Non-Academic Administrative Policies

Alcohol

I. Introduction

Furman University is committed to the health, safety, and well-being of members of the Furman community. The University recognizes that the use of alcoholic beverages by those of legal age is a matter of personal choice. The University requires that those who choose to consume alcohol on University property abide by applicable law and University policy and expects that such individuals will conduct themselves responsibly, mindful of the rights of others. Individuals are responsible for behaving in a manner that is not disruptive or endangering to themselves or others, and all members of the University community share responsibility for creating an environment that limits dangerous drinking behaviors.

II. Applicability

This policy applies to the consumption, possession, service, and sale of alcoholic beverages on University property (regardless of the sponsor or the source of funds), to all Events sponsored by the University or for which alcohol is purchased using University funds (regardless of the location of the Event), and to all Student Events (regardless of the location of the Event). It applies to all members of the University community and visitors to the campus (including but not limited to faculty, staff, students, guests, and alumni).

III. Definitions

As used in this policy, the following terms have the meanings given to them below.

The “Appropriate Vice President” means:

• for Event organizers who are faculty members, the Vice President for Academic Affairs and Provost or an authorized designee;
• for Event organizers who are staff, the Vice President overseeing the division in which the Event organizer works or an authorized designee;
• for Student Event organizers, the Vice President for Student Life or an authorized designee;
• for Event organizers who are members of the President’s senior administrative team (including the President), the Event organizer;
• for Event organizers who report to the President and are not members of the President’s senior administrative team, the President; and
• for third-party Event organizers (i.e., organizations or individuals who are neither employed by nor enrolled at the University), the Vice President for Finance and Administration (or an authorized designee) or the appropriate Facility Operator (as that term is defined in the Use of University Space policy).

“Event” has the definition given to it in the Use of University Space policy, without giving consideration to the exclusions to such definition provided therein, and with the exception that the following gatherings do not constitute “Events” for purposes of this policy: (A) religious ceremonies, when they are held in the Charles Ezra Daniel Memorial Chapel using wine pursuant to the approval and supervision of the Associate Vice President for Spiritual Life or designee, (B) academic courses using alcohol as required for classroom instruction.

“On Campus” means any property owned or leased by the University.  “Off Campus” means any property that is not On Campus.

“Student Event” means any Event that is primarily planned, funded, and/or executed by one or more students or that a reasonable person would conclude is primarily planned, funded, and/or executed by one or more students, regardless of whether the students are operating as a recognized student organization pursuant to the Student Organization Policies and Procedures.

“Third-party Vendor” means a vendor or bartender holding a valid license to serve or sell alcohol issued by the South Carolina Department of Revenue. Third-party Vendors serving and selling alcohol at Events On Campus must be approved by the Vice President for Finance and Administration or designee in order to operate On Campus and must provide a copy of their current license and proof of insurance naming the University as an additional insured/loss payee under their general commercial liability policy.

IV. Policy Details

A. Compliance with Laws

All possession, consumption, service, and sale of alcohol must be in accordance with applicable South Carolina state laws. All individuals are expected to understand such laws and ensure that they do not violate them. It is also the responsibility of each individual to ensure that the University does not, through such person’s actions, violate the law.

The following is a brief synopsis of certain laws in effect at the time of the adoption of this policy. For detailed and updated information on the laws of the State of South Carolina, please consult the South Carolina Code of Laws.

• Underage Consumption: It is unlawful for a person under the age of 21 to purchase, attempt to purchase, consume, or knowingly possess alcoholic liquors, beer, ale, porter, wine, or other similar malt or fermented beverage.
• Driving Under the Influence (DUI): It is unlawful for a person to drive a motor vehicle within the State of South Carolina while under the influence of alcohol.
• Open Containers in Motor Vehicles: It is unlawful for a person to have in his possession, except in the trunk or luggage compartment, beer or wine in an open container in a motor vehicle of any kind while located upon the public highways or highway rights of way of the State of South Carolina.
• Purchase of Beer or Wine for a Person to Whom It Cannot Lawfully Be Sold: It is unlawful for a person who purchases beer or wine while on licensed premises to give the beer or wine to a person to whom beer or wine cannot lawfully be sold on the premises.
• Transfer to Person Under the Age of 21 Years: It is unlawful for a person to transfer or give to a person under the age of 21 years for the purpose of consumption of alcoholic liquors in the State of South Carolina.
• False Information About Age: It is unlawful for a person to whom beer or wine cannot be lawfully sold to knowingly give false information concerning his age for the purpose of purchasing beer or wine.

As sworn officers of the State of South Carolina, the Furman University Police Department may enforce these and other state laws.

Campus Security Authorities (“CSAs”) are reminded that they are required by the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (the “Clery Act”) to report to University Police allegations of Clery Act crimes that they receive or observe, which include liquor law violations. For more information regarding CSA reporting requirements, contact University Police.

B. Compliance with University Requirements

All possession, consumption, service, and sale of alcohol must be in accordance with applicable University requirements, including those set forth in this policy.

1. Possession of Alcohol On Campus. Individuals may only be in possession of alcohol On Campus as follows:

   1. At an Event, pursuant to the provisions of this policy and the Use of University Space policy,

   2. While tailgating at a major athletic Event, pursuant to the provisions of this policy and the Tailgating at Major Athletic Events policy and Student Tailgates policy,

   3. At a restaurant or venue On Campus, such as the Paddock, when the individual has purchased alcohol from the restaurant or venue and pursuant to the provisions of this policy, or

   4. For students, pursuant to the provisions of this policy and as provided in the Student Handbook, including but not limited to the Student Organization Policies and Procedures, the student Alcohol policy, and the Student Tailgates policy.

2. Event Rules

   1. Security. Furman University Police (or security personnel approved by Furman University Police) must be present, at the expense of the Event organizer, at all times during (i) any Student Event On Campus, including those contemplated by the Student Organization Policies and Procedures, but excluding the consumption of alcohol within the living units of the North Village apartments pursuant to the provisions of the student Alcohol policy (ii) any Event On Campus at which attendance is expected to exceed 75 guests and at which alcohol will be served or sold, and (iii) as otherwise required by the Use of University Space policy.  It is also recommended that Furman University Police be notified of any Event On Campus at which alcohol will be served, sold, or consumed, whether or not their presence is required at the Event.

