Implementing Culture

We recommend a holistic approach to inclusivity  —  one that covers every aspect of the culture. There is no silver bullet, no one-size-fits-all solution. Efforts must be comprehensive and tailored to the unique needs of each organization. Implementing an inclusive culture requires always planning ahead and being able to evolve as a company grows and people change, new processes are added to operations, the number of teams increases, and coordination gets more complex.

Why did we choose this area?

Hiring is obviously an important part of diversity and inclusion. We have seen a lot of focus on the subject, which is needed. At least equally important, though, is the next phase of work, which begins once an employee starts. A company’s processes and teams should set all employees up for realizing their potential, enabling each employee to contribute to their full ability.

Too often, biases and structures protect and favor one group or type of employee over others. Instead, a company should have a strategy for incorporating everyone onto the team and making them welcome and successful. Moreover, diversity and inclusion initiatives must follow employees throughout their time at a company, and must evolve with changes in the company and industry.

How do we think about implementing culture?

It takes a lot of effort to build diversity and inclusivity into a new startup and culture, and even more to fix it if it’s missing. Dedicated resources are needed to design, track and implement changes  —  and to make sure they are working.

Transparency and shared documentation can help in building a shared culture. We recommend an innovative, opportunity-driven approach. Too often, the focus of documentation is risk mitigation, which means avoiding knowledge of potential problems, using minimum requirements, and a conservative approach. We see it instead as an opportunity to be ambitious, bold, and proactive, which means identifying problems early to address and fix them before they get bigger, investing in and accommodating differences, and taking the time to understand and empathize.

For the first time, startups have started to develop technological products and services that can help mitigate bias at scale, built by founders with experience in and deep understanding of the tech culture and startups. Technology solutions can help mitigate by suggesting better language in job descriptions, providing partial anonymity to candidates, tracking metrics across the hiring process, and more. Many are specifically designed to combat bias in not only hiring, but also the workplace generally.

What are we concerned about?

Funding external programs, while laudable, does not on its own constitute a diversity strategy. A robust diversity and inclusion strategy must first and foremost focus on building a workplace culture that supports its goals.

Codes of conduct, and culture building initiatives generally, must have senior-level buy-in to be successful. Leadership and managers set the tone and should be actively involved. They decide whether diversity and inclusion are priorities for their groups and teams and can model inclusive behaviors. They have the power to create or support the creation of structures that advance diversity and inclusion efforts. Most importantly, they establish and enforce the accountability mechanisms for workplace standards to ensure that all employees adhere to them. Without senior-level buy-in and manager level implementation, the potential for impact is limited.

Building diversity and inclusion into a company in its earliest days is important and will pay dividends over time. We’ve seen startups too often wait, focusing on other priorities, and by the time they get to it, the engineering team has 30 men, mostly white, with a homogenous, exclusive culture that women and people of color are reluctant to join.

What are our recommendations?


Drive diversity top-down from the CEO level

Diversity requires an integrated company-wide effort across teams and functions at all levels of the organization. The only person who can lead this effort is the CEO. The CEO must set the vision and the prioritization of diversity and inclusion so all employees understand its importance, have the hard conversations, and do the hard work required.


Outmoded diversity policies that have dominated  —  and failed  —  corporate America are unhelpful contributions to the cause of inclusivity in the workplace. Policies that require employees to report behavior they consider inappropriate, triggering an automatic HR investigation, often exacerbate the problem. More often than not, they ensure that no one comes forward. Who would file a formal complaint against their CEO for making a sexist or racist comment? These approaches mean that day-to-day exclusionary and offensive practices stay hidden, along with their cumulative effect of driving women, LGBTQA employees, and employees of color out the door in disproportionate numbers.

VCs and tech companies should not adopt the policies and practices that already demonstrably do not work in corporate America. Instead, they should build HR from the perspective of inclusionary practices, not legal liability.

Companies should explore alternative methods to traditional policy-making and conflict resolution techniques, as we discuss here and in our section on addressing and resolving conflict. Without rethinking how HR interacts with employees and operates, the company will perpetuate the history of competing interests between HR and the needs of employees.

Culture is codified in the earliest days of a startup, so bringing in HR and D&I to build, reinforce, and maintain values and company culture is key to making sure inclusivity starts and grows with a startup.

