ETHICS & ACCOUNTABILITY PROCESS
Effective date: Dec 1, 2023
Last updated: Mar 24, 2025
All certified Trainers are bound by the RHI Code of Ethics and commit to enforcing our No Harassment Policy. If you would like to report an incident please use this Ethics Circle Reporting Form.
I. Introduction
This document outlines the steps in the Radical Honesty Institute (RHI) accountability process for all RHI owners, staff, Supervisors, Trainers, and Trainer Candidates (TC’s) collectively called “Team Members”. It is intended to serve as the foundational document in the process. All other supporting documents and protocols are linked to it.
A. Scope of Authority of the Ethics Circle (see current members at bottom of page)
Develops RHI’s ethical policies, including the Code of Ethics and No Harassment Policy
Educates Team Members on RHI’s ethical policies
Acts as a sounding board for ethical issues
Investigates reports of concern and breaches of ethics
Facilitates mediation conversations between complainants and respondents (subjects of accountability)
Reports findings of investigations to the Accountability Circle
Fosters a Speak Up! culture through education and organizational policies
B. Scope of Authority of the Accountability Circle (see current members at bottom of page)
Develops and educates on reporting channels and protocol
Reviews the Ethics Circle’s investigation reports
Decides on accountability actions and next steps, including any restorative, educative, or reflective steps
Manages the post-accountability action phase
Facilitates mediation conversations between complainants and respondents (subjects of accountability)
Manages disputes between RHI leadership
C. Scope of Authority Ombuds Function (see current Ombuds Function at bottom of page)
Monitors and manages the Ethics and Accountability Circles’ compliance with RHI policies
Ensures that RHI personnel are trained and educated on ethics and accountability policies
Manages the appeal process of Ethics and Accountability Circles’ procedures and decisions on accountability actions
D. Purpose of the Ethics & Accountability Process
To foster safe environments for Radical Honesty Team Members workshop participants, and coaching clients. This is the Ethics & Accountability Circles’ highest priority.
To uphold the RHI's mission, and Code of Ethics.
To protect the Radical Honesty (RH) brand and inspire trust in our Team Members, workshop participants, coaching clients, and the public at large.
To provide a fair, consistent, clear, structured, and impartial accountability protocol for our Team Members.
E. Importance of Accountability and Consequences
To ensure that all Team Members recognize their responsibility for their actions and that they are held accountable.
To serve as a deterrent against misconduct.
To foster a culture of trust, safety, respect, professionalism, and ethical best practices.
F. The Need for a Fair and Consistent Accountability Process
To ensure that accountability actions are not arbitrary.
To establish trust in the accountability system, both among our participants and our Team Members.
To promote respect for RHI's policies and a smoother-functioning organization as we grow, learn, and develop.
II. Policy and Procedure Review
A. Review of Existing Ethics & Accountability Policies
Ethics and Accountability Circles will continue to review our policies to ensure they are effective and updated with best practices.
We will implement periodic training on the policies to inform RHI organization and community members.
B. Identification of Team Member Misconduct
Our Code of Ethics defines types of misconduct and behaviors that warrant accountability action.
We will provide adequate ethics training to ensure Team Members understand the boundaries of acceptable conduct and what types of behaviors constitute breach of our ethical policies.
III. Initial Incident Reporting
A. Reporting of Concern
We have created accessible and confidential and/or anonymous channels for reporting misconduct, visible and searchable to the public on the RH website via our Speak Up! page. The primary first point of contact is this Ethics Circle Reporting Form.
We encourage individuals to report incidents without fear of retaliation with a Whistleblower Protection Policy.
B. Documentation and Incident Reports
All reported incidents of problematic behavior, including dates, times, locations, and individuals involved will be recorded. This includes verbal reports to RHI leadership, anonymous reports, emails and texts sent to RHI personnel, oral or written statements, interviews conducted during an investigation, and any other means of communication.
C. Maintaining Confidentiality
Confidentiality and anonymity are crucial for protecting complainants (people reporting incidents), fostering a 24/48 Speak Up! culture, and inspiring trust in RHI leadership and the accountability process.
Records may be kept confidential or anonymous based on the preferences of the person reporting the incident. At minimum, the report will be made available to Ethics and Accountability Circle personnel. The person reporting the incident can also choose to make their statement available to the RHI leadership, the subject of accountability (the respondent), third party agencies, or the entire RHI Trainer community.
IV. Investigation
A. Appointment of Investigator
An investigator will be appointed by the Ethics Circle to review any incident reports and gather information to gain a fuller understanding of what occurred. This may involve conversations with any complainants, named witnesses, and the respondent (subject of investigation).
