Equity Policy and Procedures

I. Policy Overview

II. Accessibility

III. The Role of the Equity Officer(s)

IV. Scope of Policy

V. Definitions

VI. Prohibited Conduct

VII. Reporting Alleged or Suspected Violations of this Policy

a. Where and How to Report

b. Anonymous Reporting

c. Confidential Resources

d. Confidential Advisor

VIII. Privacy and Confidentiality of Reports to the College

a. Amnesty

b. Obligation to Act in Good Faith

IX. Resolution Process

a. College Response When a Report is Received: Initial Review and Assessment

b. Supportive Measures

c. Interim Measures for Safety

d. Right to a Support Person

e. Conflict of Interest

f. Informal Resolution Process and Options

g. Formal Resolution Option: Information Gathering Process

h. Corrective Action

i. Specific Procedures for Tenured Faculty Members

j. Appeal

1. Grounds for Appeal
2. Appeal Procedures

k. Procedural Discretion

l. Complaints relating to Retaliation, Violation of Supportive Measures, and other Procedural Violations

I. Policy Overview

As described in the Nondiscrimination Policy as well as the Christ-Centered Diversity Commitment, Wheaton College is a Christian liberal arts institution committed to treating all individuals as equal image-bearers of Jesus. The College affirms diversity as part of God’s original and eternal design for humanity and sees its importance for knowing and worshiping God and serving His purpose. As followers of Christ, we are called to exercise our Christian freedom responsibility in holiness and humility (Eph. 1:4, Col. 3:12); to walk in a manner worthy of our calling (Eph 4:1-3); to uphold justice, mercy and the equitable treatment of everyone (Mic. 6:8, Matt. 23:23, James 2:1-13); to edify one another and build up the Body of Christ (Rom 14:19; Eph 4:11-16).

Furthermore, we are committed to a learning, living, and work environment where we love our neighbor as we love ourselves and treat everyone with respect and dignity. Therefore, as described in our Nondiscrimination Policy, Wheaton College expects that all interactions will be free of unlawful discrimination and harassment. Harassment, discrimination and bias-related incidents and behaviors fundamentally violate our Christian calling and negatively impact an individual’s experience at the College. Although many interpersonal conflicts and some forms of misconduct can be resolved without going through a formal process and may be addressed by following the spirit and guidance found in Matthew 18:15-20, the forms of harassment and discrimination governed by this policy may be legal matters for which both the government and the College may require a formal process.

II. Accessibility

Wheaton College is committed to making the processes described in this Policy accessible to all members of the Wheaton College community, including providing reasonable accommodations to persons with disabilities. To learn more about the policies and procedures specific to requesting reasonable accommodations, please visit the “Accessibility & Disability Services” section of the Learning & Accessibility Services webpage (students) or the Employee Handbook (Faculty and staff).

Further inquiries may be directed as follows:

ADA/Section 504 Coordinator for Students:
Melissa Norton, Student Services Building #209, (630) 752-5674, melissa.norton@wheaton.edu

ADA/Section 504 Coordinator for Employees:
Gina Cristman, Human Resource Generalist, Blanchard #154, (630) 752-5060, gina.cristman@wheaton.edu

III. The Role of the Equity Officer(s).

The College’s Equity Officer(s) is responsible for the coordination of training, education, communications, and the administration of the procedures for the handling of suspected or alleged violations of this Policy.

The Equity Officer(s) and their contact information are as follows:

Director of Equity & Title IX Coordinator
Beth Maas, Student Services Building #211
beth.maas@wheaton.edu
(630) 752-7515

Equity Officer for Students & Deputy Title IX Coordinator
Dr. Carrie Williams
Student Services Building #215
carrie.williams@wheaton.edu
(630) 752-5797

Equity Officer for Employees & Deputy Title IX Coordinator
Karen Tucker
Blanchard Hall #154
karen.tucker@wheaton.edu
(630) 752-5060

IV. Scope of Policy

The instructions and procedures outlined in this policy are intended for all members of the College community, including faculty, and staff (hereinafter “employees”), students, volunteers, visitors, and other guests of the College community, and to contractors, consultants, and vendors doing business with or providing services to the College. Individuals not affiliated with Wheaton College who experience harassment, discrimination or bias on Wheaton’s campus may also submit an online report. Wheaton College may modify its response protocols, depending on the circumstances.