   2. Required Approvals.

      1. Event Approval. All Events, whether on or off campus, at which alcohol will be served, sold, or consumed must be approved by the Appropriate Vice President, with the exception of Events held at the following locations On Campus, which do not require approval of an Appropriate Vice President, provided that alcohol is served or sold by an approved Third-party Vendor:

         1. The Amphitheatre;

         2. Cherrydale Alumni House;

         3. Hartness Pavilion;

         4. The Trustee and Faculty Dining Rooms;

         5. Furman University Golf Course;

         6. The Garden Room of the Chapel;

         7. Herring Center for Continuing Education;

         8. The Football Stadium;

         9. Timmons Arena;

         10. The David E. Shi Institute for Sustainability;

         11. North Village Pavilion;

         12. Trone Student Center; and

         13. Younts Conference Center.

             In addition, except as provided in the Student Handbook, all Student Events and all Events that it would be reasonable to expect that students would attend, in either case at which alcohol will be served, sold or consumed, must also be approved by the Vice President for Student Life at least fourteen days in advance of the Event (even, for the avoidance of doubt, those held at the above-listed locations).

      2. Approval for the Service, Sale, or Consumption of Liquor or Spirits.  When approved 14 days in advance by the Appropriate Vice President and Furman University Police, liquor and spirits may be sold, served, and consumed at Events at Younts Conference Center at which students will not be present. When approved 14 days in advance by the Appropriate Vice President (and the Vice President for Student Life, for Events that it would be reasonable to expect that students would attend), liquor and spirits may be sold and served at Events Off Campus.

   3. Event Requirements and Recommendations.

      1. Consumption of alcoholic beverages is permitted only by, and alcoholic beverages may be served or sold only by and to, persons of legal drinking age.

      2. Individuals selling or serving alcohol may not consume alcohol.

      3. Except as otherwise permitted by applicable University policy, alcohol must be purchased from a Third-party Vendor (i.e., it may not be purchased by the sponsor of the Event and provided to the Third-party Vendor to be served), with the exception of alcohol donated to the University pursuant to its Gift Acceptance Policy, which may be delivered to the Third-party Vendor to be served.

      4. Except as otherwise permitted by applicable University policy, any service or sale of alcohol must be by a Third-party Vendor. This is true regardless of whether the vendor is supplying the alcohol or simply serving the alcohol.  For Events that are Off Campus, Event organizers are responsible for ensuring that off-campus vendors hold the requisite license.  (For convenience, a list of off-campus Third-party Vendors whose licenses have already been provided to the University is available from the Office of Student Involvement and Inclusion.) All Event organizers and attendees must abide by the rules of the Third-party Vendor with respect to the service or sale of alcohol to the extent that those rules are more restrictive than those set forth in this policy.

      5. Except as otherwise permitted by applicable University policy, Events may not be BYOB (i.e., alcohol must be served or sold at the Event and cannot be brought to the Event, even by an individual of legal drinking age), and no outside beverages may be brought into an Event.

      6. Individuals who are intoxicated or disorderly may not be served or sold alcohol, and such persons may not be allowed to remain on the premises where alcohol is sold, served, or consumed after such condition is known to the person selling or serving the alcohol.

      7. It is recommended that non-alcoholic beverages and food be made available at all Events where alcohol is served or sold.

      8. On-campus Events with alcohol are limited to beer and wine only, with the exception of Events that have been approved by the Appropriate Vice President pursuant to Section IV(B)(2)(c)(ii) above. Off-campus Events with alcohol are recommended to be beer and wine only; however, liquor and spirits may be sold and served at off-campus Events with the approval of the Appropriate Vice President(s) as set forth in Section IV(B)(2)(c)(ii) above.

      9. At all Student Events with alcohol and all Events with alcohol that it would be reasonable to expect that students would attend, event organizers must ensure that there is a method for identifying attendees as of legal drinking age or not.

      10. Student Events that serve or sell alcohol or at which alcohol is consumed must follow the Student Organization Policies and Procedures regardless of whether the Event organizers are operating as a recognized student organization (as defined in such Policies and Procedures).

   4. Storage Management. Unconsumed alcohol purchased from a Third-party Vendor must be returned to the Third-party Vendor for storage or disposal following an Event. Unopened, donated alcohol must be stored in Farmer Hall, Cherrydale Alumni House, or the President’s Suite at Paladin Stadium, as appropriate, before and after an Event. Opened, donated alcohol must be disposed of following an Event. Employees and other Event attendees may not take unconsumed alcohol home with them (whether the alcohol is opened or unopened).

C. Failure to Comply with Policy

Violations of this policy can result in both criminal prosecution and University action pursuant to applicable policy, including dismissal from the University.

D. Other Policies

This policy applies in addition to, and not in lieu of, other applicable University policies, including but not limited to the following:

• The Use of University Space policy. 
• The Student Handbook, including but not limited to the student Alcohol policy and Student Tailgates policy.
• The Tailgating at Major Athletic Events policy. 
• University employees are bound by all other applicable University policies, including the University’s Drug-free Workplace Policy (850.1). 

E. Liability

Organizations that and individuals who host an Event at which alcohol is present may be held responsible for the actions and well-being of their members and guests.

Bias Incident Response & Support

I. Purpose

The purpose of the Bias Incident Response & Support policy is to supplement and work with campus units to connect those who have experienced an act of bias (or those who have witnessed such an act) with appropriate support and resources. Furthermore, the BIRS team works with campus units and offices to coordinate the response to incidents that are likely to affect the campus climate.

BIRS is not a disciplinary procedure and does not investigate, arbitrate, or replace other Furman procedures or services, nor does it override the responsibility or authority of any University office designated to address complaints of alleged discrimination, harassment or hate crimes.

