Internal use only · not for participant distribution
POIETO INC · Policy Document 11
Peer Safety & Conduct Incident Protocol
For staff and program leads · distinct from the staff-misconduct framework Reviewed annually · June 2026 · Living document
1. Purpose
This protocol governs how POIETO responds when one program participant harms, threatens, or creates safety concerns for another participant. It establishes a clear, tiered response framework that protects all parties and ensures incidents are documented, escalated, and resolved appropriately.
This protocol is distinct from the staff-misconduct framework. Concerns about staff conduct toward participants are governed by the Safe Interaction & Abuse Prevention Policy (Doc 01) and Organizational Abuse Prevention Policy (Doc 02). Do not collapse the two. If you are unsure which applies, assume both and notify the Designated Investigator.
2. Scope
This protocol applies to all POIETO programs. It covers participant-to-participant conduct occurring:
During program sessions, on-site or remote
Between sessions at program sites, including common areas and before/after session hours
In any program-related communication channel (group chat, shared platforms, program email threads)
It applies regardless of the age of the participants involved. See Section 4 for age-specific decision guidance.
3. Severity Tiers
Classify the incident using the descriptions below. When in doubt, escalate to the higher tier. Tier classification may be revised upward as more information becomes available.
Tier 1 — Low
Verbal conflict, unkind behavior, boundary crossing without physical contact
Examples: heated argument, name-calling, social exclusion, persistent boundary-pushing that has not escalated to threats or physical contact.
Response
De-escalate in session; separate participants as needed without removing anyone from the program
Document on the Session Log for that day
Notify Program Lead by end of session, or same day if not in session
Examples: pattern of targeted harassment, explicit verbal threats, grabbing, pushing, or any non-consensual physical contact that does not rise to assault.
Sexual harassment: Unwelcome sexual comments, requests, gestures, or messages directed at another participant — verbal, written, or digital. A single severe incident may be treated as Tier 3.
Discriminatory harassment: Conduct that targets a participant based on race, gender identity, sexual orientation, religion, disability, or any other protected characteristic.
Digital harassment: Harassment conducted through program communication channels (group chat, shared platforms) is covered by this protocol and treated with the same severity as in-person conduct.
Response
Remove the responsible participant from the current session activity (not from the program) to cool down
Notify Program Lead and Designated Investigator the same day — do not wait until the next session
Complete Incident Report Form (Doc 03) same day
If any party is under 18: parent/guardian notification required (see Section 4)
Tier 3 — Serious
Physical assault, sexual contact, credible threats of violence, disclosure of abuse, conduct requiring law enforcement
Examples: physical assault, credible threats with intent to harm, a participant disclosing that they are being abused or have witnessed abuse, conduct that may require law enforcement or mandated reporting.
Sexual contact between participants is always Tier 3 — regardless of claimed consent. This includes any unwanted sexual touching, sexual assault, or sexual exploitation. Do not downgrade to Tier 2.
If any party involved in sexual contact is under 18, mandatory reporting to DCFS is required — see Section 4 and Step 4 in Section 5. Contact the Designated Investigator immediately, before any other action.
Response
Ensure immediate physical safety of all parties; contact 911 if needed
Notify Program Lead and Designated Investigator immediately by phone — do not wait to complete paperwork first
Complete Incident Report Form (Doc 03) same day
Mandatory reporting obligations apply — see Section 5, Step 4 and Section 4
Preserve any relevant communications or materials until the Designated Investigator instructs otherwise
3a. Sexual Conduct — Special Rules
Sexual conduct between participants requires specific handling beyond the standard tier framework. These rules apply in addition to the tier response above.
Zero Tolerance — Cross-Reference Doc 01
POIETO’s Zero Tolerance Statement extends to participant-to-participant sexual conduct
The Zero Tolerance Statement in the Safe Interaction & Abuse Prevention Policy (Doc 01, §1) applies to sexual abuse, exploitation, and misconduct in all forms. It is not limited to staff conduct. A participant who sexually harasses or assaults another participant triggers POIETO’s zero tolerance framework in addition to this protocol.
Sexual conduct — mandatory rules
These apply regardless of participant age or claimed consent
Do not mediate sexual harassment or sexual contact incidents directly between the parties. These require Designated Investigator involvement, not peer resolution.
Do not ask the affected participant to confront or re-engage with the person who harassed them.
Sexual contact is always Tier 3 — upgrade if you initially classified it lower.
Verbal sexual harassment is minimum Tier 2. A single severe or threatening incident may be Tier 3.
Under 18 + sexual contact = mandatory DCFS report. No discretion. Contact Designated Investigator and DCFS simultaneously. See Section 5, Step 4.
