EQUAL EMPLOYMENT OPPORTUNITY

It is a fundamental policy of Trinity School not to discriminate on the basis of race, color, sex, national origin, age, veteran status, disability, or any other characteristic protected by law, with respect to recruitment, hiring, training, promotion, and other terms and conditions of employment.

It is the policy of the school to base decisions on employment solely upon an individual Christian’s qualifications relating to the requirements of the position for which the individual is being considered. As Trinity School is a faith-based institution, religion is a bona fide occupational qualification, and the school reserves the right to use religion as a criterion in the hiring process, as permitted by law.

As such, all employees will affirm in writing their subscription to Trinity’s doctrinal statement, will be members in good standing of a Christian church, and will give personal testimony of faith in Christ.

The school will ensure that all personnel actions such as compensation, benefits, transfers, layoffs, school-sponsored training, promotions, terminations, and disciplinary actions are applied impartially within the above-stated parameters and criteria.

ADA/DISABILITY ACCOMMODATION

In compliance with the Americans with Disabilities Act (ADA) and applicable state law, Trinity School will not unlawfully discriminate against qualified applicants or employees with disabilities who can perform the essential functions of their jobs with or without reasonable accommodations. The school will not discriminate based on disability or perceived disability in hiring, promotion, discharge, compensation, job training, benefits, classification, referral, or any other aspects, terms, or conditions of employment.

In accordance with the law, it is the school’s policy to provide such qualified applicants and employees with reasonable accommodations, except where such accommodations would impose an undue hardship on the school. Any employee who requires an accommodation to perform the essential functions of their job should contact the Human Resources representative and request such an accommodation. The individual with the disability should be prepared to discuss what type of accommodation is needed to perform the job and should be aware that dialogue regarding the exact accommodation that may be granted may occur. Trinity may require the employee to provide medical documentation regarding their disability and accommodations consistent with the law. In collaboration with the candidate or employee, the school will make every effort to identify and implement an accommodation that is reasonable and will not impose an undue hardship.

THE PREGNANCY WORKERS FAIRNESS ACT, AND THE PROVIDING URGENT MATERNAL PROTECTIONS FOR NURSING MOTHERS ACT

Trinity fully complies with the Pregnant Workers Fairness Act (PWFA) and provides reasonable accommodations to employees with known limitations related to pregnancy, childbirth, or related medical conditions, unless the accommodation will cause the employer an undue hardship, meaning significant difficulty or expense for Trinity. Employees covered by this policy should follow the process set forth in Trinity’s Americans with Disabilities Act policy. Examples of possible reasonable accommodations include the ability to sit or drink water; receive closer parking; receive additional break time to use the bathroom, eat, and rest; and take unpaid leave or time off to recover from childbirth.

In accordance with the Fair Labor Standards Act (FLSA), Trinity also provides reasonable break time to any covered employee to express breast milk for their nursing child for one year after the child’s birth each time such employee has need to express the milk.

In addition, Trinity fully complies with the Providing Urgent Maternal Protections for Nursing Mothers Act (“The PUMP Act”) which provides that nursing employees are entitled to a place to pump at work, other than a bathroom, that is shielded from view and free from intrusion from coworkers and the public. Please reach out to the Human Resources representative for more information.

FILING A DISCRIMINATION CLAIM WITH THE SCHOOL

An employee who believes they have been subject to or have observed any form of unlawful discrimination should promptly submit a written complaint to the Head of School and the Director of Community and Belonging. If the object of the complaint is the Head of School, the employee should submit the complaint to the chair of the Board of Trustees and inform the Director of Community and Belonging. The complaint should be specific and should include facts, the names of individuals involved, and the names of any witnesses, if applicable.

The school will promptly undertake a thorough investigation and will attempt to resolve the issue. Those investigating for the school will preserve the confidentiality of facts and identities as much as practical. Those making complaints are expected to maintain appropriate confidentiality as well and to act professionally and discreetly at all times. The school will not retaliate against any employee for filing a complaint or for participating in an investigation in good faith.

