Internal use only · not for participant distribution
POIETO INC · Policy Document · Cal/OSHA SB 553

Workplace Violence
Prevention Plan (WVPP)

All employees · all program sites · reviewed annually · June 2026

1. Policy Statement

POIETO INC is committed to providing a workplace free from violence, threats of violence, intimidation, and harassment. This plan applies to all employees, teaching artists, contractors, and volunteers at all POIETO locations and program sites.

Workplace violence will not be tolerated in any form. All reports will be taken seriously and investigated promptly. This Workplace Violence Prevention Plan (WVPP) is maintained in compliance with California Labor Code Section 6401.9 (SB 553, effective July 1, 2024) and Cal/OSHA regulations.

This plan is a living document. It is reviewed annually each June and updated whenever a violent incident occurs, a new hazard is identified, or program operations change materially. The current version is maintained by the Designated Coordinator and is available to all employees on request.

2. Definitions

Workplace violence means any act of violence or threat of violence that occurs in the workplace, including physical assaults, attempted assaults, threatening behavior, verbal or written threats, harassment, and intimidation. Cal/OSHA identifies four types:

Type 1
Criminal Intent
The perpetrator has no legitimate relationship to the workplace. Violence occurs in connection with another crime (robbery, burglary, vandalism). The target is the business, not a specific person. Example: an armed robbery at a program site.
Type 2
Customer / Client / Participant
Violence by someone who receives, has received, or is seeking services from POIETO. Most relevant to POIETO's work. Example: a program participant threatening or assaulting a teaching artist or staff member.
Type 3
Worker on Worker
Violence by a current or former POIETO employee, contractor, or volunteer against another employee. Includes bullying, threats, and physical aggression originating within the organization.
Type 4
Personal Relationship
Violence by someone who has a personal relationship with a POIETO employee (current or former intimate partner, family member). Domestic violence, stalking, or a related threat that enters or affects the workplace.

Violent incident means any workplace violence event, including incidents that did not result in injury, credible threats, and concerning behaviors that are precursors to violence. All violent incidents must be logged (Section 8).

3. Responsibilities

Employer

CM
Founder & Employer
Christine Meinders
christine@poieto.com

The Employer is responsible for:

Designated Coordinator

GS
COO — Designated WVPP Coordinator
Ginny Song
ginny@poieto.com · 310-560-4685

The Designated Coordinator is responsible for:

All Employees, Teaching Artists, Contractors, and Volunteers

Every person covered by this plan is responsible for:

4. Hazard Identification and Assessment

POIETO has identified the following hazards and risk factors specific to its operations. This list is reviewed annually and updated when new sites, programs, or populations are added.

Identified Hazards

Hazard Violence Type Current Control
Working at off-site partner program sites not owned or controlled by POIETO Type 1, 2 Pre-use site assessment; partner site contact maintained; check-in/check-out protocol
Working with participants who may have experienced trauma, housing instability, or justice-system involvement Type 2 Trauma-informed staff training; de-escalation protocols; never-alone policy
Staff working alone with a participant before or after sessions Type 2 Prohibited by contract (Section 7.4.3.4); program scheduling requires site staff presence at all times
Physical layout of partner sites (limited exits, poor sightlines, isolated spaces) Type 1, 2 Pre-use site assessment checklist; egress plan documented before first session
External threats entering the program site (unknown individuals, criminal activity) Type 1 Rely on partner site security; POIETO staff know site security contact; 911 as first response
Domestic violence, stalking, or personal relationship threats involving a POIETO employee Type 4 Mandatory notification to Designated Coordinator; safety planning with employee; coordinate with law enforcement as needed

Pre-Use Site Assessment

Before a new partner program site is used for the first time, and at least annually thereafter, the Designated Coordinator or designee conducts a site safety assessment using the checklist in Appendix A. The assessment evaluates:

Assessment results are documented and retained by the Designated Coordinator. Any unacceptable hazard must be corrected before POIETO staff begin working at that site.

5. Preventive Measures

Never Alone Rule. No POIETO staff member, teaching artist, contractor, or volunteer may be alone with a participant at any time. Doors must remain open. Partner site staff must be present and accessible. This requirement is codified in Section 7.4.3.4 of POIETO's program contracts with partner organizations.

Check-In / Check-Out Protocol

All program staff notify the Program Lead of their arrival at and departure from each program site. If a staff member does not check out within 30 minutes of the expected end of session, the Program Lead initiates contact. If contact cannot be established within 15 additional minutes, the Program Lead notifies the Designated Coordinator.

Incident Logging

All incidents, threats, and concerning behaviors are logged in the Violent Incident Log (Section 8) on the day they occur. Logging is mandatory regardless of whether the incident resulted in injury.

Partner Site Contacts

POIETO maintains current contact information for each partner site's on-site security personnel and management. This information is documented in the program file for each site and reviewed at the start of each program year.

Restraining and Protective Orders

Any POIETO employee who is a named protected party in a restraining order or protective order, or who obtains such an order involving another person connected to the workplace, must notify the Designated Coordinator immediately. The Designated Coordinator will work with the employee to assess workplace safety, coordinate with law enforcement if appropriate, and document the notification.

