Title IX Policy
233 Mill Street Waterbury, CT
203-753-7910

Title IX Policy

Industrial Management and Training Institute’s Title IX Policy

Title IX Coordinator:
Janice Shannon - 203-753-7910, jvshannon@imti.edu , 233 Mill Street, Waterbury, CT. 06706.


SEXUAL MISCONDUCT AND TITLE IX
Both the Department of Education and the United States Supreme Court have found that sexual harassment is a form of sexual discrimination prohibited by Title IX. Industrial Management and Training Institute recognizes that such behavior undermines the academic and professional excellence that Industrial Management and Training Institute provides to and expects from the members of its community. As set forth below, Industrial Management and Training Institute prohibits harassment and discrimination that unreasonably interferes with an individual’s performance or that creates a hostile environment, whether such conduct happens on or off campus. To that end, and in accordance with federal and state law, Industrial Management and Training Institute has implemented the following policies. For more information on these policies, or to report any of the conduct prohibited below, please contact Industrial Management and Training Institute’s Title IX Coordinator: Kim Nguyen - 203-753-7910, Kimng@imti.edu, 233 Mill Street, Waterbury, CT. 06706.

NONDISCRIMINATION POLICY :
Industrial Management and Training Institute is an affirmative action/equal opportunity educator and employer, fully committed to the goal of providing equal opportunity and full participation in its educational programs, activities, and employment without discrimination because of race, color, religious creed, sex, age, national origin, political affiliation, marital status, veteran status, sexual orientation, physical disability, learning disability or mental retardation, past or present history of mental disorder, or any other consideration not directly and substantively related to effective performance. This policy implements Federal and State laws, regulations, and executive orders. All acts of discrimination, sexual violence, and harassment should be reported to Kim Nguyen - 203-753-7910, Kimng@imti.edu, 233 Mill Street, Waterbury, CT. 06706 All sexual harassment claims should be reported per our Sexual Harassment Policy on the following page. Reports describing conduct that is inconsistent with our policies will be promptly and thoroughly investigated. Students have the right to file a criminal complaint while filing a complaint on any of the above acts. Complaints about violations of these policies will be handled discreetly, with facts made available to those who need to know to investigate and resolve the matter.

HARASSMENT/INTOLERANCE POLICY :
The staff, faculty, student body, and administration of Industrial Management and Training Institute form a multicultural community of individuals from diverse race, ethnic, and class backgrounds, national origins, religious and political beliefs, physical abilities, and sexual orientations. We believe that activities, programs, and everyday interactions are enriched by acceptance of one another in an environment of positive engagement and mutual respect. Acts of racism or harassment directed against individuals or specific groups of individuals will not be tolerated. Harassment is conduct that is physically threatening, harmful, or humiliating. It may be based upon an individual’s race, color, religion, national origin, creed, service in the uniformed services (as defined in state and federal law), veteran status, sex, age, political ideas, marital or family status, pregnancy, physical or mental disability, genetic information, gender identity, gender expression, or sexual orientation. Harassing conduct may take various forms, including, name-calling, bullying, cyberbullying, graphic or written statements (including the use of cell phones or the Internet), or other conduct. Harassment does not have to include intent to harm, be directed at a specific target, or involve repeated incidents. Bullying is unwanted, aggressive behavior that involves a real or perceived power imbalance. The behavior is repeated, or has the potential to be repeated, over time. Bullying can take many forms: texting, intimidation, and even cyber bullying just to name a few. Bullying can impact a person's self-esteem, self-worth and cause devastating emotional effects no matter what the age. Cyberbullying is bullying that takes place using electronic technology. Electronic technology includes devices and equipment such as cell phones, computers, and tablets, as well as communication tools including social media sites, texts, etc. Examples of cyberbullying include text messages or emails, rumors sent by email or posted on social networking sites, and embarrassing pictures, videos, website, or fake profiles. The Administration of Industrial Management and Training Institute is committed to provide educational opportunities to all who seek and can benefit from them. They recognize that an important part of providing opportunity is creating a welcoming environment in which all people can work and study together, regardless of their differences. Industrial Management and Training Institute recognizes that it has an obligation to provide programs that promote pluralism and diversity and encourage the educational community to respect and appreciate the value and dignity of every person and his or her right to an atmosphere not only free of harassment, bullying, cyberbullying, hostility, and violence, but supportive of individual academic, personal, social, and professional growth. If it is determined that inappropriate conduct has been committed by a student, Industrial Management and Training Institute will take such action as it deems appropriate under the circumstances. Such actions may range from counseling to termination to contacting local law enforcement. It may include other forms of disciplinary action as Industrial Management and Training Institute deems appropriate in its discretion under the circumstances.

