2021-2022 Administrative Policy Manual

Apr 19, 2024

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2021-2022 Administrative Policy Manual [ARCHIVED COPY]

Section 12 - Miscellaneous

12.0 Miscellaneous
12.1 Nondiscrimination and harassment
12.2 Equal Opportunity and Affirmative Action
12.3 Americans with Disabilities Act and Requests for Reasonable Accommodations
12.4 Interment of Persons On Campus
12.8 Campus Security and Police

12.9 Protection of Non-Student Minors
12.90 Testing Services
12.91 Elected/Appointed Officials on Campus

12.0 Miscellaneous

Reviewed May 26, 2016

See Board of Regents Policy Manual Section 12.0.

Nondiscrimination and Harassment

Non-Discrimination and Anti-Harassment Policy

Policy Number: 12.1
Effective Date: March 17, 2022
Revision History: February 1, 2018; February 2022
Policy Contact: Executive Director of the Office of Diversity and Equity Compliance

Purpose and Policy Statement

This policy provides information and guidance regarding discrimination and harassment, the investigation of allegations related to discrimination and/or harassment (based on a protected class), and the consequences for discrimination and/or harassment.

Georgia Gwinnett College (GGC) is committed to providing a learning, working, and living environment that promotes personal integrity, civility, and mutual respect and is free of all forms of discrimination and harassment. GGC does not discriminate on the basis of sex or gender in any of its education or employment programs and activities in compliance with Title IX of the Education Amendments Act of 1972.

GGC follows the BOR 6.7 Policy on Sexual Misconduct and the BOR Human Resources Administrative Manual Employee Relations: Prohibit Discrimination & Harassment Policy. This Policy incorporates by reference the applicable sections of the University System of Georgia (USG) Policy on Sexual Misconduct and BOR Human Resources Administrative Manual Employee Relations: Prohibit Discrimination & Harassment. All allegations of discrimination and harassment based on the protected categories other than Sexual Misconduct alleged against a student Respondent(s) will be covered by this Policy and applicable BOR policies.

Bias based on the protected categories of race, color, sex (including sexual harassment and pregnancy), sexual orientation, gender identity, ethnicity or national origin, religion, age, genetic information, disability, or veteran status will not hinder employment, study or institutional services, programs, or activities. Bias factors will not be permitted to have an adverse influence upon decisions regarding students, employees, applicants for admission, applicants for employment, contractors, volunteers, or participants in or users of institutional programs, services, and activities. Georgia Gwinnett College will continue in its efforts to maintain an institutional environment free of such bias and restates its policy prohibiting the interference of such bias.

Every member of the GGC Community is expected to uphold this Policy as a matter of mutual respect and fundamental fairness in human relations. Every student of this institution has a responsibility to conduct themselves in accordance with this Policy as a condition of enrollment, and every College employee has an obligation to observe College policies as a term of employment.

Scope

All members of the College community (as defined below) are responsible for understanding and complying with this policy.

Definitions

Members of the College Community: Any persons employed by or affiliated with the College in any way and persons participating in any College program or activity, including, but not limited to:

College faculty, staff, administrators, employees, job applicants, independent contractors, and vendors;

College students;

Volunteers and participants in any College program or activity; and

Guests and visitors to campus, to any property owned or leased by the College, or to any property where a college program or activity is being conducted.

Complainant: An individual who is alleged to have experienced conduct that violates this Policy.

Confidential Employees: Individuals employed by the institution to whom a Complainant or alleged victim may talk in confidence, as provided by law. Disclosure to these employees will not automatically trigger an investigation against the Complainant’s or alleged victim’s wishes. Privileged Employees include those providing counseling, advocacy, health, mental health, or sexual-assault related services (e.g., sexual assault resource centers, campus health centers, pastoral counselors, and campus mental health centers) or as otherwise provided by applicable law. Exceptions to confidentiality exist where the conduct involves suspected abuse of a minor (in Georgia, under the age of 18) or otherwise provided by law, such as imminent threat of serious harm.

Consent: Words or actions that show a knowing and voluntary willingness to engage in mutually agreed-upon sexual activity. Consent cannot be gained by force, intimidation or coercion; by ignoring or acting in spite of objections of another; or by taking advantage of the incapacitation of another where the Respondent knows or reasonably should have known of such incapacitation. Minors under the age of 16 cannot legally consent under Georgia law.

Consent is also absent when the activity in question exceeds the scope of consent previously given. Past consent does not imply present or future consent. Silence or an absence of resistance does not imply consent.

Consent can be withdrawn at any time by a party by using clear words or actions.

Dating Violence: Violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the alleged victim. The existence of such relationship shall be determined based on the totality of the circumstances including, without limitation to: (1) the length of the relationship; (2) the type of relationship; and (3) the frequency of interaction between the persons involved in the relationship.

Dating violence includes, but is not limited to, sexual or physical abuse or the threat of such abuse. Dating violence does not include acts covered under the definition of Domestic Violence.

Discrimination: Decision-making based on race, color, sex (including pregnancy), sexual orientation, gender identity, ethnicity or national origin, religion, age, genetic information, disability, or veteran status.

Other examples that may constitute discrimination as defined above include, without limitation:

Hiring, termination, promotion, salary actions, and other employment decisions based on protected categories, i.e. race, sex, disability, etc.;

Assigning grades, or making academic decisions based on protected categories, such as race, sex, disability, etc.; and/or

Refusing acceptance or admission to a person with a disability without consideration of accommodations.

Discriminatory harassment: Unwelcome verbal or physical conduct based on race, color, sex (including sexual harassment and marital, parental, and pregnancy status), sexual orientation, gender identity, gender expression, ethnicity or national origin, religion, creed, age, genetic information, disability, or veteran status when it is sufficiently severe, persistent or pervasive to:

Unreasonably interfere with the individual’s work or educational performance;

Create an intimidating, hostile, or offensive working or learning environment; or

Unreasonably interfere with or limits one’s ability to participate in or benefit from an instructional program or activity.

Disability: Disability means, generally, (i) a physical or mental impairment that substantially limits one or more of an individual’s major life activities, (ii) a record of such impairment, or (iii) being regarding as having such impairment.

Domestic Violence: Violence committed by a current or former spouse or intimate partner of the alleged victim; by a person with whom the alleged victim shares a child in common; by a person who is cohabitating with, or has cohabitated with, the victim as a spouse or intimate partner, or by a person similarly situated to a spouse of the alleged victim.