The Policy applies to conduct by or against a member of the College community, including online or electronic conduct, whether the conduct occurs on-campus, or it occurs off-campus.

More specifically, the policy applies when conduct:

Occurs during a College-sponsored educational activity or program;
Adversely impacts the education or employment of a member of the College community; or
Threatens the health or safety of a member of the College community. While the College is committed to the principles of free inquiry and expression, the discrimination, harassment and biased behavior prohibited by this Policy are neither legally-protected speech or expression nor the proper exercise of academic freedom.

Federal law requires the College to use its Title IX Sexual Harassment Policy and Procedures to handle reports of sexual harassment covered by Title IX. The College is committed to providing a safe, respectful, and inclusive learning and working environment for everyone. That means the College also prohibits other forms of sex-based misconduct, including sex-based harassment, dating violence, domestic violence, stalking, and other sexual misconduct, even when those behaviors are not covered by Title IX. For allegations of sex-based harassment, dating violence, domestic violence, stalking, or other sexual misconduct not explicitly covered by Title IX, the College will address reports using this Policy and will apply Title IX definitions of sexual harassment, sexual misconduct, coercion and consent where applicable.

V. Definitions

Bystander. A bystander is a person who is present and observes an incident but is not directly involved. Additional information on Bystander Intervention is available here.
Complainant. Complainant means an individual who is alleged to have experienced conduct that violates this Policy, regardless of whether the individual wishes to pursue a resolution process. A Complainant may be a student, employee, or third party.
Confidential Resource. A Confidential Resource is an individual who, by law or professional licensure, is prohibited from disclosing information shared in confidence except in limited circumstance, including licensed counselors, medical providers, ordained clergy acting in their pastoral role, and victim advocates, to the extent recognized under Illinois law.
Designee(s). Specific faculty and staff members located throughout our various campus locations who serve as Information Gatherers, Decision-Makers, Informal Resolution Facilitators, or Appeal Officers during an Equity Resolution Process. These individuals are trained annually on topics related to policy, process, investigations, decision-making, informal resolution, and trauma informed practices. Equity Officers may designate these individuals (or hire trained professionals from outside agencies. to serve in one of these roles during an Equity Resolution Process.
Good Faith. Good Faith means a report or participation undertaken with honest intent and reasonable belief, even if the facts alleged are ultimately determined to be unsubstantiated. A finding that no policy violation occurred does not, by itself, establish lack of good faith. However, knowingly false reports or testimony may be subject to disciplinary action and are not protected under this provision.
Preponderance of the Evidence. Preponderance of the Evidence is a standard of proof requiring that the evidence show a fact or claim is more likely true than not true.
Prohibited Conduct. Prohibited conduct includes bias, discrimination, harassment and sexual harassment as defined in Section IV of this policy.
Protected Class. Protected Class means any category or characteristic protected from harassment and discrimination under federal or Illinois law, including but not limited to race (including traits associated with race, such as hair texture and hairstyles), color, national origin (including shared ancestry), citizenship, sex, marital status, disability, age, military status, and pregnancy.
Reasonable cause is when the facts and circumstances alleged or reported, if taken as true, would lead a reasonable person to believe conduct in violation of the Policy may have occurred.
Respondent. Respondent means an individual who is alleged to have engaged in conduct that violates this Policy.
Supportive Measures. Supportive Measures means individualized services offered as appropriate, reasonably available, and without fee or charge to the Complainant or Respondent to restore or preserve access to the College’s programs and activities, protect safety, or deter prohibited conduct without unreasonably burdening either party. Supportive measures are non-disciplinary and non-punitive and are available regardless of whether a Complainant chooses to participate in a resolution process. Examples include but are not limited to:
1. Referral to counseling or medical services;
2. Employment accommodation (e.g. modification of work schedule, referral to the Employee Assistance Program;
3. Academic accommodation (e.g. course schedule modifications, referral to Learning and Accessibility Services;
4. Housing and dining accommodation;
5. Mutual no-contact directives;
6. Campus escort services;
7. Referral to Student Wellness (e.g. leave of absence) .

