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Here’s how 20 different venture capital firms are policing sexual harassment

A breakdown of what some VC firms are sharing in new disclosures.

Dave McClure resigned from 500 Startups after allegations of sexual misconduct. 500 is one of the VC firms releasing its sexual harassment policies.
Dave McClure resigned from 500 Startups after allegations of sexual misconduct. 500 is one of the VC firms releasing its sexual harassment policies.
Noam Galai/Getty Images for TechCrunch

Venture capital firms have spent the last year grappling with whether they were equipped to handle sexual harassment complaints against their employees or their portfolio companies.

While some firms had internal codes of conduct, many did not have policies that similarly applied to the entrepreneurs they fund.

So that’s why it was newsworthy this week when about 20 firms this week publicly shared their sexual harassment policies, with about 20 more promising (we’ll see!) to share theirs upon request. There’s a wide range of detail in these so-called external policies collected by MovingForward, a new advocacy effort to push VC firms to be more transparent about how they police bad behavior.

Some of the already-posted policies are as short as one paragraph. Others are almost 10 pages long.

There are a few consistent themes:

  1. Firms almost all promise to be willing to terminate employees who violate the policy. That, of course, has not historically always happened.
  2. Firms are trying to get more serious about how sexual harassment is defined. Several even go so far as to list specific examples of actions that would qualify as a violation of their policies.
  3. Firms now consider entrepreneurs — who do not work for the venture capital firms — as parties to these agreements. Misconduct toward an entrepreneur is no different from misconduct toward a fellow partner.

Here’s a handy look at some of what stood out. We focused on the firms that actually posted what they considered to be their full, formal, lawyered policies, as opposed to an abbreviated version of it or a blog post that generally described their thinking on the issue.

  • 500 Startups: It’s notable that 500 is one of the first to publicly post their policy. Reminder: The leader of 500, Dave McClure, allegedly sexually assaulted the co-founder of the MovingForward initative, Cheryl Yeoh.
  • Andreessen Horowitz: “Andreessen Horowitz may take disciplinary action against an employee who exhibits poor judgment or engages in inappropriate behavior, even if it falls short of being severe or pervasive.”
  • Bowery Capital: Unusually, it highlights that even the firm’s limited partners are expected to follow the policy.
  • DFJ: The policy at DFJ is especially under the microscope given some of the actions allegedly taken by Steve Jurvetson, the firm’s founder. Jurvetson was ousted from the firm even though he has not been publicly accused of sexual harassment.
  • First Round Capital.
  • Flybridge Capital: Just two sentences.
  • Foundry Group: Probably the most detailed policy at eight pages, Foundry — which invests in some other VC funds — promises to “conduct due diligence regarding past incidents of sexual harassment involving founders or GPs.” They also try to ask for prospective GPs they would fund to affirm in a side letter that they’ve never been accused of harassment.
  • Homebrew: Homebrew posted the document it is asking its employees to sign and date, including a good amount of detail on its complaint procedure.
  • Kapor Capital: In addition to its policy, Kapor is sharing an “addendum” with four imagined situations that can be used for training purposes.
  • Norwest Venture Partners: Norwest emphasizes that they have a full-time exec who focuses on HR — not every firm has someone in-house to handle HR issues, a point of criticism for some advocates.
  • Refractor Capital: A very concise definition of sexual harassment: “Sexual harassment occurs when submission to or rejection of unwelcome sexual conduct is used as a basis for an employment or other business decision.”
  • Revolution.
  • Scale Venture Partners.
  • Spark Capital: Spark, interestingly, says that romantic relationships within a single chain of command — a gray area in Silicon Valley — “are not permitted.” Relationships outside it — think two people who do not report to one another — are okay.
  • Techstars: Techstars shared their Code of Conduct, which doesn’t have much specifically on harassment beyond promising to “ban or fire mentors, investors, employees, contractors” who harass others.
  • True Ventures.
  • Undiscovered Ventures: Two sentences also.
  • Union Square Ventures: USV says their policy applies even to non-USV employees on occasion: “If harassment occurs on the job or at a work-related event such as at a conference or off-site meeting and by someone not employed by USV, the procedures in the policy should be followed as if the harasser were an employee of the USV.”
  • Zetta Ventures: Like Techstars, Zetta posted their Code of Conduct, which doesn’t have much guidance on harassment issues specifically.

Find something else in these documents that is interesting? Email me at

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