Study and Intern Abroad Non-Harassment

Policies

Non-Harassment Policy – Study Abroad Programs

As a participant in a study abroad program, you are entitled to an environment that is free of harassment, discrimination, or retaliation. All forms of harassment are strictly prohibited and will not be tolerated.

API will conduct a prompt and thorough investigation of all allegations of discrimination, harassment, or retaliation. API will take appropriate corrective action, if and where warranted.

You should discuss questions regarding this policy with your Resident Director(s), the head of API’s Student Success division (see below), or any other designated member of API management, the names and contact information to be provided or available
upon request.

To understand your rights and what to do if you believe your rights have been violated, please review the below. Should you have any questions please contact API’s head of Student Success, Carolyn Lutes ([email protected]).

Harassment

Harassment (including sexual harassment and sexual assault) and other forms of harassment can be based upon an individual’s age, ancestry, sex, sexual orientation (including transgender status, gender identity or expression), pregnancy (including childbirth, lactation, and related medical conditions), gender, race (including physical characteristics that are historically associated with race including, but not limited to, natural hair, hair texture, hair type, and protective hairstyles such as hair color or
manner of wearing hair that includes, for example, braids, regardless of whether the braids are created with extensions or styled with adornments, locks, and twists), religion, color, national origin, physical or mental disability, genetic information (including testing and characteristics), veteran status, uniformed servicemember status, or any other status protected by federal, state, or local laws. All forms of harassment on any API Program are strictly prohibited and will not be tolerated.

Sexual Harassment

While it is not possible to identify every act that constitutes or may constitute sexual harassment, the following are some examples of sexual harassment:

Unwelcome requests for sexual favors
Lewd or derogatory comments or jokes;
Comments regarding sexual behavior or the body of another;
Sexual innuendo and other vocal activity such as catcalls or whistles;
Obscene letters, notes, emails, invitations, photographs, cartoons, articles, or other written or pictorial materials of a sexual nature;
Repeated requests for dates after being informed that interest is unwelcome;
Retaliating against another for refusing a sexual advance or reporting an incident of possible sexual harassment to API or any government agency;
Offering or providing favors such as favorable evaluations or grades in exchange for sexual favors; and
Any unwanted physical touching or assaults or blocking or impeding movements.

Sexual Assault

Sexual assault is defined as unwanted conduct of a sexual nature that is inflicted upon a person or compelled using physical force, manipulation, threat, or intimidation.

Other Harassment

Other harassment is verbal or physical conduct that insults or shows hostility or aversion toward an individual because of the individual’s protected characteristic.

Again, while it is not possible to list all the circumstances that may constitute other forms of harassment, the following are some examples of conduct that may constitute harassment:

The use of disparaging or abusive words or phrases, slurs, negative stereotyping, or threatening, intimidating, or hostile acts that relate to the above protected categories;
Written or graphic material that insults, stereotypes, or shows aversion or hostility toward an individual or group because of one of the above protected categories and that is placed on walls, bulletin boards, email, voicemail, or elsewhere on our premises; and
A display of symbols, slogans, or items that are associated with hate or intolerance toward any select group.

Reporting Discrimination and Harassment

If you feel that you have witnessed or have been subjected to any form of discrimination or harassment (including sexual assault), document the conduct, and immediately report it to your on-site Resident Director. If you are not comfortable
reporting to your Resident Director, you may also contact the stateside Student Success team at [email protected] or (866) 311-2261. If you wish to keep the complaint anonymous, you may make that indication when contacting the Student Success team. Please note that in some situations, API will be required to notify your home university to enable them to fulfill their legal obligations under applicable law, including Title IX.

API prohibits retaliation against participants who, based on a reasonable belief, provide information about, complain, or assist in the investigation of any complaint of harassment or discrimination. We will promptly and thoroughly investigate any claim and take appropriate action where we find a claim has merit. To the extent possible, we will retain the confidentiality of those who report suspected or alleged violations of the harassment policy. Remedial action will be taken as appropriate and when warranted.