25+ employees

Make HR one of the first 25 hires

Someone needs to build culture, set boundaries and expectations of behavior, communicate them clearly, and make sure people comply. HR should be responsible for both recruiting and retention, and reinforce the company’s commitment to D&I. It must set up fair processes for people ops and hiring, onboarding, promotions and compensation, and performance reviews. It should drive and provide operational transparency. This includes processes like building organization charts, training for both employees and managers, building the code of conduct, and determining and implementing benefits.

Ultimately, the most important characteristic for HR is good judgment, with commitment to diversity and inclusion a close second. It is the responsibility of HR to look for problems to prevent, not just to react to problems after the fact. Tech experience  —  and startup experience  —  is also important, to add credibility and weight.

Most startups begin by hiring a junior HR coordinator, who is expected to perform all these important activities plus plan company events, but often has no guidance, no guidelines and no experience, especially around the complicated issues of diversity and inclusion. Don’t take the junior HR coordinator route. Instead, hire for experience and judgment. Technology experience can provide much needed credibility  —  especially with engineers  —  and startup experience can ensure that the HR lead understands how hands-on they will have to be and what possible outcomes and problems could be.

You may not be able to hire a strong candidate internally with great judgment, a commitment to D&I, and tech startup experience. Then you may want to outsource to an advisor or contractor with that background with an HR coordinator internally providing help, especially around culture. Just make sure they will be available on short notice to help navigate problems as they arise.

HR should be about solving problems, some of which will be complicated and nuanced, focusing on positive outcomes for employees and the company. That means startups need an HR person who is not afraid to roll up sleeves and have hard conversations, who thinks long-term, and who knows how to prevent problems from snowballing. The HR person’s first response to a problem should not be to bring in legal, because legal is about risk mitigation for the company and can accelerate conflict. Startups are about risk taking and innovation and working together as a team to head off problems early.

75+ employees

Hire and empower a D&I lead to execute the CEO’s vision for inclusivity

Research indicates that the biggest gains in managerial diversity and effective diversity programming happen where responsibility has been established. The CEO needs to designate a person within the organization to monitor implementation of policies and evaluate their effectiveness. Ensure that person has the power to take action and make tough decisions where required. Ideally, this person should have some level of expertise related to diversity and inclusion, and be allowed to focus on inclusivity on a full time basis. Some companies hire a Head of Diversity and Inclusion to do this work. However, responsibility can also be assigned through the creation of a committee.

Because D&I efforts must be comprehensive, the D&I lead should be included in all aspects of a company, including planning, strategy, and executive meetings and discussions. D&I leads should report directly to the CEO or COO for maximum efficacy. CEOs should always think about and prioritize diversity and inclusion; when there is a COO who cares about diversity, their role in people operations can make them an appropriate manager and owner of D&I  —  as a proxy for the CEO. The D&I lead should serve as the CEO’s or COO’s deputy initially as an advocate, and eventually as a full-time dedicated leader at the VP level in the company.

The D&I role should be internally focused on building D&I into the culture, into every team, into every function, and into the company as a whole. External initiatives around hiring and PR may be a small part of the role as well. Team members who reflect the diversity of the company should be involved in the process of choosing the D&I lead. If you do not have any, consider having an outsider vet candidates.

It may seem early to add a D&I specialist at 75 employees, but in our experience, problems can start even earlier and are hard to fix later.

15+ employees

Develop effective codes of conduct

Often included as part of an employee handbook, workplace codes of conduct govern behavior and ethics of employees in a professional environment. In addition to a broad statement of principles, a code of conduct can include policies concerning dress code, attendance policy, use of company property, and appropriate workplace behaviour. Ultimately, a company’s code of conduct codifies and communicates company values and expected behaviour of its employees.

Well-designed codes of conduct serve as critical tools for building workplace culture, and can be instrumental in the creation of an open, respectful environments. Leadership can use codes of conduct to communicate their commitment to diversity and inclusivity with employees as well as clients and vendors. The specific policies contained within these documents can clearly articulate ways in which employees uphold their organization’s commitment to inclusivity in their everyday interactions and behaviours. Moreover, codes of conduct can create a default expectation of safety and accountability when standards are breached.

