The Period Pantry.

1. Purpose

The Period Pantry (“Organization”) is committed to maintaining a safe, inclusive, respectful, and welcoming environment for every person who works with, serves, supports, or participates in the Organization. The Organization does not tolerate discrimination, harassment, sexual harassment, bullying, intimidation, abusive conduct, or retaliation.

This policy establishes standards of conduct; identifies conduct that is prohibited; explains how to raise a concern; describes the Organization’s response and investigation process; and confirms the Organization’s commitment to fair, prompt, and appropriate corrective action. This policy is intended to comply with applicable federal, state, and local requirements, including Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act, the Age Discrimination in Employment Act, the Genetic Information Nondiscrimination Act, and applicable Maryland laws. Where a law provides greater protection than this policy, the Organization will follow the law.

2. Scope

This policy applies to all individuals who work with, represent, serve, support, or participate in The Period Pantry, including:

• Employees and applicants;
• Supervisors, managers, and officers;
• Volunteers;
• Interns;
• Student ambassadors;
• Board members;
• Contractors, consultants, and vendors;
• Donors, partners, and community members; and
• Participants, clients, visitors, and other third parties.

The policy applies to conduct occurring in person or electronically, including at Organization offices, Period Pantry sites, schools, community events, meetings, trainings, fundraisers, volunteer activities, travel, and other work- or program-related settings. It also applies to email, text messages, phone calls, video meetings, social media, messaging platforms, shared documents, and other electronic communications. Conduct outside a traditional workplace or event may violate this policy when it has a work-related or program-related impact, affects the Organization’s people or working environment, or is connected to the Organization.

3. Equal Opportunity and Prohibited Discrimination

The Period Pantry provides equal opportunity in employment, volunteer service, internships, student ambassador activities, board service, contracting, programs, services, partnerships, and all other Organization activities. Decisions will be based on qualifications, performance, organizational and program needs, conduct, and other legitimate considerations, without unlawful discrimination.

For purposes of this policy, protected characteristics include, but are not limited to:

• Race;
• Color;
• Religion, religious belief, religious practice, or creed;
• National origin or ancestry;
• Sex;
• Pregnancy, childbirth, or related medical conditions;
• Sexual orientation;
• Gender identity or gender expression;
• Age;
• Disability, perceived disability, or record of disability;
• Genetic information;
• Marital status;
• Military or veteran status;
• Citizenship or immigration status, to the extent protected by law;
• Hair texture or protective hairstyle associated with race;
• Genetic information;
• Any other characteristic protected by law; and
• Association with an individual who has, or is perceived to have, a protected characteristic.

The Organization also prohibits discrimination or harassment because an individual is perceived to have a protected characteristic, or because the individual associates with a person who has, or is perceived to have, a protected characteristic. The Organization will provide reasonable accommodations when required by applicable law and will engage in a timely, good-faith process to identify effective accommodations.

4. Prohibited Harassment

The Period Pantry prohibits harassment based on a protected characteristic. Harassment is unwelcome verbal, physical, visual, written, or electronic conduct that is based on or motivated by a protected characteristic and that creates an intimidating, hostile, abusive, or offensive environment; unreasonably interferes with work, volunteer service, participation, or access to a program or service; or improperly affects an employment, volunteer, program, or other Organization decision. A single incident may violate this policy when it is sufficiently serious, and repeated conduct may violate this policy even when each incident, considered alone, appears less serious.

Prohibited harassment includes, but is not limited to:

• Slurs, insults, threats, or derogatory comments related to race, color, religion, national origin, ancestry, sex, sexual orientation, gender identity or expression, age, disability, or another protected characteristic;
• Stereotyping, mocking, or degrading jokes, stories, images, gestures, or impressions based on a protected characteristic;
• Displaying, sending, sharing, or distributing offensive materials, including pictures, cartoons, memes, messages, symbols, recordings, or content posted online;
• Excluding, isolating, or treating an individual differently because of a protected characteristic or association with a protected individual;
• Unwelcome sexual comments, advances, requests, or contact;
• Misgendering or intentionally refusing to use an individual’s stated name or pronouns;
• Derogatory comments about race, religion, disability, age, national origin, sexual orientation, gender identity, or other protected characteristics; and
• Any conduct that creates an intimidating, hostile, abusive, or offensive environment or improperly affects an employment, volunteer, program, or other Organization decision.

Everyone covered by this policy is expected to contribute to a respectful environment and to raise concerns promptly. The Organization will review concerns fairly and will take appropriate action when a violation is substantiated.

