Miki Agrawal, the co-founder of Thinx — a company that makes “period underwear” — doesn’t think much of boundaries. “I just love the taboo space,” she told New York last year, of her mission to (profitably) destigmatize menstruation. And in a promotional video for the product, she said, “My favorite thing to talk about are the things you’re not supposed to talk about.” According to a complaint filed late last week by a former employee (and echoed in interviews with multiple current and former employees), those things have included: the size and shape of her employees’ breasts, an employee’s nipple piercings, her own sexual exploits, her desire to experiment with polyamory, her interest in entering a sexual relationship with one of her employees, and the exact means by which she was brought to female ejaculation. Her alleged boundary-breaking in the workplace isn’t just verbal. Per the detailed complaint, filed with the City of New York Commission on Human Rights, Agrawal also touched an employee’s breasts and asked her to expose them, routinely changed clothes in front of employees, and conducted meetings via videoconference while in bed, apparently unclothed. (She also is said in the filing to have shared nude photos of herself and others — “including but not limited to her fiancé” — with staff.) At least once, she supposedly FaceTimed into a meeting from the toilet.

The complaint, brought by Chelsea Leibow, the 26-year-old former head of public relations at the company — whose distinctive Thinx PR emails acquired some renown — also describes a culture of fear and a pattern of ageism, in which members of the mostly female, mostly 20-something staff were routinely referred to as “children,” with the few employees in their 30s tagged “nannies.” The filing — which also names the company’s COO and CFO, for their failure to address repeated complaints about Agrawal’s behavior — comes on the heels, just over a week ago, of Agrawal’s leaving from her post as CEO (as first reported in Jezebel) and the publication of an article in Racked that made clear that, despite the company’s feminist branding and mission, the women who worked there felt exploited by low pay and substandard benefits. The complaint notes that the only two employees who had evidently successfully negotiated higher salaries were men. Per Racked, 10 of the company’s 35 employees have left since January (a Thinx spokesperson says the number is lower but declined to specify); several others departed either voluntarily or were fired last year by Agrawal, whom staffers described as erratic, retaliatory, and extraordinarily difficult to work for.

Agrawal, who responded to initial reports that she was out as CEO by saying she remained the “SHE-eo,” wrote a post on Medium to address the Racked and Jezebel stories: “MY THINX RIDE” is “a personal statement from me, Miki, as a human being, not as a representative of THINX,” in which she explains that she “was maniacally focused on top and bottom line growth and on our mission to break the taboo … Like any Co-Founder/CEO, all I did was the best I could under these crazy circumstances. Yes, I have made a TON of mistakes along the way but I can proudly say that our company has grown from an idea in my head to an innovation that is worn by millions of satisfied women globally in a few short years.” One mistake she acknowledges: the lack of any human-resources infrastructure — neither designated HR managers nor HR training or policies (including sexual-harassment or anti-retaliation policies) — during much of the company’s history. “I didn’t put HR practices in place because I was on the road speaking, doing press, brand partnerships, editing all of the creative and shouting from the rooftops about THINX so we can keep going,” she explained. (One employee told me that staffers had been advocating for an HR structure since late 2015; when Agrawal announced her resignation, the company promised to put one in place.)

When I contacted Agrawal for comment, she first directed me to the Medium post, and then we spoke on the phone about the sexual-harassment allegations, which she called “baseless” and with “absolutely no merit.” Agrawal said her legal team has contacted third-party employment counsel. She noted that she was speaking for herself, not the company, and recorded the call. A Thinx spokesperson replied to a list of allegations from Leibow’s filing with this statement: “We take matters related to our company culture very seriously. THINX has not been served with a legal complaint or charge from any agency related to Ms. Leibow’s allegations. When the issues were brought to our attention following her departure from THINX, the company commissioned an investigation that concluded the allegations had no legal merit. The company cannot comment further on these legal matters.”

Chelsea Leibow. Photo: Courtesy of Chelsea Leibow/Copyright 2016. All rights reserved.

