UHRP Code of Ethics, Conflict of Interest, Discrimination, and Harassment Policy

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July 9, 2024

High ethical standards are of utmost importance and are essential for establishing and maintaining a good reputation and successful activities of any organization. This Code describes ethical conduct expected of the Board Directors, Officers, and employees of the Uyghur Human Rights Project (UHRP). In no case shall the ethical conduct expected of Directors, Officers and employees be inconsistent with federal, state, or local law.

Each Board Member and all UHRP employees shall abide by the organization’s Code of Ethics and Conflict of Interest Policy. The UHRP Code of Ethics and Conflict of Interest Policy forms an integral part of the organization’s employee contracts.


The use of confidential information obtained as a consequence of duties or employment with UHRP must be limited to the proper conduct of the organization. Directors and employees of the organization may not use or permit others to use confidential information to advance a private interest or as a means of making a profit.


It is against the law to discriminate against any employee for any reason including, but not limited to, discrimination by reason of race, color, sexual orientation or gender, age, national origin, disability, religion, veteran’s status, national reserve unit duty obligations or other protected status. Every employee has a responsibility to prevent and eliminate discrimination and to report any incidents of discrimination that take place at UHRP. Mutual respect is a core value of UHRP.


Board Members and employees must avoid all actual or perceived conflicts of interest. Apart from authorized reimbursement of legitimate expenses of the organization, or duly authorized compensation for services rendered, Board Members and employees may not personally benefit from doing business with UHRP, must disclose any relationships with those who do business with the organization, must not use the organization’s property for their personal benefit, and not compete with UHRP.


Board Members and employees are free to participate in partisan activities on their own time. However, it must be clear at all times that any Board Member or employee participates in partisan activities as an individual and not as a representative of UHRP.


Employees shall cooperate with federal, state, and local enforcement investigations and activities within the bounds permitted by law. Employees who are presented with a subpoena, warrant, or court order have the right to an attorney when speaking with an investigator.


UHRP uses public communications to educate the public, provide information, increase awareness of our work, and to recruit colleagues. We will present only truthful, informative, and non-deceptive information in these materials.


UHRP is tax-exempt because of our mission. A tax-exempt entity may not permit insiders (directors or officers who can influence organization decisions) to benefit personally from service contracts with the organization. Those with whom we do business should not receive more than fair market value for the goods or services they provide. Violation of the tax rules can result in loss of the organization’s tax exemption or can cause the IRS to penalize the person receiving an excess benefit and the personnel who approved the payment.


UHRP will not tolerate unauthorized distribution or possession of controlled substances. Employees who are convicted of felonies or engage in conduct that could lead to the conviction of felonies are subject to disciplinary action, up to and including termination.


  1. Employees shall treat colleagues with respect, courtesy, fairness, and good faith.
  2. Employees should create and maintain conditions that facilitate ethical and competent professional performance by colleagues.
  3. Employees should extend to colleagues outside of the organization the same respect and cooperation that is extended to co-workers.
  4. Employees should be mindful that attitudes and behaviors that are negative in nature adversely affect the workplace and the organization. Therefore, all grievances, whether personal, procedural, or policy-related should be directed to a supervisor.
  5. Employees shall not engage in verbal, emotional, or behavioral harassment of colleagues.
  6. Any employee having knowledge of unethical practices on the part of another colleague should report such practices to a supervisor, the Executive Director, or, if the situation requires it, a Board Member.


  1. Employees should adhere to commitments made to UHRP.
  2. Employees should use the resources of the organization with scrupulous regard and only for the purpose for which they are intended. Every employee has a responsibility to protect UHRP against loss, theft, and misuse of resources.
  3. Employees are expected to maintain complete and open communication with management regarding matters that pertain to the organization. No employee shall deliberately conceal information or mislead supervisors or the Board of Directors.
  4. Employees are expected to confer with a supervisor on any royalties, honoraria, other sources of income during their term of employment, as well as any gifts above a de minimus value that they may receive in relation to their work for UHRP.


Difficult questions of judgment may arise in connection with the Code of Ethics. If any doubt exists regarding the propriety of any action or activity, Board Directors should seek advice from the Board Chair and employees should seek advice from the Executive Director or, if the situation requires it, from a Board Member. All employees are expected to promptly report the existence of any relationships, interests, or actions that might violate or appear to violate the Code of Ethics.