The investigator will inform the respondent and any necessary or relevant parties of the opening of the investigation providing necessary details and foreseeable next steps.
The investigator may choose to delay informing the respondent of the investigation or withhold information about the case if they deem necessary in order to maintain the integrity of the investigation, and in some cases may send the investigation report directly to the AC without informing or interviewing the respondent.
B. Gathering Evidence and Witness Statements
The investigator is responsible for gathering and documenting all relevant evidence, such as formal statements, emails, and video recordings.
All investigators will be trained in interview best practices and follow this Investigation Protocol.
Throughout the process, conversations between the Ethics Circle and the complainant(s) and respondent(s) will be documented.
Complainant(s) and respondent(s) are welcome to bring a support person of their choosing to all conversations with the Ethics Circle.
C. Analyzing the Impact of the Concern
The impact of the concern will be evaluated based on the evidence collected.
The investigator will compile an investigation report summarizing the investigation and their findings, and providing their recommendation for next steps.
The investigator will forward their report to the AC for review. The investigation report is an internal document and not public.
V. Accountability Action
Introduction
Occasionally, the Accountability Circle at the Radical Honesty Institute faces tough decisions regarding discipline for Team Members. This may stem from ongoing issues or serious incidents that contradict our mission-supporting policies. Often, these issues involve participant safety, legal compliance, excessive use of Institute resources, or conduct unbecoming for a Team Member of the Institute.
A. Allowing the Respondent to Present Their Perspective
Before any accountability action is decided, the respondent will have an opportunity to present their perspective.
The complainant and the respondent will be made aware of their right to a support person of their choosing to accompany them throughout the process so that they feel safe and resourced, and to help them understand, keep track of the process, and adequately advocate for their interests.
The AC is responsible for ensuring a fair and open dialogue throughout this stage.
Video calls between the AC and the respondent(s) will be recorded and documented.
Complainant(s) and respondent(s) are welcome to bring a support person of their choosing to all conversations with the AC.
B. Determining Appropriate Actions
An Accountability Circle Member will prepare a Case Brief for the other AC members. The case brief is an internal document and not public.
Definition: Personal Accountability Action Plan (PAAP)
An agreed empathetic plan with SMART (Specific, Measurable, Actionable, Reasonable and Time-bound) Goals, and followed up by Accountability Circle, can be applied at any level.Accountability actions will be tailored to the nature and severity of the misconduct, with attunement to the emotions and needs of everyone involved, while striving to choose the lowest accountability action that will address the concern. Possible actions include the following, in order of ascending severity (see section E below for examples):
No Case
The Evidence was evaluated and the complaint was found to not meet the criteria for a case, Not enough Evidence, No Merit, Malicious Complaint
No Fault found
Could include actions to prevent these situations in the future.
Constructive Counseling
Feedback given in a caring way, discussing the concerns found and using consensus to find a corrective action for the respondent to execute at their own discretion.
Formal Warning
AC will formally document concerns or issues with respondent conduct in writing, outlining specific issues, expectations, timelines and consequences if improvements are not made.
Limitations on Roles
Temporary Removal from Role (during an RHI event)
Removal as participant, TC, helper, Co-lead, etc, basically any role from workshop, for 1 or more days up to the entire workshop.
Limitation on Future Roles
Respondent cannot join Training program, cannot rise to seniority level, cannot be staff or hold office in the Institute. Time limited, condition limited or permanent.
Limitation on Workshop Participation
Respondent cannot attend certain or all workshops. Time limited, condition limited or permanent.
Probation
Respondent conduct will be placed under close supervision and monitoring for a defined period. We see this as a corrective, protective, and rehabilitative measure. During probation, the respondent is expected to address specific performance or conduct issues and demonstrate improvement before having their title and privileges reinstated.
Suspension
The respondent temporarily loses the privileges of their title, role, or duty as a result of serious misconduct. This is a punitive, protective, and corrective measure and may have various durations, depending on the severity of the situation. The respondent is expected to address specific performance or conduct issues and demonstrate improvement before having their title and privileges reinstated.
Decertification
This involves the removal of the Supervisor, Trainer, or TC title and privileges, due to serious misconduct, unethical behavior, or violation of the RHI Code of Ethics. Ability to complete the certification program again after a period of time.
Lifetime decertification
Removal of all titles and privileges with no ability to ever regain them.
In cases where fault is found, the respondent may be required to pay a monetary fine, compensating RHI for the cost of the investigation and accountability process.