Workplace Access and Visitor Management

At partner program sites, POIETO staff follow the host site's access and visitor management procedures. POIETO does not operate a facility of its own that is open to the public; all access controls at program sites are the partner organization's responsibility, supplemented by POIETO's site assessment process.

6. Reporting Procedures

Anyone who experiences, witnesses, or becomes aware of a violent incident or credible threat must report it immediately. There is no minimum threshold for reporting — threats, concerning behavior, and near-misses must all be reported.

If there is immediate danger to any person: call 911 first. Do not attempt to handle an active violent incident without law enforcement. Your safety comes before documentation.

Reporting Chain

  1. 1Immediate danger: Call 911. Evacuate if safe to do so. Do not return to the area until law enforcement declares it safe.
  2. 2Notify Program Lead verbally during the same incident or immediately after. The Program Lead is responsible for the group and must be informed without delay.
  3. 3Notify Designated Coordinator (Ginny Song) the same day. Contact: ginny@poieto.com · 310-560-4685. If the Designated Coordinator is unavailable, notify the Founder (Christine Meinders, christine@poieto.com).
  4. 4Complete a Violent Incident Log entry (Section 8) the same day. The Designated Coordinator can assist if the affected person is unable to complete the entry.
  5. 5Tier 3 incidents per Peer Safety Protocol (Doc 11): Notify Christine Meinders, Founder — christine@poieto.com. Refer to Doc 11 for classification guidance.

Reporting Methods

Reports may be made verbally, by phone, or by email. Anonymous reports are accepted. Anonymous reporters should contact the Designated Coordinator by email without identifying themselves; investigations will proceed on the available information. POIETO will make every reasonable effort to protect the reporter's identity.

No retaliation. POIETO will not retaliate, and will not permit retaliation, against any person who reports a workplace violence concern in good faith. Retaliation is a separate violation of this policy and will be addressed under the Harassment and Discrimination Prevention Policy (Doc 09).

7. Response Procedures

During an Incident

Immediately After an Incident

Post-Incident Support

POIETO recognizes that workplace violence incidents cause distress beyond physical injury. After any significant incident:

Employer Investigation

The Designated Coordinator (or the Founder, if the incident involves the Designated Coordinator) will investigate every reported incident to determine the cause, identify corrective actions, and update the Violent Incident Log. Investigation will begin as soon as practicable after a report is received and no later than five business days following the incident. Findings and corrective actions are documented in the Violent Incident Log.

Serious injuries must be reported to Cal/OSHA immediately (within 8 hours): (213) 576-7451 or 833-579-0927. A serious injury includes any hospitalization, amputation, loss of eye, or death. The employer's workers' compensation carrier (The Hartford, claims: 800-327-3636) must also be notified without delay.

8. Violent Incident Log

POIETO maintains a Violent Incident Log as required by California Labor Code Section 6401.9(c)(6). Every workplace violence incident must be entered in the log on the day it occurs, including incidents that did not result in injury, threats, and concerning behavior that did not escalate.

Log Contents

Each entry records the following, using roles rather than names where doing so protects individual privacy:

Retention and Access

The log is maintained by the Designated Coordinator. Log entries and supporting documentation are retained for a minimum of five (5) years. The log is reviewed by the Designated Coordinator and Founder:

Employees may request access to the log. Entries will be provided with identifying information redacted to the minimum degree necessary to protect individual privacy while preserving the substance of each record.

Appendix A — Site Safety Assessment Checklist

ItemOK / IssueNotes / Required Action
Entry and exit points are clearly identified and accessible
Lighting is adequate in all program areas and exterior paths
Staff can maintain sightlines to participants at all times during programming
No isolated spaces where one-on-one contact could occur unobserved
On-site security personnel or system present and contact info obtained
Partner site emergency/evacuation procedures reviewed and shared with POIETO staff
Communication (cell signal, landline, or radio) available throughout site
No unacceptable access control gaps (unauthorized persons able to enter program area)

Appendix B — Violent Incident Log Entry

Complete one form per incident. Retain completed forms for 5 years. Use roles, not names, where indicated.

9. Training

All employees, teaching artists, contractors, and volunteers who may have contact with participants or who work at program sites receive WVPP training before their first day of participant contact and annually thereafter.

When Training Is Required

Training Content

Training covers, at minimum:

Documentation

Training completion is documented for each person: name, date, training topic, and trainer or provider. Records are retained for a minimum of one year and reviewed during the annual WVPP review.

Appendix C — WVPP Training Log

DateEmployee / Contractor / VolunteerRoleTraining TopicTrainer / Provider
 
 
 
 
 
 

10. Annual Review

This WVPP is reviewed annually each June by the Designated Coordinator and the Founder. An out-of-cycle review is also conducted whenever a violent incident occurs or a new hazard is identified. The annual review evaluates:

Employees are invited to contribute to the annual review. Input may be provided to the Designated Coordinator by email, verbally, or anonymously. Contributions from the team are documented and considered in the review.

The date and participants of each annual review are documented and retained. Any material changes to the plan are communicated to all employees within 30 days of adoption.

Appendix D — Annual Review Record

Acknowledgment

By signing below, the employee confirms they have received, read, and understood the POIETO INC Workplace Violence Prevention Plan, and agree to follow its requirements.

Employee Acknowledgment


Employer Countersignature