Anti-Discrimination Policy

Policy Ref.:  P6

I. Anti-Discrimination and Harassment Policy

Purpose:  To set forth Carnegie’s policy against discrimination, harassment (including sexual harassment and gender misconduct) and retaliation, and to outline the system for reporting, processing, and addressing violations of this policy.

Carnegie strives to provide a work environment that is free from discrimination or harassment on the basis of race, color, ethnicity, national origin, ancestry, age, religion, physical or mental disability, medical condition, pregnancy, genetic information, citizenship status, marital status, military and veteran status, sex, gender, gender identity and expression, sexual orientation, personal appearance, political affiliation, family responsibilities, matriculation status, or any other protected status in accordance with all applicable federal, state and local laws (each, a “protected category”).  Carnegie further forbids retaliation against employees for engaging in protected activity as described in this policy.  Where discrimination, harassment, and/or retaliation have occurred, the institution will act to stop the prohibited conduct, prevent its recurrence, and discipline or take other appropriate action against those responsible.

  1. Overview

Carnegie is committed to prohibiting discrimination, harassment (including sexual harassment) and retaliation and is committed to complying with all applicable laws and government regulations.  This policy is intended to protect all employees, fellows, volunteers, agents, and applicants (collectively, “Carnegie community”) from such conduct, whether by a member of the Carnegie community or by a third party doing business with Carnegie, and regardless of whether the conduct occurs at a Carnegie facility, a Carnegie-related event or other work related event.  Those responsible for such conduct will be subject to appropriate disciplinary action through a prompt and equitable process in accordance with this and any other applicable institutional policies.

All aspects of the institution’s practices, including recruiting, hiring, discipline, termination, promotions, transfers, compensation, benefits, training, leaves of absence, and other terms and conditions of employment, are covered by this policy.  

Training. In compliance with certain federal and state laws, and/or in furtherance of this policy, all Carnegie employees, fellows, and volunteers must periodically complete required training programs provided by Carnegie. The training provides information about how to recognize discrimination, harassment, retaliation, or other abusive behavior in the workplace, how to report concerns of such inappropriate conduct, and how to appropriately respond to reports received from others.  Failure to complete the required training shall be grounds for discipline, up to and including termination from employment.

III. Prohibited Conduct

  1. Discrimination

No members of the Carnegie community or Carnegie-affiliated person shall, on the basis of any of protected category, refuse to hire or employ a person; refuse to select for, bar from, or discharge a person from a training program leading to employment; or discriminate against a person in compensation, terms, conditions, or privileges of employment.  Carnegie does not discriminate on the basis of any protected category in connection with any aspect of employment at Carnegie.  See Carnegie’s Equal Employment Opportunity Policy for more details.

  1. Harassment Based on Protected Category Status

No members of the Carnegie community or Carnegie-affiliated person shall engage in verbal, written or physical conduct that denigrates or shows hostility or aversion toward an individual on the basis of an individual’s protected category, or that of an individual’s relatives, friends or associates, and that (1) has the purpose or effect of creating an intimidating, hostile, or offensive work environment; (2) has the purpose or effect of unreasonably interfering with an individual’s work performance; or (3) otherwise adversely affects an individual’s employment opportunities.

Harassing conduct includes, but is not limited to:

  • Epithets, slurs or negative stereotyping;
  • Threatening, intimidating, or hostile acts;
  • Denigrating jokes; or
  • Written or graphic material that denigrates or shows hostility or aversion toward an individual or group that is placed anywhere on the employer’s premises or circulated in the workplace, on institution time or using institution equipment, by e-mail, phone (including voice messages), text messages, social networking sites or other means.
  1. Sexual Harassment

No Carnegie-affiliated person shall engage in sexual harassment.  Federal law defines sexual harassment as unwelcome sexual advances, requests for sexual favors, or visual, verbal or physical conduct of a sexual nature when: (1) submission to such conduct is made either explicitly or implicitly a term or condition of employment; (2) submission to or rejection of such conduct is used as the basis for employment decisions affecting the employee; or (3) such conduct has the purpose or effect of unreasonably interfering with an employee’s work performance or creating an intimidating, hostile, or offensive working environment.