II. Definition of a Bias Incident

Bias incidents are acts or omissions, whether verbally, in writing, or otherwise, that harm, discriminate against, or demonstrate hate against a person or group based on facets of that person’s or group’s identity. Such facets of identity may include, but are not limited to race, color, national origin, sex, sexual orientation, gender, gender expression, gender identity, pregnancy, disability, age, religion, veteran status, or any other characteristic or status protected by applicable local, state, or federal law. Bias incidents are antithetical to the University’s values and commitment to diversity and inclusion as described in the Furman University Nondiscrimination Policy. 

Examples of bias incidents may include:

• Use of dehumanizing, derogatory, or insulting language based on characteristics such as race, ethnicity, gender or disability in person, in writing, on social media, and/or on whiteboards.
• Culturally insensitive themed parties
• Using a racial, ethnic, or other slur in a joke or to identify someone
• Ridiculing a person’s gender identity or expression as observed through behavior, clothing, hairstyle, voice, and/or body characteristics
• Insulting a person’s traditional manner of dress
• Imitating someone with a disability
• Language and imagery objectifying a person based on their identity

The list above is not exhaustive; rather, it provides examples of incidents that may constitute bias incidents.

Please be aware, however, that just because the expression of an idea or point of view may be offensive or inflammatory to some, it is not necessarily a bias-related incident. The University values freedom of expression and the open exchange of ideas and, in particular, the expression of controversial ideas and differing views is a vital part of the University discourse. While this value of openness protects controversial ideas, it does not protect harassment or expressions of bias or hate aimed at individuals that violate the Student Conduct Code.

III. Bias Incident Response & Support Team

The Bias Incident Response & Support (BIRS) Team includes the Assistant Dean of Student Conduct; Title IX & ADA/Section 504 Coordinator; Associate Vice President for Spiritual Life/University Chaplain; Associate Dean of Diversity, Equity and Inclusive Excellence; Associate Vice President for Human Resources; Associate Dean and Director of Housing and Residence Life; Associate Dean and Director of the Center for Inclusive Communities; and other members of the university community as appropriate. The BIRS Team oversees the BIRS plan, partners with campus resources to reduce the effects of bias incidents on the university community, and works with University Communications to update the campus community.

Examples of support offered by the BIRS team include:

• Assigning a member of the BIRS Team for initial follow-up support;
• Connecting faculty to their faculty ombudsperson; Connecting staff to their staff ombudsperson;
• Connecting students to counseling services, chaplaincy, or student success coordinators;
• Connecting students to appropriate university offices to pursue reasonable measures such as housing relocation and academic assistance;
• Advising students and employees on formal grievance options; and
• Other support efforts designed to ameliorate negative effects that complainant(s) may experience.

Sample responses offered by the BIRS plan include:

• Communicating with appropriate campus offices to initiate appropriate investigative and disciplinary processes for violations of University policy;
• Arranging mediation via appropriate campus or community offices (when appropriate);
• Working with University Communications to notify the campus of bias incidents (when appropriate);
• Supporting campus units in the facilitation of dialogues, awareness campaigns, and similar initiatives, across campus and/or in targeted populations;
• Tracking trends to develop interventions and preventative strategies; and
• Other measures designed to stop biased behavior and prevent reoccurrence.

Concurrent with the BIRS plan, the University may conduct investigations into violations of University policy using existing processes such as, but not limited to, the Sexual Misconduct Policy, the Student Disability Grievance Procedure, Student Conduct Procedures, or University Grievance procedures.  

IV. Hate Crimes

The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (the Clery Act) establishes federal guidelines to determine whether a bias incident reaches the threshold of a hate crime.  Hate crimes are criminal offenses against a person or property motivated in whole or in part by a perpetrator’s bias against the victim’s actual or perceived (1) race, (2) religion, (3) disability, (4) sexual orientation, (5) ethnicity, (6) gender, (7) gender identity, or (8) national origin. Aggravating factors such as time, place, and intent can affect whether a bias incident rises to the level of a hate crime.

All hate crimes are bias incidents, but not all bias incidents are hate crimes.  The University acknowledges, however, that biased behavior can be hateful and inflicts harm to members of our community.

V. Procedures for Reporting Bias Incidents

Preserving information is essential to the University’s response to bias incidents. If you experience or witness a bias incident, please do the following to document it: 

• If you see a written slur or discover words or symbols that are biased in nature, do not erase it. 
• If you have a camera or cell phone camera, take a photo of any evidence, such as physical injury, damaged property, or a license plate. 
• If the incident is verbal, please write down exactly what was said to the best of your recollection. 
• Ascertain/retain the contact information of any possible witnesses. 

Students and employees perceive that they have experienced a bias incident, as well as those who are witnesses to a bias incident, are encouraged to report it immediately by one of the following means: 

• Complete the Online Report 
• Complete an in-person report to:  
  • Associate Dean of Diversity, Equity and Inclusive Excellence (faculty), 864-294-2029, Administration Building 200B 
  • Human Resources (employees), 864-294-2217, 2600 Duncan Chapel Rd, Suite 200
  • Student Life (students), 864-294-2202, Suite 215 Trone Student Center 
  • Furman Police (students or employees), 864-294-2111, Estridge Commons
• Anonymously via:  
  • Furman’s Campus Conduct Hotline, 866-943-5787 
  • Live Safe App available for iPhone or Android (choose Furman as School or Agency) 

The University will address bias incidents reported anonymously based on the information provided, though an anonymous report may hinder the ability to respond effectively.

VI. Confidential University Resources

Students, staff, and faculty can utilize confidential university resources to discuss bias incidents and inquire about support. Confidential resources are not obligated to share information that is provided to them but will report aggregate statistics about such information.  This allows individuals to explore their options in a non-pressured environment while they make informed decisions about how to manage a bias incident. 

The following resources are available for confidential support.  