VI. Prohibited Conduct

If the alleged conduct falls outside the purview of this policy, the Equity Officers may refer the Complainant to the applicable college policies.

Prohibited conduct under this Policy includes, but is not limited to the following actions:

Bias. Bias means prejudice, predisposition, or inclination for or against an individual or group based on Protected Class that affects decision-making, behavior, or treatment in a manner inconsistent with the College’s commitment to equal opportunity.
Discrimination. Discrimination is unequal, adverse treatment of an individual because of the individual’s actual or perceived membership in a legally protected class, (as defined herein. in all aspects of its education programs, activities, admissions, and employment, including but not limited to:
1. Recruitment, hiring, promotion, transfer, compensation, benefits, discipline, and termination of employment;
2. Admissions, recruitment, financial aid, and scholarships;
3. Academic programs, courses, grading, and degree requirements;
4. Student services, housing, athletics, and extracurricular activities;
5. Access to facilities, programs, and College-sponsored events.
Harassment. Harassment is unwelcome verbal, non-verbal, or physical conduct directed toward an individual because of the individual’s actual or perceived legally protected class when:
- Quid Pro Quo Harassment. an employee of the College conditions the provision of aid, benefit, or service of the College on an individual’s participation in unwelcome conduct based on a protected class; or such conduct has the purpose or effect of substantially and unreasonably interfering with an individual’s employment or education; or
- Hostile Environment Harassment. the unwelcome conduct based on Protected Class is sufficiently severe, pervasive/persistent, or objectively offensive such that it limits or alters the conditions of education or employment; or limits or alters the individual’s ability to participate in or benefit from College programs or activities. Whether conduct creates a hostile environment is evaluated based on the totality of the circumstances, including by not limited to:
  1. The frequency of the conduct;
  2. The nature and severity of the conduct;
  3. Whether the conduct was physically threatening;
  4. The effect of the conduct on the person subject to the conduct;
  5. Whether the conduct was directed at more than one person, or a group of people;
  6. Whether the conduct arose in the context of other discriminatory conduct;
  7. Whether the conduct unreasonably interfered with the educational or work performance of the person subject to the conduct;
  8. Whether the speech or conduct deserves the protections of academic freedom;
  9. Whether the Respondent holds a position of authority over the Complainant such as a supervisor or professor.
Retaliation. Retaliation exists when materially adverse action, including reputational harm, is taken or attempted against an individual with the purpose of interfering with any right or privilege secured by law/policy, because of that individual’s participation in the protected activity under this Policy. Adverse Action includes but is not limited to: termination, demotion, suspension, denial of promotion or tenure, coercion, harassment, or any other materially adverse treatment. Retaliation may also include intimidation, threats, coercion, harassment or discrimination against an individual. Protected activities include but are not limited to:
1. Making a good faith report of conduct believed to be a violation of this Policy.
2. Cooperating in good faith in an Information Gathering Process under this Policy, and/or
3. Participating as a witness to any report of conduct in violation of this policy.
Sexual Harassment. Sexual Harassment is a form of harassment that includes:
1. Quid Pro Quo Conduct. an employee conditions the provision of an aid, benefit, or service of the College on an individual’s participation in unwelcome sexual conduct.
2. Unwelcome Conduct. unwelcome conduct that is determined by a reasonable person to be so severe, and pervasive, and objectively offensive that it effectively denies a person equal access to the College’s education programs or activities.
3. Sexual Misconduct. sexual assault/violence, dating violence, domestic violence, and/or stalking. Depending on the nature, geographical location and severity of the alleged conduct, the behavior may be covered by the College’s Title IX Sexual Harassment Policy and Procedures or this Policy. Relevant definitions of sexual misconduct can be found in the Title IX Policy.