Incapacitation: The physical and/or mental inability to make informed, rational judgments. It can result from mental disability, sleep or any state of unconsciousness, involuntary physical restraint, status as a minor under the age of 16, or from intentional or unintentional taking of alcohol and/or other drugs. Whether someone is incapacitated is to be judged from the perspective of an objectively reasonable person.

Nonconsensual Sexual Contact: Any physical contact with another person of a sexual nature without the person’s consent. It includes but is not limited to the touching of a person’s intimate parts (for example, genitalia, groin, breasts, or buttocks); touching a person with one’s own intimate parts; or forcing a person to touch his or her own or another person’s intimate parts. This provision also includes “Fondling” as defined by the Clery Act.

Nonconsensual Sexual Penetration: Any penetration of the vagina, anus, or mouth by a penis, object, tongue, finger, or other body part; or contact between the mouth of one person and the genitals or anus of another person. This provision also includes “Rape, Incest, and Statutory Rape” as defined by the Clery Act.

Privileged Employees: Institution employees who have been designated by the institution to talk with a Complainant or Respondent in confidence. Confidential Employees must only report that the incident occurred and provide date, time, location, and name of the Respondent (if known) without revealing any information that would personally identify the alleged victim. This minimal reporting must be submitted in compliance with Title IX and the Clery Act. Privileged Employees may be required to fully disclose details of an incident in order to ensure campus safety.

Reasonable accommodations (employees): In general, an accommodation is any change in the work environment or in the way things are customarily done that enables an individual with a disability to enjoy equal employment opportunities. There are three categories of “reasonable accommodations”:

modifications or adjustments to a job application process that enable a qualified applicant with a disability to be considered for the position such qualified applicant desires; or

modifications or adjustments to the work environment, or to the manner or circumstances under which the position held or desired is customarily performed, that enable a qualified individual with a disability to perform the essential functions of that position; or

modifications or adjustments that enable a covered entity’s employee with a disability to enjoy equal benefits and privileges of employment as are enjoyed by its other similarly situated employees without disabilities.

Reasonable Accommodations (students): Please refer to the Disability Services Policy and Procedure Manual

Reasonable Person: An individual who is objectively reasonable under similar circumstances and with similar identities to the person being evaluated by the institution.

Reporter: An individual who reports an allegation of conduct that may violate this Policy but who is not a party to the complaint.

Respondent: An individual who is alleged to have engaged in conduct that violates this Policy.

Responsible Employees: Those employees who must promptly and fully report complaints of or information regarding sexual misconduct to the Coordinator. Responsible Employees include any administrator, supervisor, faculty member, or other person in a position of authority who is not a Confidential Employee or Privileged Employee. Student employees who serve in a supervisory, advisory, or managerial role are in a position of authority for purposes of this Policy (e.g., teaching assistants, residential assistants, student managers, orientation leaders).

Qualified individual: An individual who satisfies the requisite skill, experience, education, and other job-related requirements for the particular position he/she holds or desires and who is capable of performing the essential functions of that position, with or without reasonable accommodation for any disability.

Sexual Exploitation: Taking non-consensual or abusive sexual advantage of another for one’s own advantage or benefit, or for the benefit or advantage of anyone other than the one being exploited.

Examples of sexual exploitation may include, but are not limited to, the following:

Invasion of sexual privacy;

Prostituting another individual;

Non-consensual photos, video, or audio of sexual activity;

Non-consensual distribution of photo, video, or audio of sexual activity, even if the sexual activity or capturing of the activity was consensual;

Intentional observation of nonconsenting individuals who are partially undressed, naked, or engaged in sexual acts;

Knowingly transmitting an STD or HIV to another individual through sexual activity;

Intentionally and inappropriately exposing one’s breasts, buttocks, groin, or genitals in non-consensual circumstances; and/or

Sexually-based bullying.

Sexual Harassment (Student on Student): Unwelcome verbal, nonverbal, or physical conduct based on sex (including gender stereotypes), determined by a Reasonable Person to be so severe, pervasive, and objectively offensive that it effectively denies a person equal access to participate in or to benefit from an institutional education program or activity.

Sexual Harassment (Other Than Student on Student): Unwelcome verbal, nonverbal, or physical conduct, based on sex (including gender stereotypes), that may be any of the following:

Implicitly or explicitly a term or condition of employment or status in a course, program, or activity;

A basis for employment or educational decisions; or

Is sufficiently severe, persistent, or pervasive to interfere with one’s work or educational performance creating an intimidating, hostile, or offensive work or learning environment, or interfering with or limiting one’s ability to participate in or to benefit from an institutional program or activity.

The USG also prohibits unwelcome conduct determined by a Reasonable Person to be so severe, pervasive and objectively offensive that it effectively denies a person equal access to a USG education program or activity in violation of Title IX.

Sexual Misconduct: Includes, but is not limited to, such unwanted behavior as dating violence, domestic violence, nonconsensual sexual contact, nonconsensual sexual penetration, sexual exploitation, sexual harassment and stalking.

Stalking: Engaging in a course of conduct directed at a specific person that would cause a reasonable person to fear for their safety or the safety of others or suffer substantial emotional distress.

For the purposes of this definition:

Course of conduct means two or more acts, including, but not limited to, acts in which the stalker directly, indirectly, or through third parties, by any action, method, device, or means, follows, monitors, observes, surveils, threatens, or communicates to or about a person, or interferes with person’s property.

Substantial emotional distress means significant mental suffering or anguish that may but does not necessarily, require medical or other professional treatment or counseling.

Substantially limiting: A disability is substantially limiting if it substantially impairs the ability of an individual to perform a major life activity as compared to most people in the general population. An impairment need not prevent or significantly or severely restrict the individual from performing a major life activity to be considered substantially limiting.

Roles and Responsibilities

Non-Discrimination/Anti-Harassment Officer, Title VI Coordinator and Title IX Coordinator: The Executive Director of the Office of Diversity and Equity Compliance (“ODEC Executive Director”) serves as the Non-Discrimination/Anti-Harassment Officer, the College’s Title VI Coordinator, and the College’s Title IX Coordinator. The ODEC Executive Director is the individual designated by the President with responsibility for providing education and training about prohibited discrimination and harassment to the College community and for receiving and overseeing the investigation of reports and complaints of discrimination and harassment in accordance with this policy. The ODEC Executive Director or his/her designee may make recommendations to the President or the President’s designee, or other offices (such as Human Resources or Legal Affairs) as appropriate, if remedial, preventative or disciplinary measures should be taken.

