THE PROCESS

SOLACE’s complaint and investigation process is as follows:

1. COMPLAINT INTAKE

A sex worker submits a complaint alleging an injustice experienced while employed by or working under the control of an agency or establishment operating within the sex industry.

The complaint must:

• Identify the agency or establishment;

• Describe the alleged conduct; and

• Provide any available supporting information (documents, messages, names, dates).

Further evidence can be added/requested once the investigation begins and SOLACE begins reviewing. Complaints may be submitted regardless of when the conduct occurred, and cannot be submitted informally (i.e; posting in the CORAS discord does not quantify a complaint). These forms will be private and reviewed only by relevant CORAS staff initially.

2. INTAKE REVIEW

SOLACE conducts an initial review to confirm that:

• The complainant is a sex worker;

• The complaint relates to conduct occurring in the course of sex-industry work;

• The complaint made is not clearly vexatious, malicious, or an otherwise mis-use of SOLACE’s time.

• The responding party falls within SOLACE’s oversight scope and;

• SOLACE is reasonably able to act on the workers behalf

• What outcomes the worker is seeking

At this stage, SOLACE does not fully assess credibility or determine fault outside of a ‘reasonableness’ metric. The complainant will be contacted once investigations begin, and will be informed their complaint will be shared with the elected representatives and legal body. If there is conflict with these additional parties, CORAS staff will discuss next steps, and inform the complainant of their options. Privacy will be prioritized and worked around as much as possible, but complaints may be dropped if it is deemed unreasonable to proceed without the representatives and legal body.

3. EVIDENCE GATHERING

Where the complaint meets the low intake threshold, SOLACE begins evidence collection from the complainant. This may include:

• Written statements from the complainant;

• Statements from witnesses identified by the complainant;

• Collection of messages, medical records, contracts, policies, schedules, payment records, advertisements, etc;

• Review of prior complaints or patterns involving the same agency.

• Review of relevant authorities, statutes, law or relevant case law

• Interviews with the complainant or named witnesses, authorities, etc as necessary

Evidence will be gathered in a trauma-informed manner and without requiring repeated recounting of harm.

4. AGENCY CONTACT

SOLACE contacts the implicated agency or establishment to:

• Notify them that a complaint has been received;

• Provide a summary of the allegations; and

• Invite a written response and supporting documentation, or schedule meetings as necessary

Agencies are given a reasonable opportunity to respond and will be outlined in communications with them. Generally, they will have 5 business days to acknowledge receipt of our email, and 30 days to provide a defence.

Failure or refusal to engage does not halt the investigation. Refusal to engage means the investigation will continue relying solely on the complainants evidence.

5. CORROBORATION

SOLACE will also assess, as part of the later stage of the investigation:

• Internal consistency of the evidence;

• Public, private or submitted complaints of any kind of the agency

• Staff and representatives knowledge of said agency

• Corroboration between statements, documents, and timelines; and

• Whether similar concerns have been raised by other workers.

6. PRELIMINARY FINDINGS

Based on the collected evidence, SOLACE as a body will prepare preliminary findings identifying:

• The nature of the alleged injustice;

• Relevant workplace standards or expectations;

• Whether the evidence supports the concern; and

• Any gaps or unresolved issues.

If these are in dispute amongst the oversight board, if possible an in-person trial at an agreed upon location will follow, necessitating a vote.
The complainant will be offered a representative from CORAS, or legal support as is reasonable/possible.

If these facts and findings are not in dispute, a written decision will be sent out to both parties, with an explanation on a potential appeals process (if reasonable).

7. Worker Consultation

Before finalizing the publication of the investigation file and action items, SOLACE consults with the complainant to:

• Confirm accuracy of factual summaries;

• Discuss potential next steps;

• Discuss concerns;

• Ensure the worker’s wishes are respected regarding escalation or advocacy.

8. Investigation Record

The investigation concludes with a documented record containing:

• The complaint;

• Evidence reviewed;

• Agency responses (if any); and

• Preliminary findings.

• Facts and  (if requested, anonymized) write-up agreed upon by the worker to publish to the CORAS website