Leibow, who was fired in December after months of voicing concerns about Agrawal’s behavior, had started a year before and been promoted midyear. At first, the company culture seemed refreshingly “open and honest,” she said to me over the phone. A month or two after her arrival, however, Agrawal said she had an “obsession” with Leibow’s breasts, and “helped herself,” as Leibow put it to me last week. “I didn’t say anything to her at the time. If you’ve ever been touched without your consent, you know it’s jarring. The whole atmosphere was one of: this is fine, this isn’t a big deal.” (In the formal language of the complaint, it was Agrawal’s “generally aggressive and retaliatory demeanor, position of authority, and style of management” that made Leibow too intimidated to speak up.) Leibow said that Thinx’s office setup — in a co-working space at the Centre for Social Innovation — meant it wasn’t only her own co-workers who could see it happen, adding to her embarrassment. And yet, though other employees confirm that they saw their boss touching an employee’s breasts, no one stopped Agrawal or complained to her about it. “If someone had gone to her to complain,” another employee explained, “she would have held a grudge, and work becomes ten times harder when she does.”

The incident, Leibow told me, developed into a pattern, with Agrawal regularly commenting on how Leibow’s breasts looked in various outfits, and touching them, both while the two were alone, and in front of others. Agrawal gave similar attention to other employees whose bodies Leibow described as, like her own, “curvy.” (According to the filing, Agrawal “molested at least one other female employee’s breasts.” Agrawal denies any breast-touching.) Leibow said she didn’t feel like her boss was actually coming on to her, but explained her discomfort this way: “I felt that Miki objectified my body when she declared that she was ‘obsessed’ with it and made very detailed comments about my breasts, and it also seemed like a way for Miki to assert her dominance over female employees by simply doing whatever she wanted to do without asking, and showing she could get away with it.”

Agrawal — whose brand was lauded for its body positivity, and for including visible stretch marks in its advertising — also regularly engaged in what another employee termed “fat-shaming,” commenting on people’s weights either directly or behind their backs. One of the perks of the office was ice-cream Fridays; Agrawal suggested that the treat ought to be changed to fruit because ice cream was unhealthy, and because employees were too heavy, said multiple former staffers. (More recently, she suggested a teamwide no-sugar detox. “It felt pointed,” said an employee.) When employees brought up the notion of expanding Thinx’s offerings into further plus sizes due to customer demand, Agrawal replied that anyone larger than a 3X ought to go to the gym and lose weight rather than purchase new underwear, according to multiple sources. Agrawal calls the fat-shaming accusations “unfounded,” and adds that she suggested having “fruit and berries to support healthy living.”

Once, when Leibow texted her boss a photo from vacation in Mexico wearing a shirt that Agrawal had bought for her employee (open, over a swimsuit), the then-CEO replied “Couldn’t focus bc boobs [sic]. Oh and the shirt looks good too!” When Leibow got her nipples pierced, she says she told various co-workers and showed a few privately; one told Agrawal, and Agrawal asked Leibow to show her the piercings in her office. (Agrawal says Leibow showed “everybody.”) “I said yes, because Thinx was a culture of we’re all women here, this is to be expected,” Leibow told me. A male friend of Agrawal’s was seated in the glass-paned office but Agrawal said he was “cool” and indicated that Leibow should go ahead and show the piercings. “She made a lot of comments about how beautiful my breasts are, and the size and shape of my areolas,” Leibow said. “It didn’t feel good at all. I was very close to a lot of other people at work who maybe I would have felt comfortable showing the piercings to, but she was my employer, and I felt like I had to do a lot of things because it was my paycheck at the end of the day.”

A month or so later, Agrawal spoke at the North Side Media Panel, where she told the assembled audience, which Leibow estimated to number about 200, about an example of the way she encouraged her employees to let their “freak flag” fly: how Leibow had gotten her nipples pierced, and how she’d showed them to her boss. Mid-anecdote, according to Leibow, Agrawal realized she had failed to clear the story with her employee, whom she’d called out by first and last name, while pointing to her in the audience. Agrawal then paused to ask Leibow if it was okay for her to finish the story. “I was bright red and I laughed,” said Leibow. “I was so uncomfortable, and all eyes were on me. I didn’t know what else to do so I said it was okay.” (Agrawal says she “doesn’t recall” if she mentioned the piercings, but remembers talking about liberation and body positivity.) After the panel, Leibow said she confronted Agrawal, who dismissed her concerns. She used the anecdote in at least one other subsequent public appearance, a WeWork conference in September 2016, according to the filing.

