Seminary Policies Board of Directors

Non-Discrimination Policy 

HORAPOLLO UNIVERSITY prohibits discrimination on the basis of race, color, religion, creed, sex, age, marital status, national origin, mental or physical disability, political belief or affiliation, veteran status, sexual orientation, gender identity and expression, and any other class of individuals protected from discrimination under state or federal law in any aspect of the access to, admission, or treatment of students in its programs and activities, or in employment and application for employment. Furthermore, Seminary policy includes prohibitions of harassment of students and employees, i.e., racial harassment, sexual harassment, and retaliation for filing complaints of discrimination. 

The Executive Director, or designee, is also the Title VI, Title IX, Section 504, and Americans with Disabilities Act Coordinator for the campus. This person will provide information about the Seminary’s obligations with respect to the provisions of nondiscrimination statutes, including information about the requirement to provide program accessibility for persons with disabilities. 

The Seminary is committed to compliance with Title VI and Title VII of the Civil Rights Act of 1964, Title VI of the Civil Rights Act of 1968, Title I and Title II of the Civil Rights Act of 1991, the Equal Pay Act of 1963, Executive Order 11246 (1965), Title IX of the Education Amendments of 1972 and its regulations found at 34 C.F.R. part 106, Sections 503 and 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act of 1990, the Vietnam-era Veterans Readjustment Act of 1974, the Age Discrimination Act of 1975, the Age Discrimination in Employment Act of 1967, the Family and Medical Leave Act of 1993, and with [Massachusetts General Laws, Chapters 151B, 151C, and Chapter 149, all as amended.] Inquiries regarding federal laws may also be directed to: Office for Civil Rights, U.S. Department of Education, J.W. McCormack Bldg., Room 701, 01-0061, Boston, MA 02109-4557; tel. (617) 223-9662; TTY: (617) 223-9695 and to U.S. Equal Employment Opportunity Commission, John F. Kennedy Federal Building, 475 Government Center, Boston, MA 02203; tel. (617) 565-3200 or 1-800-669-4000; TTY: (617) 565-3204 or 1-800-669-6820. Inquiries regarding state laws may be directed to: [Massachusetts Commission Against Discrimination, 436 Dwight Street, Suite 220, Springfield, MA 01103; tel. (413) 739-2145; TTY: (617) 994-9196.] 

Sexual Harassment Policy 

HORAPOLLO UNIVERSITY, Inc., does not tolerate sexual, racial, religious or ethnic harassment of any kind. In compliance with Title VII of the Federal Civil Rights Act of 1964, (42 United State Code Section 2000C et seq.), it is a violation for any employee or student, male or female, to sexually harass another student or employee. HORAPOLLO UNIVERSITY is committed to providing a workplace free from this unlawful conduct. Every faculty member, mentor, and administrator is responsible for promptly responding to, or reporting any complaint or suspected acts of sexual harassment. 

What is “sexual harassment?” 

Sexual harassment is a form of sex discrimination and means unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when; 

(1) Submission to that conduct is made either explicitly or implicitly a term or condition of employment and grade evaluation; or 
(2) Submission to or rejection of such conduct by an individual is used as a component of the basis for employment or grading decisions affecting that individual: or 
(3) The conduct has the purpose or effect of substantially interfering with an individual’s work or scholastic performance or creating an intimidating, hostile, or offensive working or scholastic environment. 

It is unlawful for an individual or organization to retaliate against an employee or student for filing a complaint of sexual harassment or for cooperating in an investigation of sexual harassment. 

Examples of sexual harassment include, but are not limited to the following, when such acts or behavior come with one of the above definitions: 

∙ Either explicitly or implicitly conditioning any term of employment or student progress on the provision of sexual favors; 
∙ Unwanted touching or grabbing a sexual part of an employee’s or student’s body; 
∙ Touching or grabbing any part of a student’s or employee’s body after that person has indicated, or it is known, that such physical contact was unwelcome; 
∙ Continuing to ask a student or employee to socialize on or off-duty when that person has indicated s/he is not interested; 
∙ Displaying or transmitting sexually suggestive pictures, objects, cartoons, or posters if it is known or should be known that the behavior is unwelcome; 
∙ Continuing to write sexually suggestive notes or letters if it is known or should be known that the person does not welcome such behavior; 
∙ Referring to or calling a person a sexualized name if it is known or should be known that the person does not welcome such behavior; 
∙ Regularly telling sexual jokes or using sexually vulgar or explicit language in the presence of a person if it is known or should be known that the person does not welcome such behavior; 
∙ Retaliation of any kind for having filed or supported a complaint of sexual harassment (e.g. ostracizing the person, pressuring the person to drop or not support the complaint, adversely altering the person’s duties or work environment, etc.); 
∙ Derogatory or provoking remarks about or relating to a person’s sex or sexual orientation; 
∙ Harassing acts or behavior directed against a person on the basis of his or her sex or sexual orientation; 
∙ Off-duty conduct which falls within the above definition and affects the work environment. 