California law defines sexual harassment as unwanted sexual advances or visual, verbal or physical conduct of a sexual nature.  This definition includes many forms of offensive behavior regardless of whether such behavior is provoked by sexual desire and includes harassment of a person of the same sex as the harasser. 

Some specific examples of unacceptable conduct that may constitute sexual harassment, depending on the totality of the circumstances, including the severity of the conduct and its pervasiveness, include, but are not limited to:

  • Direct or implied requests by a supervisor/manager for sexual favors in exchange for actual or promised job benefits (examples: favorable reviews, promotions, salary increases).
  • Making or threatening reprisals after a negative response to sexual advances.
  • Visual conduct: leering, making sexual gestures, displaying sexually suggestive objects, photographs, cartoons or posters or transmitting pictures of the same.
  • Verbal conduct: sexual advances or propositions; making or using derogatory or provoking comments about or relating to an employee’s gender, sexual orientation or sexual activity, including epithets, slurs, sexually explicit jokes; comments about an employee’s body or dress; verbally abusive behavior of a sexual nature; or suggestive or obscene letters, notes or invitations.
  • Continuing to ask an employee to socialize on or off duty after that person has indicated an unwillingness to do so.
  • Coerced sexual acts.
  • Physical conduct: touching, assaulting, impeding or blocking movements.
  • Off-duty conduct that falls within the above definition and affects the work environment.

Please note that while this policy sets forth Carnegie’s goals of promoting a workplace that is free of sexual harassment, the policy is not designed or intended to limit Carnegie’s authority to discipline or take remedial action for unacceptable workplace conduct, regardless of whether that conduct satisfies the legal definition of harassment.

  1.  Sexual Assault

Sexual assault is a form of sex discrimination.  No Carnegie-affiliated person shall engage in any type of sexual contact without consent, including touching of private body parts over or under the clothing or any form of penetration.

  1. Retaliation

No Carnegie-affiliated person shall threaten or take adverse action against anyone on the basis of his or her bringing a complaint or report of discrimination, harassment, or retaliation; participating in an investigation of alleged discrimination, harassment, or retaliation; or protesting alleged discrimination, harassment, or retaliation.   

Acts of retaliation should be reported immediately and will be promptly investigated and addressed.


II.  Procedures

  1. Responsibility

In furtherance of Carnegie’s policy to protect each member of the Carnegie community from discrimination, harassment (including sexual harassment), and retaliation, Carnegie requires that each of its supervisors and managers be responsible for the prevention and elimination of all forms of discrimination, discriminatory harassment, and retaliation within their respective departments.

  1. Complaint Procedure

Carnegie strongly encourages the prompt reporting of all violations of this policy.  If you feel that you have been discriminated, harassed, and/or retaliated against or observe such behavior in violation of this policy by another individual, including a supervisor, manager, a member of the Carnegie community or third party doing business with the institution, please promptly report the discrimination, harassment or retaliation to Human Resources.  Other reporting options include the Complaint Hotline and/or Office of General Counsel.   Additional reporting options as listed in Reporting Violations may also be used.  Complaints or reports of gender-based misconduct, including sexual harassment and sexual assault, should be promptly reported to Carnegie’s Anti-Discrimination Policy Title IX Coordinator, Marcia Hawkins.   All supervisors must report complaints of misconduct under this policy immediately, so the institution can investigate and resolve the claim internally (a supervisor’s failure to report may result in disciplinary action). 

Intentionally false and malicious complaints of harassment, discrimination or retaliation (as opposed to complaints that, even if erroneous, are made in good faith) are prohibited and may be subject to disciplinary action following a formal determination that the complaint was made in bad faith.


In addition to reporting to any of the individuals listed below, employees may report complaints of misconduct to Carnegie’s Complaint Hotline.   An individual may make an anonymous report to this Complaint Hotline, with the understanding that any investigation may be hampered due to the inability to: identify the employee; obtain all of the necessary facts; and/or gain any needed clarification for any investigation.



Marcia Hawkins, Senior Human Resources Manager


*For individuals in California

Clare Tuma, Human Resources Business Partner




Benjamin Aderson, General Counsel      


Emily Williams, Assistant General Counsel



Complaint Hotline



Note: unless stated otherwise, each of the above listed individuals is located at 1530 P St NW, Washington, DC 20005

The individuals listed above are also available to discuss any questions or concerns that employees may have regarding Carnegie’s Harassment and Discrimination Policy.

