Policy against Harassment and Age Discrimination

It is the policy of the College to maintain a learning and working environment that is free from religious, racial, sexual harassment, or age discrimination. The College strictly prohibits any form of religious, racial, sexual harassment or age discrimination.

It shall be a violation of this policy for any student, teacher, administrator, or third party, (present on the premises), or other College personnel to harass a student, teacher, administrator, or other College personnel through conduct or communication of a sexual nature or regarding religion, race, or age discrimination as defined by this policy.

It shall be a violation of this policy for any student, teacher, administrator, or third party, (present on the premises), or other College personnel to inflict, or attempt to inflict religious, racial, sexual harassment, or age discrimination upon any student, teacher, administrator, or other college personnel.

The College will act to investigate all complaints, formal or informal, verbal or written, of religious, racial or sexual harassment of age discrimination, and to discipline or take appropriate action against any student, teacher, administrator, or other College personnel who is found to have violated this policy.

Religious, Racial, and Sexual/Gender Harassment and Age Discrimination Defined

Religious  Harassment/Bias:  Definition. Religious  discrimination  involves  treating a person unfavorably because of his or her religious beliefs.  Religious harassment/bias occurs when:

  1. Submission to conduct or communications of a religiously derogatory, harassing or biased nature is made a term or condition, of obtaining or retaining employment, or of obtaining an education; or
  2. Submission to or rejection of conduct or communication of a religiously derogatory, harassing, or biased nature by an individual is used as a factor in decisions affecting that individual’s employment or education; or
  3. The conduct or communication of a religiously derogatory, harassing or biased nature has the purpose or effect of substantially interfering with an individual’s employment or education, or creating an intimidating, hostile, or offensive employment or educational environment.

Racial Harassment/Bias:  Definition. Race discrimination includes discrimination on the basis of ancestry or physical or cultural characteristics associated with a certain race, such as skin color, hair texture or styles, or certain facial features. Racial harassment/bias occurs when:

  1. Submission to conduct or communication of a racially derogatory, harassing, or biased nature is made a term or condition of obtaining or retaining employment, or of obtaining an education; or
  2. Submission to or rejection of conduct or communications of a racially derogatory, harassing or biased nature by an individual is used as a factor in decisions affecting that individual’s employment or education; or
  3. The conduct or communication of a racially derogatory, harassing or biased nature has the purpose or effect of substantially interfering with an individual’s employment or education environment, or creating an intimidating, hostile, or offensive employment or educational environment or otherwise adversely affects an individual’s employment or academic opportunities.

Sexual/Gender Harassment:  Definition. Sexual/Gender harassment includes unwelcome physical or verbal conduct relating to an individual’s gender or directed at an individual because of gender; unwelcome sexual advances, requests for sexual favors, sexually motivated physical conduct or other verbal or physical conduct or communication of a sexual or gender biased nature occurs when:

  1. Submission to that conduct or communication is made a term or condition of obtaining or retaining employment, or of obtaining an education; or
  2. Submission to or rejection of that conduct or communication by an individual is used as a factor in decisions affecting the individual’s employment or education; or
  3. The conduct or communication has the purpose or effect of substantially or reasonably interfering with an individual’s employment or education, or creating an intimidating, hostile or offensive employment or educational environment.

Age  Discrimination/Bias:  Age  discrimination  involves  treating  someone  less favorably because of his or her age.  It is unlawful to harass a person because of his or her age. Age discrimination occurs when:

  1. Submission to conduct or communications of an age discriminatory, harassing, or biased nature is made a term or condition of obtaining or retaining employment, or of obtaining an education; or
  2. Submission to or rejection of conduct or communication of an age discriminatory, harassing, or biased nature by an individual is used as a factor in decisions affecting that individual’s employment or education; or
  3. The conduct or communication of an age discriminatory, harassing, or biased nature has the purpose or effect of substantially interfering with an individual’s employment or educational environment.

