Harassment Policy

“Be Excellent to each other” is our motto.

AUTONOMY Associates and Students are held to a standard of excellence that exemplifies that mission.

Harassment/Sexual Harassment/Discrimination Policy Statement

AUTONOMY is committed to providing a safe environment for all its employees free from discrimination on any ground and from harassment at work including sexual harassment. Autonomy Unlimited will operate a zero-tolerance policy for any form of sexual harassment in the workplace, treat all incidents seriously and promptly investigate 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 confidence.

No one will be victimized for making such a complaint.


Who Does this Policy Statement Apply To?

This Policy Statement applies to all employees, freelancers, volunteers, sub-contractors, managers, assistants, and agents working for, with, or on behalf of AUTONOMY . No exemptions apply.

Anyone can be a victim of sexual harassment, regardless of their sex and of the sex of the harasser.

AUTONOMY recognizes that sexual harassment may also occur between people of the same sex. What matters is that the sexual conduct is unwanted and unwelcome by the person against whom the conduct is directed. The principles involved here continue to apply to race, color, religion, or national origin.

Anyone, including employees of AUTONOMY clients, customers, faculty, students, casual workers, contractors, or visitors who sexually harasses another will be reprimanded in accordance with this internal policy.

This does NOT apply to personal conversations and relationships outside of AUTONOMY, but discretion is advised. Being excellent to each other includes having responsibility for the situations that you are involved in.

All sexual harassment is prohibited whether it takes place within Autonomy Unlimited physical/virtual premises or outside, including at social events, business trips, training sessions or conferences sponsored by AUTONOMY.

Definition of sexual harassment

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

Sexual harassment can involve one or more incidents and actions constituting harassment may be physical, verbal, and non-verbal. Examples of conduct or behavior which constitute sexual harassment include, but are not limited to:

Physical conduct

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

Verbal conduct

  • Comments on 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 (by phone or by email)

Non-verbal conduct

  • Display of sexually explicit or suggestive material
  • Sexually suggestive gestures
  • Whistling
  • Leering
  • Displaying nudity in virtual meetings

Disciplinary Actions

Employees are subject to disciplinary action, up to and including removal, for engaging in sexually harassing behavior.

Disciplinary action will include:

  • A written warning
  • A poor performance review or evaluation
  • A performance improvement plan
  • A reduction in rank or pay
  • Termination of employment
  • Termination of Lifetime Enrollment
  • Ban from all AUTONOMY community networks

Although not every instance of inappropriate sexual behavior may fit the legal definition of sexual harassment, such behavior in the workplace undermines morale and violates the AUTONOMY standards of conduct. Accordingly, disciplinary action may result even if the conduct is not sexual harassment under the law.

Complaints Procedures

Anyone who is subject to sexual harassment should, if possible, inform the alleged harasser that the conduct is unwanted and unwelcome. AUTONOMY recognizes that sexual harassment may occur. in unequal relationships (i.e., between a supervisor and his/her employee) and it may not be possible for the victim to inform the alleged harasser.

If a victim cannot directly approach an alleged harasser, he/she can use this safety portal to file a confidential complaint to be received by Lisa Arbecheski: [email protected]

When a complaint of sexual harassment is received, AUTONOMY will designate a special person assigned to:

  • immediately record the dates, times, and facts of the incident(s)
  • ascertain the views of the victim as to what outcome he/she wants
  • ensure that the victim understands the company’s procedures for dealing with the complaint
  • discuss and agree the next steps: either informal or formal complaint, on the understanding
  • that choosing to resolve the matter informally does not preclude the victim from pursuing a
  • formal complaint if he/she is not satisfied with the outcome
  • keep a confidential record of all discussions
  • respect the choice of the victim
  • ensure that the victim knows that they can lodge the complaint outside of the company
  • through the relevant country/legal framework

Throughout the complaints procedure, a victim is entitled to be helped by a counsellor within the company. AUTONOMY will nominate a counsellor and provide them with special training to enable them to assist victims of sexual harassment. AUTONOMY recognizes that because sexual harassment often occurs in unequal relationships within the workplace, victims often feel that they cannot come forward. AUTONOMY understands the need to support victims in making complaints.

Informal Complaints Mechanism

If the victim wishes to deal with the matter informally, the designated person will:

  • give an opportunity to the alleged harasser to respond to the complaint
  • ensure that the alleged harasser understands the complaints mechanism
  • facilitate discussion between both parties to achieve an informal resolution which is acceptable to the complainant, or refer the matter to a designated mediator within the company to resolve the matter
  • ensure that a confidential record is kept of what happens
  • follow up after the outcome of the complaints mechanism to ensure that the behavior has stopped
  • ensure that the above is done speedily and within 60 days of the complaint being made

Formal Complaints Mechanism

If the victim wants to make a formal complaint or if the informal complaint mechanism has not led to a satisfactory outcome for the victim, the formal complaint mechanism should be used to resolve the matter.

The designated person who initially received the complaint will refer the matter to a special assigned agent to instigate a formal investigation. The special assigned agent will report to a panel of three assigned managers in accordance with this policy.

The person carrying out the investigation will:

  • interview the victim and the alleged harasser separately
  • interview other relevant third parties separately
  • decide whether or not the incident(s) of sexual harassment took place
  • produce a report detailing the investigations, findings and any recommendations
  • if the harassment took place, decide what the appropriate remedy for the victim is, in consultation with the victim (i.e.- an apology, a change to working arrangements, a promotion)
  • if the victim was demoted as a result of the harassment, training for the harasser, discipline, suspension, dismissal)
  • follow up to ensure that the recommendations are implemented, that the behavior has stopped and that the victim is satisfied with the outcome
  • if it cannot be determined that the harassment took place, he/she may still make recommendations to ensure the proper functioning of the workplace
  • keep a record of all actions taken
  • ensure that all records concerning the matter are kept confidential
  • ensure that the process is done as quickly as possible and, in any event, within 7-14 days of the complaint being made

Outside Complaints Mechanisms

A person who has been subject to sexual harassment can also make a complaint outside of the company. They can do so through their own legal routes.

Sanctions and disciplinary measures

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

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

The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable deterrent sanctions will be applied to ensure that incidents of sexual harassment are not treated as trivial.

Retaliation based on an employee filing a complaint will include disciplinary action.

Implementation Of This Policy

AUTONOMY will ensure that this policy is widely disseminated to all relevant persons. It will be included in the staff handbook. All new employees must be trained on the content of this policy as part of their induction into the company.

Every year, AUTONOMY will require all employees to attend a refresher training course on the content of this policy.

Monitoring And Evaluation

AUTONOMY recognizes the importance of monitoring this sexual harassment policy and will ensure that it anonymously collects statistics and data as to how it is used and whether or not it is effective.

Supervisors, managers and those responsible for dealing with sexual harassment cases will report on compliance with this policy, including the number of incidents, how they were dealt with, and any recommendations made. This will be done yearly. As a result of this report, the company will evaluate this policy’s effectiveness and make any necessary changes.

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