Sexual harassment is harassment on the basis of sex, sexual orientation, self-identified or perceived sex, gender expression, gender identity and the status of being transgender. Sexual harassment includes unwelcome conduct which is either of a sexual nature, or which is directed at an individual because of that individual’s sex, when:

A sexually harassing hostile work environment includes, but is not limited to, words, signs, jokes, pranks, intimidation or physical violence which are of a sexual nature, or which are directed at an individual because of that individual’s sex.

Sexual harassment also consists of sexually explicit derogatory statements or sexually discriminatory remarks that are offensive or objectionable to the recipient, that cause the recipient discomfort or humiliation, or that interfere with the recipient’s job performance. It includes any unwanted verbal or physical advances that are sexual in nature.

Sexual harassment also occurs when a person in authority tries to trade job benefits for sexual favors. This can include hiring, promotion, continued employment or any other terms, conditions or privileges of employment. This is called “quid pro quo” harassment.

Any employee who feels harassed should report it so that any violation of this policy can be corrected promptly. Any harassing conduct, even a single incident, can be addressed under this policy.

Examples of Sexual Harassment

Who Can Be a Target of Sexual Harassment?

Sexual harassment can occur between any individuals, regardless of their sex or gender.  

Winrock protects employees, paid or unpaid interns, and non-employees, including independent contractors, and those employed by companies contracting to provide services in the workplace.

Harassers can be a superior, a subordinate, a coworker or anyone in the workplace including an independent contractor, contract worker, vendor, client, customer or visitor.

Where Can Sexual Harassment Occur?

Prohibited sexual harassment is not limited to the physical workplace itself. It can occur while employees are traveling for business or at employer-sponsored events or parties. Calls, texts, emails, and social media usage by employees can constitute harassment, even if they occur away from the workplace premises, on personal devices, or during non-work hours.

Reporting Sexual Harassment

Preventing sexual harassment is everyone’s responsibility. Winrock cannot prevent or remedy sexual harassment unless it knows about it. 

Any employee who has been subjected to behavior that may constitute sexual harassment is encouraged to report such behavior using any of the channels described in this Code: to a manager, Chief of Party, HR Lead or HR Manager, any member of the Executive Team, the Chief Risk and Compliance Officer, or via Winrock’s Hotline, online or by telephone.

Anyone who witnesses or becomes aware of potential instances of sexual harassment should report such behavior to the same channels: a manager, Chief of Party, HR Lead or HR Manager, any member of the Executive Team, the Chief Risk and Compliance Officer, or via Winrock’s Hotline, online or by telephone.

All managers who receive a complaint or information about suspected sexual harassment, observe what may be sexually harassing behavior, or for any reason suspect that sexual harassment is occurring are required to report such suspected sexual harassment to the Chief Risk and Compliance Officer.

All complaints or information about sexual harassment will be investigated, led by the Chief Risk and Compliance Officer. Investigations will be conducted in a timely manner and will be confidential to the extent possible.

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