15+ employees

Put thought into the process of developing your code of conduct

The process of developing a code of conduct can itself be a culture-building exercise. Companies should establish a team of drafters who believe in and want to build diversity and inclusion into your startup. Ideally the team should be diverse and should include influencers who can build company support for the code of conduct; otherwise consider bringing an outsider to help review or consider working from one of the sample codes of conduct shared below as a baseline. The team should think critically about what the code should contain and who will be in charge of enforcement. Often, codes of conduct are drafted by counsel with input from a broader multi-disciplinary team comprised of people who represent different levels of management and business function. However, companies should take less of a risk-mitigating, law-oriented approach and more of a collaborative, values-driven approach. A participatory process can encourage a company’s leaders across functions to think critically about their approach to culture building and create buy-in amongst the document’s authors, who through their involvement become more invested in the code’s successful implementation.

Currently, most of the code of conduct templates adapted by tech companies are based on codes of conduct for events, developed in response to rampant harassment, assault, and exclusion occurring at tech conferences. However, it should be noted that while useful, these codes do not cover the range and depth of interactions that occur in workplace settings. Generally, conferences occur on an annual basis, are relatively short in duration, and are conducted over a definitive time period. Conference spaces are populated by larger groups of people whose interests may not necessarily align outside of the conference topics. Workplace interactions, however, are usually more intimate and continuous. Those sharing the space have been vetted to a higher degree and intentionally selected in part for their ability to productively interact with colleagues frequently over time. Finally, in the workplace, there is a broader foundation of shared goals that are influenced by company values and business objectives. As they design their codes of conduct, startups may want to look to other industries for examples.

15+ employees

Make your code of conduct comprehensive and visible

Your code of conduct should open with a statement of purpose, tailored to your organization and reflecting its mission, values, and business drivers. Generally, a company’s code of conduct should be integrated into, reference, or incorporate its other policies. These policies can include anti-discrimination, anti-harassment, inclusive benefits, supplier agreements, and confidentiality policies. Ideally, a company’s commitment to inclusion would not only be expressed in regards to policies specifically concerned with diversity, but threaded through all policies and practices to encompass a more holistic approach.

Codes of conduct should be publicly shared, easily accessible, and highly visible. A code of conduct that is hidden in an obscure corner of a company’s internal website does little good. In fact, low visibility may do harm by communicating that a company does not really value its code of conduct. A code of conduct should include concrete examples to illustrate otherwise abstract concepts. Finally, codes of conduct are most effective when they are integrated as part of a broader process, one that includes training, enforcement, monitoring and evaluation, and continuous improvement.

15+ employees

Include a statement of values in your code of conduct

A company’s values are often what people see first when learning about a company’s culture. A strong but concise value statement is a huge draw for talented employees who are looking for a workplace they feel they would fit well with. For existing employees, the company’s values can serve as an abridged code of conduct, and a way to check in on whether their actions or experience are aligned well. When determining the most important values for your startup, it can be truly challenging to narrow down a list of options. Some topics that may be considered values can be covered in separate areas. For example, an anti-harassment policy and commitment to inclusivity are standalone statements that complement solid company values.

Here are our recommendations for developing strong value statements for your organization:

  • Use “people first” language, to support the idea that your employees will be treated humanely, and with empathy as valuable members of your working team.
  • Determine and state what your approach will be towards accountability. Explicitly state what accountability mechanisms are and when they will be utilized.
  • Be clear when wording your values statement, and avoid using in-house jargon or terminology when possible. This helps ensure that those outside of your organization can understand, which is great for recruiting new talent.

A code of conduct clearly defines and communicates its scope, including the environments, situations, and persons to which it applies.

Companies should commit to creating an inclusive environment for everyone, taking care to recognize those groups who tend to be targeted for exclusion. At minimum, the list of those specified should include the classes of individuals legally protected from discrimination, known as protected classes. In California, for example, state and federal law prohibit discrimination on the basis of race, color, national origin, religion, sex, age, disability, sexual orientation, gender identity, gender expression, marital status, or medical/genetic condition.