Equity & Compliance Investigator/Disability (504) Coordinator: The Equity & Compliance Investigator shall be appointed to investigate individual complaints by the Non-Discrimination/Anti-Harassment Officer or his/her designee to conduct investigations pursuant to alleged violations of the Non-Discrimination and Anti-Harassment Policy. The Investigator also shall be appointed to individual complaints by the Title IX Coordinator or his/her designee to conduct investigations pursuant to alleged violations of the Student Sexual Misconduct Policy. The Equity & Compliance Investigator also serves as the College’s Disability Coordinator under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973.

ODEC does not serve as an advocate or representative for any party.

Reporting

Any administrator, supervisor, faculty member, or other person in a position of authority who is not a Privileged or Confidential Employee who knows of, or receives a complaint of, potential discrimination or harassment or potential violation of the Amorous Relationship Policy must fully report the information or complaint to the ODEC promptly. Student employees who serve in an advisory role are Responsible Employees and in positions of authority for purposes of this Policy (e.g., residential assistants, orientation leaders, etc.) and must also promptly report discrimination or harassment to ODEC. A complaint or report of discrimination or harassment made to any Responsible Employee generally obligates the College to investigate the incident and take appropriate steps to address the situation. The responsibility to investigate rests with ODEC and not with the Responsible Employee who receives the complaint or report. Failure to promptly report may constitute a separate violation of the NDAH Policy and may provide a basis for discipline under this Policy. This provision does not apply to disclosures of sexual misconduct to privileged or confidential resources as identified by the USG Sexual Misconduct Policy or this Policy.

GGC encourages any person who feels they have been discriminated against or harassed to promptly report the incident to the ODEC. Any member of the GGC Community who observes discrimination or harassment of another person on campus, in connection with a College program or activity, or in a manner that creates a hostile environment for members of the GGC Community should report the conduct to ODEC. No member of the GGC Community should assume that an official of the College already knows about a particular discriminatory or harassing situation.

Complaints and reports of discrimination and harassment should be reported as soon as possible after the incident(s) in order to be most effectively investigated. Complaints may be made in person, in writing, via submission of a complaint form (https://www.ggc.edu/community/diversity-equity-compliance/title-ix/file-a-complaint/complaint-form/), email (titleix@ggc.edu), or via the telephone. Under some circumstances, including for complaints made under Title IX, ODEC may require a Complainant to submit a complaint in writing. Complaints can also be made anonymously, but this may limit the extent to which the complaint can be investigated.

Where the discrimination or harassment alleged is potentially of a criminal nature, GGC Community members are encouraged to also contact the GGC Police Department (for conduct that occurred on campus) or local law enforcement in the relevant jurisdiction (for conduct that occurred off campus). Except as required by the Clery Act for purposes of crime statistics reporting, police will not be notified of a sexual assault without the Complainant/ victim’s consent unless there is an imminent threat of harm or the incident involves someone under the age of 16. GGC Community members have the right to simultaneously make a complaint under this Policy and to law enforcement.

Confidentiality

GGC strongly supports an individual’s interest in confidentiality. When a Complainant or alleged victim requests that his or her identity be withheld or the allegation(s) not be investigated, GGC officials will attempt to protect the confidentiality of the individual to the extent reasonably possible. The OODEC Executive Director/Title IX Coordinator will consider whether the request can be honored while still providing a safe and nondiscriminatory environment for the College community.

All participants in the process (including the Complainant and Respondent, witnesses, advisors, mediators, and members of hearing panels) are expected to respect the confidentiality of the proceedings and circumstances giving with a College program or activity, or in a manner that creates a hostile environment for members of the GGC Community should report the conduct to ODEC. No member of the GGC Community should assume that an official of the College already knows about a particular discriminatory or harassing situation.

If a Complainant reports discrimination or harassment to a Responsible Employee but wants to maintain confidentiality, the Responsible Employee or person in a position of authority will communicate this request to ODEC as well.

Until resolution has been achieved, participants are expected to discuss the matter only with those persons who have a genuine need to know.

Examples of situations in which confidentiality cannot be maintained include:

When GGC is required by law to disclose information (such as in response to legal process);

When disclosure of information is determined by the Office of Diversity and Equity Compliance to be necessary for conducting an effective investigation of the allegation; or

When confidentiality concerns are outweighed by GGC’s interest in protecting the safety or rights of others.

The Complainant will be informed of any decision to act contrary to the request for confidentiality or no investigation before any disclosures are made and before an investigation begins.

Amorous relationships

The College follows the GGC APM 8.2.23 Policy on Amorous Relationships, which prohibits some forms of amorous relationships. However, amorous relationships that are not prohibited under GGC policy may still result in sexual harassment allegations. See the Policy on Amorous Relationships for additional information.

Conflict of Interest

If the Complainant, Respondent, or ODEC representative asserts that a complaint presents an actual or apparent conflict of interest for ODEC, the complaint should be submitted or referred to the Chief of Staff to resolve the conflict of interest. An actual or apparent conflict of interest is a financial interest, relationship, or other circumstance that would lead a reasonable person to doubt the objectivity of the ODEC representative. If the Chief of Staff determines there is no actual or apparent conflict of interest, the OODEC staff shall conduct the inquiry into the complaint.

However, if the Chief of Staff determines that an actual or apparent conflict of interest exists for the ODEC, then the Chief of Staff, in consultation with the Office of Legal Affairs staff, shall appoint an independent individual with appropriate experience and training to conduct the inquiry into the complaint.

Duty to Cooperate During Investigations

This policy statement is hereby incorporated to ensure that faculty, staff, and students of Georgia Gwinnett College are informed of their responsibility to participate in investigative activities. An employee/student of Georgia Gwinnett College shall cooperate to the fullest extent possible in any internal investigation conducted by the College or the Board of Regents when directed to do so by persons who have been given investigative authority by the President of the institution, or his/her designee. Failure to cooperate fully shall be grounds for adverse personnel or enrollment actions, including but not limited to job termination, suspension, or dismissal from the College. Further, a student may be subject to adverse enrollment actions by the ODEC Executive Director or his/her designee under this policy without the need of further action by another office/department.