SEXUAL HARASSMENT POLICY :
It is the policy of Industrial Management and Training Institute that no member of the Industrial Management and Training Institute community—students, faculty, administrators, staff, vendors, contractors, or third parties—may sexually harass any other member of the community. “Sexual harassment” is any unwelcome conduct of a sexual nature, which includes, but is not limited to, unwelcome sexual advances; sexual acts that are non-consensual or perpetrated against a person who is incapacitated; the use or threatened use of sexual favors as a basis for academic or employment decisions; conduct that creates a hostile, intimidating, or offensive academic or working environment; conduct of a sexual nature that has the effect of unreasonably interfering with an individual’s work performance; and other verbal, nonverbal, or physical conduct of a sexual nature that is sufficiently severe, persistent, or pervasive to limit a person’s ability to participate in or benefit from an educational program or activity. “Incapacitation” means the physical and/or mental inability to make informed, rational judgments. Where an intoxicant is involved, incapacitation is a state of intoxication where the intoxicant consumed impairs a person's decision-making capacity, awareness of consequences, and ability to make fully informed judgments. “Consent” means words or actions that show an active, knowing, and voluntary agreement to engage in mutually agreed-upon sexual activity. Consent cannot be gained by force, by coercion, by ignoring or acting despite the objections of another, or by taking advantage of the incapacitation of another, where the actor knows or reasonably should have known of such incapacitation. Intoxication is not an excuse for failure to obtain consent. Consent is also lacking when the activity in question exceeds the scope of consent previously given. Complaints of sexual harassment should be directed to Kim Nguyen - 203-753-7910, Kimng@imti.edu, 233 Mill Street, Waterbury, CT. 06706

SEXUAL VIOLENCE STATEMENT :
Sexual violence is a prohibited form of sexual harassment. Sexual violence includes physical sexual acts perpetrated against a person’s will or where a person is incapable of giving consent due to use of drugs and/or alcohol or to an intellectual or other disability. Some examples of sexual violence may include rape, sexual assault, sexual battery, sexual coercion, dating violence, and domestic violence. TITLE IX STATEMENT It is the policy of Industrial Management and Training Institute to comply with Title IX of the Education Amendments of 1972, which prohibits discrimination (including sexual harassment and sexual violence) based on sex (gender) in our educational programs and activities. Title IX also prohibits retaliation for asserting or otherwise participating in claims of sex discrimination. Any inquiries concerning Title IX should be directed in writing to Industrial Management and Training Institute’s designated Title IX Coordinator, Kim Nguyen - 203-753-7910, Kimng@imti.edu, 233 Mill Street, Waterbury, CT. 06706.

GRIEVANCE PROCEDURE FOR DISCRIMINATION, HARASSMENT, SEXUAL HARASSMENT AND TITLE IX :
Investigation and Confidentiality: Industrial Management and Training Institute promptly and thoroughly investigates and resolves complaints alleging sex discrimination, sexual harassment, and sexual violence, including sexual assault, stalking, dating violence, and domestic violence.

Any student, faculty, or staff member with questions or concerns about the applicable policies or who believes that he or she has been the victim of sex discrimination, sexual harassment, or sexual violence is encouraged to contact Industrial Management and Training Institute’s Title IX Coordinator.