BIAS AND HARASSMENT POLICY

Overview

At Trinity School, we believe that God has created everyone in his image and commanded us to love one another as he loves us. Sin tarnishes his image in us and causes us, at times, to mistreat others. Yet as a community, we remain committed to resisting sin and living in love. Harassment of any sort detracts from the dignity of victim and perpetrator and can lead to their physical, psychological and spiritual harm. Harassment offends our Lord and corrupts the Christian community and society. As a Christian community, we must promote, not diminish, human dignity.

Therefore, we seek to prepare young people for and to model community life according to Christian principles. Specifically, we aim to uphold the following values:

·        glorifying God in all relationships and activities;

·        respecting others because all persons are created in God’s image;

·        upholding God’s righteousness and justice as the foundation of our conduct toward others;

·        abiding by all applicable civil and criminal laws, including those specifically prohibiting harassing or other discriminatory conduct.

Prohibited Conduct

Harassment and incidents of bias based on an individual’s race, sex, color, national origin, age, disability, veteran status, or any other characteristic protected by law are prohibited within the Trinity community.

General Forms of Harassment and Related Conduct

Examples of prohibited conduct include but are not limited to the following:

·        Communicating in a way (e.g., by written or oral comments or innuendo) or engaging in any other conduct, such as shunning, that demeans, intimidates, or insults another community member. This includes vulgar, abusive, humiliating, or threatening language or jokes, or other crude or rude behavior. Use of vulgar, profane, or sexually oriented language that demeans or ridicules people because of their race, age, gender, religion, national origin, disability, or any other characteristic protected by law will not be tolerated.

·        Displaying, publicizing, or transmitting by electronic means any materials or content that has the same effect (as described immediately above) as if it were communicated in person.

·        Failure to stop offensive behavior upon request.

·        Failing to report or to report honestly an incident of alleged harassment.

·        Failing to cooperate fully with an investigation into allegations of harassment.

·        Retaliating against any individual for their role in reporting instances of harassment or for assisting with or otherwise supporting an investigation into charges of harassment.

Sexual Harassment

As a specific concern within the general umbrella of harassment, the school strictly prohibits sexual harassment, including the following:

·  Unwelcome sexual advances

·  Requests for sexual favors

·  Sexual slurs, jokes, or innuendoes

·  Displays of sexually suggestive objects or pictures

·  Discussions of one’s sexual activities

·  Sexually suggestive language or gestures

·  Unwelcome petting, touching, or pinching

·  Other verbal or physical contact of a sexual and offensive nature

·  Any conduct that interferes with an individual's work, academic performance, or participation in any other school activity or that otherwise creates, for the individual, an intimidating, hostile, or offensive school environment.

Bias Incidents

A bias incident is any occurrence that displays an unreasoned or unfair distortion of judgment in favor or of against a person or group. Bias incidents can be perpetrated by individuals, groups, or systems. General forms of bias incidents include, but are not limited to, the following:

·  Assuming criminality on the basis of race

·  Assigning intelligence to a person on the basis of their race or gender

·  Making jokes about a person’s race or sexual orientation

·  Assigning a student to a part in a play based primarily on race

·  Favoring one gender for work assignments that any gender can perform equally well

·  Dismissing the stories of others without listening empathetically

·  Taking intellectual property, traditional knowledge, cultural expressions, or artifacts from someone else’s culture without permission and making them your own

·  Ignoring marginalized voices and stories in the selection of curriculum and the design of lessons

·  Hiring someone based primarily on familial relationships (nepotism)

Reporting Harassment or Bias Incidents

The following procedures are available to any member of the Trinity School community who believes they have been harassed, have observed harassment, or have experienced an incident of bias in violation of this policy. Barring extenuating circumstances, informal procedures should first be pursued before initiating formal procedures. In any instance in which a school staff member responsible for carrying out any of these procedures is allegedly engaged in conduct prohibited under this policy, that staff member’s supervisor or other designee appointed by the Head of School shall assume the responsibility in question.

The Head of School has the right to modify these procedures when necessary to better serve the policy’s objectives. In instances in which the Head of School is alleged to have engaged in misconduct, the chair of the Board of Trustees or the chair’s designee shall assume the Head of School’s role in the investigation.