Before any adverse enrollment actions are taken, the institution must make reasonable efforts to give the student the opportunity to be heard. If any adverse enrollment action is taken, the terms of the action take effect immediately. The student shall receive notice of the action and will be given the opportunity to respond.

Within three business days of receiving a challenge the institution will determine whether the adverse enrollment action should continue.

False Claims and Statements

Falsification of claims, false statements, and false allegations against members of the campus community, in furtherance of these policies or other GGC or USG policies is prohibited, and may lead to disciplinary actions up to and including termination.

Academic Freedom and Freedom of Expression

The rights guaranteed by the First Amendment, including the right to free speech, free expression, free exercise of religion, and the right to assemble peaceably are of the utmost importance, and Georgia Gwinnett College is committed to protecting those rights. However, to the extent that a member of the College community’s approach to exercising these rights creates a discriminatory or harassing environment on the basis of a protected class, the Office of Diversity and Equity Compliance will investigate all allegations pursuant this policy. Academic freedom and freedom of expression will not excuse behavior that constitutes a violation of the law or College/USG policy.

Prohibition Against Retaliation

Anyone who, in good faith, reports what they believe to be discrimination or harassment under this Policy, or who participates or cooperates in, refuses to participate or cooperate in, or is otherwise associated with an investigation may not be subjected to retaliation. Anyone who believes they have been the target of retaliation for reporting discrimination or harassment, for participating or cooperating in, or otherwise being associated with an investigation should immediately contact ODEC. Any person found to have engaged in retaliation in violation of this Policy will be subject to disciplinary action under this Policy.

Retaliation can take many forms including, without limitation:

Departing from any customary employment or academic practice regarding the individual;

Impeding the individual’s academic or professional advancement in any College activity or program;

Refusing to hire, transfer, or promote, or firing the individual;

Transferring or assigning the individual to a lesser position in terms of wages, hours, work responsibilities, job classification, job security, employment, or academic status;

Unwarranted, excessive, or disparate discipline, or negative evaluation of the individual;

Denying the individual access to training or other benefits of employment;

Excluding the individual from academic or work-related meetings, events, or activities;

Refusing to grant reasonable leave or accommodation requests; or

Threats or other acts of intimidation.

Retaliation is not tolerated. Any College community member found to have engaged in retaliation in violation of the APM 12.1 Non-Discrimination and Anti-Harassment policy will be subject to disciplinary action. False Accusations

Individuals are prohibited from knowingly making false statements or knowingly submitting false information to a College official. Any person found to have knowingly submitted false complaints, accusations, or statements, including during a hearing, in violation of this Policy, shall be subject to appropriate disciplinary action (up to and including suspension, expulsion, or termination). Students violating this provision will be adjudicated under the GGC Code of Conduct. Employees violating this provision will be adjudicated under this Policy.

Records

Records generated under this Policy are subject to the Georgia Open Records Act (O.C.G.A. §50-18-70, et seq.) but are maintained in accordance with, and subject to, privacy requirements under state and federal law, including the Family Educational Rights and Privacy Act of 1974 (FERPA). Additionally, the College will take reasonable steps to maintain privacy in relation to any accommodations or protective measures afforded to an alleged victim or Complainant, except to the extent necessary to provide the accommodations or protective measures.

Information pursuant to this Policy shared internally between College administrators is provided on a need-to-know basis. Complainant(s) and Respondent(s) will be provided a copy of any directly related information in the investigative file at the same time they are provided a draft copy of the investigative report. Privileged material that has not been voluntarily released in writing will not be included or otherwise considered in the investigative report and will be excluded from the released material.

Any public release of information to comply with the open crime logs or timely warning provisions of the Clery Act will not release the names of parties or information that could easily lead to a victim’s identification.

Right to be Accompanied by an Advisor or Support Person

Any party to a complaint shall have the opportunity to use an advisor (including an attorney) of their choosing for the express purpose of providing advice and counsel at their expense provided that a party may not select an advisor who is otherwise a party or witness involved in the investigation. The advisor may be present during any meetings and proceedings involved in the investigatory or resolution process in which the advisee is also eligible to be present. The advisor may advise the advisee, including providing questions, suggestions, advice on the proceedings, and guidance on responses to any questions of the participant but shall not participate directly other than for the purpose of conducting cross-examination of the other party in a formal hearing under Title IX pursuant to the USG Policy to Prohibit Discrimination & Harassment. If in connection with a formal hearing under Title IX a party does not have an advisor, the College will provide an advisor solely for the purpose of conducting cross-examination during the formal hearing on behalf of the relevant party.

All communication during the investigation process will be between the College and the party and not the advisor. The College will copy the party’s advisor prior to the finalization of the investigation report when the College provides the parties the right to inspect and review directly related information gathered during the investigation. With the party’s written permission, the advisor may be copied on all communications.

Amnesty for Students

Individuals should be encouraged to come forward and to report prohibited discriminatory or harassing conduct notwithstanding their consumption of alcohol or drugs. Information reported by a student during an investigation concerning their own consumption of drugs or alcohol will not be used against the particular student in a disciplinary proceeding or voluntarily reported to law enforcement; however, students may be provided with resources on drug and alcohol counseling and/or education, as appropriate. Nevertheless, these students may be required to meet with staff members in regards to the incident and may be required to participate in appropriate educational program(s). The required participation in an educational program under this amnesty procedure will not be considered a sanction.

Nothing in this amnesty provision shall be interpreted to prevent an individual who is otherwise obligated by law (including under the Clery Act) to report information or statistical data as required.

Investigation Process, Procedures, and Resolution

The College’s complaint process, outlined herein, is the procedure used to investigate complaints or reports of discrimination and harassment covered by this Policy, to end any discrimination and harassment found, to remedy the effects of discrimination and harassment, and to prevent any recurrence. If appropriate and permitted under applicable law, ODEC may recommend that the Complainant and Respondent attempt to resolve their differences through an informal resolution.

Proceedings under this Policy may be carried out prior to, simultaneously with or following civil or criminal proceedings. Decisions about the timing of specific actions will be made by ODEC based on the status of the evidence and other relevant case factors. These procedures do not replace the right of the Complainant or Respondent to file complaints or seek remedies available under state or federal law.

Any member of the College Community who feels they have experienced discrimination or harassment is encouraged, but not required, to clearly explain to the alleged offender that the behavior is objectionable and request that it cease. The College encourages any member of the GGC Community to report any unresolved incidents of discrimination or harassment as outlined in this Policy.