In the event HORAPOLLO UNIVERSITY receives a complaint of sexual harassment, or otherwise has reason to believe that sexual harassment is occurring, we will take all necessary steps to ensure that the matter is promptly investigated and addressed. We are committed, as required by law, to take action if we learn of potential sexual harassment, even if the aggrieved student or employee does not wish to formally file a complaint. 

Every staff member is responsible for promptly responding to, or reporting, any complaint or suspected acts of sexual harassment. Staff members should report to: Candace Kant, Academic Dean (who is designated to receive such complaints or reports), or to Holli Emore, Executive Director. Failure by a staff member to appropriately report or address such sexual harassment complaints or suspected acts shall be considered to be in violation of this policy. 

Care will be taken to protect the identity of the person with the complaint and of the accused party or parties, except as may be reasonably necessary to successfully complete the investigation. It shall be a violation of this policy for an employee or student who learns of the investigation or complaint to take any retaliatory action which affects the working or study environment of any person involved in this investigation. 

If the allegation of sexual harassment is found to be credible, this organization will take appropriate corrective action. The organization will inform the complaining person and the accused person of the results of the investigation and what actions will be taken to ensure that the harassment will cease and that no retaliation will occur. Any employee, supervisor, or agent who has been found by the employer to have harassed another employee will be subject to sanctions appropriate to the circumstances, ranging from a verbal warning up to and including dismissal. 

If the allegation is not found to be credible, the person with the complaint and the accused person shall be so informed, with appropriate instruction provided to each, including the right of the complainant to contact any of the state or federal agencies identified in this policy notice. 

Any student or employee who believes that s/he has been the target of sexual harassment, or who believes s/he has been subjected to retaliation for having brought or supported a complaint of harassment, is encouraged to directly inform the offending person or persons that such conduct is offensive and must stop. If the person does not wish to communicate directly with the alleged harasser or harassers, or if direct communication has been ineffective, then the person with the complaint is encouraged to report the situation as soon as possible to one of the contacts given above, or to her or his supervisor at HORAPOLLO UNIVERSITY. It is helpful to an investigation if the student or employee keeps a diary of events and the names of people who witnessed or were told of the harassment, if possible 

If the complainant is dissatisfied with HORAPOLLO UNIVERSITY’s action, or is otherwise interested in doing so, s/he may file a complaint by writing or calling any of the following state or federal agencies: 

1. South Carolina Human Affairs Commission, 2611 Forest Drive, Post Office Box 4490, Columbia, S.C. 29240, 803-737-7800, Fax: 803-253-4191. Complaints should be filed within 300 days of the adverse action. 

2. Equal Employment Opportunity Commission, 1 Congress Street. Boston, MA 02114, tel: 
(617) 565-3200 (voice), (617) 565-3204 (TDL)). Complaints must be filed within 300 days of the adverse action. 

Each of these agencies can conduct impartial investigations, facilitate conciliation, and if it finds that there is probable cause or reasonable grounds to believe sexual harassment occurred, it may take the case to court. Although employees are encouraged to file their complaint of sexual harassment through this employer’s complaint procedure, an employee is not required to do so before filing a charge with these agencies. 

In addition, a complainant also has the right to hire a private attorney and to pursue a private legal action in state court within 3 or 6 years, depending on the type of claims raised. 

A copy of this policy will be provided to every employee, and extra copies will be available in the HORAPOLLO UNIVERSITY’s administrative office at P.O. Box 212804, Columbia, SC 29221, or at  

Reasonable accommodations will be provided for persons with disabilities who need assistance in filing or pursuing a complaint of harassment, upon advance request. 

Confidentiality Policy 

It is the policy of HORAPOLLO UNIVERSITY that board members, faculty, and staff of HORAPOLLO UNIVERSITY may not disclose, divulge, or make accessible confidential information belonging to, or obtained through their affiliation with HORAPOLLO UNIVERSITYto any person, including relatives, friends, and business and professional associates, other than to persons who have a legitimate need for such information and to whom HORAPOLLO UNIVERSITY has authorized disclosure. 

Board members, faculty and staff shall use confidential information solely for the purpose of performing services as a trustee or employee for HORAPOLLO UNIVERSITY. 

This policy is not intended to prevent disclosure where disclosure is required by law. 

