I. Non-Discrimination Statement and Policy
Rectory School complies with all applicable civil rights laws and does not discriminate on the basis of any protected characteristics in any of its educational programs or activities, including employment. Protected characteristics (or protected classes) include race, color, religion, age, sex, sexual orientation, marital status, national origin, alienage, disability, pregnancy, veteran status, gender identity or expression, or any other basis prohibited by state or federal law. The School is specifically required by Title IX and other applicable federal and state laws not to discriminate in such a manner.
It is also the express policy of Rectory School to prohibit any form of discrimination or discriminatory harassment whether by students, School employees or third parties subject to the control of Rectory School. Students, employees and third parties are expected to adhere to a standard of conduct that is respectful of the rights of all members of the school community.
Students and employees are entitled to an employment and educational environment that is free of discrimination and discriminatory harassment. This policy is intended to provide notice of compliance with federal and state civil rights laws to all employees, students, parents/guardians, applicants for admission and employment, and other interested persons, as appropriate. Rectory School requires all persons, agencies, vendors, contractors, and other persons and organizations doing business with or performing services for the school to adhere to this non-discrimination policy and to all applicable federal and state laws pertaining to school operations.
For an employee, discrimination is defined as when an employer refuses to hire, disciplines or discharges any individual, or otherwise discriminates against an individual with respect to his or her compensation, terms, conditions, or privileges of employment on the basis of the individual’s actual or perceived membership in a protected class. For students and others, discrimination may also occur when a person, is denied participation in, or the benefits of, a program or activity of the School because of their actual or perceived membership in a protected class.
Protected class harassment is a form of discrimination that is prohibited by law and by this policy. Harassment in this context is defined as any unwelcome conduct on the basis of actual or perceived membership in a protected class that creates a hostile environment such that the conduct unreasonably interferes with, limits or denies an individual’s educational or employment access, benefits or opportunities. The discriminatory effect can result from conduct that is verbal, written, graphic or physical conduct that is severe or pervasive and objectively offensive. Sexual violence is a form of sexual harassment. For the purposes of this policy, sexual violence refers to physical acts that are sexual in nature, perpetrated against a person’s will or where a person is incapable of giving consent due to the victim’s use of drugs or alcohol.
Any individual who engages in a protected activity under this policy is protected from reprisal or retaliation, which is defined as any materially adverse action taken because of a person’s participation in such protected activity. Protected activity includes reporting an incident that may be a violation under this policy, participating in the grievance process, supporting a person who participates in the grievance process as described in the School’s policies or assisting in providing information relevant to an investigation under this policy.
The Rectory School provides for the prompt and equitable resolution of any complaint alleging discrimination or unlawful harassment. When harassment rises to the level of creating a hostile environment, the School may take disciplinary action or other corrective action as appropriate. Students who engage in discrimination/harassment may be subject to dismissal; employees who engage in discrimination/harassment may be subject to discharge from employment. In addition, anyone who engages in retaliation as defined under this policy is also subject to other interventions and corrective action as determined by the School.
II. Designation of Responsible Employee(s)
Lisa Garvey is the individual appointed by Rectory School to serve as its Responsible Employee. The Responsible Employee oversees implementation of this policy and coordinates efforts to comply with and carry out the School’s responsibilities under this policy, including the investigation of any complaint about which the School has actual notice. The Responsible Employee may coordinate and designate other school employees to assist in carrying out these responsibilities, including assistance in investigating and resolving complaints and implementing corrective measures to stop, remediate and prevent discrimination, harassment and retaliation prohibited under this policy.
The Responsible Employee (or their designee) shall make specific and continuing steps to notify students, parents/guardians, employees, applicants for admission and employment and the public of where and how to initiate the grievance (complaint) process described in this policy. The Responsible Employee will also ensure adequate non-discrimination policies are in place, recommend new procedures or modifications to procedures and monitor the implementation of this policy.
Anyone with any questions about Rectory School’s non-discrimination policies, or who is alleging a violation of this policy should contact the Responsible Employee:
Lisa Garvey, Accounting and HR Manager
P.O. Box 68
Pomfret, CT 06258
860-928-9025 ext. 320
In the alternative, allegations of violations of this policy may also be made to any of the following individuals:
Fred Williams, Headmaster
Tonya Rayment, CFO
For more detailed information about how to file a complaint and the grievance procedures, please refer to the Non-Discrimination Grievance Procedures in Section III of this Manual.
In addition to filing a complaint internally with the Rectory School in accordance with this policy, individuals may also make inquiries and/or file a complaint with the following agency:
Office of Diversity, Inclusion & Civil Rights (ODICR)
U.S. Small Business Administration
409 Third Street, SW, Suite 6400
Washington, DC 20416,
Any student, parent/guardian or employee may also file a complaint with the Connecticut Commission on Human Rights and Opportunities:
Connecticut Commission on Human Rights and Opportunities
450 Columbus Blvd.
Hartford, CT 06103-1835
Employees may also file a complaint regarding employment discrimination with the Equal Employment Opportunity Commission:
Equal Employment Opportunity Commission, Boston Area Office
John F. Kennedy Federal Building
475 Government Center
Boston, MA 02203
Mandatory Reporting of Child Abuse and Neglect
Matters involving the possible abuse of a minor must be immediately reported to the School and to appropriate outside officials. All school employees are considered mandated reporters. Mandated reporters are required by law to report suspicions of abuse or neglect if, in the ordinary course of their employment, they have reasonable cause to suspect or believe that a child has been abused or neglected or placed at imminent risk of serious harm, or if a student has been the victim of a sexual assault by a school employee. A mandated reporter must report, or cause a report to be made, as soon as practicable, but not later than twelve (12) hours to the Connecticut Department of Children and Families (DCF) or local law enforcement. Any school employee with a concern related to possible abuse or neglect of a minor must report such concern immediately in accordance with the School’s Mandated Reporting Policy contained in Rectory School Employee Handbook
III. NON-DISCRIMINATION GRIEVANCE PROCEDURES
A. Any individual who has experienced discrimination or harassment on the basis of a protected class, or believes that a student or employee has been discriminated against or harassed in violation of this policy should report their concern promptly to the Responsible Employee at the contact information in Section I of this Manual. Any person (including students) who need assistance in preparing a written complaint, are encouraged to discuss the situation with the Responsible Employee.