     3. Investigation

Carnegie will respond to complaints or reports of alleged violations of this policy with appropriate care and discretion and will conduct a prompt, thorough, and objective investigation that reaches reasonable conclusions based on available information.  Unless the alleged misconduct requires an alternative approach, Carnegie HR will be notified promptly of all alleged violations of this policy and an investigation of the allegations by qualified personnel will be undertaken promptly.  Carnegie will track the progress of the investigation to ensure that it is completed in a timely manner.  Although the course of an appropriate investigation will vary, it will generally include interviews with the person bringing the complaint, the person alleged to have committed the conduct, and all persons with direct and personal knowledge of the incident(s) in question.  Carnegie will seek to maintain confidentiality throughout the investigative process to the extent practicable and consistent with Carnegie's need to undertake a full investigation.

     4. Resolution

If the investigation determines that a violation of this policy has occurred, Carnegie will take prompt and effective remedial action.  Remedial action affecting the person(s) found to have violated the policy may include oral or written counseling, referral to formal counseling, disciplinary suspension or probation, or discharge from Carnegie. Additional remedial action may include hiring, reinstatement, promotion, and back pay.  Such measures are designed to halt the inappropriate conduct, prevent its recurrence, and redress its effects.  Carnegie retains the right to take whatever action it believes appropriate under the circumstances, up to and including terminating the employment of the person(s) found to have violated the policy.

Carnegie also retains complete discretion to address inappropriate workplace conduct that does not constitute a violation of this policy.

    5.  Legal Information

Carnegie is committed to responding promptly and effectively to any complaint or report of discrimination, harassment (including sexual harassment), and/or retaliation. 

Although employees are free to file formal charges of discrimination, harassment (including sexual harassment), and retaliation with government agencies, as noted below, Carnegie is committed to responding quickly and effectively to any report of discrimination, harassment (including sexual harassment), or retaliation, and hopes that employees will feel comfortable coming forward and allowing us to pursue a resolution of any matter internally.  We believe that we have created a flexible and fair complaint resolution process and that we will be able to work together to address any issues.

In addition to Carnegie’s internal procedure, an employee may pursue a complaint of discrimination, harassment (including sexual harassment), or retaliation by contacting the federal and state agencies listed below.

Federal and State Agencies:


U.S. Equal Employment Opportunity Commission
San Francisco District Office
450 Golden Gate Avenue
5 West, P.O. Box 36025
San Francisco, CA 94102-3661
(800) 669-4000


California Department of Fair Employment and Housing
Elk Grove Office
2218 Kausen Drive
Suite 100
Elk Grove, CA  95758
(800) 884-1684



U.S. Equal Employment Opportunity Commission
Baltimore Field Office
GH Fallon Federal Building
31 Hopkins Plaza, Suite 1432
Baltimore, MD 21201
(800) 669-4000


Maryland Commission on Civil Rights
6 Saint Paul Street
Suite 900
Baltimore, MD 21202-1631
(800) 637-6247


Washington, DC

U.S. Equal Employment Opportunity Commission
Washington, DC Field Office
131 M Street, NE
Fourth Floor, Suite 4NWO2F
Washington, DC 20507-0100
(800) 669-4000


District of Columbia Office of Human Rights
441 4th Street NW
Suite 570|
North Washington, DC 20001
(202) 727-4559


Office of Civil Rights (for claims of gender-based misconduct, including sexual harassment)

U.S. Department of Education
Office for Civil Rights
Lyndon Baines Johnson Department of Education Bldg
400 Maryland Avenue, SW
Washington, DC 20202-1100
(800) 421-3481


Employees who believe that they have been discriminated against, harassed (including sexually harassed) or retaliated against may file a complaint with any applicable agency, including those listed above.  Information regarding how an agency will investigate and respond to a complaint may be obtained from the agency.  Available legal remedies may include hiring, reinstatement or promotion of employees, back pay, actual damages, including emotional distress, and changes to employer policies and practices.

Additional References:

For individuals in California:  

California Law Prohibits Workplace Discrimination and Harassment

Transgender Rights in the Workplace

Sexual harassment brochure