Non-Harassment Policy – Internships

As a participant in an internship, you will be engaged in a work environment with employees who are not associated with Academic Programs International (“API”). Although you are not an employee of the host company of your internship, you will very much be a part of the work environment and you have certain rights of which you should be aware. You are entitled to an environment that is free of harassment, discrimination, or retaliation. All forms of harassment are strictly prohibited and will
not be tolerated.

API will conduct a prompt and thorough investigation of all allegations of discrimination, harassment, or retaliation. API will take appropriate corrective action, if and where warranted.

Workplace Harassment

Workplace harassment (including sexual harassment and sexual assault) and other forms of workplace harassment can be based upon an individual’s age, ancestry, sex, sexual orientation (including transgender status, gender identity or expression),
pregnancy (including childbirth, lactation, and related medical conditions), gender, race (including physical characteristics that are historically associated with race including, but not limited to, natural hair, hair texture, hair type, and protective hairstyles such as hair color or manner of wearing hair that includes, for example, braids, regardless of whether the braids are created with extensions or styled with adornments, locks, and twists), religion, color, national origin, physical or mental disability, genetic information (including testing and characteristics), veteran status, uniformed servicemember status, or any other status protected by federal, state, or local laws. All forms of harassment of, or by, employees, vendors, visitors, customers, and clients are strictly prohibited and will not be tolerated.

Sexual Harassment

Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when (1) submission to such conduct is made either explicitly or implicitly as a term or condition of an
individual’s employment (or as applicable, internship); (2) submission to, or rejection of such conduct by an individual is used as the basis for employment (internship) decisions affecting such individual; or (3) such conduct has the purpose or effect of unreasonably interfering with an individual’s work (internship) performance or creating an intimidating, hostile, or offensive work environment.

While it is not possible to identify every act that constitutes or may constitute sexual harassment, the following are some examples of sexual harassment:

Unwelcome requests for sexual favors;
Lewd or derogatory comments or jokes;
Comments regarding sexual behavior or the body of another;
Sexual innuendo and other vocal activity such as catcalls or whistles;
Obscene letters, notes, emails, invitations, photographs, cartoons, articles, or other written or pictorial materials of a sexual nature;
Repeated requests for dates after being informed that interest is unwelcome;
Retaliating against another for refusing a sexual advance or reporting an incident of possible sexual harassment to the internship host, API or any government agency;
Offering or providing favors or employment (internship) benefits such as promotions, favorable evaluations, favorable assigned duties or shifts, etc., in exchange for sexual favors; and
Any unwanted physical touching or assaults or blocking or impeding movements.

Sexual Assault

Sexual assault is defined as unwanted conduct of a sexual nature that is inflicted upon a person or compelled using physical force, manipulation, threat, or intimidation.

Other Harassment

Other workplace (internship) harassment is verbal or physical conduct that insults or shows hostility or aversion toward an individual because of the individual’s protected characteristic.

Again, while it is not possible to list all the circumstances that may constitute other forms of workplace harassment, the following are some examples of conduct that may constitute workplace harassment:

The use of disparaging or abusive words or phrases, slurs, negative stereotyping, or threatening, intimidating, or hostile acts that relate to the above protected categories;
Written or graphic material that insults, stereotypes, or shows aversion or hostility toward an individual or group because of one of the above protected categories and that is placed on walls, bulletin boards, email, voicemail, or elsewhere on our premises, or circulated in the workplace; and
A display of symbols, slogans, or items that are associated with hate or intolerance toward any select group.

Reporting Discrimination and Harassment

If you feel that you have witnessed or have been subjected to any form of discrimination or harassment (including sexual assault), document the conduct, and immediately report it to your on-site Resident Director. If you are not comfortable reporting to your Resident Director, you may also contact the Student Success team in the U.S. at [email protected] or (866) 311-2261. If you wish to keep the complaint anonymous, you may make that indication when contacting the Student Success team. Please note that in some situations, API will be required to notify your home university to enable them to fulfill their legal obligations under applicable law including Title IX.

API prohibits retaliation against interns who, based on a reasonable belief, provide information about, complain, or assist in the investigation of any complaint of harassment or discrimination.

We will promptly and thoroughly investigate any claim and take appropriate action where we find a claim has merit. To the extent possible, we will retain the confidentiality of those who report suspected or alleged violations of the harassment policy. Remedial action will be taken as appropriate and when warranted.