Procedures

When an employee believes they have been harassed, have observed harassment, or have experienced an incident of bias in violation of this policy, the following procedures shall apply.

 Informal Procedures

The employee shall make a request for advice or counsel (orally or in writing) to their supervisor, the Director of Community and Belonging, their division head or department director, the Associate Head of School, or the Human Resources representative, for example, to evaluate perceptions or clarify issues. Where feasible, the concern should be presented to the alleged offender to allow the parties to resolve any misunderstanding and, when applicable, to reconcile if an offense has occurred. If this informal procedure does not resolve the matter and the employee wishes to pursue it further, they shall document the informal steps taken and then follow the formal procedures outlined below. Under certain circumstances, requiring informal procedures may be inappropriate or harmful to the reporting individual. In such cases, the employee may request to proceed directly to the formal procedures.

Formal Procedures

If the informal procedure proves unsatisfactory, a formal written complaint may be filed with the Director of Community and Belonging promptly after the informal procedure ceases. The Director of Community and Belonging shall promptly initiate an investigation, including discussion with all parties involved. The Director of Community and Belonging may appoint an ad hoc committee or other designee to investigate the case and recommend action. A decision shall be made within 10 working days after the date of submission of the complaint unless the Director of Community and Belonging determines that additional time is required. 

If it is determined that a violation of this policy has occurred, the Human Resources representative will recommend appropriate disciplinary action. The appropriate action will depend on the following factors:

(a) the severity, frequency and pervasiveness of the conduct;

(b) prior complaints made by the complainant;

(c) prior complaints made against the respondent; and

(d) the quality of the evidence (e.g., firsthand knowledge, credible corroboration).

If the investigation is inconclusive or if it is determined that there has been no violation of policy but potentially problematic conduct may have occurred, the Human Resources representative may recommend appropriate preventive action.

The Director of Community and Belonging and Human Resources representative will meet with the Head of School or Associate Head of School and the offender's supervisor to review the investigative reports and recommendations for corrective and/or preventative action to decide what action, if any, will be taken.  Once a final decision is made by the offender's supervisor and the Head of School, the Human Resources representative and the supervisor will meet with the offender to notify them of the findings of the investigation and any disciplinary action to be taken, up to and including termination.  

The Director of Community and Belonging and the Human Resources representative will meet with the complainant to notify them of the findings of the investigation within 10 days of the complaint being filed. 

Retaliation against any employee who, based on a reasonable belief, reports an incident of alleged offensive workplace behavior or who participates in an investigation will not be tolerated. 

All complaints and investigations are treated confidentially to the extent possible, and information is disclosed strictly on a need-to-know basis. The identity of the complainant is usually revealed to the parties involved during the investigation, and the Director of Community and Belonging and the Human Resources representative will remind all parties of Trinity’s non-retaliation policy throughout the investigation process.

False and ill-natured complaints of harassment, discrimination, or retaliation (as opposed to complaints that, even if erroneous, are made in good faith) may be the subject of appropriate disciplinary action.

Reporting for Personnel Files

For bias incidents and harassment, the investigation file and records of communications will be retained in a confidential file. Relevant disciplinary action, training, counseling, or direct communications with the employee will be placed in the employee’s personnel file. 

Preliminary Suspensions and Disciplinary Action

 When necessary (e.g., for reasons of safety or community concern), any person alleged to have engaged in misconduct under this policy may be suspended (with pay for an employee) pending the outcome of the investigation. Such a suspension is a non-judgmental administrative procedure and shall not constitute a finding of wrongdoing.

Upon completion of the investigation, a violator may be subject to disciplinary and/or corrective actions including, but not limited to, the following:  oral or written warning or reprimand; counseling; probation; suspension with or without pay; up to and including termination. 

Non-Retaliation

Trinity School prohibits reprisal or retaliation against any person for (a) reporting or intending to report violations of this policy; (b) supporting someone for reporting or intending to report a violation of this policy; or (c) participating in the investigation of reported violations of this policy. After consideration of the nature and circumstances of the reprisal or retaliation and in accordance with applicable federal, state, or local laws, policies, and regulations, the Head of School and Human Resources representative shall determine the consequences and remedial action for a person found to have engaged in reprisal or retaliation.