• Trone Center for Mental Fitness (students only) - via phone at (864) 294-3031 or in person on the lower level of Earle Student Health Center;  
• Office of Spiritual Life (all students and employees) - via phone at (864) 294-2133 or in person on the lower level of Daniel Chapel; or 

• University Ombudsperson (all employees) 

VII. BIRS Plan Implementation

• The BIRS Team Coordinator or designee will promptly engage with the appropriate members of the BIRS Team for consultation in response to bias incidents. The BIRS Team will review all bias incident submissions to determine if they meet the University’s definition of a bias incident.
• Individuals who report a bias incident will be contacted within one (1) to three (3) business days by a BIRS Team Member. 
• A BIRS Team Member will offer to connect a complainant with appropriate support personnel at the University, which include the following: 
  • Student complainants: Student Success Coordinators, the Office of Spiritual Life and/or the Trone Center for Mental Fitness
  • Staff complainants: Staff Ombudsperson and/or the Office of Spiritual Life 
  • Faculty complainants: Faculty Ombudsperson and/or the Office of Spiritual Life 
• The BIRS Team Coordinator may convene additional members of the University to make recommendations regarding response and support. If warranted by the severity of the incident, a University response to the incident will be developed and implemented in a timely manner. 
• The BIRS Team Coordinator will maintain a record of the incident, support, and response. Data of reported bias incidents will be shared with the university community each semester.
• Those who report bias incidents are expected to have done so in good faith. Should a concern arise that an alleged incident was fabricated or submitted under false pretenses, the University reserves the right to utilize appropriate disciplinary procedures to address the misuse of the BIRS process

Brand and Licensing Use

Students, staff, faculty, or other individuals, businesses, and organizations (including student organizations) must obtain approval and/or a license to use Furman University’s trademarks and logos in any manner and for any purpose. Requests may be submitted to brandreviewboard@furman.edu.

Ethics Policy

I. Introduction

The University is committed to the highest possible standards of ethical conduct.  Accordingly, this Ethics Policy forms the ethical principles that will guide Employees in all decisions and activities, consistent with the mission and values embraced by the University’s mission statement. It applies to all Employees. This Policy is not intended to replace existing
policies and procedures or those that may be adopted in the future; rather, it is intended to complement and be read in conjunction with such policies and procedures. This Policy is also not intended to address or provide an answer to every situation; rather, the principles set forth herein are intended to guide Employees in identifying and resolving issues of ethical conduct that may arise in the course of their various transactions and relationships with others. Employees are expected to make ethical decisions, and they are encouraged to consult their supervisors or the Vice President over their departments when issues arise that they need assistance in addressing. For purposes of this Policy, the term “Employee” means and includes all employees of the University, including part-time employees, temporary employees, and any person under an employment contract or similar arrangement with the University, and shall, for purposes of this Policy only, include volunteers.

II. Ethical Principles

1. Respect. Employees will nurture a climate of respect, fairness, and civility toward others even in the face of disagreement.
2. Honesty and Integrity. Employees will act and communicate truthfully and candidly. Employees will make decisions based on the greater good and conduct themselves free from personal conflicts or appearances of impropriety or self-dealing.
3. Confidentiality. Employees will respect other individuals’ privacy and will treat as confidential all information that is designated as confidential or that they should reasonably understand to be confidential in nature. Such information includes but is not limited to education records pursuant to the Family Educational Rights and Privacy Act and its implementing regulations.
4. Stewardship. Employees will use University resources in a wise and prudent manner in order to achieve the University’s educational mission and strategic objectives. Employees will not use University resources for personal benefit or gain.
5. The Pursuit of Excellence. Employees will conduct all University affairs diligently, exercising professional care and striving to meet the high expectations the University has set for itself.
6. Responsibility and Accountability. Employees will be trustworthy and answerable for their conduct, decisions, and obligations and will comply with all applicable laws, regulations, policies, and procedures.

III. Reporting Violations

Employees may report concerns relating to failures to adhere to this Policy by contacting the University’s Office of Human Resources (864-294-2217) or by calling the confidential and
anonymous Campus Conduct Hotline (866-943-5787).

IV. Modifications and Amendments

The University may modify or amend this Policy from time to time as it may deem necessary and appropriate.

Inclement Weather

Decision-making process and notification

The Provost and the Vice President for Academic Affairs is responsible for decisions to cancel, delay, or modify class schedules due to inclement weather.  They rely on the University Police and the National Weather Service for information on weather and road conditions affecting the campus.  Scheduled cancellations or modifications due to inclement weather are typically made by 10:00 p.m. on the preceding day, or no later than 6:00 a.m. on the day the inclement weather is expected.  During inclement weather common sense safety precautions should be taken - if you are unable to safely travel to or across campus, then please stay put.  If the decision is made to cancel, delay, or otherwise modify class schedules due to inclement weather, the University will use the following means to communicate with students, faculty, and staff:

• University Communications will notify local radio and TV stations.
• University Communications will post decisions on Furman’s web page.
• University Police will send email and text messages through the Furman Emergency Alert System.  To confirm your emergency contact number visit MyFurman.
• University Police will maintain a recorded message on the University’s Weather line: 864-294-3766.

Operating hours of Dining Hall, Duke Library and Trone Student Center

At the end of the recording at 864.294.3766, the caller will be advised for the Library, Dining Hall and Trone Student Center hours, to press “0” now. This will take the caller to another recording with that information. Each of these areas has access to their recording to make updates as needed.

Delay in starting classes and reporting for work

If a decision is made to delay classes, the announcement will indicate a specific time for the start of classes and reporting to work. These times will be based on one of the class starting times as outlined below. Students should go to the class that starts at the time the University has opened.

• Monday, Wednesday, and Friday - 8:30 a.m., 9:30 a.m., 10:30 a.m. or 11:30 a.m.
• Tuesday and Thursday - 8:30 a.m., 10:00 a.m., or 11:30 a.m.
• Decisions about evening classes are made separate from day classes.

Campus activities

If inclement weather affecting road conditions occurs during the weekday afternoon or on a weekend, individuals will be advised to contact sponsors of various campus events and activities for information regarding delays or cancellations.

Special work requirements

Some areas on campus (i.e. University Police, Student Health Center, Trone Student Center, Dining Hall, Housing and Residence Life, Library and Facilities Services) must continue to provide services. Each of these areas has developed staffing plans for inclement weather and should review their plan with all employees in their department at this time.  During a campus closure due to inclement weather, employees should remain at home unless directed by their supervisor to report for work.

Posting and Solicitation

The University recognizes the need for registered student groups and other University sanctioned organizations and individuals to communicate their activities, services, and ideas to the campus community, as well as the need to provide a visually pleasing and organized setting for the campus community to receive such communication.

