Policy Overview

Cummings Graduate Institute for Behavioral Health Studies (CGI) is committed to a work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits unlawful discriminatory practices, including harassment. Therefore, CGI expects that all relationships among persons in the office will be business-like and without of bias, prejudice and harassment.

It is the policy of CGI to ensure equal employment opportunity without discrimination or harassment on the basis of race, color, religion, gender, sexual orientation, sexuality, gender identity, national origin, age, disability, genetic information, marital status, amnesty or status as a covered veteran. CGI prohibits any such discrimination or harassment.

CGI encourages reporting of all perceived incidents of discrimination or harassment. It is the policy of CGI to promptly and thoroughly investigate such reports. CGI prohibits retaliation against any individual who reports discrimination or harassment or who participates in an investigation of such reports.

Definitions of Harassment

Sexual harassment constitutes discrimination and is illegal under federal, state and local laws. For the purposes of this policy, sexual harassment is defined, as in the Equal Employment Opportunity Commission Guidelines, as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when, for example: a.) submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment; b.) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; c.) or, such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile or offensive working environment.

Sexual harassment may include a range of subtle and not-so-subtle behaviors and may involve individuals of the same or different gender. Depending on the circumstances, these behaviors may include unwanted sexual advances or requests for sexual favors; sexual jokes and innuendo; verbal abuse of a sexual nature; commentary about an individual's body, sexual prowess or sexual deficiencies; leering, whistling or touching; insulting or obscene comments or gestures; display in the workplace of sexually suggestive objects or pictures; and other physical, verbal or visual conduct of a sexual nature.

Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this policy, harassment is verbal, written, ad visual, media, or physical conduct that denigrates or shows hostility or aversion toward an individual because of their race, color, religion, gender, sexual orientation, sexuality, national origin, age, disability, marital status, citizenship, genetic information or any other characteristic protected by law or that of their relatives, friends or associates, and that a) has the purpose or effect of creating an intimidating, hostile or offensive work environment; b) has the purpose or effect of unreasonably interfering with an individual's work performance; or c) otherwise adversely affects an individual's employment opportunities.

Harassing conduct includes 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 the employer's premises or circulated in the physical or virtual workplace, on the Institute’s time or using the Institute’s equipment via e-mail, phone (including voice messages), text messages, tweets, blogs, social networking sites or other means.

Policy Responsibility

This policy applies to all staff, faculty, and students who may be on a contract with CGI , whether related to conduct engaged in by fellow team members or someone not directly connected to CGI (e.g., an outside vendor, consultant or customer).

Conduct prohibited by these policies is unacceptable in the workplace, school environment, learning setting, webinars, discussion bords, emails and in any school or work-related. In addition, this includes but is not limited to social media, conversations, text messages, in person conversations, etc. If the action of discrimination occurred during or prior to working or enrolling at CGI, we will conduct an investigation and determine if actions need to be taken against the employee and/or student. The investigation will be conducted by a committee.

The Chief Executive Officer and the Chief Operating Officer of CGI will be responsible for the dissemination of this policy.

Directors, managers and supervisors are responsible for implementing equal employment practices within each department.

The HR department is responsible for overall compliance and will maintain personnel records in compliance with applicable laws and regulations.

Policy Procedure

Individuals who believe they have been the victims of conduct prohibited by this policy statement or who believe they have witnessed such conduct should discuss their concerns with their immediate supervisor or the Human Resources Department. This can be communicated via email, in person, over the phone, etc.

When possible, CGI encourages individuals who believe they are being subjected to such conduct to promptly advise the offender that their behavior is unwelcome and request that it be discontinued. Often this action alone will resolve the problem. CGI recognizes, however, that an individual may prefer to pursue the matter through complaint procedures.

CGI encourages the prompt reporting of complaints or concerns so that rapid and constructive action can be taken before relationships become irreparably strained. Therefore, although no fixed reporting period has been established, early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment.

Any reported allegations of harassment, discrimination or retaliation will be investigated promptly. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge.

Confidentiality will be maintained throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action. CGI will try to the greatest extent possible to keep the reporter’s anonymity protected.

Retaliation against an individual for reporting harassment or discrimination or for participating in an investigation of a claim of harassment or discrimination is a serious violation of this policy and, like harassment or discrimination itself, will be subject to disciplinary action. Acts of retaliation should be reported immediately and will be promptly investigated and addressed.

Misconduct constituting harassment, discrimination or retaliation will be dealt with appropriately.

If a party to a complaint does not agree with its resolution, that party may appeal to Human Resources Department or the CEO.

False and malicious complaints of harassment, discrimination or retaliation will be the subject of appropriate disciplinary action.

Forms

At this time, there are no forms associated with this policy.

Approvals/Revision History

Policy was revised on: July 20th, 2020

Policy was approved by: Amanda Harrison, Chief Operating Officer