Uncivil behavior that is not based on a protected class does not fall within the purview of this policy. However, such behavior may violate other College policies. If you have questions or concerns regarding bullying or uncivil behavior, contact Human Resources (for employees) or Residence Life (for students) for assistance.

VII. Reporting Alleged or Suspected Violations of this Policy

The College requires all employees and strongly encourages students and other individuals, including third-party bystanders, to report incidents of bias, discrimination and harassment to the Equity Officers. This expectation does not apply to confidential resources. Student Health Services, the Counseling Center, and ordained staff in the Chaplain’s Office are considered confidential resources and employees working in these areas are not required to report prohibited conduct that they learn of through a confidential role. Confidential resources are encouraged, but not required, to provide the student or employee with contact information for the Equity and Title IX office as well as information about how to file a report.

The College maintains multiple methods for reporting conduct that potentially violates this Policy such as reporting by email, online, in-person, video conference, or by telephone. Although there is no specific time limit for reporting a suspected violation of this Policy, it is helpful for the College to learn about incidents as quickly as possible with as much information as possible. Information that can be useful (where applicable) includes photographs, copies of emails/text messages, written communications, and the name/contact information for witnesses and others involved in the incident. Individuals are encouraged to report even if they do not have supporting documentation, if they don’t know who is responsible for the incident, or if there is a significant time lapse between the incident and the report. However, these factors may impact the College’s ability to respond to the incident.

A. Potential Policy Violations may be reported to:

Equity Officers and Title IX Coordinator (“Equity Officers”)

Beth Maas
Director of Equity & Title IX Coordinator
Student Services Building #211
equityandtitleIX@wheaton.edu
(630) 752-7885

Dr. Carrie Williams
Deputy Title IX Coordinator & Equity Officer for Students
Student Services Building #215
carrie.williams@wheaton.edu
(630) 752-5797

Karen Tucker
Deputy Title IX Coordinator & Equity Officer for Employees
Blanchard #154
karen.tucker@wheaton.edu
(630) 752-5060
Public Safety
Individuals may also report incidents under this Policy to Wheaton College’s Department of Public Safety. Public Safety can assist in securing resources and/or making a report to the local police, regardless of the location where the incident occurred. Reports made to Public Safety are not confidential and must be shared with the Equity Officers. Please note: Public Safety employs student workers. If you wish to speak with a non-student, you may ask to speak with an officer.
Phone: (630) 752-5911
Email: public.safety@wheaton.edu
In Person: Chase Service Center
Online
An online report may be filed through Wheaton Gateway, click here or go to www.wheaton.edu/titleixandequity.
Anonymous Reporting
The College recognizes that in some instances, individuals may wish to initiate an anonymous report. Individuals wishing to make an anonymous report may visit the College’s anonymous reporting link or go to www.wheaton.edu/titleixandequity. However, individuals wishing to make an anonymous report should understand that the College may be limited in its ability to act on information from anonymous reports.
Bystander or Third-Party Reporting
As a Christian community seeking to live out an ethic of care, the College encourages members of the College community to practice gracious and conscientious bystander intervention. While attempting to intervene in a situation may not always be appropriate (e.g., if there is a threat to physical safety. , one of the most effective ways to counteract incidents of bias, harassment, or discrimination is to report it immediately.

B. Employee Reporting Obligations.

All College employees, with the exception of Confidential Resources, must promptly report to the Equity and Title IX Office any information they receive regarding conduct that may violate this policy. Employees who fail to report as required may be subject to disciplinary action.

