Nondiscrimination Policy

Our Commitment

Equal Opportunity & Equal Dignity

Lokahi Connect believes that every learner deserves access to evidence-based literacy instruction and every person deserves to be treated with dignity. Our name itself — lōkahi, a Hawaiian value of unity, harmony, and balanced wholeness — commits us to building programs, workplaces, and partnerships that reflect that principle.

Lokahi Connect does not discriminate on the basis of any protected characteristic in any of its programs, services, activities, hiring, contracting, volunteer engagement, governance, or educational offerings. We prohibit discrimination, harassment, bullying, and retaliation in every aspect of our work, and we comply with all applicable federal, state, and local civil rights laws.

Scope & Protected Characteristics

Who and What This Policy Covers

Protected Characteristics

Lokahi Connect prohibits discrimination, harassment, and retaliation on the basis of any of the following actual or perceived characteristics, or association with a person who has any of these characteristics:

• Race, color, ethnicity, ancestry, or national origin (including traits historically associated with race, such as hair texture and protective hairstyles)
• Religion, creed, spiritual practice, or absence thereof
• Sex, including pregnancy, childbirth, lactation, and related medical conditions
• Gender, gender identity, gender expression, and transgender status
• Sexual orientation
• Age
• Disability — physical, mental, sensory, learning, neurodevelopmental, or cognitive — including dyslexia, ADHD, autism spectrum conditions, and other neurodivergent identities
• Medical condition, genetic information, or results of genetic testing
• Marital, partnership, or familial status
• Veteran or military status, including status as a service member's family
• Citizenship, immigration, or refugee status (consistent with applicable federal law)
• Primary language, English-language-learner status, or accent
• Socioeconomic status, source of income, or receipt of public assistance
• Housing status, including unhoused or transitional housing status
• Political affiliation or activity (where protected by law)
• HIV status or status as a survivor of domestic violence, sexual assault, or stalking
• Any other basis protected by federal, state, or local law

Scope of Application

This policy applies to:

• All programs and services — including direct student instruction, the Meaning-First Student Lab, educator professional development, coaching, tutoring, assessments, referrals, research collaborations, and community events.
• All employment practices — recruitment, hiring, training, compensation, benefits, promotion, discipline, termination, leave, and access to facilities and resources.
• Volunteers, interns, fellows, contractors, consultants, and board members.
• Students and families we serve — including admission, enrollment, scheduling, accommodations, materials, evaluations, and continued participation.
• Vendors, grantees, grantors, donors, and partner organizations.
• Online spaces — our websites, digital tools, social channels, virtual classrooms, and any third-party platform used to deliver our programs.
• Conduct that occurs off-site when it affects the Lokahi Connect community, including at conferences, field events, home visits, and sponsored travel.

What We Prohibit

Discrimination, Harassment & Retaliation

Discrimination

No person will be denied admission, enrollment, employment, advancement, services, accommodations, or equal access to any program or benefit because of a protected characteristic. Facially neutral practices that have the purpose or effect of excluding or disadvantaging members of a protected group are also prohibited.

Harassment

Harassment — including verbal, written, visual, physical, or electronic conduct — is prohibited when it is based on a protected characteristic and creates an intimidating, hostile, humiliating, or offensive environment, or when it unreasonably interferes with a person's work, learning, or participation. This includes, but is not limited to:

• Slurs, epithets, stereotyping, jokes, or derogatory comments about a protected class
• Deliberate misgendering, refusal to use a person's stated name or pronouns, or outing a person's identity without consent
• Sexual harassment, including unwelcome sexual advances, requests for sexual favors, sexualized comments or imagery, sexual coercion, and quid pro quo conduct
• Bullying, intimidation, threats, or cyber-harassment directed at any member of the community, including students
• Ableist language, mockery of disability-related accommodations or communication styles, or sabotage of assistive supports
• Display or circulation of discriminatory symbols, materials, or content

Retaliation

Lokahi Connect strictly prohibits retaliation against any person who, in good faith, reports discrimination or harassment, participates in an investigation, requests an accommodation, opposes a discriminatory practice, or exercises any right protected by law or by this policy. Retaliation is itself a violation of this policy, and claims of retaliation will be treated as seriously as the underlying complaint.

Access & Accommodations

Supporting Every Learner and Every Person

Students and Families

Our core mission is to serve learners who have been underserved by conventional literacy approaches — including students with dyslexia, ADHD, autism, language-based learning differences, multilingual learners, and those with other disabilities. Lokahi Connect will provide reasonable instructional accommodations, communication supports, and material adaptations so that every student can participate meaningfully in our programs. Individualized learning plans, assessments, and referrals will be developed without regard to any protected characteristic.

Employees, Volunteers, and Participants with Disabilities

In accordance with the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act, the Washington Law Against Discrimination, and other applicable laws, Lokahi Connect provides reasonable accommodations for qualified individuals with disabilities. To request an accommodation — including accessible materials, modified schedules, captioning, sign-language interpretation, assistive technology, or other supports — contact the Nondiscrimination Officer (below). We engage in a good-faith interactive process to identify effective accommodations.