5. Sexual Harassment

Sexual harassment is a form of prohibited harassment and discrimination. It includes unwelcome sexual advances, requests for sexual favors, and other verbal, visual, physical, written, or electronic conduct of a sexual nature when submission to or rejection of the conduct is used as a condition of employment, volunteer service, participation, or another Organization decision; when the conduct affects an individual’s work, service, participation, or access to an Organization program or benefit; or when the conduct creates an intimidating, hostile, abusive, or offensive environment.

Sexual harassment may be committed by or directed toward a person of any sex, sexual orientation, gender identity, or gender expression. The person who engages in the conduct and the person who experiences it may be the same or different sex or gender. Sexual harassment may be committed by a supervisor, coworker, volunteer, participant, donor, partner, vendor, or other third party.

Examples of sexual harassment include, but are not limited to:

• Unwelcome sexual advances, propositions, requests for dates or sexual favors, or repeated unwanted requests for personal or romantic contact;
• Offering or implying employment, volunteer, program, scheduling, funding, partnership, or other benefits in exchange for sexual or romantic conduct;
• Threatening or taking an adverse action because a person rejected, resisted, or reported sexual or romantic conduct;
• Sexual comments, jokes, stories, questions, gestures, sounds, or remarks about a person’s body, appearance, clothing, sexual activity, sexuality, or gender;
• Unwelcome touching, brushing against, blocking, cornering, staring, leering, or other physical conduct of a sexual nature;
• Displaying, sending, requesting, or sharing sexually suggestive or explicit images, videos, messages, memes, drawings, or other materials;
• Repeatedly asking about a person’s sexual history, relationships, anatomy, reproductive choices, or private life; and
• Sexual conduct or communication through email, text, social media, video meetings, messaging platforms, or other electronic means.

Conduct does not need to be directed at a particular person, intended to offend, or motivated by sexual desire to violate this policy. A person does not need to confront the person engaging in the conduct before reporting it.

6. Bullying, Intimidation, and Abusive Conduct

The Period Pantry prohibits bullying, intimidation, and abusive conduct. These are repeated or severe acts or omissions that a reasonable person would find hostile, threatening, humiliating, coercive, or abusive, whether or not the conduct is based on a protected characteristic and whether it occurs in person or electronically. The Organization will address conduct that undermines a person’s safety, dignity, ability to work or participate, or access to an Organization program or service.

Examples include, but are not limited to:

• Repeated insults, ridicule, humiliation, or public shaming;
• Threats, menacing behavior, intimidation, coercion, or attempts to make a person fear for their safety, job, volunteer role, participation, or reputation;
• Deliberately isolating, sabotaging, undermining, or withholding information from a person to interfere with their work or participation;
• Abusive shouting, profanity directed at a person, hostile outbursts, or aggressive gestures;
• Unwanted physical contact, blocking a person’s movement, following, stalking, or invading personal space;
• Repeatedly targeting a person with hostile messages, posts, comments, or other electronic communications;
• Retaliatory or humiliating use of a person’s private information, image, identity, or personal circumstances; and
• Any other pattern or serious incident of conduct that a reasonable person would consider abusive, threatening, or unsafe.

Reasonable performance feedback, good-faith coaching, setting expectations, assigning work, making legitimate decisions, or addressing misconduct does not constitute bullying or abusive conduct when done respectfully and for a legitimate purpose. Even so, these actions may not be used as a pretext for discrimination, harassment, or retaliation.

7. Third-Party Conduct

The Organization does not tolerate prohibited conduct by or against donors, partners, community members, participants, clients, visitors, vendors, contractors, consultants, school personnel, or any other third party who interacts with The Period Pantry. A third party’s conduct may violate this policy even when the third party is not an employee or does not report to the Organization.

When the Organization receives a report involving a third party, it will take reasonable and appropriate steps based on the circumstances. Steps may include speaking with the third party, setting conduct expectations, changing points of contact or work arrangements, limiting or ending access to an event, site, program, or partnership, notifying a responsible organization, or taking any other action permitted by law and appropriate to protect people and the Organization’s work. Individuals are encouraged to report third-party conduct promptly, even if they are uncertain whether the Organization can control the third party.