The complaint also cites at-work nudity as a common state for the CEO, usually while changing outfits or trying on new Thinx products, say employees, sometimes in her glass-walled office but often out in the open in their co-working space. “I forgot that’s not a normal thing to do until you brought that up,” another former employee said, confirming the regularity of those incidents. “Catching her changing was common and unfortunate.” (Agrawal says that she only ever changed in her office, behind her desk.) Leibow remembers that at last year’s SXSW, where Thinx had a pop-up store, Agrawal stripped down entirely directly outside of the changing rooms (Agrawal says she was in one), in full view of both her staff and customers, to try on bathing suits. “There never was an apology or acknowledgement,” said Leibow, who noted that on rare occasions other team members would change at the office to try on products — but not with the same kind of nonchalance, and not out in the open. Just a few weeks ago, another employee said, Agrawal’s breast came out of her low-cut top while she was talking to a staff member, and she neither addressed it nor hid it. The CEO also considered videoconferences clothing-optional, according to Leibow and others, and the filing states “it was common for Agrawal to conduct such meetings while audibly or visibly using the toilet.”

To get a sense of Agrawal’s “She–E.O.” persona, watch her host a Thinx YouTube series on “being a modern day, badass female CEO” in the video below.

At an all-female underwear company with a casual office culture, nudity was perhaps not as shocking as it might have been in other work environments, but according to employees it was paired with a sexual aggressiveness that was disturbing. At one meeting in December 2015 just before the holidays, while staff ate cake, Agrawal launched a discussion of polyamory. She said she had an interest in it, and was considering trying it. She then pointed to employees individually and asked if they, themselves, had ever tried it. “The power dynamic was such that people wouldn’t feel comfortable saying they didn’t want to be asked that,” explained one person present. Separately, according to the complaint, Agrawal had directly expressed interest in a sexual or romantic relationship with another female employee; several current and former employees say that Agrawal frequently told her assistant, a lesbian, how “hot” she found her. One source says she’d introduce her assistant by saying they flirted with one another all the time.

At another meeting, after a weekend retreat where she took a workshop on “squirting,” Agrawal reported back on her experience, in great detail, to several employees. According to Leibow, the CEO expressed the desire to have the man who’d brought her to the point of ejaculation that weekend teach Agrawal’s fiancé what to do to achieve the same result; she illustrated what she’d learned with hand motions. Leibow and others acknowledged that employees talked about their sex lives at work, or with co-workers they considered friends after hours, but Leibow insisted that “it was a company culture where the executive team and the other employees operated on very different planes. There was a lot that was comfortable for co-workers that was not with any of the executives.” Another former staffer likened working at the company to working in a TV-writing room: Stories and vulnerabilities are shared and turned into copy. “We’d talk about shame we’d felt about our bodies, and all of that went into building a brand message that felt authentic,” she explained. “But with Miki I never felt safe enough to share. I know that she wanted to have that casual relationship, and I think some people decided to have that out of fear.”

Agrawal declined questions about specific aspects of her sex life that she’d discussed with her employees. “The team talks about vibrators and vaginas and vaginal steam baths, all these kinds of things all the time,” she says. “And if things are taken out of context, of course it’s going to seem like I’m saying something that’s not appropriate … At the time it did absolutely not make them uncomfortable. They were responsive and engaged and excited.” One employee said that having sexually frank conversations with Agrawal was a tactic: “Once it turned into a thing, it made me feel like I had an in,” she explained. She said she doesn’t believe Agrawal was actually pursuing a sexual relationship with anyone at the company; rather, she called it performative. “She’s not a predator and it’s not malicious, but that doesn’t make it right. And it all boils down to the fact that she has no conception of it not being right.”

Employees described themselves as shocked, if not surprised, by a post–Burning Man Medium entry Agrawal wrote that contained a description of her time in the Orgy Dome, “trying to conceive for the first time ever.” She wanted to make sure that it was something the company’s customers read; off-line, she gave staffers more explicit descriptions of what she’d done in the Dome. Multiple employees recounted that when a team arrived at Agrawal’s apartment for a video shoot, they were told over the intercom not just that they’d have to wait, but specifics on why: Agrawal and her fiancé, trying to get pregnant, had just had sex and she needed to keep her legs up for a while. Agrawal, who is now expecting, also told employees (at a meeting with two board members present) that she was hoping to be among the small group of women who give orgasmic birth.

