Equal Opportunity, Nondiscrimination, Anti-Harassment, and Non-Retaliation Policy

Policy Summary

The university is an Equal Opportunity employer and institution committed to maintaining a nondiscriminatory, harassment-free, diverse work and education environment. The university does not unlawfully discriminate on the basis of protected characteristics or on any other basis prohibited by applicable law in any of its programs, activities, or employment practices. 

Related Regulations

This policy affirms the university's commitment to and compliance with Title IX of the Education Amendments of 1972, Title VI of the Civil Rights Act of 1964, Title VII of the Civil Rights Act of 1964, as amended, Section 504 of the Rehabilitation Act of 1973, the District of Columbia Human Rights Act, and other applicable laws relating the equal opportunity and nondiscrimination.

Who is Governed by this Policy 

• Students
• Staff
• Faculty
• Those participating in university programs or activities

Policy

The George Washington University does not unlawfully discriminate against any person on the basis of protected characteristics or any other basis prohibited by federal law, the District of Columbia Human Rights Act, or other applicable laws. This policy covers all programs, services, policies, activities, and procedures of the university, including participation in education programs and employment.

Protected characteristics covered by this policy are those personal traits, characteristics, and/or beliefs that are defined by applicable law as protected from unlawful discrimination and/or harassment. They include age, color, disability, gender, gender identity or expression, genetic information, marital or familial status, national origin, pregnancy, race, religion, sex, sexual orientation, veteran status, and/or other characteristics protected by applicable law. Notwithstanding the above, this policy does not address discrimination on the basis of sex or gender-related conduct covered by the university’s Title IX Sexual Harassment and Related Conduct Policy.

Unlawful discrimination is adverse treatment of an individual based on a protected characteristic, rather than individual merit. Examples of conduct that can constitute unlawful discrimination if based on an individual’s protected characteristic include but are not limited to:

• Singling out or targeting an individual for different or less favorable treatment (e.g., more severe discipline, denial of promotion) because of their protected characteristic
• Failing or refusing to hire an individual because of their protected characteristic
• Failing or refusing to allow an individual to participate in an activity, program, or organization based on their protected characteristic (e.g., student/faculty/staff organizations, university groups or associations, university committees, etc.)
• Terminating an individual from employment or an educational program based on their protected characteristic.

Discriminatory harassment is any unwelcome conduct based on a protected characteristic where such conduct creates a hostile environment or where enduring such conduct becomes a condition of: continued employment; continued access to an educational program or activity; or an academic or employment decision about an employee or student. A hostile environment exists when the conduct is sufficiently severe, persistent, or pervasive that it unreasonably interferes with, limits, or deprives an individual from participating in or benefiting from the university’s educational, employment, co-curricular, and/or campus-residential experience when viewed through both a subjective and objective standard.  This means that an aggrieved party’s subjective perception that certain conduct violates this policy must be objectively reasonable to constitute discriminatory harassment.

A hostile environment can be created by persistent or pervasive conduct or by a single or isolated incident, if sufficiently severe. The more severe the conduct, the less need there is to show a repetitive series of incidents to prove a hostile environment. Discriminatory harassment:

• May be blatant and intentional and involve an overt action, a threat or reprisal, or may be subtle and indirect, with a coercive aspect that is unstated.
• Does not have to include intent to harm or be directed at a specific target.
• May be committed by anyone, regardless of gender, age, position, or authority.
• May occur in any context, although the context often involves a power differential between two persons, which may be due to differences in social, educational, or employment relationships.
• May occur in the classroom, in the workplace, in residential settings, or in any other context or setting connected to the university or related activities.
• May be committed by or against an individual, organization, or group.
• May occur in digital environments including but not limited to social media, websites, educational platforms, and electronic mail.
• May be a one-time event or may be part of a pattern of behavior.
• May be committed in the presence of others or when the parties are alone.
• May affect not only the person to whom it is directed but also third parties who witness or observe harassment.

Nothing in this policy limits academic freedom, guaranteed by the Faculty Code and the Statement on Student Rights and Responsibilities, which is a pre-eminent value of the university. Accordingly, in an academic setting, expression that is reasonably designed or reasonably intended to contribute to academic inquiry, education or debate on issues of public concern does not violate this policy.  This policy shall also be interpreted in a manner consistent with the principles of professional responsibility as set forth in the Faculty Code and related university policies and guidelines.

Reporting Allegations of Discrimination and/or Harassment

Individuals who believe they have been discriminated against or harassed based on protected characteristics covered by this policy may make reports as follows:

• Concerns about the conduct of a student or student organization under this policy can be brought to Conflict Education & Student Accountability.

Conflict Education & Student Accountability

University Student Center, Suite 204

Phone: 202-994-6757

Email: cesagwu [dot] edu (cesa[at]gwu[dot]edu)   

Allegations of violations of this policy by a student or student organization will follow the processes outlined in the Code of Student Conduct.