C. Confidential Resources.

Individuals seeking confidential support may contact the following Confidential Resources, who are not required to report information to the College unless an imminent threat of harm exists or as otherwise required by law:

Counseling Center: located in North Harrison Hall (630) 752-5321
Student Health Services: located in North Harrison Hall (630) 752-5072
Ordained Chaplain’s Office Staff: located in Lower Beamer (630) 752-5445

D. Confidential Advisor.

Victims/survivors of sexual misconduct may speak with a Confidential Advisor who provides emergency and on-going support to individuals who have experienced sexual misconduct. Additional information about Confidential Advisors can be found here.

VIII. Privacy and Confidentiality of Reports to the College

The College will seek to protect the privacy interests of all parties involved in a report of prohibited conduct. Such allegations are private and generally only shared with College employees on a need-to-know basis. However, because the College must gather facts, respond to reports, and maintain a nondiscriminatory and safe environment, strict confidentiality cannot be guaranteed in most cases. Individuals with confidentiality concerns may speak with an Equity Officer. The Complainant, Respondent, and witnesses are expected to keep information and records shared during the resolution process private and confidential.

A. Amnesty for Good Faith Reports by Students

The College encourages students to report violations of this Policy. Students may worry about reporting if they or others were also violating College policy, such as using alcohol or drugs at the time of the incident. To support safety and remove barriers to good-faith reporting, the College will reduce or withhold Student Conduct consequences for students who report. However, the College reserves discretion to impose non-disciplinary, educational, or restorative actions when appropriate.

B. Obligation to Act in Good Faith

Reports under this Policy must be made in good faith, and all parties and witnesses are expected to be truthful. Intentionally false, exaggerated, malicious, or misleading reports or testimony may be considered retaliation and may violate this Policy or other College policies. This does not apply to reports made in good faith, even if the College does not find a Policy violation. People who are not involved in an Equity process may also violate this Policy if they spread false or misleading information about a good-faith report or about someone who participated in the process.

IX. Resolution Process and Options

Access infographic chart on equity determination

The Director of Equity and Title IX Coordinator will coordinate the College’s response to a discrimination or harassment report. The Director of Equity and Title IX Coordinator may also assign their duties under this Policy to a Designee(s).

A. College Response When a Report is Received: Initial Review and Assessment

Upon receipt of a report of a violation of the Policy, the Equity Officer(s) will conduct an initial review and assessment. If at that time it is determined that the alleged conduct, even if true, would not constitute a violation of the Policy, the matter may be referred to the appropriate campus office for resolution or closed with no further action taken by the College. Where there is reasonable cause to believe a violation of the Policy may have occurred, the College will proceed, in consultation with the Complainant as described below.

When a report is received that includes the contact information for the Complainant, an Equity Officer will:

Contact the person who reports experiencing biased behavior, discrimination, or harassment (the Complainant) to provide information about policies, resources, resolution options, and available supportive measures,
Invite the Complainant to meet. The Complainant is not obligated to meet with an Equity officer; however, this meeting creates an opportunity to further describe the incident and discuss desired outcomes. If the individual chooses not to meet with the Equity Officer, the College’s ability to take responsive action may be limited.
Discuss available resolution options and supportive measures. Equity Officers seek to resolve concerns in alignment with the wishes of the Complainant. Exceptions to this are when the College has reason to believe a threat to campus safety exists or has information which sufficiently establishes a pattern of harmful behavior by the Respondent, or when the Equity team wishes to provide education or other measures to prevent harm or provide (individual) or institutional remedies.

The Equity Officers may exercise discretion to determine appropriate responsive action based on the facts and circumstances. At an Equity Officer’s discretion, and with consideration of the Complainant’s wishes, options for responsive action may include (1. No action beyond the report, (if appropriate and requested by the Complainant), (2. Informal Resolution, or (3. Formal Resolution (Information Gathering Process). The Equity Office will document the report received, the responsive action taken, and the outcome.