Reporting Procedures

Any person who believes he or she has been the victim of religious, racial, or sexual harassment or age discrimination by a student, teacher, administrator, third party (present on the premises), or other College personnel, or any person with knowledge or belief of conduct which may constitute religious, racial, or sexual harassment or violence or age discrimination toward a student, teacher, administrator, or other College personnel will report the alleged acts immediately, not to exceed thirty days.   The reporting procedures are as follows:

Present the case in person or by telephone to Leili McMurrough, Program Director, or Stephanie Kann at 847-808-8444. If the report was given verbally the administration shall reduce it to written form within 48 hours. Submission of a good faith complaint or report of religious, racial, sexual harassment, or age discrimination will not affect the complaint or reporter’s future employment grade or work assignments.

Investigation

The College, upon receipt of a report or complaint alleging religious, racial or sexual harassment or age discrimination shall immediately undertake or authorize an investigation. The investigation may consist of personal interviews with the complainant, the individual(s) against whom the complaint was filed, and others who may have knowledge of the alleged incident(s) or circumstances giving rise to the complaint. The investigation may also consist of any other methods and documents deemed pertinent by the investigator or the College administration.

In addition, the College may take immediate steps, at its discretion, to protect the complainant, students, teachers, administrators, or other College personnel pending completion of an investigation of alleged religious, racial or sexual harassment or age discrimination.

In determining whether alleged conduct constitutes a violation of this policy, the College should consider the surrounding circumstances, the nature of the behavior, the relationships between the parties involved and the context in which the alleged incidents occurred. All parties to the complaint of religious, racial or sexual harassment, or age discrimination will be provided with notice of the allegations and an opportunity to present documentary and/or testimonial evidence to the college’s designated investigator(s). Whether a particular action or incident constitutes a violation of this policy requires a determination based on all the facts and surrounding circumstances.

If harassment on the basis of religion, race or sex discrimination is found, the College will take reasonable steps to end the harassment or discrimination, redress the actual problem(s), and reasonably attempt to prevent recurrence.

The administration shall send a written report to the complainant upon completion of the investigation, within 45 days of the complaint. If for some reason 45 days is unreasonable, all parties will be notified, with an explanation for the delay. Within 15 additional days, a total of 60, all parties will be notified of the results of the investigation.

The report shall be maintained for a minimum of three years, and include a detailed description of the alleged act of harassment or age discrimination, and the College’s response, including but not limited to the names of all the parties involved in the alleged incident, any investigatory actions by the College, the College’s findings, and any disciplinary or remedial action taken by the College. If a person found to have committed an act of racial and/or sexual harassment, or age discrimination is not disciplined, the record will contain an explanation as why no disciplinary action was taken.

If the complaint involves a member of the administration, (Heather Braatz, Dede Frank, Stephanie Kann or Leili McMurrough), it should be filed directly with the Board of Directors who will conduct the investigation as outlined above. To file directly with the Board of Directors, give the Program Director the complaint in a sealed envelope. If the complaint involves the Program Director give the sealed envelope to another member of the administration to be forward to the Board of Directors. The Board of Directors will send a written report to the complainant upon completion of the investigation. The report shall include all items mentioned in the above paragraph.

Reprisal

The College will discipline or take appropriate action against any student, teacher, administrator, or other College personnel who retaliates against any person who reports alleged religious, racial or sexual harassment, or any person who testifies, assists or participates in any investigation, or who testifies, assists or participates in a proceeding or hearing relating to such harassment or age discrimination. Retaliation includes, but is not limited to, any form of intimidation, reprisal, or harassment.

Discipline

The College will take such disciplinary action it deems necessary and appropriate, including warning, suspension, immediate discharge, or expulsion to end discriminatory harassment and prevent its recurrence.  Immediate termination from the program may also require forfeiture of fees paid for that quarter, and additionally, the individual will remain responsible to pay to the College any fees owed that were not yet paid (see College refund policy).

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Updated July 2019

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