15+ employees

Monitor, audit and survey the results of your code of conduct

A code of conduct alone is not enough to build an inclusive culture. Codes of conduct must be designed and implemented alongside other supportive components to be truly effective. There are several elements to ensuring that a code of conduct successfully promotes the development of an inclusive working culture. Companies, particularly those with limited resources, may be tempted to rely solely on the code of conduct as means by which to develop inclusive working environments. Where such efforts fail, we are concerned that companies will dismiss codes entirely.

Organizations should regularly monitor and audit the implementation of their code of conduct, paying close attention to levels of compliance and effectiveness of enforcement mechanisms. Organizations should share the results of these audits with their employees in ways that respect the privacy of those involved. Companies could report on metrics such as suspected breaches, mechanisms for reporting, whether reports were substantiated, and the company’s response.

To be effective, a code must also be relevant, meaning it should be regularly updated. In addition to obtaining information from audits, organizations should also solicit their employees for feedback on their code of conduct. Collectively, this information should inform revision and improvements to the code. Additionally, codes should be regularly updated to reflect changes in the law, regulations, and ethical norms.

15+ employees

Complement your code of conduct with a clear anti-harassment policy

Creating a strong company culture is the act of building a foundation for success. An anti-harassment policy is a non-negotiable cornerstone of a fully inclusive company. In an ideal world, creating an inclusive workplace with a comprehensive code of conduct will prevent harassment violations from occurring. However, an inclusive company still needs a clear framework for addressing code of conduct violations. An anti-harassment policy ensures that in the event of an incident, employees have a clear expectation of their rights and the processes available for them to seek support.

Anti-harassment policies should be explicitly clear, defining what is not appropriate, outlining the steps for reporting an incident, and explaining what to expect once a report has been filed. Alongside this, listing the consequences of certain examples of violations can and will act as a deterrent for those who may have past experience in workplaces that are more permissive.

Consider offering more than one option for incident reporting. Without an option that allows for anonymity, should a situation arise where an employee may fear retaliation, an incident may go unreported.

When writing anti-harassment policies, attempt to approach them not as a company looking to avoid liability, but from the perspective of an employee who has been faced with an incident they need to report. Offering easy, non-confrontational ways to resolve conflict can enable employees to self-regulate and manage incidents. Bookending this option with resources and a pledge of support from the company helps to defeat the expected tendency to diminish a reporter’s experience.

The footnote of a solid anti-harassment policy is not about the written policy itself, but is instead about creating a culture where violations are less likely to occur. That means employees must understand that actions that violate policies have negative consequences, including a permanent record in their personnel file. If violations do unfortunately occur, plan to support and train your human resources or people/culture teams on everything from avoiding the use of language that creates a perception of doubt, up to and including when it is appropriate to engage law enforcement, lawyers, and other third parties. Use conflict resolution strategies rooted in our suggestions for creating an environment where employees feel confident when reporting violations. Use a range of reporting methods, a third party ombudsperson, and a clear system for tracking complaint resolutions.

When violations do occur, managers must periodically follow up with employees at three months and again at six months to determine if they feel the situation was resolved and to discuss whether the inappropriate behavior has stopped. In addition to making employees feel valued, these follow ups will confirm that the company takes the code of conduct and related policies seriously  —  and is both comfortable talking about specific problems and willing to work on solutions until the problems are actually solved.

15+ employees

Develop effective, integrated policies

Diversity policies such as codes of conduct, anti-discrimination, and anti-harassment policies are crucial components to any inclusivity imitative. However, companies should be careful when developing their diversity policies. Poorly crafted diversity policies can do more harm than good. Studies show that the very presence of a diversity policy can lead high status individuals within organizations to discount claims of unfair treatment, even when such claims are justified.1

In some cases, the introduction of diversity programs can result in a decrease in diversity.2 Poorly communicated diversity policies can also create perceptions of unfair treatment by dominant groups, while doing little to assuage the concerns of employees from underrepresented groups about whether they will be treated fairly in the workplace.3 Therefore, it is important that companies critically consider the diversity programs and policies they implement.

Policies that do not acknowledge power dynamics are also flawed. “Context always matters, with the most important element being the power relationship between the parties. Power relationships include official rank or status in organizational hierarchy, as well as cultural variables, such as who is expected to defer to whom based on gender, age, race, immigration status or other factors.4” Policies should consider power dynamics within and outside of the workplace. These dynamics can impact the way a controversial situation is viewed, interfere with a person’s ability to speak up, and influence the nature and severity of an organization`s response to a compliant.

