

12. Record-keeping

12.1. We maintain confidential records of all harassment and bullying complaints, including:

• The nature of the complaint and parties involved
• Investigation notes and findings
• Actions taken and outcomes
• Any follow-up or monitoring

12.2. Records are kept separately from general personnel files and are accessed only on a need-to-know basis. Records are retained in accordance with our document retention policy and applicable laws.

13. Policy Review

13.1. This policy will be reviewed annually and updated as needed to reflect changes in Anti Entropy's operations and applicable laws.