Harassment & Nondiscrimination Policy

STATEMENT OF NON-DISCRIMINATION

North American Trade Schools does not discriminate on the basis of sex, age, disability, race, color, national origin, ancestry, creed, religion or sexual orientation in its admissions to or treatment in its programs or activities, including advertising, training, placement and employment.

The School Director is the Compliance Officer of the Title IX – the Educational Amendments Act of 1972, which prohibits discrimination on the basis of sex in any education program or activity receiving federal financial assistance; The Americans with Disabilities Act of 1990; Section 504 of the Rehabilitation Act of 1973; The Age Act; and all other nondiscrimination statutes and regulations.

The Compliance Officer is the individual that ensures the school acts in compliance with laws and regulations regarding discrimination.

The School Director may be reached by phone at 1-800-638-5490 or mail at North American Trade Schools, 6901 Security Blvd., Ste. 16, Baltimore, MD 21244.

North American Trade Schools shall make reasonable accommodations for identified physical and mental impairments that constitute disabilities, consistent with the requirements of federal and state regulations and laws.

Harassment and discrimination are prohibited under North American Trade Schools policy. The school encourages employees, students and third parties who have been subject to harassment or discrimination to immediately report incidents to designated employees. North American Trade Schools will investigate complaints promptly and corrective action will be taken when allegations are substantiated.

The school assures that any investigation will be conducted in an impartial manner, including an impartial decision maker.

No retaliation or reprisals may be taken against an individual for filing a complaint or reporting discrimination under good faith or against any person providing truthful information as a witness in an investigation or related proceeding. Reprisal or retaliation is in itself unlawful discrimination and constitutes an independent violation of this policy.

HARASSMENT DEFINED

Harassment consists of verbal, written, graphic or physical conduct relating to a person’s race, color, national origin, ancestry, gender, age disability/handicap, sexual orientation, religion, creed or any other legally protected classification when such conduct:

  • Is sufficiently severe, persistent or pervasive that it affects an individual’s ability to participate in or benefit from an educational program or activity or to perform job functions; or it creates an intimidating, threatening or abusive educational or work environment.
  • Has the purpose or effect of substantially or unreasonably interfering with an individual’s academic or work performance.
  • Otherwise adversely affects an individual’s learning or employment opportunities

SEXUAL HARASSMENT

Sexual harassment consists of unwelcome sexual advances, requesting or demanding sexual favors, displaying or distributing sexually offensive materials and other inappropriate verbal, written, graphic or physical conduct of a sexual nature when:

  • Submission to such contact is made explicitly or implicitly a term or condition of a student’s academic status or an individual’s employment.
  • Submission to or rejection of such conduct is used as the basis for academic or employment decisions affecting the individual.
  • Such conduct deprives a student of educational aid, benefits, services and treatment.
  • Such conduct is sufficiently severe, persistent or pervasive that it has the purpose or effect of substantially interfering with a student’s school performance or employee’s job performance; or creating an intimidating, hostile or offensive educational or working environment.

HARASSMENT & NONDISCRININATION POLICY

This policy covers, without limitation, harassment by a student to another student, a student to an employee, an employee to a student, an employee to an employee, a third party to a student or employee, a student or employee to a third party, a male to male, a female to female, a male to female, a female to male.

The school’s Director of Education is designated as the Coordinator and The School Director is designated as the Compliance Officer to both serve as the Coordinator and compliance officer for purposes of Title IX of the Educational Amendments Act of 1972, the Americans with Disabilities Act of 1990, Section 504 of the Rehabilitation Act of 1973 and all other nondiscrimination statutes and regulations.

The Compliance Officer oversees the school’s policies and actions regarding harassment and discrimination. The Coordinator assists in communicating the policies and in taking action in the event of a complaint. Both the Compliance Officer and Coordinator accept and respond to complaints. Therefore, a complaint may be made with either individual. In the event that a complaint is against the Compliance Officer it should be made to the Coordinator if against the Coordinator than it should be made to the Compliance Officer.

REPORTING VIOLATIONS; FILING COMPLAINTS

A student, employee or third party who believes he or she has been subject to conduct violating the North American Trade Schools nondiscrimination and harassment policy is encouraged to promptly report the incident to the School Director. A student may report the incident to an administrator, department chairperson or instructor.

A school employee who has been notified or suspects a student has been subject to conduct which constitutes a violation this policy should notify the School Director of the incident immediately and no later than twenty four hours unless mitigating circumstances exist and justify a reasonable extension of the timeline. If it is not possible to contact the School Director in a timely manner or in the event the complaint is against the School Director, the Director of Education should be notified. The School Director or Director of Education may be reached by telephone at 1-800-638-5490 or mailed at North American Trade Schools, 6901 Security Blvd., Ste. 16, Baltimore, MD 21244.