Any suspected violations of the Code of Ethics should be referred to the Executive Director or, if the situation requires it, a Board Member. Violations of the Code of Ethics are grounds for disciplinary action, up to and including dismissal. In situations where infractions of the Code may have violated federal or state law, such infractions will be disclosed as appropriate and reported to enforcement agencies as required.


The Uyghur Human Rights Project (UHRP) is committed to a workplace free from sexual harassment. UHRP has a zero-tolerance policy for any form of sexual harassment. Individuals associated with UHRP are required to work in a manner that prevents sexual harassment in the workplace and promotes respect for their co-workers and others. All sexual harassment is prohibited whether it takes place within UHRP premises or outside, including at social events, business trips, training sessions or conferences.

This policy applies to all current and former employees of UHRP. It also applies to individuals performing tasks on behalf of UHRP, such as volunteers, consultants, contractors, suppliers of services, and board members. 

UHRP handles all incidents with utmost seriousness and swiftly investigates all sexual harassment allegations, whether they are recent or historical, with confidentiality. Individuals making such complaints will not face any retaliation.

Any individual associated with UHRP covered by this policy who engages in sexual harassment or retaliation will be subject to remedial and/or disciplinary action, up to and including termination of their relationship with UHRP. Any individual associated with UHRP, regardless of position or title, who knowingly allows sexual harassment to continue, will be subject to discipline, up to and including termination.

Sexual harassment can occur unexpectedly and to anyone, irrespective of their gender or the gender of the alleged perpetrator. What is significant is that the behavior in question is deemed inappropriate, unwanted, or unwelcome by the person targeted by it. UHRP acknowledges that sexual harassment can stem from power dynamics, frequently arising in unequal workplace relationships.

Definition of Sexual Harassment

Sexual harassment involves unwanted behavior of a sexual nature directed at a colleague based on their sex, sexual orientation, and/or gender identity or expression (including gender reassignment). This behavior is considered unwelcome or offensive by the recipient or a witness and aims to, or results in, violating the employee’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive work environment.

The following are examples which illustrate such conduct, though it is not an exhaustive list: 

  • Non-consensual physical contact or sexual contact. 
  • Contact which is intimidating, or physically or verbally abusive. 
  • Non-verbal conduct, such as staring or gestures. 
  • Suggestions that sexual favors may further a person’s career, or that refusal of such may hinder it. 
  • Sexual advances, propositions, suggestions or pressure for sexual activity made at work or outside work. 
  • Repeated unwanted invitations to meet outside work. 
  • E-mails, text messages, or other digital communications with sexual content unrelated to work. 
  • Sharing or displaying sexually-explicit pictures.
  • Jokes that are based on sexual or gender issues directed at the complainant. 
  • Sexually explicit jokes or crude/vulgar jokes on sexual or gender-based issues, even if not directed at the complainant. 

While intention is an aggravating factor, an act can still be deemed sexual harassment even if the perpetrator did not intend it to be. While harassment often involves ongoing or repeated actions and patterns of behavior, some of the aforementioned actions can constitute sexual harassment even if they occur as isolated incidents. 

Protection against sexual harassment is provided by both employment law and criminal law, depending on the specific circumstances. Certain types of gender-based violence, such as rape and sexual assault, are both criminal offenses and workplace issues. If the complainant decides to do so, criminal incidents can be reported to the police. UHRP will cooperate with authorities in criminal investigations.

Reporting Sexual Harassment

Preventing sexual harassment is everyone’s responsibility. Any individual associated with UHRP who has been subjected to behavior that may constitute sexual harassment or witnesses or becomes aware of potential instances of sexual harassment is encouraged to report such behavior.

Internally, individuals who have experienced sexual harassment can seek guidance or discuss their concerns with confidential helpers, a staff representative (see below), a member of the management team, the executive director, a designated member of the Board of Directors, or the Chair of the Board of Directors. They also have the option to be accompanied by a colleague during these discussions.

Anyone approached by a complainant seeking advice and discussion is responsible for:

  • Ensuring that the matter be discussed confidentially, in a comfortable and private setting, free from interruptions. Consent from the complainant must be obtained if the recipient of this information feels it necessary to share it with others.
  • Listening attentively, openly, and without judgment to the complainant, taking minimal notes with the complainant’s agreement.
  • Ensuring the complainant understands their options for reporting a complaint, both internally and externally, and supporting them in making their own decision on how they wish to proceed.

Informal Complaints

Anyone who experiences or witnesses sexual harassment can consider various informal options to address the unwanted and inappropriate conduct.