If it’s surprising that more employees didn’t complain about the alleged sexual harassment, they point to the way that other complaints were handled by the company. “I can recall multiple occasions when I tried to be honest about salaries or employment policies,” Leibow said, and Agrawal “would stew, treat you like shit, then pick a moment to blow up and tell you how ungrateful you are and how you should be thanking her for the opportunity, how dare you.” In March 2016, Agrawal responded to a raft of complaints about the company’s culture and policies — largely prompted by a sudden reduction in vacation days — by holding an open forum in which the entire staff sat around in a circle and, one by one, aired their issues. One employee said that she was unable to afford birth control under the company’s health-care plan. (Many of the company’s employees were under the age of 26 and still on their parents’ plans when they were hired, but were now beginning to age out and reckon with Thinx’s expensive coverage.) According to a source who observed their dynamic, Agrawal subsequently froze the woman out of projects and “looked right through her” at work. Another employee who was vocal at the meeting said the CEO rarely spoke to her again. A third was asked to change her email password so that Agrawal, who felt the woman had betrayed her trust, would have access to all of her future communication, and forced the woman to show her all of her previous emails and Slack messages; when word of that went around the office, staffers began frantically deleting Slack conversations. One longtime employee who’d encouraged other staffers to be outspoken was fired shortly thereafter (for cause, says Agrawal). Agrawal would later call the forum a coup, although she told me over the phone that no one suffered retribution, and says that birth-control coverage was doubled on the spot.

Agrawal’s methods of maintaining control over her staff were extreme, according to employees. She would tell staffers that if they quit, she wouldn’t ever recommend them to future employers, said one Thinx employee; others she would threaten to fire before their bonuses kicked in. One employee speculated that the very structure of offering low salaries in combination with end-of-year bonuses was a way of maintaining as much control as possible. Agrawal disputes all this, and said of the company’s pay scale, “when you’re a start-up, you simply can’t match corporations.”

People on the creative and design teams, in particular, frequently had their jobs threatened for opposing Agrawal’s ideas, according to one current employee. At another employee forum, a current staffer criticized something Agrawal had done while representing the brand and, according to a source, the then-CEO later brought up the criticism at the woman’s performance review as something for which she “should” be firing her.

Agrawal is just as controlling about her own image. When I wrote a profile of her in January 2016 that Agrawal didn’t like (I quoted her saying that she hadn’t identified as a feminist until she started her company), she not only responded to the piece on Medium, but also, according to a former staffer, required employees at Thinx to leave comments on the piece at the Cut, praising her and Thinx. Similarly, after a series of negative comments about her appeared on Glassdoor (one described her as “Trump-like”), she directed employees to counteract those with positive posts and allegedly wrote one herself, per Racked. When I asked Agrawal about those incidents, she says that she simply asked her employees to weigh in and “please be honest,” in much the way a restaurateur who’d received poor Yelp reviews would ask other customers to counteract it. (Agrawal has also been a restaurateur.) She denied leaving her own Glassdoor review. “I know the founder of Glassdoor, and I’m working on getting the IP addresses of everyone who left reviews,” she told me. (Update: A Glassdoor spokesperson says this is false and that the company has always fought for “users’ anonymity and free speech.”)

Last spring, Agrawal decided to appoint two “Culture Queens” to handle complaints from the staff. Neither had a background in or received additional training in HR (one was the vice-president of marketing for a sister brand, and the other was formerly the events and community manager), according to the filing, but they were among the oldest employees at Thinx. By all accounts, they had no real power: They could either take the complaint (often about Agrawal) to her or the COO, or simply listen while people vented their frustrations. Agrawal says she chose them because they “brought a lot of positive high vibration to the office” and were not meant as a substitute for HR.

Leibow says she raised the issue of Agrawal’s inappropriate touching to the women designated to handle complaints multiple times, and frequently spoke to them about her concerns about her boss’s behavior, which she thought was becoming more erratic and angry as the company grew. According to the complaint, the “Culture Queens” expressed similar concerns about their boss’s behavior. The last time she spoke to one of the Culture Queens about Agrawal was a week before her termination.

