The Mindfulness Initiative

Sexual Harassment Policy

This sexual harassment policy is based on international good practices and includes the components which make a sexual harassment policy comprehensive.

Policy Statement

The Mindfulness Initiative is committed to providing a safe environment for its staff, volunteers, supporters and associates free from discrimination on any ground and from harassment at work including sexual harassment. The Mindfulness Initiative opposes any form of sexual harassment in its workplace, its programs or other activities, treats all incidents seriously and promptly investigates any 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 victimised for making such a complaint.

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. The following examples of conduct or behaviour which constitute sexual harassment are not exhaustive.  Sexual harassment can include any conduct of a sexual nature which is unwanted and unwelcome by the recipient, including, but 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 favours

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



Anyone can be a victim of sexual harassment, regardless of their sex and of the sex of the harasser. The Mindfulness Initiative recognises 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 Mindfulness Initiative recognises that sexual harassment is a manifestation of power relationships and often occurs within unequal relationships in the workplace, for example between manager or supervisor and employee. The behaviour of anyone, including employees of the Mindfulness Initiative, clients, volunteers or associates who sexually harasses another will be dealt with as a matter of the utmost seriousness in accordance with this internal policy.

All sexual harassment is prohibited whether it takes place within The Mindfulness Initiative’s premises or elsewhere, including training sessions or conferences, trips that are part of the charity’s work, social events, or other gatherings, meetings or work organized by or taking place on behalf of the charity

Complaints procedures

Victims of sexual harassment may want to resolve the matter in different ways. Some may wish to have an informal resolution; others may want more formal measures.

Informal resolution mechanisms may be inappropriate where the allegation is serious or where the harasser is also the victim’s supervisor or any other senior official, stakeholder  or leading figure in the charity and its work.

Anyone who is subject to sexual harassment should, if possible, inform the alleged harasser that the conduct is unwanted and unwelcome. The Mindfulness Initiative recognises that sexual harassment may occur in unequal relationships (i.e. between a supervisor and his/her employee) and that 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 approach one of the designated officials of the charity responsible for receiving complaints of sexual harassment. This person could be another senior member of staff, or a trustee.

When a designated person receives a complaint of sexual harassment, he/she will:

  • 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 charity’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 written record of all discussions
  • respect the choice of the victim
  • ensure that the victim knows that they can lodge the complaint outside of the charity through the relevant country/legal framework

Throughout the complaints procedure, a victim is entitled to be helped by a counsellor within or associated with the charity. The Mindfulness Initiative will nominate one or more counsellors trained in assisting victims of sexual harassment and meet all costs associated with such counsellors provided assistance when required.

The Mindfulness Initiative recognises that because sexual harassment often occurs in unequal relationships within the workplace, victims often feel that they cannot come forward. The Mindfulness Initiative 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 (who could be engaged and paid for by the charity for this purpose) to resolve the matter
  • ensure that a confidential record is kept of what happens and retained in the files of the charity for future reference and for statistical reporting purposes
  • follow up after the outcome of the complaints mechanism to ensure that the behaviour has stopped
  • ensure that the above is initiated within 14 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 senior official of the charity to instigate a formal investigation. The matter will be brought to the attention of the trustees or a trustee to whom such responsibility is delegated. The trustees may decide to deal with the matter themselves or refer the matter to an external investigator they would engage and pay for their professional services or seek any other expert advice they deem necessary  under the circumstances.

The person(s) 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. This may include, but not be limited to, an apology, a change to working arrangements, training or counselling for the harasser, disciplinary action in line with current best practice in charities, suspension, dismissal.
  • follow up to ensure that the recommendations are implemented, that the behaviour has stopped and that the victim is satisfied with the outcome
  • ensure that the above is initiated within 14 days of the complaint being made

If the person(s) carrying out the investigation  cannot determine that the harassment took place, he/she/they may still make recommendations to ensure proper functioning of the charity to make clear it’s policy and procedures on sexual harassment and to rectify any conditions of work that may have contributed to the inability to determine whether the harassment took place.

Outside complaints mechanisms

A person who has been subject to sexual harassment can also make a complaint outside of the charity. They can do so through any of the mechanisms available in the country, such as an employment tribunal, ombudsperson. If the harassment was of a potentially criminal nature, the Mindfulness Initiative will advise the victim to report the matter to the police and be of whatever assistance it can be in supporting them to do that.

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
  • suspension
  • dismissal
  • withdrawal of any accreditation or status they may have been given by the charity in its activities such as training or research programs
  • exclusion from participation in any or all of the programs and events organized by the charity

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. Certain serious cases, including physical violence, will result in the immediate dismissal of the harasser and, in the event of any such aggression being of a potentially criminal nature, the . the Mindfulness Initiative will advise the victim to report the matter to the police and be of whatever assistance it can be in supporting them to do that.

Implementation of this policy

The Mindfulness Initiative will ensure that this policy is widely disseminated to all relevant persons. All employees, volunteers and associates will have this policy brought to their attention. It is the responsibility of the leadership of the charity to ensure that all employees, volunteers and those involved with the work are aware of the policy.

Monitoring and evaluation

The Mindfulness Initiative recognises the importance of monitoring this sexual harassment policy and will ensure that it assesses whether or not it is effective.

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 on a yearly basis to evaluate the effectiveness of this policy and make any changes needed.

Designated officials

The trustees of the Mindfulness Initiative designate the following officials of the charity to be those to whom individuals may bring complaints of sexual harassment under this policy and to hold primary responsibility for ensuring that this policy is implemented and its procedures adhered to:







This policy and these appointments will be reviewed annually by the trustees of the charity.