GGC employees identified as witnesses are required to fully cooperate with an investigation. Any member of the College Community who willfully disregards, delays, or thwarts an investigation or makes false statements during an investigation may be found in violation of this Policy and subject to disciplinary action under this Policy; provided, however, that this provision does not require persons accused under this Policy to make a statement or respond to the allegations against her/him during the investigation. If the accused chooses not to provide a statement or response to the allegations, that silence will be considered a general denial of the allegations. However, the investigation may ultimately proceed and result in a policy violation if the evidence collected proves a violation by a preponderance of the evidence.

The NDAH Officer/Title IX Coordinator or their designees will explain to all parties that he/she is not an advocate or representative for either the Complainant or the Respondent. Advocacy, counseling, and support resources available on campus and in the greater community.

Information obtained during the course of the complaint process will be shared with other participants or witnesses in the investigation only to the extent necessary to conduct a thorough, fair and impartial investigation.

Standard of Review

Investigative findings under this Policy will be made using the preponderance of the evidence standard (i.e., “more likely than not”). This standard requires that the information supporting an alleged violation be more convincing than the information in opposition to it. Any decision to suspend or to expel a student, or to suspend or terminate an employee, must also be supported by substantial evidence.

Interim Protective Measures

The ODEC Executive Director or his/her designee may impose interim protective measures before the final resolution of an investigation to ensure equal access to the College’s education programs and activities or if failure to take the interim measures would constitute an immediate threat to the safety and well-being of the Complainant/victim or other members of the College Community. Before any such measures are instituted, however, the ODEC Executive Director should, where practicable, provide the Respondent with the initial opportunity to respond to the allegations and to the imposition of any interim protective measures.

Imposing interim measures does not indicate that a violation of this Policy has occurred. Such measures are designed to protect the Complainant and the College Community, and are not designed to harm the Respondent.

These interim measures may include but are not limited to:

Change of College housing assignment;

Issuance of a “no contact” directive;

Restrictions or bars to entering certain College property;

Administrative Leave (employees);

Changes to academic or employment arrangements, schedules or supervision;

Interim suspension; and/or

Other measures designed to promote the safety and well-being of the parties and the College Community.

If an interim suspension or administrative leave is issued, the terms of the suspension/leave take effect immediately. When requested by the Respondent, a hearing with the ODEC Executive Director to determine whether the intermediate suspension should continue will be held within three (3) business days of the request.

Initiating an Investigation

Investigations may be initiated by the ODEC Executive Director. In connection with the investigation and resolution of complaints brought under this Policy, all parties shall receive written notice of the allegations and shall be provided an opportunity to respond. Any party (Complainant and Respondent) shall be allowed to remain silent or otherwise not participate in or during the investigation and resolution process without an adverse inference resulting, provided that if a party chooses to remain silent or otherwise not participate in an investigation, the investigation may still proceed and policy charges may still result and be resolved. Timely and equal access to information/evidence that is collected during the investigation will be provided to the parties upon request.

In some instances, ODEC may conduct a preliminary due diligence inquiry to determine if a formal investigation is warranted.

Informal Process

The informal process is an opportunity to bring resolution to a complaint through awareness, education, and/or a facilitated discussion. An informal resolution may be appropriate if the Complainant, or alleged victim, Respondent, and ODEC Executive Director or his/her designee all agree that an informal process is appropriate. The informal process is not available when a student is alleging Sexual Misconduct against an employee.

During an informal process, fact-finding occurs to the extent necessary to resolve the conflict and protect the interest of the parties and the College community, but the ODEC Executive Director or his/her designee does not decide whether the policy has been violated. The terms of the informal resolution must be designed to stop any prohibited behavior, restore or preserve an environment free from prohibited discrimination or harassment, and prevent the reoccurrence of prohibited harassment or discrimination. The Complainant or Respondent always has the option to end the informal process and request a formal process, if the request to end the informal process comes before the agreement of the terms of an informal resolution. A failed informal process will not be a factor in the formal resolution process.

Informal resolution may include, but are not limited to:

Training;

Changes to work or academic arrangements;

Housing reassignment;

Informal discussion with person whose conduct, if not stopped, could rise to the level of discrimination or harassment;

A GGC PD officer escorting an individual to their car or class;

Advisory discussion with the Respondent’s supervisor, professor or advisor; and

“No contact” directive to one or more of the parties.

An informal resolution represents the final disposition of the complaint and is not appealable.

Formal Process

All complaints that are not resolved through the informal process or to which the informal process does not apply are resolved through a formal process involving a full investigation conducted by the ODEC Executive Director’s designee.

As part of the formal process, the Executive Director or designee will:

Inform the parties of their right to be interviewed and provide evidence;

Inform the parties of their right to an advisor;

Inform the parties of their right to determine their level of participation including the right to remain silent;

Obtain information and evidence, including the identity of any witnesses, from the parties;

Attempt to obtain information from the identified witnesses;

Ask relevant questions, submitted by the parties, to any witness or party;

Ask additional questions deemed relevant by the investigator;

Collect and maintain appropriate documentation of the investigation and any evidence obtained;

Disclose appropriate information to others only on a need-to-know basis consistent with state and federal law;

Keep the appropriate supervisors/administrators/faculty informed of the status of the complaint and investigation, and seek input from them as appropriate when implementing any resolution or discipline; and

Provide the Complainant, alleged victim, and the Respondent the opportunity to review the evidence collected and respond to that evidence.

If the Respondent chooses to remain silent without providing a verbal or written response to the allegations, the investigator will consider the absence of a response as a general denial of the alleged misconduct. The investigation will proceed and a Policy violation may be found against the Respondent if supported by a preponderance of the evidence.

The interviews and exchange of information through the investigator, including the opportunity to respond to evidence and to provide the investigator questions a party wishes to pose to the other party or a witness, constitute the hearing process for all complaints of discrimination and discriminatory harassment other than Title IX Sexual Misconduct, which is adjudicated in accordance with the USG Policy to Prohibit Discrimination & Harassment.

At the completion of the investigation process, the investigator will prepare a draft report of findings, which will be shared with the parties. The parties will have the opportunity to review the draft report. The parties will have at least ten (10) business days to submit a written response to the report. The investigator will respond to any additional information provided in the responses by continuing the investigation, make any modifications to the investigation report as appropriate, or finalize the report of findings without further action. At a parties’ request, the investigative file may be reviewed as well during this ten (10) day window.