Link the policy and specific behaviors to the type of culture the organization seeks to create, as well as the organization’s mission and core values. All-inclusive approaches to diversity have been shown to increase feelings of inclusion, while mitigating resistance and perceptions of favoritism.5 Highlight the benefits of the policy for members of both majority and minority groups. Frame diversity discussions in terms of shared interests and positive impacts on performance rather than remediation, the law, or ethics.

15+ employees

Emphasize principles over rules in a diversity policy

Rather than trying to individually regulate the wide array of different interactions that take place in the workplace, policies should focus on supporting the driving principles of creating an inclusive culture. Companies may want to consider an impact- or outcome-oriented approach, one that focuses more on achieving outcomes consistent with principles than regulating specific types of conduct. It also creates room for nuance, considering power dynamics and other factors at work when employees engage in behavior that violates company policies and values.

Some companies have chosen to view this approach through the lens of a zero-tolerance stance. A zero-tolerance stance conveys that the behaviors governed by the policy are taken seriously and are understood to have a deleterious effect on individuals, workgroups, and the organization as a whole.

However, a zero-tolerance rule requires rote application of a policy (and, presumably, disciplinary procedures if the policy is violated) without any room for nuance or judgment regarding how to achieve the best outcome consistent with the principles.

Ironically, zero-tolerance rules may in some ways be antithetical to diversity, because they treat everyone and/or every behavior equally, rather than understanding the individual, subjective experience, nuance, and context of behaviors. Take a strong, consistent, principled stance and make sure that it is modeled by top management.6 Rigid policies disempower HR managers and can stifle win-win solutions. They may be necessary, though, if the culture is so flawed that rigid rules are needed to ensure discipline and prevent inaction from being the default solution.

15+ employees

Don’t separate forms of harassment

Don’t create separate policies to govern different forms of harassment. This makes matters confusing, and dealing with harassment issues in different documents forgoes the opportunity for the organization to state its larger view  —  that inappropriate conduct undermines the organization’s business and/or mission. It also decouples anti-harassment and inclusivity initiatives from the organization’s core values and other broader elements of its culture. Separating types of harassment can also be divisive, inadvertently prioritizing one type of victimization over another, and failing to account for one person being affected by bias or discrimination as a member of multiple underrepresented groups.7

15+ employees

Make guidelines specific and cover all employee behavior in all settings

Provide multiple examples in plain language that reflect the kinds of day-to-day situations encountered by employees. Detail the range of responses which may occur should the policy be violated. Outline the scope of the policy. Describe who is covered, where, and when.8

Examples could include:

  • Trust and confidentiality
  • Respectful and effective approaches to communication
  • Preferred working methods
  • Standards of professionalism
  • Use of company property
  • Use of social media
  • Belittling, or subtle expressions of bias
  • Verbal, physical, or written abuse or assault
  • Bullying, intimidation, or victimization
  • Discrimination
  • Harassment
  • Intoxication
  • Inappropriate use of company property or assets
  • Failure to comply with company values
  • Illegal activity
  • Breaches of other company policies
  • Workplace decor  —  visual cues can communicate culture and carry cultural baggage. For example, inappropriate or disproportionately masculine environmental elements can undermine inclusivity messaging and exacerbate feelings of exclusion.

Once you’ve developed your inclusive team, ensuring that all employees feel welcome and enabled to succeed in your workplace, it’s time to handle the outside world. Your commitment shouldn’t end once you and your employees leave the office for the evening.

15+ employees

Consider networking and relationship building in behavior guidelines

In tech, the pathway to advancement is often forged by the relationships that people form within their companies and the sector at large. The secretive, fast-paced, high-growth, high-risk nature of the technology industry necessitates that those within it rely heavily on their trusted networks to keep up with the demands of business. Networking, public outreach, team-building and other relationship-building mechanisms are crucial components of work within many tech firms. In most companies, decisions related to recruitment, hiring, collaborative working arrangements, performance evaluations, promotions, and termination are all heavily influenced by relationship concerns and can be group decisions.