B. Supportive Measures

The Equity Officer will offer Supportive Measures to the Complainant and, as appropriate, to the Respondent regardless of whether the Complainant chooses to pursue an Informal or Formal Resolution Process. Supportive Measures are designed to restore or preserve equal access to the College’s programs and activities and deter further acts of alleged misconduct, bias, discrimination, harassment, or retaliation without unreasonably burdening either party. Supportive Measures are non-disciplinary, non-punitive and without fee or charge. The College will keep supportive measures confidential whenever possible, as long as doing so does not prevent the College from providing those measures. Violation of a directive and/or other action issued as a part of a supportive measure may result in disciplinary action.

C. Interim Measures for Safety

In cases where there is reasonable cause to believe the alleged Respondent is a threat to any person(s) or property, or where multiple Complainants have been directly impacted by the Respondent's conduct and a potentially significant pattern of harm may exist, the College may impose interim measures, including but not limited to:

Interim suspension of a student pending resolution of the matter;
Interim removal of an employee from campus or from specific duties, with or without pay, pending resolution;
Interim restrictions on access to campus facilities or programs;
Interim no-contact directives;
Other measures necessary to protect health or safety.

D. Right to a Support Person

The Complainant and Respondent may bring a non-attorney support person to any meeting or interview related to a report under this Policy. In employee matters, a supervisor, subordinate, or peer from the same department may not serve as a support person because of possible conflicts of interest. The College may continue with any meeting, interview, document review, or report review even if a support person is not available.

A support person may not speak for the individual or participate directly in meetings or proceedings. Support persons must also keep any records shared during the process confidential. These records may not be shared with others, made public, or used for any purpose not approved by the College. The College may limit or remove a support person’s role if they do not follow these participation or privacy rules. Support persons will be required to sign the Support Person Expectation Agreement.

E. Conflicts of Interest

The College requires any official involved in information gathering, decision-making, or appeals to disclose any actual or potential conflict of interest. A conflict exists when an employee’s interests may interfere, or appear to interfere, with their ability to be fair and unbiased.

Anyone who believes an assigned Equity Officer or Designee has a conflict of interest or bias should notify the Director of Equity and Title IX Coordinator right away and request a replacement. If the concern involves the Director of Equity and Title IX Coordinator, the request may be submitted to the Vice President for Student Development.

Written requests must be submitted within three (3) days after notice of the official’s involvement and must describe the conflict. If a conflict is found, the College will take appropriate steps to address it and maintain a fair process. The Director of Equity and Title IX Coordinator makes the final decision, unless the request involves that individual, in which case the Vice President for Student Development makes the decision.

F. Informal Resolution Process and Options

In some cases, reported actions, communications or conduct may not violate this Policy or the Complainant may not want to participate in a Formal Resolution Process. However, the reported conduct is still unwelcome or harmful. The College offers informal resolutions to address such unwelcomed behavior.

After assessing the unwelcomed behavior, the Equity Officers may decide that Informal Resolution is an effective option to: (1. stop the conduct, (2. address the impact of the behavior and, (3. help prevent reoccurrence.

Informal resolutions are primarily designed to address unwelcomed behavior, provide care, and seek to restore relationship between the parties Informal Resolution emphasizes repair, education, and prevention through mutually agreeable outcomes rather than formal adjudication and disciplinary sanctions. In some instances, notifying an individual that certain actions or words were offensive and asking them to stop may be enough to address the concern. Restorative Justice conversations or coaching conversations may also be an appropriate method for addressing the unwelcomed behavior.

Examples of Informal Resolution options may include but are not limited to:

Facilitated mediation between the parties;
Supportive measures;
Restorative Justice conversation or circle;
Targeted and/or broad-based training;
Educational programming or coaching for relevant individuals or groups; or other reasonable remedies that support the goals of the Policy.

G. Formal Resolution Option: Information-Gathering Process

After assessing the unwelcome behavior, the Equity Officers may determine that the appropriate responsive action is to conduct a formal information gathering process. In making this determination, the Equity Officers will consider: (1) The nature of the alleged conduct, (2) the severity of the alleged conduct, (3) the wishes of the Complainant, and (4) any other relevant factors.