Only enrolled students, registered student organizations and campus departments may post signs, banners, or other forms of publicity to communicate their activities (including but not limited to flags) on campus. All items to be posted must have the name of the individual student or registered student organization and/or department clearly identified as the sponsor or the words “sponsored by (name of organization)” on each item. Chalking is only allowed to advertise specific events, can only occur one week prior to the event, and must be removed the day after the event.

The University retains the right to deny posting of any materials on campus. Questions about any part of this policy should be re- ferred to the Office of Student Life. This policy applies in addition to Housing & Residence Life policies regarding windows.

The following guidelines are intended to outline the procedures by which such organizations and individuals can display and promote campus-related events and programs.

1. Promotion of illegal drugs or any other illegal activities in text, graphic or any other form is prohibited. Promotion of alcohol is prohibited except when previously approved by the Dean of Students Office. 
2. Individuals or groups found damaging or tampering with another group’s publicity prior to an event’s occurrence, for any reason, unless otherwise instructed to remove the publicity, will potentially lose the privilege of posting publicity through that medium in the future and may be addressed through the appropriate University disciplinary process.
3. Materials should not overlap or conceal other items. Persons who post are asked to be considerate of others who have posted. Posting is on a first-come, first-served basis, and is dependent upon space limitations. 
4. Signs may be posted on bulletin boards in any academic building. Signs posted elsewhere in academic buildings will be removed. 
5. Chalking may only occur on exterior sidewalks or roads not commonly used for vehicle traffic. Chalking building walls, interiors of buildings, or roads commonly used for traffic is not allowed.
6. Signs cannot be posted on exterior doors, windows, floors or painted surfaces. Signs, posters and banners may not be displayed outdoors unless approved by the Office of Student Life.
7. Signs or fliers to be posted in the Trone Student Center stairwell mezzanine or in the PalaDen must be brought to the Information Center in the Hill Atrium and left with the attendant to be displayed. Fliers/signs must be 8-1/2” x 11” or 11” x 14” in size, and will be posted for two weeks, or until the end of the event, whichever comes first. Only one flyer per organization per event may be displayed in each area. Digital fliers may be submitted to the Office of Student Involvement for posting on digital displays.
8. Signs or fliers posted in campus housing must be approved by Housing and Residence Life who will distribute the fliers.
9. Signs or fliers promoting events on campus must contain information substantially similar to the following:  Furman University encourages persons with disabilities to participate in its programs and activities.  If you anticipate needing an accommodation due to a disability or have questions about the physical access provided, please contact [name and email address of sponsoring department contact person] as soon as possible.
10. All signs and chalking should be removed by the originating party within 24 hours after the event has concluded. 
11. Posting of signs or banners in the dining hall is available at the banner area and the bulletin boards at the entrance of the dining hall. Banners must be approved, hung, and removed at the manager’s discretion. Additional regulations include the following: 
    • No on-table promotions are allowed in any Dining Services operation except for Dining Services events. 
    • Informational fliers may be posted on the bulletin boards located at the entrances to the dining hall. 
    • Banners may not be any longer than floor level of the dining hall mezzanine. 
    • Banners may not be hung on railings. 
    • All banners must be dated, indicating the day the banner is hung. Banners will be removed after 7 days. If an individual and/or group wishes to keep the banner, it is the responsibility of the individual and/or group to return to the Dining Hall within the 7-day time period to take down the banner. Writing “do not move” on the banner does not grant the banner permanent residence. 
    • Dining Services is not responsible for hanging banners or deciding which banners are hung in which spot. 
    • Dining Services is not responsible for any lost or stolen banners. 
    • When setting up or removing a banner, all trash must be cleaned up by individual and/or group.

Violation of the Posting Policy may result in the removal of the items. Additionally, sponsoring individuals and/or organizations may be subject to follow-up with the Vice President for Student Life and/or designee. Responsibility for interpreting the University Posting Policy shall reside with the Vice President for Student Life and/or designee.

Risk Management/Off-Campus Programs and Release Forms

As the University’s engaged learning programs have grown, so have off campus activities supporting these programs. As described in File 367.1 of the University Policies and Procedures, insurance coverage is in place for programs that take place on or off campus. Risks involved with off-campus programs are greater and more difficult to control, and additional precautions are needed to best protect the University, its students, faculty, and staff. Program directors are responsible for assessing the risks involved with the management of their off-campus programs and for collecting and maintaining files of Consent, General Release, and Indemnity Agreements according to the following guidelines. Risk Management and off campus programs are described in File 367.5 of the University Policies and Procedures.

1. Consent, General Release, and Indemnity Agreements are not required for faculty and staff travel. Furman employees are covered by insurance and this coverage includes General Liability, Foreign Liability, Excess Liability, and Workers’ Compensation insurance.
2. Consent, General Release, and Indemnity Agreements are required any time a student leaves campus as part of some Furman-related course, organization, or activity. This includes, but is not limited to, internships, off-campus research, courses involved in service learning, and class field trips. In addition, this applies to activities that are not officially sponsored by the University if the off-campus activity or event is directed by or required by a University official/employee.
3. Signatory Requirements:
   • Consent, General Requirement, and Indemnity Agreements for students traveling to other countries, and all students under the age of 18 will require the signatures of parents or guardians.
   • Consent, General Release, and Indemnity Agreements for students 18 and older who are traveling within the United States will require the signature of the student traveler only.
4. Courses or programs that require students to leave campus several times during the term for field trips or similar activities may fulfill this requirement by securing one release at the beginning of the term. The release should be clearly worded to cover the activity for the full term of the course or program. Two examples of this are intern programs that require repetitive visits, and Heller Service Corps travel.
5. Basic information required of all off campus programs, provides a “release” section, the language of which should not be altered unless approved by the Risk Manager or Legal Counsel. Additional space is provided for the program director to include other important provisions and agreements.
6. The program director should keep a file of the Consent, General Release, and Indemnity Agreements for no less than seven (7) years.
7. Questions about the administration of this policy should be directed to the Risk Manager at Facilities Services.

Sexual Misconduct Policy

Furman’s Sexual Misconduct Policy can be found here.