The investigator may consolidate multiple allegations arising out of the same set of facts and circumstances, or similar allegations against a common party if the allegations become known during the pendency of an investigation. The parties shall have the opportunity to request or object to the consolidation; however, the investigator shall have the authority to make the final determination.

The investigator may consider a pattern of behavior in determining whether the Policy has been violated, if evidence of that pattern is known during the pendency of an investigation or if a prior investigation of similar conduct is available.

Right to Discontinue

If at any time during the complaint review, investigation, or informal resolution process, the ODEC Executive Director/Title IX Coordinator or their designee determine a complaint is invalid, untrue, or filed for reasons not covered under GGC policy, the ODEC Executive Director/Title IX Coordinator or their designee may discontinue the complaint review. The ODEC Executive Director or his/her designee may make recommendations to the President or the President’s designee, or other offices (such as Human Resources or Legal Affairs) as appropriate, if remedial or preventative measures should be taken.

Resolution

The amount of time needed to investigate will depend in part on the nature of the allegation(s) and the evidence to be investigated (e.g., the scope of the allegations, the time period and number of events implicated by or relevant to the complaint, the number or availability of witnesses involved and the volume of documents). The formal investigation process, including the exhaustion of appeal rights, should conclude within 120 business days of receipt of the complaint. The ODEC Executive Director/Title IX Coordinator or their designee will advise the parties if it is determined that the investigation process has been delayed and that the 120 business days may not be met. The parties must be apprised of the additional estimated amount of time needed for the investigation. Upon conclusion of the investigation, the ODEC Executive Director/Title IX Coordinator or their designee will notify the Complainant and Respondent, in writing, of the results of the investigation. The written decision will be disclosed only to the parties and College officials as appropriate to determine and enforce any remedial actions, discipline, or sanctions, and to prepare for any appeals. ODEC will determine whether remedial action is effective. Complainants are encouraged to report any reoccurrence of conduct that were found to violate this Policy, as well as to report any retaliation for the complaint or related investigation.

Remedial and preventative measures may be imposed by the ODEC even in the absence of a violation of this Policy if conduct is found to occur that may, if not addressed, rise to the level of a violation. Any unprofessional conduct or inappropriate behavior found during the course of the investigation that is not covered by the Policy will be referred to the respective department (Student Integrity, Housing, etc.) or Human Resources for review

Remedies

Where discrimination or harassment in violation of this policy is determined to have occurred, the College will take timely action to remedy the effects. Potential remedies for the Complainant or victim include, but are not limited to:

Extensions of time to re-do or complete academic work without academic or financial penalty;

Changes to academic or employment arrangements, schedules, or supervision that minimize the burden on the Complainant or victim;

Provision of, or referral to, medical, counseling, and academic support services;

Change of College housing assignment;

Training/retraining on this policy and other relevant topics for individuals or groups implicated in discrimination or harassment;

“No contact” directives; and

Other measures designed to redress negative impact of discrimination and harassment.

Sanctions

If a violation of this policy is found, the level of discipline and type or scope of sanctions will depend on the severity and nature of the discrimination or harassment, the weight of the evidence, and the need to maintain a safe and respectful environment. ODEC will also consider any history of past discriminatory or harassing behaviors, retaliatory conduct, the Respondent’s willingness to accept responsibility, and previous institutional responses to similar conduct. Available sanctions include, but are not limited to:

If a finding of responsibility is reached, additional factors considered when determining a sanction/responsive action may include, but are not limited to:

The nature, severity of, and circumstances surrounding the violation(s),

History of the Respondent’s prior conduct,

The College’s prior response to similar conduct,

The College’s need to bring an end to the sexual harassment, prevent the future recurrence of sexual harassment, and remedy the effects of the sexual harassment on the Complainant and the community,

The impact on the parties,

Any other information deemed relevant by the Hearing Panel

Student Sanctions

The broad range of sanctions for students includes, but is not limited to, the following:

Warning: A formal statement that the conduct was unacceptable and a warning that further violation of any College policy, procedure, or directive will result in more severe sanctions/responsive actions.

Required Training or Participation: A mandate to meet with and engage in either College- sponsored or external counseling to better comprehend the misconduct and its effects or to required participation in sensitivity training, sexual misconduct training, volunteering, community service, etc.

Probation: A written reprimand for violation of institutional policy. Terms of the probation will be articulated and may include denial of specified social privileges, exclusion from co-curricular activities, exclusion from designated areas of campus, no-contact orders, and/or other measures deemed appropriate.

Suspension: Termination of student status for a definite period of time and/or until specific criteria are met, or both.

Expulsion: Permanent termination of student status and revocation of rights to be on campus for any reason or to attend College-sponsored events.

Withholding Diploma: The College may withhold a student’s diploma for a specified period of time and/or deny a student participation in commencement activities.

Revocation of Degree: The College reserves the right to revoke a degree previously awarded from the College for violations of College policies, procedures, or directives in obtaining the degree, or for other serious violations committed by a student prior to graduation.

Revocation of alumni privileges

Organizational Sanctions: Deactivation, loss of recognition, loss of some or all privileges for a specified period of time.

Other Actions: Including, but not limited to:

Removal from student housing;

Restriction from College premises;

Temporary or permanent separation of the parties (by way of example only: change in classes, reassignment of residence, no contact orders, limiting geography where parties may go on campus) with additional sanctions for violating orders;

Counseling or mentoring;

Removal from leadership/supervisory positions within the GGC community;

Revocation of honors or awards;

Loss of GGC privileges (i.e., using GGC athletic facilities, parking on campus, using the campus library, utilizing the dining hall);

Community service;

Any other discretionary sanctions that are directly related to the violation or conduct and that are aimed at eliminating Discriminatory Misconduct, preventing its recurrence, and addressing its effects on the Complainant and, if applicable, the GGC community.

