Harassment Policy & Procedures

Introduction
Harassment, sexual harassment, and sexual assault, whether verbal or physical, are acts of aggression. They include various forms of sexual abuse and sexual assault, including both acquaintance and stranger rape. All such behavior is illegal under both state and federal law. It is also a violation of standards of conduct that are cherished in the SIT community and is not tolerated under any circumstances. An individual who engages in harassment, sexual harassment, or sexual assault is subject to appropriate disciplinary action by the administration, including, but not limited to, reprimand, suspension, termination, or expulsion. In addition, he or she may face possible criminal or civil liability. It is further illegal for an employee or student to attempt in any way to retaliate against a person who makes a claim of sexual harassment. Any such retaliation will also result in disciplinary action, up to and including expulsion, and may also result in
criminal or civil liability. SIT, in an effort to create an environment where all people can work and study without fear of discrimination, harassment, exploitation, or intimidation, is committed to the following: educating the community about harassment, sexual harassment, and sexual assault; implementing appropriate, consistent, and prompt procedures for protecting the rights and well-being of victims, respondents, and the community at large; and assisting victims in securing needed services. All students and staff must familiarize themselves with and observe the Harassment Policy and Procedures. All students and staff, regardless of their country or territory of origin, must abide by US laws and regulations while in the United States. Students and/or staff involved in programs in countries other than the United States must abide by laws and regulations of their host country while overseas and observe the SIT Harassment Policy
and Procedures. Harassment, sexual harassment, and sexual assault, as
defined below, are never acceptable, although a special effort is made to explain and clarify the rules for those from other cultures who may not be familiar with such a code of behavior.

Definition of Harassment
Harassment is a form of discrimination and is defined as verbal or physical conduct that denigrates or shows hostility or aversion toward an individual because of his/her age, ethnic origin, gender, nationality, physical and learning ability, race, religion, sexual orientation, gender identity, protected veteran status, or any other characteristic protected by law, or that of is/her relatives, friends, or associates, and that:

  • has the purpose or effect of creating an intimidating, hostile, or offensive work, educational, or living environment;
  • has the purpose or effect of unreasonably interfering with an individual’s work or academic performance; or
  • otherwise adversely affects an individual’s employment or educational opportunities.

Harassing conduct includes, but is not limited to, epithets, slurs, or negative stereotyping; threatening, intimidating, or hostile acts; denigrating jokes; and written or graphic material that denigrates or shows hostility or aversion toward an individual or group and that is placed on walls or elsewhere on World Learning / SIT premises or program site.

Sexual Misconduct and Harassment: Policy and Procedures

Policy Statement
Sexual harassment, nonconsensual sexual contact, nonconsensual sexual intercourse, sexual exploitation, domestic violence, dating violence, and stalking are prohibited, and will not be tolerated by any program of School for International Training (SIT), including SIT Graduate Institute, SIT Study Abroad, and the International Honors Program. Any act or attempted act that falls within the definition of sexual harassment, nonconsensual sexual contact, nonconsensual sexual intercourse, sexual exploitation, domestic violence, dating violence, or stalking is a violation of SIT policy. Disciplinary sanctions for any member of the SIT community engaging in such conduct may include suspension or dismissal from SIT, termination of employment, and referral for criminal investigation and prosecution by local law enforcement. Victims of any such conduct are encouraged to contact the director of counseling and disability services for confidential support and assistance (services are available to all, regardless of gender identity and expression or sexual orientation). All other SIT staff and faculty are required to report such conduct to SIT’s Title IX coordinator. Victims of sexual harassment, nonconsensual sexual contact, nonconsensual sexual intercourse, sexual exploitation, domestic violence, dating violence, or stalking are also encouraged to notify SIT’s Title IX coordinator immediately.

Student Rights & Responsibilities
Reason for the Policy

SIT is committed to creating and maintaining a community in which its members are free from all forms of harassment, exploitation, intimidation, and violence. SIT recognizes the long-lasting and detrimental effects of sexual misconduct and assault on the individual victim, on the entire community, and on SIT’s mission to prepare its students to lead productive, responsible, and creative lives.

Applicability of the Policy
This policy applies to all members of the SIT community.
Notice of Nondiscrimination
SIT does not discriminate on the basis of race, color, ethnic or national origin, sex, sexual orientation, gender identity, religion, age, ancestry, disability, military status, veteran status, or other non-merit reasons, in admissions, educational programs, or activities and employment, and complies with all applicable federal and state laws regarding nondiscrimination and affirmative action, including Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act of 1973, and Title VII of the Civil Rights Act of 1964. Title IX of the Education Amendments of 1972 is a federal law that specifically prohibits sex discrimination in education. Sex discrimination includes sexual harassment
and sexual assault.