Tailgating at Major Athletic Events

Furman University provides the opportunity for tailgating at approved venues on the Furman campus for football and other major athletic events.  University Athletics, on consultation with University Police, is responsible for designating activities as a major athletic event. The requirements established for tailgating are intended to ensure a safe and enjoyable environment for students, alumni and guests. 

Tailgating is permitted for alumni and campus guests (Non-Student Tailgaters) in the athletic event parking lots adjacent to an individual’s parking space as designated by the Athletics Department and/or Furman Police Department.  Tailgating that is not adjacent to a parking space must be reserved by registering 14 days in advance with the Athletics Department. 

Non-Student Tailgaters will be permitted to set-up no more than four (4) hours prior to the start of the athletic event.  Tailgating ends at the start of the athletic event. The tailgate area must be cleaned up, all belongings removed (i.e. furniture) and Furman-provided tents lowered no later than two (2) hours after the conclusion of the athletic event.  Rented tables and chairs may be left for Facilities Services to collect.

Open alcohol containers are only permitted for Non-Student Tailgaters who are 21 and older in the area adjacent to an individual’s parking space as set out above.  Students may only consume alcohol in the designated location for student tailgating (see Student Tailgates).

• Non-Student tailgating is strictly a “BYOB” event in which individuals who choose to bring their own alcoholic beverages, limited only to beer and wine products, are solely responsible for their disposition and individually assume all liability associated with their choices.
• Individuals are responsible for and expected to follow all federal, state, and local laws, as well as students must abide by the Student Conduct Code and all student organization, group and team policies.

The following behaviors are strictly prohibited:

• Public urination
• Littering in or around tailgating areas
• Activities/games that encourage binge drinking
• Public drunkenness
• Throwing beer cans or other items
• Intentional disruption of other tailgating areas
• Inappropriate language, aggressive behavior or other misconduct that is disruptive to the Furman community

Other Rules:

• Staking tents is prohibited.  Tents may be held down with sandbags or weights.  Shallow sprinkler, electric and natural gas lines run under all tailgating areas.
• Electrical extension cords may not be run across sidewalks or roads.
• Charcoal grills are prohibited.  Gas grills are permitted and a fire extinguisher is required.
• Tables, chairs, and tents may not be removed from other tailgate spots.
• Trash must be placed in the provided trash bins or bagged and left next to the trash bins.

Music

All individuals are expected to be good neighbors.  Individuals who feel their neighbor’s music is too loud and/or offensive are encouraged to talk with their neighbors about the disturbance and/or contact the Furman Police if the disturbance fails to cease.  Individuals are expected to comply with reasonable requests.

Catering

Catering is available (not required) through Furman Catering.  Click here to order online.  Orders must be received by 2:00 p.m. at least three (3) business days before the athletic event.

Enforcement

Non-Student Tailgaters in violation of the tailgating policies are subject to action taken by the Furman Police and/or local law enforcement, to include being trespassed from University property.  Students in violation of the tailgating policies are subject to action taken by the Furman Police and/or local law enforcement, as well as University disciplinary action as outlined in the Student Handbook.

Further guidelines for students, student organizations, groups and teams are available at Student Tailgates.

Use of University Space

1. Use of University Space

Robust engagement with all topics that affect society and the human condition allows Furman University to effectively develop students for citizenship, intellectual curiosity, and lifelong learning in the tradition of a liberal arts education. Accordingly, the University has adopted this policy and its focus on the timing, location, and logistics of Events to allow for broad access to University Space. However, the University reserves the absolute right as a private landowner to refuse any request for the use of its space that–in the University’s sole discretion–is either inconsistent with the mission, character, and values of the University, or that may present potential or actual adverse logistic or administrative conditions including, but not limited to, any safety or security concerns. The right of refusal for the use of University Space includes the cancellation of an Event. Note that this policy is not intended to nor should it conflict with the academic freedom of Furman’s faculty.

2. Definitions

An Event is broadly defined and interpreted by the University as any planned gathering of individuals or groups, including, but not limited to, performances, forums, rallies, dances, speakers, conferences, concerts, lectures, social functions, celebrations, protests, and other presentations.

The following activities are expressly excluded from the definition of an Event for the purposes of this policy:

1. Academic courses offered by the University;
2. Individual or group academic study sessions;
3. Meetings of the Board of Trustees of the University;
4. NCAA-sanctioned athletic events;
5. Faculty meetings;
6. Staff and Administration meetings;
7. Recognized Student Organization meetings;
8. University Commencement, Baccalaureate, and Convocations;
9. Camps, conferences, and weddings approved by the Director of Conference & Event Services;
10. Tailgating, which is addressed by a separate policy that can be found here;
11. University alumni events, provided that they are planned, organized, and supervised by University personnel acting within the scope of their employment; and
12. Orientation or other meetings or presentations regularly held or conducted as part of University business operations.

Notwithstanding the aforementioned, the University reserves the right to determine whether an activity on campus is an Event for the purposes of this policy.

An External Registrant includes any unrecognized student organization(s) as well as any person(s) not currently enrolled at or employed by the University who:

1. requests to use University Space;
2. is primarily responsible for planning, funding, and executing the Event; or
3. is so associated with the Event that a reasonable person would conclude the organization or person is primarily responsible for it.

A Facility Operator is a University employee who has primary decision-making responsibility for a University Space and includes, but is not limited to, staff in Athletics, Office of Spiritual Life, Conference & Event Services, McAlister Auditorium, Trone Student Center, and Registrar.

An Internal Registrant includes any Recognized Student Organization(s) as well as any person(s) currently enrolled at or employed by the University who:

1. requests to use University Space;
2. is primarily responsible for planning, funding, and executing the Event; and
3. is so associated with the Event that a reasonable person would conclude the organization or person is primarily responsible for it.

The Space Usage Committee is a committee composed of Facility Operators, the Chief of University Police, the University Risk Manager, and one faculty member from the University’s Cultural Life Programs Committee or their designees.

A University Space is any property owned, leased, or operated by the University.