Employee Sanctions

The broad range of sanctions for employees includes, but is not limited to, the following:

Warning or Reprimand: Verbal or Written

Performance Improvement/Management Process

Required Counseling

Required Training or Education

Probation

Workplace Restrictions

Reassignment

Suspension

Termination

Other Actions: Including, but not limited to:

Restriction from College premises;

Temporary or permanent separation of the parties (limiting geography where parties may go on campus) with additional sanctions for violating orders;

Removal from leadership/supervisory positions within the College community;

Right to Appeal

All parties shall have the right to appeal the outcome of the formal process to the College President pursuant to this policy. The President must receive a written appeal within ten (10) business days after the receipt of the written notification of the institutional decision being appealed. The appeal must be based on one of the following reasons:

Material failure to comply with applicable procedures in this Policy or to conduct a reasonably thorough investigation;

Partiality, bias, or conflict of interest by the ODEC Executive Director/Title IX Coordinator or their designee;

Findings, if not overturned or modified, would result in a substantial injustice to a party or parties, including a substantially inadequate or excessive sanction; or

New evidence that was not reasonably available to be presented by the parties during the course of the investigation.

The Office of President will notify the non-appealing party of the appeal and provide that party an opportunity to respond in writing. The President or his/her designee may receive additional information if he/she believes such information would aid in the appeal.

The President may:

Affirm the original finding and sanction;

Affirm the original finding, but issue a new sanction of greater or lesser severity;

Remand the case back to the Office of Diversity and Equity Compliance to correct a procedural or factual defect; or

Reverse or dismiss the case if there was a procedural or factual defect that cannot be remedied by remand.

A decision by the President or his/her designee will be made within a reasonable time and the ODEC Executive Director, the Complainant, the Respondent, and alleged victim (if the complaining party is not the alleged victim) will be notified in writing of the decision on the appeal. During the time of the appeal and review, disciplinary action(s) or remedial/preventative measure(s), if any, taken because of the original complaint may be implemented and enforced. Upon request of the appealing party, the President may, at his or her discretion, suspend the imposition of the disciplinary action(s), sanction(s), or remedial/preventative measure(s) while the appeal is pending.

If an appeal is not filed within the appeal period, the findings become final and are not subject to any review.

Related Regulations, Statutes, Policies, and Procedures

Federal Laws
The Equal Pay Act of 1963 (EPA)
Title VI of the Civil Rights Act of 1964 (Title VI)
Title VII of the Civil Rights Act of 1964 (Title VII)
Executive Order 11246 issued in 1965 (as amended by 11375)
The Age Discrimination Act of 1967 (ADEA)
Title IX of the Educational Amendments of 1972 (Title IX)
Section 501 of the Rehabilitation Act of 1973 (Section 501)
Section 503 of the Rehabilitation Act of 1973
Vietnam Era Veterans’ Readjustment Assistance Act of 1974 (VEVRAA)
The Pregnancy Discrimination Act of 1978
Title I of the American with Disabilities Act of 1990 (ADA)

Americans with Disabilities Act Amendment Act of 2008 (ADAAA)
Genetic Information Nondiscrimination Act of 2008 (GINA)
The Lilly Ledbetter Fair Pay Act of 2009

Board of Regents Policy Manual 8.2.18.6 Amorous Relationships
Board of Regents Policy Manual 8.2.1 Equal Employment Opportunity
Board of Regents Policy Manual 6.6 Non-Discrimination and Anti-Harassment
Board of Regents Policy Manual 8.2.18.5 Sexual Harassment
Board of Regents Policy Manual 6.7 Sexual Misconduct

Equal Opportunity and Affirmative Action

Policy Number: 12.2
Effective Date: February 1, 2018
Revision History: June 30, 2016
Policy Contact: Executive Director of the Office of Diversity and Equity Compliance

Purpose and Policy Statement

This policy provides information regarding equal opportunity and affirmative action. Georgia Gwinnett College complies with University System of Georgia Board of Regents Policy 8.1.2 Equal Opportunity and federal law, which prohibits discrimination or harassment of employees or applicants on the basis of sex, gender identity, sexual orientation, race, color, religion, creed, national origin, age, physical or mental disability, protected veteran status, or any other characteristic protected by law with regard to any employment practices, including recruiting, advertising, job application processing, hiring, upgrading, training, promoting, transferring, compensating, assigning job responsibilities, providing benefits, and/or other terms, conditions, or privileges of employment, provided the individual is qualified, with or without reasonable accommodations, to perform the essential functions of the job. This policy applies to all jobs at the College. The College will continue to ensure that individuals are employed, and that employees are treated without regard to their sex, gender identity, sexual orientation, race, color, religion, creed, national origin, age, physical or mental disability, protected veteran status, or any other characteristic protected by law during employment, in all employment practices as follows:

Employment decisions at the College are based on legitimate job-related criteria. All personnel actions or programs that affect qualified individuals, such as employment, upgrading, demotion, transfer, recruitment, advertising, termination, rate of pay or other forms of compensation, and selection for training, are made without discrimination. Employees may choose to voluntarily disclose their sex, race, national origin, disability and protected veteran status at any time by contacting Human Resources. Such information will be maintained in a confidential manner and will not be used against an individual when making any employment decisions. Employees with disabilities and disabled veterans are encouraged to inform the Office of Payroll and Benefits if they need reasonable accommodations to the known physical or mental limitations of an otherwise qualified applicant or employee to promote the employment of qualified individuals with disabilities and disabled veterans, unless such accommodations would impose an undue hardship on the College’s business operations. Applicants seeking employment with the College should contact the Office of Human Resources to request reasonable accommodations.

The College’s affirmative action program and related policies were developed in accordance with Executive Orders 11246 and 11375, as amended; Title VI and VII of the Civil Rights Act of 1964; the Age Discrimination Act of 1967; Title IX of the Education Amendments of 1972; the Rehabilitation Act of 1973 (Sections 503 & 504); the Vietnam Era Veterans Readjustment Assistance Act of 1974, as it amends 38 U.S.C. 4212; the Americans with Disabilities Act of 1990 (Title II) and their implementing regulations.

Scope

All members of the College community (as defined below) are responsible for understanding and complying with this policy.

Definitions

Members of the College community: any persons employed by or affiliated with the College in any way and persons participating in any College program or activity, including, but not limited to:

College faculty, staff, administrators, employees, independent contractors, vendors;
College students;
Volunteers and participants in any College program or activity; and
Guests and visitors to campus, to any property owned or leased by the College, or to any property

ODEC or DEC: Office of Diversity and Equity Compliance

Roles and Responsibilities

Non-discrimination/Anti-Harassment Officer, Title VI Coordinator and Title IX Coordinator: the Executive Director of the Office of Diversity and Equity Compliance (“DEC Executive Director”) serves as the Non-Discrimination/Anti-Harassment Officer, the College’s Title VI Coordinator, and the College’s Title IX Coordinator. The DEC Executive Director is the individual designated by the President with responsibility for providing education and training about prohibited discrimination and harassment to the College community and for receiving and overseeing the investigation of reports and complaints of discrimination and harassment in accordance with this policy.