All complaints by a student, employee or third party who asserts to have been subject to conduct violating this policy may be made in writing on the Form for Complaint of Discrimination or Harassment available in the school’s education office. If the incident was reported verbally the School Director shall inform the student, employee or third party of the right to file a complaint, the complaint procedure and provide the Form of Complaint of Discrimination or Harassment as well as assist the complainant to file an appropriate written complaint if he/she so desires. If the complainant does not choose to file a written complaint, verbal complaints of discrimination or harassment will also be accepted by NATS.

Complaints shall be filed within thirty calendar days of an incident or they may be deemed untimely. Filings occurring after thirty calendar days due to mitigating circumstances which justify a later filing shall be considered.

Even if no written complaint has been filed by or on behalf of a person who believes a violation of this policy has occurred, the School Director or Director of Education will conduct an informal investigation upon receiving a report of possible violation. The Director will change the victims academic or employment situation if changes are requested by the victim and reasonably available in order to prevent further violations during the period before completion of any informal and formal procedures.

If an informal investigation suggests that a violation of this policy has occurred, the Compliance Officer (School Director) shall review the available information and conduct such further investigation as he/she deems appropriate. If the School Director concludes that a violation of this policy exists, prompt and corrective action will be taken to ensure that conduct violating this policy ceases and will not reoccur. The School Director shall initiate what disciplinary procedures he/she deems appropriate.

RIGHTS DURING COMLAINT PROCEDURE

While conducting an investigation of a complaint regarding harassment or discrimination and until the conclusion of the procedure, the School Director/Compliance Officer shall be responsible to:

  • Permit an employee or student to be accompanied by a representative at any conference, meeting or hearing pertaining to the investigation.
  • Provide the opportunity for both the complainant and the accused to present witnesses and evidence.
  • Take necessary actions reasonably calculated to prevent any other violations of this policy prior to the completion of the complaint procedure.
  • Comply with the confidentiality requirements of this policy.
  • Notify the complainant and the accused of the status of the investigation and complaint procedure on a periodic basis and at appropriate stages of the procedure.
  • Ensure no retaliation or reprisals may be taken against an individual for filing a complaint or reporting discrimination under good faith or against any person providing truthful information as a witness in an investigation or related proceeding
  • Assure that any investigation is conducted in an impartial manner, including an impartial decision maker

INVESTIGATION

A formal investigation shall include individual interviews with the complainant, the accused and others with knowledge relative to the incident. The investigator also shall consider all information presented by the complainant and the accused. The investigator may evaluate any information and materials relevant to the investigation. The investigation shall be conducted and completed as thoroughly and speedily as possible.

The obligation of this investigation will not be negated by the fact that a criminal or insurance investigation is pending or has been concluded.

The School Director will report on the status of the investigation to the complainant and the accused within ten calendar days of the complaint file date and every five calendar days thereafter. The school will make every attempt to resolve the complaint within 15 calendar days of the filing. The school may extend the investigation when necessary to ensure equitable resolution.

Upon conclusion of the investigation, the school’s findings shall be provided to the complainant and the accused.

ADMINISTRATIVE ACTION

If the investigation results in a finding that the complainant is factual and constitutes a violation of this policy, the school shall take immediate corrective action calculated to ensure that such conduct ceases and does not reoccur.

Any student or employee found to have engaged in conduct violating this policy shall be subject to disciplinary action up to and including expulsion from school or termination of employment.

CONFIDENTIALITY

The confidentiality of all parties shall be maintained with respect to the filing, investigation and disposition of all complaints under this policy, consistent with the school’s investigative and legal obligations. The school shall not disclose the name of a complainant to an alleged violator/perpetrator/harasser if the complainant so requests, but the scope of a reasonable response to the complaint may be limited as a result.

While a complainant has the right to learn the outcome of his/her complaint, the school shall not disclose to a complainant any sanction or discipline imposed upon a student or employee to the extent such disclosure is prohibited by the Family Educational Rights and Privacy Act or other applicable laws, regulations, rules, constitutional requirements or orders. In rare cases, exceptions may apply.

APPEALS

If the complainant or accused is in disagreement with the outcome of his/her complaint, either party has the right to appeal the decision. The Compliance Officer or Coordinator must be notified that the complainant wishes to appeal a decision. The appeal will be heard by an Appeal Board comprised of the four school managers who have access to consult with the School President.

The appeal will be conducted in an impartial manner by impartial decision makers and the Appeal Board will make a decision within 15 calendar days of the filed appeal date.

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