Respect: No Harassment and No Bullying #

At DAI, we expect everyone to treat each other with respect. Whether a colleague, a manager, or supervisor—or even someone we work with outside DAI—respect underpins everything we do. It is an essential part of the right to decent work, enshrined in all our core values and in international standards. It is a cornerstone of our professional practice.

Respect in the workplace is about being fair, abandoning discriminatory behaviors, and valuing everyone’s contribution. It means that we treat other people and their work with the respect due to them as human beings and as colleagues, regardless of our personal opinions. At its most basic, it means being treated as we would wish to be treated ourselves. Racism and other discriminatory behaviors, bullying, and harassment are the very opposite of respect.

So how do we define harassment? How do we know the difference between harassment and bullying?

Firstly, harassment is always linked to some form of discrimination. This can be discrimination based on race, sex, gender, age, sexual identity, disability, religion, or any other characteristic that is protected by law or regulation, such as veteran status in the United States. Even if a form of discrimination isn’t prohibited in one country, if it is prohibited anywhere, then it falls within this Code. Harassment can be verbal or non-verbal communication (including writing or pictures), physical conduct, threats, retaliation, or repeated small actions or micro-aggressions. Harassment has the intention and/or the consequence of creating an intimidating, hostile, or offensive work environment. It unreasonably interferes with an individual’s work performance and can adversely affect an individual’s employment opportunities. It damages the victim’s self-esteem and confidence and can even have long-lasting physical or mental health consequences.

Bullying is behavior which is: repeated, hurtful, abuses power, and intentional. It can include belittling or excluding someone; picking on a person; criticizing them publicly or unreasonably; or shouting at someone. Like harassment, it can take place in a physical location or online. Like harassment, bullying is bad for the individual, bad for the work environment, and bad for DAI.

Bullying and harassment can be one-on-one or involve people ganging up on an individual to make them feel belittled or excluded.

If you are experiencing harassment, bullying, or other forms of disrespect at DAI, you can tell Human Resources, your line manager, the Ethics and Safeguarding team (ethics@dai.com; safeguarding@dai.com), a trusted colleague, or the client. If you witness harassment, or bullying at DAI, you must tell someone, and you should support the victim. Don’t be a bystander.

Bystander Behavior #

Fraud, corruption, human rights abuses, and exploitation only happen because other people remain silent. Almost always, someone could have noticed and acted. At DAI, we believe we all have responsibility to take action, whenever we see, hear, or suspect any behavior that contradicts our core values.

In cases of discrimination, abuse, exploitation, harassment, or bullying, we ask everyone to put themselves in the position of the victim and think: “What would I want someone to do?” In cases of fraud or corruption, we ask everyone to remember that the money should be spent on helping shape a more livable world, not to go into the pockets of wrongdoers.

If you see, hear, or suspect something, you must speak up. If it’s safe to do so, you can take immediate action such as disrupting the behavior, supporting the victim (even just going and standing by them can be effective), or letting the perpetrator know that you have witnessed what they’re doing. If it’s not safe at the time, you can still support the victim and you must report what you have witnessed. Choose to be an ally, not a bystander.

If you see something, say something.

Safe, Secure, and Healthy Work Environment #

The safety and security of employees and affiliates are DAI's top priorities. The company will ensure that appropriate arrangements, processes, and procedures are in place to provide a secure workplace, taking account of the operating environment and level of risk involved in the performance of DAI’s work. In preparing for international work travel and especially for travel to countries determined by DAI to be high or very high risk, and as required by DAI’s Global Security policy, staff should coordinate with DAI Global Security (DAIsecurity@dai.com). In countries where DAI has an existing presence, travelers should also coordinate with in-country Security Focal Points based with projects. DAI staff are required to follow the procedures and guidance outlined in DAI’s Global Security policy and in project security plans.

DAI is also committed to providing a work environment free from illegal drugs, violence, threats of violence, and the influence of alcohol. The illegal use, sale, purchase, transfer, or possession of any controlled substance while on DAI premises or conducting DAI business is strictly prohibited. We all have a duty to comply with health and safety rules. While we must also be responsibly alert to our surroundings to avoid taking unnecessary risks, we must all report any risks, threats, or incidents as soon as possible.

Non-Retaliation and Whistleblower Protection #

The willingness of employees and the understanding of the need to report concerns is essential to the enforcement of this Code. In fact, it is your duty to raise breaches of this Code to management’s attention. Failure to notify management may itself, in some circumstances, be a basis for disciplinary action. Accordingly, anyone may submit a responsible concern or complaint regarding ethics or compliance without fear of dismissal or retaliation of any kind.

DAI will not discharge, demote, suspend, threaten, harass, or in any manner discriminate against any person in terms and conditions of employment based upon any lawful actions that person may take in making a good-faith report of ethics or compliance concerns. Supervisors are trained and expected to listen to allegations in a respectful manner. If you have questions or concerns about possible retaliation or any other obstacle to reporting, please contact the Ethics and Compliance Officer, Global Director of Safeguarding, Human Resources, or the ethics hotline.