The Equity Officers or their Designee(s) will gather information regarding the potential policy violation and will promptly, fairly, and impartially determine an outcome as he or she deems appropriate. This process will include but not be limited to the following steps:

Notice: The Equity Officers or designee(s) will notify the Respondent of the allegations verbally or in writing, and the Respondent will be given the opportunity to respond.
Interviews and Supporting Documentation: Both parties will have the opportunity to provide details and supporting documentation about their unique perspective relevant to the allegations. The Parties will also be given the opportunity to provide names of other relevant witnesses. The Equity Officers or designee(s) will have the discretion to review documents, and interview witnesses they deem to be relevant and helpful to the resolution of the matter.
Outcome: After reviewing all of the relevant information gathered, the Equity Officers or designee(s) will then determine the outcome using the preponderance of the evidence standard. An Equity Officer will communicate the outcome and sanctions, if applicable, to the individuals.

H. Corrective Action

The ongoing safety of people on campus;
The seriousness of the incident;
The Respondent’s response;
The Respondent’s conduct record; and
The impact the conduct may have on the campus community.

The Equity Officers or their Designee(s) will consult with Residence Life for students and Human Resources for employees. They will review the Respondent’s conduct record and make sure any sanctions are consistent with College policies and past actions.

Corrective actions for employees may include but are not limited to: verbal or written warning, educational requirements, mandatory training or coaching, performance improvement plan, behavioral requirement, transfer, demotion, suspension without pay, loss of compensation, loss of privileges or leadership and/or access restrictions, loss of recognition, no contact and/or no trespass directives, restitution, termination of employment, and/or ineligibility for rehire. Any corrective actions imposed on a faculty member shall comply with any applicable terms of a faculty member’s contract with the College and the College’s Faculty Handbook.
Corrective actions for students may include, but are not limited to: verbal or written warning, educational requirements, mandatory training or coaching, parent notification, assessment conducted by the Dean of Student Wellness, community service, behavioral requirement, loss of privileges, or leadership positions and/or access restrictions, limitations or restrictions on housing or program eligibility, no contact and/or no trespass directives, restitution, probation, suspension, expulsion, and/or ineligibility for re-admission or employment.
Corrective actions for third parties (visitors, contractors, vendors) may include but are not limited to: Restrictions regarding access to campus properties, College facilities, programs, or activities; Termination of contracts, agreements, or business relationships with the College, and/or permanent ban from college property.

When an information-gathering process reveals that a campus organization (such as a student club, athletic team, campus academic department, or staff/faculty committee) has committed or promoted behavior that violates this Policy, the organization and its members may be disciplined. Corrective action to the organization may include, but is not limited to, loss of College privileges (including, but not limited to, prohibition of the organization’s participation in certain activities and the use of College facilities), educational requirements for organization members, required additional oversight of organization activities, and temporary or permanent loss of funding and/or loss of recognition by the College, in addition to individual members of the organization who are determined responsible for a Policy violation being subject to the sanctions listed above. All campus organizations/departments are responsible for the actions of their members when those members are acting or operating in, with, or on behalf of the campus organization/department.

The Equity Officers or their designees have the sole right to determine whether conduct violates this Policy or is otherwise inappropriate.

I. Specific Procedures for Tenured Faculty Members

For cases involving Tenured Faculty Members as Respondent, the Provost or his/her Designee(s) will decide whether the policy was violated and what sanctions, if any, should be imposed. If the Provost or his/her Designee(s) imposes the sanction of employment termination, the Provost or his/her Designee(s) will follow the procedures for termination for cause set forth in the Faculty Handbook following the expiration of the relevant period for appeals. If the Faculty Handbook process results in a decision not to terminate the faculty member’s employment, the matter will return to the Provost or Designee(s) to decide whether another sanction should be imposed.

If the Provost has a conflict of interest and is unable to serve as decision maker, the Director of Equity and Title IX Coordinator or their designee will appoint an alternate decision maker such as an academic dean as the Provost’s Designee.