• Concerns about the conduct of a non-faculty staff member under this policy can be brought to the Equal Employment Opportunity and Access office.

Equal Employment Opportunity and Access (EEOA)

2013 H Street, NW, Suite 204

Washington, D.C. 20052

Phone: (202) 994-9656

Email: eeogwu [dot] edu (eeo[at]gwu[dot]edu)

Allegations of violations of this policy will be reviewed and/or investigated by EEOA or designee.

• Concerns about the conduct of a faculty member under this policy can be brought to the Office of the Provost, Office for Faculty Affairs.

Office of the Vice Provost for Faculty Affairs

1918 F Street, NW

Washington, DC 20052

Phone: (202) 994-5884

Email: facultyaffairsgwu [dot] edu (facultyaffairs[at]gwu[dot]edu)

Allegations of violations of this policy will be reviewed and/or investigated by the Office for Faculty Affairs or designee. Concerns reported by students will follow the processes outlined in the Student Discrimination Report Procedures. Nothing in this policy shall be construed to revoke any right of a faculty member to file a grievance under the Faculty Code.

• Concerns of discrimination and harassment under this policy may also be reported through the university’s ethics and compliance hotline, EthicsPoint.Reports may be made on an anonymous basis. The Office of Ethics, Compliance, and Risk will review hotline reports concerning discrimination and harassment under this policy and refer the report to the appropriate office(s) for further consideration as appropriate.

Reports may be made online or by phone: 

EthicsPoint

Phone: 888-508-5275

Reporting Allegations of Title IX Sexual Harassment and Related Conduct

Individuals who believe they have been discriminated against or harassed based on conduct prohibited by the university’s Title IX Sexual Harassment and Related Conduct Policy may make reports to the university’s Title IX Office.

Title IX Office

812 20th Street, NW

Building YY

Washington, DC 20052,

Phone: (202) 994-7434

Email: titleixgwu [dot] edu (titleix[at]gwu[dot]edu)

Online Reporting Form

External Reporting Options

Inquiries concerning this policy and federal and local laws and regulations concerning discrimination in education and employment programs and activities may be directed to the university’s Office of Equal Employment Opportunity and Access (contact information above) or the Office of the Vice Provost for Diversity, Equity, and Community Engagement (812 20^th Street NW, Washington, DCT 20052, phone: 202-994-7434 or email:diversegwu [dot] edu). Inquiries may also be directed to the U.S. Department of Education Office for Civil Rights, the U.S. Equal Employment Opportunity Commission, or the applicable state or local agency (for example, the District of Columbia Office of Human Rights).

Sanctions and Corrective Action

Findings of violations of this policy made by the offices identified above may result in the imposition of sanctions and/or corrective action, in accordance with applicable policies, e.g., the Code of Student Conduct, the Student Discrimination Report Procedures, the Faculty Code, and the Employee Handbook.  Sanctions and corrective actions for students and student organizations may include, but are not limited to, censure, disciplinary probation, restitution, removal from university residence, suspension, expulsion, restriction from employment at the university, educational program attendance, educational project, professional assessment, removal from specific courses, activities or organizations, No Contact Order, transcript notation and/or notification to other institutions, withholding or delaying the conferral of a degree, prohibitions against participation in academic honor ceremonies (such as graduation), training, and guidance.

Sanctions and corrective actions for faculty and staff include but are not limited to, oral or written warning/reprimand, suspension, termination of employment, training, guidance, and adjustment of supervisory or evaluative responsibilities. Dismissal of a tenured faculty member will be subject to Article V.C.1. of the Faculty Code and Section F of the Procedures for Implementation of the Faculty Code.

The university may take appropriate measures at any time to protect the health and safety of members of the university community.

Retaliation

Retaliation against a person who reports an allegation of discrimination or harassment or who provides information or participates in an investigation or proceeding related to this policy is prohibited by law. Allegations of Retaliation will be investigated and may result in disciplinary action, up to and including expulsion or termination. Retaliation is materially adverse action, such as disciplinary action, violence, threats, or intimidation, intended to punish or discourage an individual or group of individuals from engaging in protected activity.  Protected activity includes making a good faith report under this policy; filing an external complaint for issues arising under this policy; participating in proceedings related to this policy; or opposing in a reasonable manner and consistent with university policy an action reasonably believed to constitute a violation of this policy. More information can be found in the university’s Non-Retaliation Policy.

Contacts

Contact	Phone Number	Email Address
Conflict Education & Student Accountability (CESA)	202-994-6757	cesagwu [dot] edu
Equal Employment Opportunity and Access (EEOA)	202-994-9656	eeogwu [dot] edu
Office of the Vice Provost for Faculty Affairs	202-994-5884	facultyaffairsgwu [dot] edu
Title IX Office	202-994-7434	titleixgwu [dot] edu
Vice Provost for Diversity, Equity, and Community Engagement (ODECE)	202-994-7297	diversegwu [dot] edu
Office of Ethics, Compliance, and Risk	202-994-3386	complygwu [dot] edu