8. Reporting Prohibited Conduct

Any individual covered by this policy who experiences, witnesses, or learns of discrimination, harassment, sexual harassment, bullying, intimidation, abusive conduct, retaliation, or another violation of this policy should report the concern as soon as possible. A person does not need to be certain that conduct is unlawful, have proof, or know the correct legal term before making a good-faith report. Reports may be made verbally or in writing through any of the following channels:

• To the individual’s supervisor or manager;
• To the Executive Director or Board Designee;
• To the Board of Directors or an Authorized Representative when the concern involves the Executive Director, a board member, an officer, or another person to whom reporting would be inappropriate; or
• Through another reporting channel or designated contact made available by the Organization.

When possible, a report should include:

• The date, time, and location of the conduct;
• The name and role of each person involved or present;
• A description of what occurred, including relevant words, actions, messages, or images;
• The names of witnesses and any documents, messages, photographs, recordings, or other information that may help with the review; and
• Any steps already taken and the outcome or effect of the conduct.

If there is an immediate danger or threat to safety, call 911 or contact local emergency services first. Do not wait to make a policy report if immediate help is needed. After contacting emergency services, or when it is safe to do so, notify a supervisor, the Executive Director or Board Designee, the Board of Directors, or an Authorized Representative.

9. Duty to Report and Cooperation

All individuals covered by this policy share responsibility for maintaining an environment free from discrimination, harassment, bullying, intimidation, abusive conduct, and retaliation. Any person who experiences, witnesses, or receives a credible report of conduct that may violate this policy is expected to raise the concern promptly through an available reporting channel. A person who receives a report should listen respectfully, avoid promising a particular outcome or confidentiality, preserve relevant information, and promptly refer the concern to the Executive Director or Board Designee, or to the Board of Directors or an Authorized Representative when appropriate.

Individuals are expected to cooperate honestly and appropriately in any review or investigation, to provide relevant information when asked, to preserve documents and electronic communications, and to maintain appropriate discretion. No person is required to investigate a concern independently or confront the person whose conduct is at issue.

10. Investigation Procedure

The Organization will respond to reports promptly and take reasonable steps to conduct a fair and impartial review. The process may be adjusted to fit the circumstances, the roles of the people involved, the need for safety, and applicable law. The expected process is:

1. Receipt and initial assessment: The Organization will receive the report, acknowledge it when practicable, assess immediate safety and interim needs, identify conflicts of interest, and determine the appropriate person to coordinate the review.
2. Interim measures: When appropriate, the Organization may take temporary steps to protect people or preserve the integrity of the review, such as changing schedules or reporting relationships, separating individuals, adjusting contact, providing support or safety resources, or placing a person on leave consistent with applicable law and the person’s status. Interim measures are not a finding of responsibility.
3. Investigation plan: The reviewer will identify the issues to be examined, the relevant people and information, and the expected sequence of interviews or document review. The Organization may retain an outside investigator, attorney, or other qualified professional when appropriate, including when the report involves a senior leader, board member, potential conflict of interest, specialized subject matter, or a need for additional independence.
4. Information gathering: The reviewer may interview the person who reported the concern, the person accused of misconduct, and witnesses, and may review relevant documents, communications, photographs, recordings, policies, schedules, or other information. The person accused of misconduct will be informed of the substance of the concern and given a meaningful opportunity to respond, subject to safety, privacy, and legal considerations.
5. Findings and action: After considering the available information, the Organization will determine whether this policy or another rule may have been violated and what action, if any, is appropriate. The Organization may make findings based on a preponderance of the evidence or another standard required by applicable law or the circumstances.
6. Follow-up and closure: The Organization will communicate the outcome to the extent appropriate and permitted by privacy obligations. The Organization will take reasonable steps to address substantiated misconduct, prevent recurrence, monitor for retaliation, and document the review and resulting action.

The Organization will protect privacy to the extent practicable and consistent with a thorough, fair review, safety, and legal obligations. Complete confidentiality cannot be guaranteed. Information will be shared only with people who have a legitimate need to know, and all participants are expected to respect the privacy of the process. The Organization will not tolerate interference with a review, destruction or alteration of relevant information, knowingly false information, or retaliation.

11. No Retaliation

The Period Pantry strictly prohibits retaliation against any person who, in good faith, reports a concern, opposes conduct believed to violate this policy or applicable law, requests an accommodation, participates in an investigation or review, provides information, serves as a witness, supports another person who raises a concern, or exercises a legal right. Retaliation is prohibited even when a review does not substantiate the original concern and even when the reporting individual is mistaken about the facts or the law.

Retaliation may include, but is not limited to:

• Termination, demotion, reduction in hours, or undesirable reassignment or scheduling;
• Exclusion from meetings, events, assignments, opportunities, programs, or benefits;
• Threats, intimidation, harassment, bullying, or other hostile treatment;
• Denial of a benefit, opportunity, reference, partnership, or service;
• Negative treatment, interference, or adverse action that could discourage a reasonable person from making a report or participating in a review; and
• Any other action taken because a person engaged in protected activity.