3. How to Request a University Space

Because the University may require additional consideration before granting a reservation, Internal and External Registrants should make a space request no later than 14 days prior to an Event. Failure to submit a request within 14 days may result in the request being denied without consideration.

To request athletic space, including but not limited to Timmons Arena, contact Athletics at 864-294-3267.

To request space in the Physical Activity Center (PAC) or challenge course, contact Campus Recreation at 864-294-2414.

To request space in Daniel Chapel, contact the Office of Spiritual Life at 864-294-2133.

To request McAlister Auditorium contact via phone at 864-294-3516 or email mcalister@furman.edu. Click here for more information about booking McAlister Auditorium

To request space in the Trone Student Center, Internal Registrants should contact Trone Student Center staff at trone@furman.edu. Guidelines for reserving the Trone Student Center are available on this webpage. Internal Registrants may submit Trone Student Center space requests online.

Internal Registrants may request academic space by contacting the Registrar at 864-294-2030 or using the University’s online administrative reservation system. External Registrants may not request academic space.

Weddings, summer camps/conferences, outdoor space, and all other requests, both internal and external, should be directed to Conference and Event Services at 864-294-2390. Information about reserving Younts Conference Center and other campus venues is available here.

4. Fees

All Registrants should contact the appropriate Facility Operator regarding applicable fees.

5. Insurance

External Registrants are responsible for insuring their own property and any business income/extra expense exposure. Under no circumstances will the University be liable for any loss or damage to any property of Registrants.

6. Approval Process

Space requests can generally be approved by the Facility Operator. However, circumstances like the following may prompt the need for additional consideration by the University prior to granting a reservation:

1. Events using outside food services or catering;
2. Events using outdoor spaces that also include amplified sound, facilities assistance (e.g. tables, chairs, trash cans, tents, power), traffic and parking assistance (e.g. road closures, clearing lots, directing traffic), art exhibitions, athletic competitions not sanctioned by the NCAA, runs/walks, or carnival rides;
3. Events open to the general public that, based on the expected number of attendees or otherwise, may congest free movement around campus, become targets for increased criminal activity, become newsworthy, or otherwise require additional logistical support from campus staff;
4. Events that require contracts for talent such as speakers, musical performances, etc. (Internal Registrants may not sign talent contracts. Students should refer contractual matters to the Office of Student Involvement. All others Internal Registrants should refer to the policy 370.5 “Contract Approval and Signature Authority,” which can be found [here]);
5. Events that include showing a film or other copyrighted material on campus;
6. Events with no prior history on campus and no equivalent comparison;
7. Events that were previously disruptive to campus; and
8. Events that include minors (Furman undergraduate students who are under the age of 18 are not considered minors for the purpose of this policy).

If a space request may require additional consideration by the University, the Facility Operator can consult the University’s Risk Manager. At the Risk Manager’s discretion, the request may be forwarded to the Space Usage Committee for approval. Alternatively, the Risk Manager may send the request back to the Facility Operator for approval.

7. Space Usage Committee

The Space Usage Committee meets as needed to consider space requests. Pending requests may be deferred for any length of time or for any reason. The committee is chaired by the University’s Risk Manager and may meet in person, by phone, or electronically. All decisions of the committee are made by a simple majority vote. Quorum exists so long as the University’s Risk Manager, the appropriate Facility Operator, and the Chief of University Police or their designees are able to participate. Until the Space Usage Committee makes a decision, the requested space can be held so no other Internal or External Registrants may request it.

In considering whether to approve the use of University Space, the Space Usage Committee is guided by best practices for safe and orderly Events. These practices include, but are not limited to:

1. University-wide events, such as Convocation, Commencement, Homecoming/Reunion, orientation, and Family Weekend have priority over all other events. Similarly, religious observances of a particularly solemn nature receive deference in scheduling. University-wide events as well as religious observances can be found on the University calendar, which is located here.
2. The time, location, and other logistical matters of an Event must not disrupt or otherwise interfere with the operation of the University.
3. Internal and External Registrants bear responsibility for ensuring that the Event is accessible to individuals with disabilities, including but not limited to provision of interpreters, subtitles, Braille, or other reasonable accommodations.
4. Internal and External Registrants must demonstrate the ability to pay for all costs associated with the Event at the time of the space request.
5. University Police, with input from others on the Space Usage Committee, will determine the needed amount, and placement of security. If a protest or counter-protest is expected, an appropriate location must be identified by the University to allow for dissent. External Registrants are responsible for all security costs, including but not limited to costs for expected protests or counter-protests. Additionally, the University must be able to obtain the necessary security in time for the Event.
6. Internal Registrants may not serve as a front for External Registrants. External Registrants may cooperate with Internal Registrants in hosting an Event, but the Internal Registrant remains fully responsible for the conduct of the External Registrant.
7. Recognized Student Organizations must demonstrate the Event is consistent with the purposes of the organization.
8. Events registered by students must not violate Student Handbook policies. Requests that the Space Usage Committee reasonably believes will violate Student Handbook policies will be denied.
9. Events that would raise alarm on campus must have a plan that the Space Usage Committee deems appropriate for providing notice to the community prior to the Event (e.g. firing of a weapon, the setting of a fire, the use of sirens, the use of bullhorns, etc.).  

Before denying a request, the Space Usage Committee may advise Internal Registrants of any alterations to the Event that would allow for approval. This same courtesy is not extended to External Registrants. Decisions by the Space Usage Committee are final, including but not limited to whether a registrant is deemed internal or external as well as whether the request for space involves an Event.