Religious Accommodations

We provide reasonable accommodations for sincerely held religious beliefs and observances, including schedule adjustments, time for prayer or observance, and flexibility around dress or grooming standards, except where doing so would create an undue hardship.

Pregnancy, Parenting, and Related Conditions

Lokahi Connect does not discriminate on the basis of pregnancy, childbirth, lactation, recovery, parenting status, or related medical conditions. Reasonable accommodations — including schedule flexibility, private lactation space, and modified duties — are available upon request.

Language Access

We will make reasonable efforts to communicate with students, families, and staff in languages they understand, including providing translated materials or interpretation where feasible.

Legal Compliance

Applicable Civil Rights Laws

This policy reflects Lokahi Connect's commitment to comply fully with all applicable federal, state, and local anti-discrimination and civil rights laws, including but not limited to:

• Title VI of the Civil Rights Act of 1964 (race, color, national origin)
• Title VII of the Civil Rights Act of 1964 (employment)
• Title IX of the Education Amendments of 1972 (sex in education programs)
• Section 504 of the Rehabilitation Act of 1973 (disability in federally assisted programs)
• Titles I, II, and III of the Americans with Disabilities Act (disability in employment and public accommodations)
• Age Discrimination in Employment Act (ADEA) and the Age Discrimination Act of 1975
• Equal Pay Act and the Lilly Ledbetter Fair Pay Act
• Genetic Information Nondiscrimination Act (GINA)
• Pregnancy Discrimination Act and the Pregnant Workers Fairness Act
• Uniformed Services Employment and Reemployment Rights Act (USERRA)
• Washington Law Against Discrimination (RCW 49.60)
• Washington Healthy Starts Act and applicable Washington paid-leave protections
• All applicable Kitsap County and local civil rights ordinances

Where this policy and applicable law differ, the provision most protective of the affected individual will govern.

How to Report a Concern

Reporting & Complaint Procedures

Any student, family member, employee, volunteer, contractor, partner, or member of the public who believes they have experienced or witnessed discrimination, harassment, or retaliation in connection with Lokahi Connect is strongly encouraged to report it promptly. Reports may be made informally or formally, in writing or verbally, and — where permitted by law — anonymously.

How to Submit a Report

1. Email: info@lokahiconnect.org with the subject line "Nondiscrimination Concern."
2. Mail: Nondiscrimination Officer, Lokahi Connect, Bainbridge Island, WA. (Mailing address available on request.)
3. In person: Request a confidential conversation with the Nondiscrimination Officer or any member of leadership.

What Happens Next

• Acknowledgement: We will acknowledge receipt of a formal complaint within five (5) business days.
• Investigation: Complaints are reviewed promptly, thoroughly, and impartially by the Nondiscrimination Officer or a designee without conflict of interest. Investigations are conducted with as much confidentiality as is possible consistent with a fair process and legal obligations.
• Interim measures: Where appropriate, supportive or protective measures may be put in place during an investigation.
• Resolution: Findings and any corrective action will be communicated to the parties to the extent permitted by law. Corrective action may include training, discipline up to and including termination or removal, revised practices, restitution, or referral to appropriate authorities.
• Appeals: Complainants and respondents may request review of the outcome by the Board of Directors within fifteen (15) business days of the decision.

External Reporting Options

In addition to — or instead of — reporting internally, individuals may file complaints with external agencies, including:

• U.S. Equal Employment Opportunity Commission (EEOC) — employment discrimination
• U.S. Department of Education, Office for Civil Rights (OCR) — education programs
• U.S. Department of Justice, Civil Rights Division
• Washington State Human Rights Commission
• Washington State Office of the Attorney General, Civil Rights Division

Filing deadlines vary. Lokahi Connect will not retaliate against anyone for using any of these external processes.

Accountability

Governance, Training & Ongoing Review

Lokahi Connect's Board of Directors and Executive Leadership are jointly responsible for upholding this policy. Specifically:

• The Nondiscrimination Officer oversees implementation, receives complaints, and coordinates investigations and accommodations.
• All employees, regular volunteers, and board members receive training on this policy at onboarding and periodically thereafter, including on mandatory-reporting obligations where applicable (for example, reports involving minors).
• Hiring, contracting, grantmaking, and partnership decisions are reviewed for equitable process and outcomes.
• This policy is reviewed at least annually and updated as law, research, and community needs evolve.
• Lokahi Connect maintains records of complaints and resolutions consistent with legal obligations and best practices, while protecting the privacy of those involved.

This policy is adopted by the Board of Directors of Lokahi Connect and supersedes any prior nondiscrimination statements. Nothing in this policy creates a contract of employment, limits at-will employment where applicable, or confers rights beyond those provided by law.