Although these options may not always be suitable, they include:

  • Talking directly to the individual responsible, either alone or with a colleague. The goal is to inform the alleged perpetrator of the behavior and make it clear that such actions are unacceptable and must not be repeated.
  • Asking a trusted colleague or supervisor for advice or support to facilitate a meeting between both parties, allowing the complainant to explain their perspective on the offending behavior. 
  • If the complainant feels unable to speak to the individual directly, the person approached for help could talk to the alleged perpetrator on their behalf to make them aware of the behavior and request that it not be repeated.

Possible outcomes of the informal process include, but are not limited to:

  • Clarifying differing points of view
  • Resolving misunderstandings
  • Receiving an apology for the conduct
  • Acknowledging a possible violation
  • Committing to not repeat the behavior
  • Deciding whether to proceed with a formal process

In some situations, the actions described above can be suitable in addressing the behavior(s). If the complainant feels comfortable and chooses to resolve the issue informally, every effort will be made to promptly assist and support them in this process.

Formal Complaints

If a complainant is dissatisfied with the outcome of the informal process, feels unable to directly confront the alleged perpetrator themselves or through a representative, or believes the behavior is particularly serious due to factors such as intentionality, a persistent pattern, or repeated offenses despite previous complaints, they may escalate the issue by submitting a formal written complaint to one of the staff representatives listed below.

Initiating a Complaint

A written complaint can be submitted to one of the staff representatives listed below, who will serve as the Chair of the Sexual Harassment Complaint Committee. If the Chair has already been briefed on the case through confidential discussions with the complainant, they will recuse themselves and be replaced by another representative. The Chair will appoint at least two additional members to the Committee: one Board member and one staff member. 

If a party in the complaint raises a valid concern about a Committee member or if a proposed member perceives a conflict of interest, that member will step down. The Chair may then appoint a replacement. The Chair typically seeks to maintain gender balance on the Committee, with potential restructuring based on the specific details of the complaint.

The written complaint should include:

  • Identification of the alleged perpetrator;
  • Description of the alleged behavior;
  • Dates and times of the incidents;
  • Impact or harm suffered (e.g., effects on job performance, anxiety);
  • Names of any witnesses; and
  • Any actions taken by the complainant to address the harassment, recognizing that it is not the complainant’s responsibility to stop the harassment.

Upon receiving a formal complaint, the Sexual Harassment Complaint Committee, in consultation with the complainant, may take interim measures such as separating the alleged perpetrator from the complainant to facilitate an uninterrupted investigation. 


After receiving the written complaint, the Sexual Harassment Complaint Committee will refer the reported incident to an independent external investigator, specialized in harassment and toxic behavior within organizations. The investigation will seek to be impartial, neutral and objective. It will be carried out with due respect for both the rights of the complainant and the alleged perpetrator.

Communicating a Decision

After completing the investigation, typically within 45 working days from receipt of the written complaint, the committee will provide the investigator’s written decision outlining its findings to both the complainant and the alleged perpetrator. In cases where there is a delay, the reasons will be promptly communicated, and timelines will be updated for the complainant and alleged perpetrator. Both the complainant and the alleged perpetrator have the option to appeal the investigator’s findings. Appeals should be directed to the Sexual Harassment Complaint Committee, who will assess whether further action if necessary.

UHRP will consult with the complainant before disseminating the decision to anyone outside of the complaints committee. Internal communication will only occur with the complainant’s explicit consent regarding how information will be shared, ensuring that all identifying details are anonymized.

If a complaint is upheld, the perpetrator will be subject to remedial and/or disciplinary action, up to and including termination of their relationship with UHRP. In cases where a complaint is not upheld, discussions on communication will involve both parties.


The UHRP strictly prohibits retaliation against individuals who report sexual harassment. Retaliation consists of any action that would keep a person from coming forward to make or support a sexual harassment claim. 

No person covered by the policy shall be subject to adverse employment actions including discharge, discipline, discrimination, or otherwise being subjected to an adverse employment action because the UHRP personnel reports an incident of sexual harassment, or otherwise assists in the investigation of a harassment complaint. 

Any UHRP personnel who retaliates against an individual involved in a sexual harassment investigation will be subject to disciplinary action, up to and including termination.


Regular training and information on sexual harassment will be provided to all UHRP personnel. New hires are required to undergo training on preventing gender-based violence and harassment in the workplace. 

Representatives at UHRP

Staff Representatives should be contacted on the process outlined in this policy.

  • Zubayra Shamseden – zshams@uhrp.org
  • Henryk Szadziewski – hszad@uhrp.org