J. Appeal

Either party may appeal an outcome involving termination, expulsion, or suspension.¹ An appeal must be submitted in writing to the Director of Equity and Title IX Coordinator within five business days of the individual being notified of the outcome. The appeal must (1) provide a detailed statement of facts and argument for the grounds upon which the request for further review is based and (2) include or reference any new supporting documentation or evidence. If a Respondent does not appeal the outcome within the timeline set forth above, the outcome will be considered final.

1. Grounds for Appeal

A request for an appeal must be based on one or more of the following reasons:

Procedural irregularity that substantially affected the outcome of the matter;
New evidence is presented that was not reasonably available at the time of the determination that could substantially affect the outcome of the matter; and
The sanctions imposed are grossly disproportionalte (i.e.) excessively harsh) given the offense or the cumulative conduct record of the Respondent. This ground for appeal will not apply to matters where termination of tenure is sought, as that proposed sanction will be reviewed through the procedures set forth in the Facutly Handbook.

Any information included in the appeal that does not apply to the above three reasons for filing an appeal will not be considered in the appeal process.

2. Appeal Procedures

Upon receipt of an appeal request, the Director of Equity and Title IX Coordinator will:

Notify the Complainant, and s/he will be provided a copy of the appeal;
Provide the Complainant with 5 days to submit a written response and supporting documentation.
Notify the Appeal Officer that an Appeal has been submitted.

A member of the Senior Administrative Cabinet or his/her Designee will serve as the Appeal Officer. After considering all relevant documentation and, if deemed necessary by the Appeal Officer, meeting with the parties or others, the Appeal Officer will make a final decision. The Appeal Officer’s decision will be provided to both parties within a reasonable time after the conclusion of the Appeal Officer’s review.

K. Procedural Discretion

The procedures set forth in this Policy reflect the College’s desire to respond to reports of bias, harassment, discrimination and/or retaliation in good faith and in a manner that promotes fairness to all involved individuals. The College recognizes that each case is unique and that circumstances may arise which require the exercise of discretion and flexibility in responding to a particular matter. Accordingly, the College reserves the right to modify the procedures in this Policy or take other action as it finds to be appropriate under the circumstances.

In circumstances where a report is made of a violation of this Policy by an individual or about an individual who is not a student or an employee of the College, the College reserves discretion to use responsive actions or procedures other than those discussed in this Policy, as appropriate under the circumstances.

If a report includes multiple allegations that could invoke more than one College policy or procedure, the Director of Equity and Title IX Coordinator shall determine in his or her discretion what process will be used to resolve the report(s) and will notify all parties of his or her determination.

L. Complaints Relating to Retaliation, Violation of Supportive Measures, and Other Procedural Violations

Any complaint relating to retaliation in violation of this Policy, violations of supportive measures, violation of the obligation to act in good faith, violation of the obligation to be truthful, or violations of sanctions should be reported promptly to the Director of Equity and Title IX Coordinator. The College will take appropriate action against any individual who retaliates against another person in violation of this Policy or who violates supportive measures, the obligation to act in good faith, the obligation to be truthful or violate sanctions.

When the College receives a complaint regarding any such violations the Director of Equity and Title IX Coordinator and/or Equity Officers may exercise discretion to determine an appropriate responsive process based on the facts and circumstances which may include a referral to an alternative College process such as Student Conduct or Human Resources for employees. In instances where the outcome of the process results in a suspension, expulsion, or termination of employment, the impacted individual may appeal the outcome in accordance with the appeal rights as set forth in this Policy. The College will notify the parties of the outcome of the complaint.

This policy will be amended from time to time, as needed, to remain in alignment and compliance with relevant State and Federal laws.

^[1] ^{In matters that implicate (110 ILCS 55/) Preventing Sexual Violence in Education Act, both parties may appeal any findings or imposed sanctions using the appeal process and grounds for appeal outlined in the policy.}

Last updated: 2026-10-05