A concern about retaliation should be reported immediately through any of the channels in Section 8. Knowingly making a false accusation or knowingly providing false information is not protected by this policy and may result in corrective or disciplinary action. A report made in good faith is protected even when the concern is not substantiated.

12. Corrective and Disciplinary Action

When the Organization determines that this policy or applicable law has been violated, it will take prompt and appropriate corrective or disciplinary action based on the facts and circumstances. Corrective or disciplinary action may include:

• Coaching, counseling, or an expectation-setting conversation;
• Education, training, or other corrective instruction;
• A written warning or documented corrective action;
• A performance improvement or conduct improvement plan;
• Changes to reporting relationships, schedules, duties, or work arrangements;
• Removal from an activity, assignment, event, program, or leadership role;
• Suspension, restriction, or termination of employment, volunteer service, internship, student ambassador service, board service, contract, vendor relationship, partnership, or other engagement;
• Limiting or ending access to an Organization site, event, program, service, communication channel, or other resource;
• Referral to law enforcement, a government agency, or another appropriate authority when warranted or required; and
• Other measures designed to stop the conduct, remedy its effects, protect individuals, and prevent recurrence.

Corrective or disciplinary action may also be taken when an individual violates the no-retaliation requirement, interferes with a review, fails to cooperate honestly, knowingly makes a false accusation, knowingly provides false information, or fails to carry out a reporting responsibility. The Organization will apply action consistently and in accordance with applicable law, the individual’s role, and the seriousness and circumstances of the conduct.

13. External Reporting Rights

Nothing in this policy prevents an individual from contacting, filing a charge or complaint with, participating in a proceeding before, or seeking information from a government agency or law enforcement agency, including the U.S. Equal Employment Opportunity Commission, the Maryland Commission on Civil Rights, the U.S. Department of Labor, or another agency with jurisdiction. An individual may exercise any right protected by applicable law, including the right to seek legal advice or representation. The Organization will not retaliate against a person for exercising a legal right or participating in an external process.

Internal reporting is encouraged because it may allow the Organization to respond promptly, but it is not a prerequisite to contacting an external agency or exercising any legal right. Time limits may apply to external reports or charges, and individuals should consult the applicable agency or a qualified advisor regarding deadlines and procedures.

14. Training and Distribution

The Organization will make this policy available to individuals covered by it through onboarding materials, handbooks, electronic distribution, the Organization’s website, or other appropriate means. The Organization will provide training or orientation on respectful conduct, prohibited discrimination and harassment, reporting channels, the duty to cooperate, and the prohibition on retaliation when appropriate to an individual’s role and as required by applicable law.

Supervisors, managers, officers, board members, and others with responsibility for people or programs may receive additional guidance on recognizing concerns, responding to reports, preserving privacy, preventing retaliation, and referring concerns promptly. Individuals are responsible for reviewing this policy, following it, asking questions when they need clarification, and completing required training.

15. No Contract of Employment

This policy is not a contract of employment, a promise of continued employment or engagement, or a guarantee of any particular process or outcome. Nothing in this policy changes the at-will nature of any employment relationship to the extent permitted by law, creates a right to employment, volunteer service, internship, board service, program participation, or a contract with The Period Pantry, or limits the Organization’s right to manage its operations and make lawful decisions. The Organization may revise, suspend, or withdraw this policy at any time, subject to applicable law. The current approved version will control.

16. Governing Law

This policy will be interpreted and applied in accordance with applicable federal law, the laws of the State of Maryland, and any applicable local law. If any provision of this policy conflicts with applicable law, the law will control and the remaining provisions will continue in effect. Nothing in this policy limits an individual’s right to contact or file a charge with a government agency, participate in an agency process, or exercise any other right protected by law.

17. Acknowledgment and Approval

I acknowledge that I have received, read, and understand The Period Pantry’s Anti-Harassment & Anti-Discrimination Policy. I understand that the policy prohibits discrimination, harassment, sexual harassment, bullying, intimidation, abusive conduct, and retaliation; explains how to report concerns; and describes my responsibility to treat others with dignity and respect, report concerns promptly, preserve relevant information, and cooperate honestly in any review. I understand that this acknowledgment does not create a contract of employment or alter any applicable employment or other relationship, and that I may ask questions or exercise any right protected by law.