Leibow heard through the office grapevine on a Thursday in mid-December that she was going to be terminated the following Tuesday at her performance review. She immediately asked the company’s CFO, Keshanee Gunawardena, if this would affect her bonus, scheduled to be handed out five days later, and asked about severance pay. Gunawardena, according to Leibow, told her the bonus wouldn’t be affected but also didn’t seem to know that Leibow was going to be fired and went into Agrawal’s office. Ten minutes later, Leibow says, she realized she was locked out of all her company accounts. She went into Agrawal’s office, where the then-CEO told her she was being fired for poor performance. (Agrawal, who insists the firing was for cause, disputes that Leibow got an early heads-up about her termination, but also adds that “when someone knows you’re going to terminate them, you have to terminate them.”) Leibow had compiled a list of her achievements in advance of her upcoming year-end review, and ticked them off. Agrawal then said that she felt a “disconnect of energy” between the two of them, according to Leibow. There would be no bonus, but there was the offer of a severance payment in the same amount, said Leibow. (Leibow didn’t accept because she would have been required to sign away her right to legal recourse.) Leibow said that Thinx COO Shama Amalean was crying as she escorted Leibow out of the building, telling her she had been “wonderful” at her job. Neither Amalean nor Gunawardena responded to requests for comment.

According to the complaint, Amalean — who had been at the company since 2015 and was promoted into the COO slot four months after her arrival — subsequently asked employees to reach out to Leibow about the circumstances surrounding her firing and encouraged them to offer their own anecdotes about Agrawal so that Leibow could bring those concerns to the board. (One source told me that upper management had been trying to relay concerns about Agrawal to the board for years without much traction.) Leibow didn’t speak to the board; instead her lawyers contacted the company on January 20. In early February, board members came to interview Thinx employees about their experiences working for Agrawal, and another source says that Amalean encouraged them to speak up. Participation was voluntary, but almost everyone either spoke to the board, or tried to — the board ran out of time before they could get to everyone. “They had a lot of questions,” noted the source. According to another person who spoke to the board, they were aware of allegations of sexual impropriety against Agrawal, and “they were kind of horrified.” Agrawal disputes that the board’s interviews had anything to do with her decision to step down, and an email to the chairman of the board went unreturned. “A fascinating thing about Miki is that she has this incredible capacity for creating her own narrative and believing it,” said one employee who worked with her closely.

When I asked Leibow why she didn’t leave the company on her own, she paused before answering. “I struggled a lot with the weight of what I was doing. I loved the mission of the company and loved the other people who worked there,” she said, adding that she was actively looking for new employment at the end of last year. “It was hard to distinguish the success I was having in my role there from my own self-worth, and I was scared about leaving. I doubt myself, like a lot of women.” One former staffer, recalling the way Agrawal would belittle employees for their age and inexperience, or tell them they didn’t know that they were talking about, referred to the feeling as the “Miki Agrawal effect”: “You leave the company feeling like you aren’t capable, good enough or smart enough. A former co-worker, who left months ago, recently said to me that it took her a long time to feel competent again.”

Leibow pointed to the unwillingness of other Thinx employees, current or former, to go on the record about Agrawal, as “indicative of how much fear is still ingrained in these people.” A former employee explained, “All of us are in our early careers, and I’m afraid out of anger and resentment she’ll make things up. You can write whatever you want on Medium. No one is going to fact-check that, and she’s surrounded by ‘yes people’ who always back her up.” A woman who voluntarily left the company said she’d later seen Agrawal riding her bike and literally hid. “It’s like a bad ex-boyfriend,” she says. “It’s a great product, and I loved the women I worked with, but it was an abusive environment.”

The defense in a sexual-harassment case, whether the harasser is a man or woman, is often that it wasn’t really harassment because the victim was complicit. During negotiations with Thinx’s representatives before the complaint was filed, the company’s lawyers cited Leibow’s social-media presence — “pictures where you could see my cleavage” — as a sign she shouldn’t have been bothered by Agrawal’s alleged behavior. But Leibow is clear about what her boundaries were. “I think it’s important to say that of course I was comfortable talking about bodily functions and feminism as it related to the company. However, there should be boundaries in every working environment,” she said. “There are companies that deal with all sorts of issues, but that doesn’t mean that the CEO can use that mission to her own personal advantage to do whatever she wants, whenever she wants.”

Agrawal — who recently raised $500,000 of funding for Tushy, her bidet venture — is slated to speak on March 23 at the New Orleans Entrepreneur Week’s Women’s Summit, directly following a discussion on “Navigating Sexuality at Work: Finding the Line Between Harmless and Harassment.”

*This article has been updated with a statement from Glassdoor.