Any person who believes that he or she is a victim of sexual harassment or violence is encouraged to make a report to both the police and the Title IX Coordinator for assistance and investigation. The police investigate criminal violations, while the Title IX coordinator will investigate violations of these policies. Reports describing conduct that is inconsistent with these policies will be promptly and thoroughly investigated, using a more-likely-than-not standard, within 60 days if possible. Knowingly furnishing false information to the School is a violation of this policy. Anyone who knowingly files a false report, knowingly pursues a false complaint under this policy, or otherwise knowingly reports, complains, or assists with a false complaint of unlawful harassment, violates this policy and is subject to investigation and discipline. Note that the failure to adequately substantiate a good-faith claim is not the same as knowingly making a false accusation.

Industrial Management and Training Institute encourages victims of sexual violence to talk to somebody about what happened – so victims can get the support they need, and so the School can respond appropriately. Complaints about violations of these policies will be handled discreetly. If a victim discloses an incident, but wishes to maintain confidentiality or requests that no investigation into an incident be conducted or disciplinary action taken, Industrial Management and Training Institute’s Title IX Coordinator will weigh that request against the School’s obligation to provide a safe, non-discriminatory environment for all students, including the victim. A request for confidentiality may limit the School’s ability to investigate a matter. In that instance, the School may take steps to limit the effects of the alleged conduct without initiating formal action against the alleged perpetrator. Although rare, there are times when the School may not be able to honor a victim’s request for confidentiality to provide a safe, non-discriminatory environment for all students. If the School determines that it cannot maintain a victim’s confidentiality, the School will inform the victim prior to starting an investigation and will, to the extent possible, only share information with people responsible for handling the School’s response. The Title IX Coordinator and/or designees will protect the privacy of all parties, including the complainant, consistent with the Academy’s obligation to provide a safe environment for members of the community. Student-victims may request information about confidential support organizations or crisis hotlines from the Title IX Coordinator.

The Title IX Coordinator may also take interim administrative actions to alleviate any threat of imminent harm to persons or property and to provide support services to the complainant. Interim administrative action is not a sanction. Instead, it is an effort to protect the safety and well-being of the victim, the accused student, third parties, or property. Actions may include, but are not limited to, no contact instructions, limited access to campus, or interim suspension.

Retaliation:
Industrial Management and Training Institute prohibits retaliation against anyone for registering a complaint pursuant to these policies, assisting another in making a complaint, or participating in an investigation under the policies. Anyone experiencing any conduct that he or she believes to be retaliatory should immediately report it in writing to the Title IX Coordinator.

Resolution :
If a complaint of discrimination, harassment, or sexual harassment is found to be substantiated by preponderance of the evidence, appropriate corrective action will follow, up to and including separation of the offending party from Industrial Management and Training Institute. Both the victim and the accused will have equal rights to participate in the investigation and resolution process, and both parties will receive simultaneous written notice of the outcome of the complaint. At no point will the School employ informal mediation to resolve complaints of sexual harassment or violence. All adjudication procedures will be conducted by Kim Nguyen, 203-753-7910, Kimng@imti.edu 233 Mill Street, Waterbury, CT. 06706, or her designate.

Reporting:
All members of the Industrial Management and Training Institute community are responsible for creating a working, learning, and living environment that is free of discrimination and harassment, including sexual harassment. To this end, Industrial Management and Training Institute strongly encourages teachers, staff, and students to report incidents of discrimination, harassment, and sexual misconduct to the Title IX Coordinator. Employees (except those empowered by law to maintain confidentiality) who receive information about or witness sexual violence, must report incidents of sexual violence to either local law enforcement or the Title IX Coordinator. These offices will ensure that victims receive information about medical treatment and support services available to them, as well work to ensure the safety of the entire campus community. Vendors, Contractors and Third Parties Industrial Management and Training Institute’s policies on discrimination, harassment, and sexual harassment apply to the conduct of vendors, contractors and third parties. If a member of the Industrial Management and Training Institute community believes that he or she has been subjected to conduct by a vendor, contractor or third party that violates these policies, the community member should contact the Title IX Coordinator. Industrial Management and Training Institute will respond as appropriate, given the nature of its relationship to the vendor, contractor or third party.
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