Title IX Coordinator
The assistant dean of Student Health, Safety, and Well- Being is the designated Title IX coordinator for SIT and is responsible for coordinating SIT’s efforts to comply with and carry out its responsibilities under Title IX. The Title IX coordinator’s core responsibilities include overseeing SIT’s response to Title IX reports and complaints and identifying and addressing any patterns or systemic problems revealed by such reports and complaints. To accomplish this, subject to the exemption for confidential employees discussed below, the Title IX coordinator must be informed of all reports and complaints raising Title IX issues, even if the report or complaint was initially filed with another individual or office or if the investigation will be conducted by another individual or office. The Title IX coordinator is available to meet with students, employees, or third parties regarding Title IX–related issues, such as issues related to SIT’s compliance with Title IX, response to Title IX reports or complaints, related grievance procedures, relevant patterns of conduct, or related education and prevention programs. The contact information for the SIT Title IX coordinator is:

Zufan Hagos
Regional Manager of Student Health, Safety & Well-Being
titleIX@sit.edu
1 Kipling Road, PO Box 676
Brattleboro, VT 05302
802 258-3544

Safe Bystander Interventions
Observers of a sexual assault or other types of gender or intimate partner–based misconduct, such as domestic violence, dating violence, or stalking, may be able to help the victim. However, it is important that you do so in a positive manner and in a way that keeps you and the victim safe. Appropriate interventions will depend on the situation. Safe and appropriate options for bystanders may include calling the police to report violent or potentially violent situations, intervening if you believe someone is in a potentially uncomfortable or unsafe situation, and/ or encouraging the target of such conduct to report the incident and seek support.

Retaliation
SIT prohibits retaliation against any individual who reports discrimination or harassment or participates in an investigation of such reports. Any attempt by a member of the SIT community to intimidate, penalize, or threaten a person who reports or who is otherwise involved or cooperating in a report of discrimination, misconduct, or harassment is strictly prohibited. Any person found to have participated in an act of retaliation will be disciplined accordingly.

Investigation
After the receipt of a report of discrimination, harassment (including sexual harassment), or sexual misconduct, the Title IX coordinator or designee will speak with the complainant to gather as much information as possible. The Title IX coordinator or designee will also speak with any witnesses or individuals who may have information about the alleged misconduct. If after this initial fact-finding phase SIT determines that a violation of SIT policy may have occurred, it will proceed with a full investigation. The complainant and the respondent will be notified that an investigation is underway and will be afforded the opportunity to speak independently with the Title IX coordinator or designee to review this procedure and to have his/her rights explained. The Title IX coordinator or designee will also speak with the respondent to listen to their side of the story and to gather any evidence he or she may offer to better understand the nature of the alleged misconduct. The complainant and the respondent will have the opportunity to submit names of individuals with knowledge of the situation, and SIT will follow up with those individuals. The Title IX coordinator or the designee will counsel the complainant and the respondent on academic and other emotional supports available. During an investigation, the Title IX coordinator or designee may ask for written statements and other documents or evidence that may aid in the investigation. Therefore, it is important to preserve all evidence associated with the conduct or that you think might help others understand what happened. Such evidence can include, but is not limited to, text messages, Facebook or Instagram posts, photos, voicemails, emails, or items of clothing. Depending on the type of conduct and the parties involved, SIT may contact local law enforcement. SIT will continue its own investigation into the alleged conduct, regardless of whether the police decide to pursue their own investigation. SIT will cooperate with all police investigations and will honor and enforce any judicial nocontact, restraining, or protective orders the parties may obtain outside the SIT process. During the investigation process, interim measures will be discussed with the parties and implemented as may be appropriate. Interim measures may include changes in class schedules, housing arrangements, work arrangements, no-contact orders, or interim suspensions. All efforts will be made to minimize the impact that these interim measures have on the complainant. In some cases, mediation may be appropriate. Mediation is a process in which SIT can arrange for the complainant and the respondent to meet to see if they can resolve the situation with the assistance of a third-party mediator who will attempt to help guide the respondent and the complainant to a mutually acceptable outcome. The mediator will likely be an administrator and will be assigned by SIT. Mediation is completely voluntary and will only be pursued with the consent of both the complainant and the respondent. At any time during the mediation process, the complainant or the respondent may stop the mediation. In cases involving a potential sexual assault or other forms of sexual violence or intimidation, however, mediation is not an appropriate option. Both the complainant and the respondent will be updated throughout the investigation process. Typically, an investigation will take 60 days, but that may vary depending on the nature and complexity of a case. At the close of an investigation, the Title IX coordinator or the designee will prepare a brief report detailing the essential content of interviews and the pertinent evidence gathered. Both parties will be provided with copies of that report.