Exclusion and harassment often occur within the context of work-related social functions, such as conferences, happy hours, holiday parties, and industry events. Troublesome interactions that do not arise to the level of overt exclusion or harassment, but still communicate bias, perpetuate stereotypes, or emphasize differences can be just as detrimental.

Possible areas to consider include:

  • Selection of the venue: Is the venue one that is legally enabled to refuse business to your employees of minority or who identify as LGBTQA? Is it fully accessible for your disabled employees? Do they offer handicap access and restrooms?
  • Alcohol: Does the meeting or event include alcoholic beverages or tolerance of drugs of any kind? How often do networking and social events feature alcohol? Is drinking permitted or encouraged in the workplace? Are there alternative beverages for people who do not want to drink alcohol or are underage? Keep employees may be struggling with addiction in mind. Also remember that alcohol is used to facilitate sexual assault and as an excuse for inappropriate behavior. In requiring employees to explicitly decline to drink alcohol, you may also unwittingly be violating their privacy, of forcing them to disclose medical conditions, a history of addiction, pregnancy, or their religion.
  • Time: Are you holding the meeting or event at a time that is reasonable for employees who have dependents who rely on them? Have you provided adequate notice to employees who may need to meet caregiving commitments secure support? Are you accommodating single parents, people with disabled family members, or others who may not have a support system available for overnight or out of town commitments?
  • Food: When considering the menu or foods available, are you keeping in mind any religious holidays that would affect your employees’ eating habits? Are there options available for vegetarians and those with religious or medical restrictions, and are these clearly labeled so employees do not have to disclose personal information?
  • Invitations: How are the invitations to and details about social events normally shared? Is it through word of mouth? Do group social interactions normally happen on an informal or ad hoc basis? Has any individual or group on the team been excluded? Invitations to social outings, official and unofficial, should be shared through a public and easily accessible means, such as through a team’s Slack channel. Official company events should be planned with the aforementioned inclusivity considerations in mind and planners should make a proactive effort to ensure that those from underrepresented backgrounds are encouraged to attend and feel welcomed at the event.
25+ employees

Develop an effective employee handbook

An employee handbook sets out policies and practices as well as benefits, and can be an important tool for diversity and inclusion. A company should be transparent about what it expects from the employee (behavior, norms, work product) and what the employee can expect from it (culture, benefits, promotions and feedback, process for when others don’t meet expectations). The employee handbook can set initial expectations, as most employees will read it when they start, and guide them through difficult situations when they need to figure out benefits  —  or how to address harassment or discrimination. An effective handbook should be a comprehensive and definitive resource for information on policies and on what employees can expect and can be expected to do. It should include the code of conduct and should link the values and culture of the company to the policies and specific behaviors the organization wants to encourage and discourage.


While Project Include provides resources as a starting point, we have not made a comprehensive search of all resources and do not necessarily agree with everything in the resources. We share these as helpful references and encourage you to continue exploring.

Case studies:

  1. Kaiser, C.R., Major, B., et al. (March 2013). “Presumed fair: Ironic effects of organizational diversity structures.” Journal of Personality and Social Psychology 104(3). Retrieved April 2016 from:

  2. Karev, A., Dobbin, F., and Kelly, E. (August 2006). “Best Practices or Best Guesses? Assessing the Efficacy of Corporate Affirmative Action and Diversity Policies.” American Sociological Review(71): pp. 589-617. Retrieved April 2016 from:

  3. Dover, T., Major, B., and Kaiser, C. (January 4 2016). “Diversity Policies Rarely Make Companies Fairer, and They Feel Threatening to White Men.” Harvard Business Review. Retrieved April 2016 from:

  4. Klein, F.K. (October 19, 2007). “Giving Notice: Why the Best and Brightest Are Leaving the Workplace and How You Can Help Them Stay.” San Francisco: Jossey-Bass.

  5. Jansen, W.S., Otten, S., and van der Zee, K.I. “Being part of diversity: The effects of an all-inclusive multicultural diversity approach on majority members’ perceived inclusion and support for organizational diversity efforts.” Group Processes and Intergroup Relations 18(6): 742-748. Retrieved April 2016 from:

  6. Klein, F.K.

  7. Ibid.

  8. Ibid.