Board members, faculty, and staff must exercise good judgment and care at all times to avoid unauthorized or improper disclosures of confidential information. Conversations in public places, such as restaurants, elevators, and public transportation, should be limited to matters that do not pertain to information of a sensitive or confidential nature. 

In addition, board members and employees should be sensitive to the risk of inadvertent disclosure and should for example, refrain from forwarding electronic media, and refrain from the use of speaker phones to discuss confidential information if the conversation could be heard by unauthorized persons. 

At the end of a board member’s term in office or upon the termination of an employee’s, volunteer’s or contractor’s relationship with HORAPOLLO UNIVERSITY, he or she shall return, at the request of HORAPOLLO UNIVERSITY, all documents, papers, and other materials, regardless of medium, which may contain or be derived from confidential information, in his or her possession. 

Acceptable Use of HORAPOLLO UNIVERSITY Electronic Communications Systems and Services 

  1. HORAPOLLO UNIVERSITY’s electronic communications systems and services are essential resources provided to the Seminary community in a manner consistent with the Seminary’s official recognition of the formal role that the community plays in fulfilling ’’s mission of providing quality higher education and practical training in Pagan ministry. 
  1. To this end, the HORAPOLLO UNIVERSITY uses, supports and provides electronic communications systems and services for telecommunications, mail, education, and research conducted by faculty, students, administrators, and officially recognized partners and supporters, whether acting individually or collectively, in their respective roles as a part of the Seminary community on behalf of HORAPOLLO UNIVERSITY. 
  1. The Seminary further recognizes that such a diverse community of faculty, students, administrators, and officially recognized partners and supporters have a clear need to freely and creatively utilize these electronic communications systems and services in the conduct of their business with and on behalf of the Seminary, and that these users additionally have the right to expect fair and equitable access to these resources in an atmosphere of mutual respect, professionalism and academic excellence. 
  1. In order to ensure such fair and equal access to and use of these essential resources by the entire Seminary community, and specifically without compromise to the exercise of academic freedom, all users are prohibited from utilizing HORAPOLLO UNIVERSITY’s electronic communications systems and services for any purposes not specifically related to the fulfillment of their individual responsibilities related to conducting the Seminary’s business. 
  1. In this regard, users are specifically prohibited from utilizing HORAPOLLO UNIVERSITY’s electronic communications systems and services not only for exclusively personal purposes but also for any unlawful, unethical or unprofessional purpose or activity. Examples of prohibited use include but are not limited to: 
  1. –Solicitation or commercial activities unrelated to the mission of the Seminary. This includes soliciting, promoting, selling, marketing or advertising products or services (e.g. consulting services) or other revenue-generating private business operations for personal financial benefit. Disputes regarding a commercial activity’s relatedness to mission of the Seminary shall be conclusively resolved by the Executive Director or designee. 
  1. –Transmission of threats, harassment or defamation. 
  1. –Download or distribution of material or programs that could be deemed harmful to the Seminary’s electronic communications systems or services. 
  1. –Violations of any state or federal laws, or any applicable Seminary policy or regulation, including but not limited to, Non-Discrimination Policy, Sexual Harassment Policy, Information Policy, Academic Honesty and Student Conduct, and Student Confidentiality. 
  1. –Violation of software licensing agreements. 
  1. –Intentional damage to equipment, software or data. 
  1. When there is reason to believe that a violation of this policy has occurred, an investigation shall be conducted under the guidance of the Executive Director or designee. Investigating officials shall examine charges of violations with due respect for individual privacy, the security of other users and the rights of due process, and are encouraged to proactively consider, in consultation with the Seminary’s executive and administrative leadership, the option of the Seminary’s consultation with legal counsel. 
  1. User access to electronic communications systems and services may be temporarily suspended while an investigation is being conducted, with prior written notification by the Executive Director or designee to the individual(s) whose access is being affected, as well as to the appropriate dean, chair or other appropriate Seminary official. 
  1. The Executive Director or designee, after consultation with the Seminary’s executive and administrative leadership, shall have the sole authority to make a final decision on what, if any, action on the part of the Seminary will be taken. 
  1. Violations of Seminary policy may result in formal sanctions, including but not limited to, limitation or revocation of access rights and/or reimbursement to the Seminary for any expense related to the violation, including costs associated with the detection and investigation of the violation, as well as from the violation itself. Violation of applicable statutes may result in criminal prosecution. 
  1. Regardless of whether the investigation’s findings warrant Seminary action, an explanation of the causal events shall be reported, in writing, to the appropriate dean, chair or other appropriate Seminary official , along with a summary of whatever course of action is decided upon by the Executive Director or designee. This report will also include what final disposition will be taken in regard to reinstatement or modification to, or revocation of, access to the Seminary’s electronic communications systems and services by the individual(s) involved in the investigation. 

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