B. Students who feel they have been discriminated against or harassed may also report their concern to any of the following:
Fred Williams, Headmaster
Melissa Zahansky, Chair of the Diversity, Equity, & Inclusion
C. Employees who feel they have been discriminated against or harassed may also report their concern to either of the following:
Fred Williams, Headmaster
Tonya Rayment, CFO
D. Timely reporting of complaints facilitates the investigation and resolution of such complaints. For this reason, complaints should be filed within thirty (30) calendar days of the alleged incident.
E. The complaint should be in writing and include the following information:
- Name of the reporter;
- Name of the alleged target/victim;
- Date of the complaint;
- Date(s) of the alleged harassment/discrimination;
- Name(s) of the person alleged to have engaged in harassment/discrimination;
- Location where incident occurred;
- Names of any witness(es) or persons with relevant information;
- Statement or summary of what occurred;
- Proposed remedy (if applicable);
- Other relevant information.
Responding to a Complaint/Investigations
A. Any complaints that are made to anyone other than the Responsible Employee should be forwarded immediately to the Responsible Employee. The Responsible Employee may inform the Head of School, CFO, Division Head or other appropriate administrators depending on the nature of the complaint and persons involved (e.g., employees, students, etc.). If the complaint involves the Head of School, notice should be given to the President of the Board of Directors for The Rectory School.
B. If the allegation involves a minor child or student, the person receiving the complaint should consider whether a child abuse report should be completed in accordance with the School's Policy on Mandated Reporting of Child Abuse.
D. Rectory School will conduct an adequate, reliable and impartial investigation. A complaint may be investigated by the Responsible Employee or his/her designee. Any complaint about an employee who holds a supervisory position shall be investigated by a person who is not subject to that supervisor’s authority. Any complaint about the Responsible Employee should be submitted to the Chief Financial Officer or Head of School; and any complaint about the Head of School should be submitted to the President of the Board of Directors.
E. Any investigation shall be conducted discreetly, maintaining confidentiality insofar as possible while still conducting an effective and thorough investigation.
F. The Responsible Employee may pursue a prompt and equitable informal resolution of the complaint with the express agreement of the parties involved. Any party to the complaint may decide to end an informal resolution and pursue a formal process at any point. Even if the parties wish to engage in informal resolution, the Responsible Employee must consider if such process is appropriate in light of the circumstances and all applicable policies and laws. There may be circumstances where even with the consent of the parties, an informal resolution is not appropriate or recommended.
G. In investigating a complaint, the Responsible Employee or designee shall:
a) offer to meet with the reporting individual (complainant) to discuss the nature of the complaint;
b) provide the individual against whom the complaint is made (respondent) an opportunity to be heard as part of the investigation. The complainant shall not be required to attend meetings with the respondent but may choose to do so as part of the resolution process.
c) provide the complainant and respondent with a copy of the School’s Non-Discrimination Policy and grievance procedures.
d) give the complainant and respondent an opportunity to suggest witnesses and/or submit materials they believe are relevant to the complaint.
e) investigate the factual basis for the complaint, including conducting interviews with individuals with relevant information and reviewing relevant materials. The investigation must be prompt, adequate, reliable and impartial.
f) maintain the privacy of all parties to the extent practicable and advise the parties, including any witnesses, of the confidential nature of the investigation.
g) advise the parties and any participating witnesses that retaliation is strictly prohibited.
h) maintain a written record of the investigation process.
i) consider whether any interim remedial measures may be appropriate to reduce the risk of further discrimination or harassment while the investigation is pending. Examples of such interim measures include, but are not limited to, no contact orders, changing schedules or classes, etc.
j) consult with the Head of School, CFO or other appropriate administrators as may be needed concerning the investigation, conclusions and/or any remedial and/or disciplinary measures.
k) complete the investigation promptly. Typically, investigations should be completed within 30 business days of receiving a complaint, if practicable. The timeline may be extended at the discretion of the Responsible Employee or designee for good cause.
l) determine whether, based on the factual conclusions of the investigation, alleged discrimination or harassment occurred, including whether the conduct created a hostile environment.
H. If the Responsible Employee or designee determines that discrimination or harassment occurred, he/she shall, in consultation with the Head of School and/or other appropriate School administrators:
i) inform both the complainant and respondent in writing of the results of the investigation and its resolution (to the extent permitted in light of applicable law and confidentiality requirements). If the complainant is a witness and not a party, information shared with the complainant may be limited.
ii) take steps that are reasonably calculated to end the discrimination, take corrective and/or disciplinary action aimed at preventing the recurrence of the harassment or discrimination.
I. If the complainant or respondent is dissatisfied with the resolution, either may make an appeal in writing to the Head of School within 10 business days after receiving notice of the resolution. The Head of School or his/her designee shall review the investigation report and other relevant materials collected as part of the investigation, along with the recommended disposition of the complaint. The Head of School or designee may conduct further investigation if deemed appropriate at his/her discretion. The Head of School or designee shall respond to the complainant in writing within fifteen (15) business days following the receipt of the written request for review.
J. Retaliation against any individual for protected activity pursuant to the School’s policy and procedures is strictly prohibited. The School will take actions necessary to prevent retaliation as a result of filing a complaint.