AC personnel will consult with investigators, RHI leadership, and third party agencies as appropriate to determine next steps and the appropriate level of accountability or disciplinary action to be taken (if any).
In cases of reports of harm done, the complainant may request a facilitated conversation as part of the process of healing and repair as part of the accountability process.
In all cases, we endeavor to match the accountability action to the misconduct.
The respondent’s attitude throughout the process, level of cooperation, willingness to take accountability for problematic behavior and its impact, and all prior incidents and patterns of behavior will be taken into consideration.
C. Consistency & Transparency in Accountability Actions
We endeavor to be consistent in our accountability actions for similar misconduct.
We endeavor to be as transparent about the process as possible without violating confidentiality or risking the integrity of the process.
We endeavor to avoid arbitrary or discriminatory actions and to be transparent about our mistakes and errors in judgment.
D. Deciding on the Level of Accountability Action
The evidence and circumstance will be carefully weighed before deciding on the appropriate accountability action, always choosing the lowest accountability action which will adequately address the concern
When appropriate, the respondent and their support person will be involved in the decision-making process about actions taken and next steps. However, the AC may choose to make the final decision without the presence of the respondent.
The documentation of the process will be made available to the respondent and any other relevant parties as appropriate.
E. Examples of Concerns and Corresponding Actions
The following list is intended as a rough guide for each category, and is by no means exhaustive.
Constructive Counseling:
Venting from more than 1 participant or team member
Concern raised from participant or team member
Participant or team member “creeped out” or hypervigilant
Unaware of personal biases or privileges
Oblivious of negative Impact of actions
Person Growth and Authenticity Plan:
Instances of constructive counseling not working
Behaviors that erode participant safety
Repeated angry coaching
Speak Up! complaints
Recorded (written) Warning:
Failure to accept responsibility for actions
Mild boundary-pushing or harassment
Endangering RHI’s social capital
Temporary Removal from Role (during an event):
Angry coaching
Becoming emotionally unregulated with no ability to self-regulate
Participant or team member safety concerns
Performing role while under the influence
Limitation on future roles
Loss of community trust
Repeated and serious boundary pushing against the Code of Ethics
Limitation on workshop participation
Violent or threatening behavior
Consent violations
Sexual Harassment
Probation:
Moderate boundary-pushing or harassment
Moderate policy violations
Behavior unbecoming of a team-member
Suspension:
Consent misunderstandings
Power dynamics misunderstandings
Large loss of community trust
Severe violation of policy
Decertification:
Grave consent misunderstandings
Grave power dynamics misunderstandings
Gross violation of policy
Goals, Desires and behavior incompatible with RHI Trainer obligations
Lifetime decertification:
Violence / serious threats
Sexual assault / rape
Willful consent violations or abuse of power and position
Illegal activities or criminal convictions at odds with RHI’s mission and values
VI. Communication
A. Notifying the Respondent of the Decision
The AC will promptly schedule a video call with the respondent to inform them of the accountability action taken and to discuss next steps.
The respondent will then receive an Accountability Action Form via email and will be required to sign and return to the AC. The AC will inform any relevant parties, which may or may not include other Team Members.
In urgent situations, the respondent may simply be informed of the accountability action taken and a video call to discuss the decision and next steps may be conducted afterward.
All efforts will be made to provide a clear explanation of the decision-making process and the reasons for the action taken. A record of the decision-making process will be provided as appropriate.
B. Providing Clarity on the Accountability Action
The AC will ensure that the terms and conditions of the accountability action are clearly explained and understood, answering any questions and addressing concerns.
C. Communication to Complainant and Witnesses
When the case is closed, the AC will inform any relevant parties along with any details they deem to be necessary or relevant.
VII. Appeal Process
A. Appeal via Ombuds Function
Either the complainant or respondent of an accountability case may, within three months, request a review of the AC’s decision via the Ombuds Function (see Ombudsman - Wikipedia).
In case of conflict of interest, the Ombudsman may appoint a substitute Ombudsman.
The appeal must be submitted using this Appeals Form, highlighting reasons the appellant believes the decision should be reconsidered, such as:
New evidence
Demonstrable flaws in process
Impartiality of the deciding parties
Sound arguments for lesser or greater action
The Ombuds Function will review and respond within 30 days but is not bound to re-investigate.
The possible outcomes of an Ombuds Function Review are the following:
Declines to hear the case:
The Ombuds function determines that the case does not warrant further investigation and upholds the AC’s decision.
Denies the appeal on its merits:
The appellant has not shown sufficient evidence that the case needs to be retried and/or that there is a likelihood of a different outcome. During a merit review, both the complainant and the respondent can present their arguments as to why or why not a case should be reviewed.