Dating and relationship dynamics: Relationship conflict between participants who are (or have been) in a romantic or sexual relationship should be assessed carefully. Do not dismiss as “personal.” If there is any element of harassment, intimidation, or non-consensual conduct, apply this protocol from Tier 2 minimum. Consult the Designated Investigator if unsure.
4. Minor / Adult Decision Tree
Age of parties determines additional obligations. Assess the ages of all involved parties before proceeding.
Condition A
All parties are 18 or older
Follow the tier response above. Notify Program Lead and Designated Investigator per tier. No automatic parent/guardian notification required.
Condition B
Any party is under 18
Tier 1: Document and notify Program Lead as normal. Parent/guardian notification at Program Lead's discretion.
Tier 2 or higher: Parent/guardian notification is required. Consult Designated Investigator before contacting family if there is any reason to believe doing so may increase risk to the participant.
Tier 3: Mandatory reporting obligations apply. Contact Designated Investigator immediately; do not make independent decisions about reporting or family contact.
Sexual contact involving any participant under 18 = mandatory DCFS report, no exceptions, no delay. Contact Designated Investigator and DCFS (800-540-4000) simultaneously. Do not wait for internal process to complete.
Condition C — Elevated
Any party is under 13
Treat as Tier 3 minimum regardless of apparent severity. Contact Designated Investigator immediately by phone. Do not proceed independently. Do not notify family before consulting Designated Investigator.
5. Reporting Layers
All incidents must follow these steps in order. Steps may occur simultaneously in a Tier 3 emergency, but none may be skipped.
1
Notify Program Lead
Notify the Program Lead verbally during or immediately after the session where the incident occurred. For incidents discovered between sessions, notify by phone same day. Program Lead is responsible for all downstream steps.
2
Notify Designated Investigator
The Designated Investigator must be notified same day for all Tier 2 and Tier 3 incidents, and immediately by phone for Tier 3.
GS
Ginny Song — Designated Investigator · COO
ginny@poieto.com · 310-560-4685
3
Complete Incident Report Form (Doc 03)
The Incident Report Form must be completed same day for all Tier 2 and Tier 3 incidents. Do not document incident details in group chat, email, or shared notes before speaking to the Designated Investigator. Submit the completed form to the Designated Investigator.
4
Notify Founder — Tier 3 incidents only
Christine Meinders must be notified for all Tier 3 incidents. The Designated Investigator will typically make this notification; if she is unreachable, the Program Lead should contact Christine directly.
When mandatory reporting obligations apply (see Section 4), contact DCFS. Do not delay a mandatory report to complete internal paperwork first.
☹
DCFS — LA County Mandatory Reporting
800-540-4000 · Available 24 hours
6. Do Not
Stop. Read before acting.
Do not handle a Tier 2 or Tier 3 incident alone. These require Program Lead and Designated Investigator involvement. An individual staff member should not make decisions about consequences, family notification, or external reporting without that consultation.
Do not document incident details in group chat, email, or shared notes before speaking to the Designated Investigator. Written communications may become part of an investigative or legal record. Capture facts; hold distribution.
Do not contact a participant's family if doing so may increase risk to the participant. This applies especially when a participant has disclosed abuse at home, or when family involvement may put a minor at greater risk. Consult the Designated Investigator first.
Do not conflate this protocol with the staff-misconduct framework. If a concern involves staff conduct toward a participant — even if participants are also involved — activate Doc 01 and Doc 02 in parallel.
Do not mediate sexual harassment or sexual contact incidents between the parties directly. These require Designated Investigator involvement. Do not ask an affected participant to confront or re-engage with the person who harassed them.
7. Distinction from Staff-Misconduct Framework
This protocol governs participant-to-participant conduct only. It does not cover:
Organizational policies on mandatory reporting by staff (see Organizational Abuse Prevention Policy, Doc 02)
Workplace harassment between employees (see Harassment, Discrimination & Retaliation Prevention Policy, Doc 09)
If you are unsure which framework applies — for example, if an incident involves both a participant and a staff member, or if staff conduct is alleged alongside participant conduct — assume both apply and notify the Designated Investigator. The Designated Investigator will determine which framework governs each strand of the concern.
When in doubt: Call Ginny Song (Designated Investigator) at 310-560-4685. You do not need certainty before reaching out.
8. Acknowledgment
Staff / Program Lead Acknowledgment
I acknowledge that I have read and understand the POIETO INC Peer Safety & Conduct Incident Protocol (Document 11). I understand the severity tiers, reporting chain, and my obligations under this policy. I agree to follow this protocol and to seek guidance from the Designated Investigator whenever I am uncertain.
Founder Countersign
Retain signed acknowledgment in employee personnel file.