Non-Discrimination and Equalities Policy #

DAI’s success hinges on its people and the diverse perspectives and approaches they bring to our work. We are an equal employment opportunity/affirmative action employer. We are committed to equal opportunity for all, in all aspects of our work. If you have any questions or concerns about possible discrimination or violations of the equalities policy, please contact your Chief of Party/Team Leader, Ethics and Compliance Officer, Human Resources, or the ethics hotline.

Diversity, Equity, Engagement, and Inclusion #

To truly shape a more livable world, DAI is directly confronting racism and racial discrimination and holding ourselves accountable for positive change within the company and in the communities, cultures, and countries where we live and work. In our commitment to anti-racism, we commit to taking deliberate actions to provide equal opportunities for DAI staff on an individual and systemic level. As such, DAI’s Diversity, Equity, Engagement, and Inclusion (DEI) program has been established to assure racial equity is at the core of DAI—as reflected in our operations, strategy, practices, policies, decisions, and behaviors—through institutionalizing internal assessment, planning, and change processes.

Disability #

DAI recognizes the value of all employees and everyone’s abilities. We expect all employees to respect the rights of people with disabilities, whether employees or not. In our employment practices, we take reasonable steps to accommodate the particular needs of people with disabilities. DAI recognizes that people with disabilities are represented in all groups and communities, so may face multiple forms of discrimination. Any form of harassment or other discrimination based on disability is against DAI’s core values, this Code and applicable legislation.

Safeguarding Against Sexual Exploitation, Abuse, and Harassment (SEAH) #

DAI has an unswerving commitment to preventing children, women, and other vulnerable adults from any form of SEAH. This policy sits alongside other DAI policies and practices such as those relating to child protection, modern-day slavery, whistleblowing, and dispute resolution (disciplinary and grievance) procedures. When any form of SEAH is committed by someone working for, or with, DAI, it is a breach of all our core values, our clients’ values, and the foundation on which the international development sector is built. DAI strives to incorporate and lead best global practice. For instance, we base our definitions of sexual exploitation, sexual abuse, and sexual harassment closely on those used by the United Nations.

DAI operates a zero-tolerance policy towards any form of SEAH, in accordance with international practice and our main clients’ policies. This means that all DAI personnel and consultants, subcontractors, and grantees must adhere to the following standards of behavior. Any allegations or concerns raised will be investigated and action taken as appropriate.

• No sexual activity with any child: A child is defined as age 18 or under, regardless of the age of consent locally—by statute or practice. Mistaken belief about the age of a child is not a defense.
• No buying sex: This includes buying any form of sexual activity from adults, whether during office hours or non-business time. It applies whether prostitution is legal locally. The prohibition includes obtaining sexual favors in return for non-monetary items such as goods or services and it includes obtaining or accepting sexual favors in return for jobs, contracts, connections, or qualifications.
• Sexual harassment or bullying of any nature that includes sexual harassment or abuse, in or outside the workplace is considered a breach of DAI’s policies.

DAI aims to prevent SEAH by minimizing opportunity (e.g., prohibiting one-on-one contact with children) through robust and repeated training (including an emphasis on reporting concerns); creating a culture where SEAH in any form is not tolerated; and maintaining a work environment where all employees feel respected, valued, and free of harassment.

Reporting Safeguarding Concerns #

If you have been subjected to any form of SEAH, or you think you have seen or heard any indication of SEAH, we want to hear from you. The willingness of employees and others to report safeguarding concerns is essential to the enforcement of this policy. Unless you are the victim/survivor, you must report all incidents, suspected incidents, or reports of incidents to the appropriate channels.

The protection of the victim/survivor and the person who raised the concern is our paramount consideration. If something happened a long time ago, we still want to know about it and if you are the victim/survivor, no one will criticize you for not raising it earlier.

Safeguarding concerns can be raised in the following ways:

• Directly to the Global Director of Safeguarding: safeguarding@dai.com
• Directly to the Ethics and Compliance Officers: ethics@dai.com
• The ethics hotline: www.DAIspeakup.ethicspoint.com and ethics@dai.com
• Directly to Human Resources at headquarters or on projects
• To a Chief of Party/Team Leader or supervisor
• To a safeguarding focal point on a project or DAI office
• Employees can always report directly to the client

DAI will not discharge, demote, suspend, threaten, harass, or in any manner discriminate against any person in terms and conditions of employment based upon any lawful actions that person may take in making a good-faith report of ethics or compliance concerns. Supervisors are trained and expected to listen to allegations in a respectful manner. If you have questions or concerns about possible retaliation or any other obstacle to reporting, please contact the Ethics and Compliance Officer, Global Director of Safeguarding, Human Resources, or the ethics hotline.

Any report, allegation, or suspected activity that breaches the above will be immediately investigated by people who are trained and experienced. DAI applies a victim/survivor-centered approach to all safeguarding concerns or allegations and investigations.