Retries the case and upholds the AC’s decision
Retries the case and overturns the AC’s decision
Retries the case and adjusts the AC’s decision
B. Forfeiture of Right to Appeal
Poor conduct during or after an accountability process may lead to the forfeiture of right to an appeal. Examples of poor conduct may include:
Uncooperative or dishonest behavior
Public distribution of misinformation or confidential information regarding Ethics Circle Investigations and/or the Accountability Circle’s decisions
Public rants via mass communications via email, text apps, etc. and/or while also accessing personal and private contact information of current or former RHI stakeholders without their permission
Contacting individual uninvolved parties about investigations, open or closed cases, and sharing confidential information with the intent to disparage RHI
Objective and/or miscellaneous unprofessional conduct
VIII. Monitoring and Follow-Up
A. Follow-Up on Accountability Actions
In cases of probation or suspension, or in the case of any mandated restorative, educative, or reflective action, the AC may appoint a support person to follow up with the respondent to guide them through the post-accountability action phase to ensure that the respondent complies with the terms of the accountability action.
This means that behavior and conduct may be monitored more closely during the accountability period, and evaluations may be done to track progress.
Any breach of the accountability terms during this time may result in further accountability action.
B. Setting Expectations for Improvement
Clear expectations for improvement for the respondent's conduct moving forward will be established and communicated.
The goal for these expectations is to offer support and guidance for improvement, and lay out a clear path forward.
IX. Documentation
A. Keeping Records of Accountability Actions
All documentation for accountability cases will be kept securely and may be kept for a maximum of 20 years, and in compliance with United States data privacy regulations.
X. Training and Prevention
A. Training on Code of Ethics and Accountability Procedures
Annual training on RHI's Code of Ethics and accountability procedures will be provided to all Supervisors, Trainers, and trainees, so that everyone knows the hows and whys of the process, as well as their responsibilities and rights.
Ad-hoc training may be provided as necessary.
B. Prevention of Misconduct Through Education
We believe education is the first line of defense against ethical violations and misconduct.
The Ethics Circle will provide regular and adequate education to Supervisors, Trainers, and trainees on potential misconduct risks and how to avoid them.
Our goal is to foster a culture of mutual respect and professionalism between RHI leadership, Supervisors, Trainers, and trainees, and our participants and clients.
C. Promoting a Culture of Accountability
With this Accountability process, we endeavor to transform Radical Honesty culture into one where all members of the organization hold themselves to a high degree of accountability for their actions.
We wish to foster a sense of shared responsibility for maintaining a safe, ethical, and respectful workshop and training environment that promotes the wellbeing of the individual (participants, clients, trainees, employees, etc.) above all else.
XI. Legal Considerations
A. Compliance with US Laws and Regulations
RHI is registered as an LLC in Denver, CO. The AC and the Managing Director will ensure that the accountability process complies with US laws and regulations.
XII. Continuous Improvement
A. Reviewing and Updating the Ethics & Accountability Process
As this process is still new, we will continually review and update it to ensure its effectiveness and relevance.
This process and all of its updates will be made available to all members of the RHI organization, including leadership, Supervisors, Trainers, trainees, and employees.
B. Learning from Past Incidents
The Ethics & Accountability Circles will ongoingly review and discuss each case for continued improvement.
Some cases may be used as case studies to educate RHI leadership, while respecting the privacy of those involved.
XIII. Conclusion
A. Reinforcing Our Commitment to Accountability
RHI acknowledges that mistakes have been made in the past that could have been avoided or promptly resolved with a culture and process dedicated to ethics and accountability.
The Ethics & Accountability Circles wish to emphasize our commitment to transforming the culture of Radical Honesty into one of accountability and of a safe, respectful environment, while upholding the long-held values of honesty and authentic self-expression.
B. Ensuring a Safe and Supportive Workshop & Training Environment
Our highest priority is to maintain safe environments for Radical Honesty workshop participants and coaching clients.
While personal growth is often uncomfortable, challenging, scary, and even intense, it should not come at the expense of undue harm or traumatization, and not accompanied by unethical behavior or misconduct.
The Ethics and Accountability Circles encourage the active involvement of all RHI leadership, Supervisors, Trainers, and TC’s in fostering this environment.
Ethics Circle Members
Michael (Mak) Kolb (Steward) | mak@radicalhonesty.com
Raven Dana | raven@stresswizardcoaching.com
Accountability Circle Members
Kerri Timar (Steward / outside consultant) | theedconsult@gmail.com
Maggie Doyle | maggiesuedoyle@gmail.com