Special Assistant Office of Diversity and Equity Compliance: the Special Assistant shall serve as and assume the responsibilities of the Non-Discrimination/Anti-Harassment Officer, Title VI Coordinator, and the Title IX Coordinator, upon task delegation or case-specific designation by the DEC Executive Director.

Related Regulations, Statutes, Policies, and Procedures

University System of Georgia Policies
Board of Regents Policy Manual 8.2.1 Equal Employment Opportunity
Board of Regents Policy Manual 4.1.2 Non-Discrimination

Board of Regents Policy Manual 8.2.16 Sexual Harassment
Board of Regents Policy Manual 4.1.7 Sexual Misconduct

Americans with Disabilities Act and Requests for Reasonable Accommodations

Policy Number: 12.3
Effective Date: February 1, 2018
Revision History: June 30, 2016
Policy Contact: Director of Payroll and Benefits and Executive Director of the Office of Diversity and Equity Compliance

Purpose and Policy Statement

This policy provides information and guidance regarding the Americans with Disabilities Act and discusses how individuals seeking a reasonable accommodation pursuant to the ADA may request an accommodation. Georgia Gwinnett College complies with University System of Georgia Board of Regents Policy and federal law, which provides that the College provides reasonable accommodations to employees who are disabled. Accordingly, Georgia Gwinnett College has made and will continue to make reasonable accommodations, which do not impose undue hardships on its business, to the known physical and mental limitations of otherwise qualified employees and job applicants.

The College reserves the right to require documentation for accommodations requests from:

(1) current and prospective students;

(2) student participants in co-curricular activities;

(3) patrons and visitors to College-sponsored events;

(4) registered participants in College-sponsored training sessions, programs, conferences, and workshops;

(5) persons using the services of the Testing Center;

(6) classified, faculty, or other job applicants and employees;

(7) authorized users of campus facilities; and

(8) other persons requesting accommodations under the ADA.

If an individual has a disability, the College encourages the individual to disclose (i) any special methods, skills, and procedures which qualify him or her for positions which he or she might not otherwise be able to do, so that he or she can be considered for any position of the kind, and (ii) the reasonable accommodations which would enable the individual to perform the job properly and safely. Such accommodations may include special equipment, changes in the physical layout of the job, elimination of certain nonessential duties related to the job, or other reasonable accommodations.

Scope

All members of the College community (as defined below) are responsible for understanding and complying with this policy.

Definitions

Disability: Disability means, generally, (i) a physical or mental impairment that substantially limits one or more of an individual’s major life activities, (ii) a record of such impairment, or (iii) being regarding as having such impairment.

Members of the College community: any persons employed by or affiliated with the College in any way and persons participating in any College program or activity, including, but not limited to:

College faculty, staff, administrators, employees, independent contractors, vendors;
College students;
Volunteers and participants in any College program or activity; and
Guests and visitors to campus, to any property owned or leased by the College, or to any property

Qualified individual: An individual who satisfies the requisite skill, experience, education, and other job-related requirements for the particular position he/she holds or desires and who is capable of performing the essential functions of that position, with or without reasonable accommodation for any disability.

Reasonable accommodations: In general, an accommodation is any change in the work environment or in the way things are customarily done that enables an individual with a disability to enjoy equal employment opportunities.”

There are three categories of “reasonable accommodations”:

(i) modifications or adjustments to a job application process that enable a qualified applicant with a disability to be considered for the position such qualified applicant desires; or

(ii) modifications or adjustments to the work environment, or to the manner or circumstances under which the position held or desired is customarily performed, that enable a qualified individual with a disability to perform the essential functions of that position; or

(iii) modifications or adjustments that enable a covered entity’s employee with a disability to enjoy equal benefits and privileges of employment as are enjoyed by its other similarly situated employees without disabilities.

Substantially limiting: A disability is substantially limiting if it substantially impairs the ability of an individual to perform a major life activity as compared to most people in the general population. An impairment need not prevent, or significantly or severely restrict the individual from performing, a major life activity to be considered substantially limiting.

Compliance

Individuals interested in submitting a request for an accommodation should contact the appropriate Georgia Gwinnett College administrative offices below for guidance. Individuals seeking accommodations may be required to provide supporting documentation.

Employment Applicant Accommodations - Upon request made to the Office of Human Resources persons applying for positions as employees at Georgia Gwinnett College will be provided reasonable accommodations in completing the application and/or interview process.
Current Employee Accommodations - Employees seeking accommodations should contact the Office of Payroll and Benefits. Employees may request that any decision to deny a request for reasonable accommodation be informally reviewed. To request reconsideration, employees should submit a written request to the Office of Payroll and Benefits within 10 business days of the initial decision. The request should explain the reasons the employee believes the request should be granted.
Student Accommodations - Students requiring accommodation due to a disability should contact the Office of Disability Services for assistance.
Testing Accommodations - Persons wishing to take GGC academic examinations administered by the Georgia Gwinnett College Testing Center should request specific accommodation through Disability Services or the Testing Center.
Visitor Accommodations - Visitors to College-sponsored events or registered participants in College-sponsored, fee-related events (e.g., training sessions, programs, conferences, and workshops) should contact the sponsor of the event for assistance in arranging accommodation.

Individuals who believe they were denied a reasonable accommodation on the basis of their protected class status, should contact the Office of Diversity and Equity Compliance to file a complaint. The Executive Director of the Office of Diversity and Equity Compliance may be reached at 678-407-5085.

Related Regulations, Statutes, Policies, and Procedures

Federal Laws
Executive Order 11246 Equal Employment Opportunity issued in 1965 (as amended by 11375)
Section 501 of the Rehabilitation Act of 1973
Section 503 of the Rehabilitation Act of 1973
Vietnam Era Veterans’ Readjustment Assistance Act of 1974 (VEVRAA)
The Pregnancy Discrimination Act of 1978
Title I of the American with Disabilities Act of 1990 (ADA)

University System of Georgia Policies
Board of Regents Policy Manual 8.2.1 Equal Employment Opportunity
Board of Regents Policy Manual 4.1.2 Non-Discrimination

12.4 Interment of Persons On Campus

Reviewed May 26, 2016

See Board of Regents Policy Manual Section 12.4.