Reporting Sexual Misconduct
All members of the SIT community who experience, witness, or hear about an incident of sexual misconduct, including sexual harassment and sexual assault, are encouraged to immediately contact SIT’s Title IX coordinator. In an emergency, please contact local law enforcement. There is no time limit on how long after an incident you can make a report of misconduct; however, SIT’s ability to respond to a report may be hindered by the length of time between the alleged misconduct and the report itself. Once SIT is informed of alleged misconduct, the Title IX coordinator or their designee will notify the complainant and any respondents of their rights pursuant to Title IX. The Title IX coordinator will help the parties involved navigate the formal complaint process and access appropriate medical, mental health, or academic services; discuss possible interim arrangements during the investigation and adjudication processes; explain individual rights; and answer questions along the way. SIT is obligated under Title IX to investigate and resolve all complaints thoroughly, impartially, and promptly, whether made formally or informally. The Title IX coordinator or their designee will therefore respond to every report of alleged sexual misconduct or harassment, facilitate the implementation of measures to stop the behavior, and take steps to prevent its recurrence. While not required, any person who believes they have been a victim of sexual harassment, sexual misconduct, sexual assault, domestic violence, dating violence, or stalking is strongly encouraged to report the incident to local law enforcement. In certain circumstances, depending on the type of conduct alleged and the parties involved, SIT may be independently obligated to contact the police.

Confidential Reporting
SIT counselors are licensed mental health professional who respect and protect confidential communications with clients. A person may report an incident of sexual harassment, sexual misconduct, sexual assault, domestic violence, dating violence, or stalking to SIT Counseling Services with the understanding that SIT will not take any action based on the report. Please be aware that all counselors have the responsibility to disclose otherwise confidential information appropriately when they perceive an immediate and/or serious threat to any person or property. In addition, medical and mental health professionals are required by law to report any allegation of sexual assault of a person under age 18. All other SIT faculty and staff members who are informed or otherwise made aware of possible sexual harassment, sexual misconduct, sexual assault, domestic violence, dating violence, or stalking must report the incident to the Title IX coordinator. If a complainant reports an incident but wishes to maintain confidentiality or requests that no investigation of an incident be conducted or disciplinary action taken, SIT must weigh that request against its obligation to provide a safe, nondiscriminatory environment for all students, faculty, and staff. The Title IX coordinator will in most cases determine whether SIT needs to perform an investigation and/or take some other action in cases where a complainant would prefer complete confidentiality. If an individual who makes a report insists that their name or other identifiable information not be revealed, and SIT is able to respect that request, the individual must understand that SIT will be unable to conduct an investigation into the particular incident or pursue disciplinary action against the alleged perpetrator. Upon receipt of a report, the Title IX coordinator and those assisting with an investigation and those participating in any disciplinary proceedings will make all reasonable efforts to maintain confidentiality and respect the privacy of those involved. SIT understands that reports of this nature can be difficult, emotional, and stressful. Therefore, SIT will only share information as is needed to conduct a prompt, thorough, and effective investigation. All members of the SIT community should understand that even if the complainant asks that SIT not pursue an investigation or decides to attempt to resolve the situation informally, SIT may still investigate the allegations and address the conduct as may be warranted under the circumstances.

Respectful (Not Confidential) SIT Resources:
Local Program Director or staff
Zufan Hagos, Title IX Coordinator, 802 258-3544
titleIX@sit.edu

Community Resources (Vermont)
Women’s Freedom Center,
24-Hour Hotline 802 254-6954
Business Line 802 257-7364
advocates@womensfreedomcenter.net
Windham County Victim Advocate 802 579-1358
Brattleboro Memorial Hospital Emergency Room 802 257-0341
Brattleboro Health Center
(Planned Parenthood) 802 257-0543
Windham County Sheriff 802 365-4949
Vermont State Police 802 254-2382

Reporting Resources
Emergency in any location in the United States: 911
Emergency in any location outside the United States: please see the program chair, local faculty, or local staff member.

Confidential SIT Resources
SIT Counselors counseling@sit.edu

Dual Relationships
Employees and students should be aware of conflicts of interest that are inherent in personal relationships where professional and educational careers are also involved, as well as potential abuses of authority. This is especially true of amorous or sexual relationships between faculty and students or between administrators and students, given the inherently unequal structure of power between them within colleges. It is the policy of SIT that faculty and administrators are not permitted to engage in consensual sexual relationships with students of SIT. Should a charge of sexual harassment arise from such a relationship, the burden and cost of providing a defense falls on the faculty member or administrator. Members of the SIT community should know that, in such instances, defenses are extraordinarily difficult to prove.

Confidentiality Policy
SIT’s responsibility regarding confidentiality is to protect the rights of the individual and to ensure the institution’s ability to make appropriate decisions regarding student life issues. Because students at SIT are educated in a holistic manner, faculty and staff are concerned about all aspects of a student’s life. From time to time, staff members may need to confer with each other regarding health or personal issues, community living, and disciplinary matters.