“Retaliation” is intimidation, threats, coercion, or discrimination against any individual for the purpose of interfering with any right or privilege secured by Title IX and its implementing regulations, or because an individual has, in good faith, opposed any practices forbidden under this Policy or made a report or complaint, testified, assisted, or participated or refused to participate in any manner in an investigation, proceeding, or hearing under Title IX and Non-Title IX Sexual Harassment policies.

It is a violation of College Policy to engage in Retaliation. This includes action taken against a bystander who intervened to stop or attempted to stop Title IX and Non-Title IX Sexual Harassment. Retaliation may take many forms, and may include intimidating, threatening, coercing, or in any way discriminating against an individual because of the individual’s complaint or participation. Action is generally deemed retaliatory if it would deter a reasonable person in the same circumstances from opposing practices prohibited by this Policy.  

The College will take immediate and responsive action upon receiving any report of Retaliation and may pursue disciplinary action as appropriate.  

Reports or Formal Complaints of Retaliation based on a complaint of Title IX Sexual Harassment or participation in the Title IX Sexual Harassment Procedures may be made in the manner specified in the Title IX Sexual Harassment Procedures, and will be processed under those Procedures in the same manner as a report or Formal Complaint of Title IX Sexual Harassment. 

Reports of Retaliation based on a complaint of Non-Title IX sexual harassment or discrimination or participation in the related procedures may be made in the manner specified in the Non-Title IX Sexual Harassment Procedures, and will be processed under those Procedures in the same manner as a report of Non-Title IX Sexual Harassment procedures.  

The College retains discretion to consolidate a report or Formal Complaint of Retaliation with a report or Formal Complaint of Title IX and Non-Title IX Sexual Harassment, as the case may be, for investigation and/or adjudication purposes if the two complaints share a common nexus. 

Individuals who engage in Retaliation as defined by this Policy may be subject to disciplinary action that may include, but is not limited to, the sanctions listed in the Title IX and Non-Title IX Sexual Harassment procedures, as appropriate, up to and including dismissal or other separation from the College.