The Frequently Asked Questions (FAQs) on safeguarding are available to all DAI personnel. If you have any questions, no matter how small, please just ask.

Child Protection #

DAI believes that all children—everyone under the age of 18—have the right to be protected from abuse, neglect, exploitation, and violence, as stated in the UN Convention on the Rights of the Child, the African Charter on the Rights and Welfare of the Child, and other instruments.

This means that we take all possible steps to protect children from:

• Physical abuse
• Sexual abuse or exploitation
• Emotional abuse
• Neglect and negligent treatment
• Trafficking
• Commercial exploitation—including child labor and modern slavery

While different countries have different definitions and understanding of what child abuse is, the basic principle will always remain that the rights and welfare of the child are paramount. Even if the local environment permits behavior which constitutes abuse, this permission will not apply to anyone associated with DAI’s work.

If you think a child is in danger of any form of abuse or neglect, you must report it through the appropriate channels. Do not investigate it yourself. If you’re not sure what to do, talk to supervisor, Chief of Party or Team Leader, Human Resources, or the Ethics and Safeguarding team. If you think that another DAI employee is abusing or neglecting a child, you must report it. In an emergency—if you think a child is in imminent danger, you must inform the local authorities.

It is not DAI’s role to decide whether a child has been abused or not. Where there is any cause for concern, DAI will ensure that the correct authorities are notified.

Anti-Human Trafficking #

We believe that all human beings should be treated with dignity, fairness, and respect, and we are committed to upholding fundamental human rights. DAI will only engage with vendors, suppliers, consultants, subcontractors, grantees, and clients that demonstrate a serious commitment to the health and safety of their workers and operate in compliance with human rights laws. DAI does not use or condone the use of slave labor, nor will we tolerate the procurement of commercial sex acts or any other form of human trafficking, nor the degrading treatment of individuals, including their employment in unsafe working conditions. Any DAI employee, vendor, supplier, consultant, subcontractor, or grantee that engages in any form of human trafficking is subject to termination. Immediately contact your supervisor, Chief of Party/Team Leader, Human Resources, Chief Ethics and Integrity Officer, or the Global Director of Safeguarding if you suspect you have witnessed any form of human trafficking.

Political Activities #

As a citizen, you have the right to engage as an individual in the political process and make political donations, as long as you do not represent that DAI is making the contribution and provided there is no conflict of interest involved with your job or your association with DAI or the client.

DAI does not fund political contributions, in cash or in kind, anywhere in the world. This prohibition includes support of political activity, political parties or their representatives, political campaigns, and candidates or any of their affiliated organizations. Any questions or concerns about political activities may be directed to your supervisor, Chief of Party/Team Leader, Human Resources, or the Ethics and Compliance Officer.

Communicating with Media and the Public #

Routine program-related media relations (e.g., publicizing workshops) are managed by the Team Leader or Chief of Party. If you are contacted by the news media on matters that are out of the ordinary or may involve reporting on DAI or the client, please contact the head of DAI Corporate Communications to coordinate a response. If you have any questions about your use of social media and how it might affect DAI, please contact the head of Corporate Communications or the Chief Ethics and Integrity Officer.

Using Information, Email, and Social Media Responsibly #

DAI uses electronic communications and resources as a routine part of business activities. Do not use electronic media to initiate, save, or send items that are hostile, harassing, offensive, threatening, or inappropriate; or to initiate or participate in any malicious, unauthorized, or fraudulent use of company resources. Also, avoid soliciting for commercial, charitable, religious, or political causes and interfering with or disrupting network users, services, or equipment. Gaining unauthorized access to databases or information sources or damaging computer equipment, software, or data are grounds for termination. With regard to employees’ personal social media accounts, DAI recognizes that social media are now an integral part of people’s lives and has no interest in intruding on that private space. But we also recognize that employees’ private and professional space may in some cases overlap. Accordingly, we ask that employees consider the professional and reputational consequences—to themselves, to DAI, and to DAI’s clients and stakeholders—of their social media activity, and that employees conduct themselves online just as they would offline, in accordance with DAI’s core values. DAI reserves the right to hold employees accountable for inappropriate posts or content that departs from this standard.

Data Privacy #

DAI recognizes the importance of protecting personal information and data. We have adopted the requirements of the European Union’s General Data Protection Regulations (GDPR) as our global standard for data privacy as reflected in our privacy policy (https://www.dai.com/privacy-policy). We only collect personal information when the data is necessary for business purposes. We collect it in a lawful and fair manner, relying primarily on the consent of individuals to collect, process, and hold data. DAI will only share your personal information with others when we are legally permitted to do so, and it will only be retained for as long as is reasonably required.

Any accidental or unlawful breach of personal data should be reported immediately to your supervisor, Team Leader/Chief of Party, the OIMT support desk (support@dai.com), or the Chief Ethics and Compliance Officer as soon as possible. If you have any questions on our data privacy efforts, please contact data_privacy@dai.com.