8. Failure to Comply with Policy

The University, through its Facility Operators, the Space Usage Committee, or other appropriate University personnel, will ensure the use of University Space and associated Events comply with this policy in the following ways:

1. Any Internal Registrant who uses University Space for an Event without prior approval may have that Event relocated or canceled if the University learns of the violation prior to or during the Event. If the University learns of an Internal Registrant’s violation after the Event, the University may take action that includes, but is not limited to, issuing a written warning, suspending privileges to use University Space for a period of time, referral to campus disciplinary processes, or pursuing any other legal remedies available to the University.
2. Any External Registrant who uses University Space for an Event without prior approval may have that Event canceled if the University learns of the violation prior to or during the Event. If the University learns of an External Registrant’s violation after the Event, the University may take action that includes, but is not limited to, issuing a written warning, permanently suspending privileges to use University Space, issuing a no trespass order, or pursuing any other legal remedies available to the University.
3. Internal and External Registrants are responsible for guaranteeing that the Event’s execution is consistent with the space request that was approved. Violations may include deviating from the space request in the marketing or orchestration of an Event, violating the Code of Conduct, producing an Event of such a low production and execution quality as to cast doubt on its merit, and insufficiently communicating with the University regarding change of location, time, or Event cancellation. If the University determines an Internal Registrant did not execute an Event consistent with the registrant’s space request, it may take action that includes, but is not limited to, issuing a written warning, suspending privileges to use University Space for a period of time, referral to campus disciplinary processes, or pursuing any other legal remedies available to the University. If the University determines an External Registrant did not execute an Event consistent with the Registrant’s space request, the University may take action that includes, but is not limited to, issuing a written warning, permanently suspending privileges to use University Space, issuing a no trespass order, or pursuing any other legal remedies available to the University.
4. If any member of the University community submits a written complaint to the chair of the Space Usage Committee regarding an Event, either before or after the Event, the chair will decide if a formal review is necessary. If formal review is called for, the Space Usage Committee will review information it deems relevant to understand the complaint and take whatever action it determines is appropriate to provide resolution.

9. Impromptu or Spontaneous Events

Vigils, forums, celebrations, or other unique Events that, by their nature, primarily benefit the University community and under no reasonable set of circumstances could meet the 14-day requirement may be granted the use of University Space provided that such Events receive expedited review by the Vice President for Student Life (for an Event that primarily benefits the University’s students) or by the Vice President for Academic Affairs and Provost, in consultation with appropriate University officials, (for all other Events). The expedited review process is only available to Internal Registrants. 

The University strongly encourages its Internal Registrants to pursue an expedited review in order to insure a safe and successful Event. However, the University supports and acknowledges that sometimes spontaneous or impromptu Events by individuals employed by or enrolled at the institution are pivotal to achieve the principles of a liberal arts education. Prior to terminating a spontaneous or impromptu Event by individuals employed by or enrolled at the institution, the University will review whether relocation to another space on campus is appropriate. This same courtesy is not extended to any organization or person who would be considered an External Registrant under this policy. The following University Space is not available for spontaneous or impromptu Events:

1. Private offices, research laboratories or associated facilities, and computer centers.
2. Specific areas of offices, museums, libraries, and other facilities that contain valuable or sensitive materials, collections, equipment, and records protected by law, or by existing University policy such as educational records, student-related or personnel-related records, or financial records.
3. Classrooms, art and music practice rooms, seminar rooms, auditoriums, meeting rooms, or outdoor spaces in which classes, meetings, or Events are being held or are scheduled to be held.
4. Outdoor and indoor locations when the free flow of traffic, both vehicular and pedestrian, is unreasonably impeded; when entrances or exits to private offices, classrooms, and meeting spaces are blocked; when undue health and safety risks are created; or when quiet hours of the University’s residential areas would be disturbed.
5. Earle Student Health Center, Trone Center for Mental Fitness, public safety services, and surrounding green space or grounds (including, but not limited to, sidewalks, access roads, parking areas, etc.), communication systems, utilities, or other facilities or services vital to the continued functioning of the University.  

10. Peaceful Demonstrations and Protests

Furman University students and employees may engage in peaceful demonstrations and protests on University property, subject to the requirements set forth in this policy. This policy affirms the University’s commitment to the open exchange of ideas and values through demonstration and protest and establishes parameters to help provide a safe environment, protect property, and promote the proper functions of the University’s mission and operations. The University strives to ensure intellectual freedom and free expression to further the discovery, improvement, transmission, and dissemination of knowledge by means of research, teaching, discussion, and debate.

Students and Recognized Student Organizations planning demonstrations or protests must make their events effective and safe, whether hosting a guest speaker, planning a march, or organizing a protest. Students and Recognized Student Organizations must register any demonstration or protest with the Associate Vice President for Student Life and Dean of Students or designee (“DOS”). As a neutral party, the Dean of Students Office can help in coordinating logistics and ensuring compliance with university policies.  Internal Registrants are expected to follow regulations established within the University Space Policy when registering a demonstration or protest. Every effort will be made to accommodate spontaneous or impromptu demonstrations or protests, including counter-demonstrations, within reason and in proper consultation with University officials.

Picketing, distributing literature, silent or symbolic protests (e.g., holding signs, standing, etc.), or short and spontaneous verbal reactions to a speaker are acceptable forms of protest and dissent, as long as they do not result in the disorderly conduct outlined in this policy. In order to reasonably accommodate protests or dissent by individuals enrolled at or employed by the institution, the University will review whether relocation to another space on campus is appropriate prior to terminating prohibited activity. This same courtesy does not extend to anyone external to the University. Riots or other destructive gatherings are not acceptable forms of protest and dissent.   

11. Disorderly Conduct Related to Events

All Events must comply with all applicable laws, ordinances, rules, and regulations of any federal, state, or local government or administrative agency. Additionally, all Events must strictly comply with all applicable University policies and procedures.

Conduct that obstructs or disrupts teaching, administration, University procedures and activities, or other authorized activities on University premises, including but not limited to Events hosted by Internal or External Registrants is prohibited.

Additionally, conduct that that impedes the rights of an Event’s attendees-including, but not limited to, excessive noise, continually interrupting a speaker, preventing an audience from seeing/engaging with a speaker during an Event, blocking entrances or exits, or impeding free movement-is prohibited.

Finally, use of masks or costumes that obscure identity, brandishing of weapons or items that could reasonably be believed to be weapons, words and actions that may incite violence, physical altercations, and any other act a reasonable person would believe is designed to intimidate or threaten participation in an Event is prohibited. Masks, costumes, and stage weapons used by cast members during a Furman-approved theatrical production are exempted.

Disorderly conduct as outlined in this policy during an approved Event may subject an individual to removal, referral to campus disciplinary proceedings, or other legal action available to the University.

12. Non-Event Use of University Space

a. Solicitation

Whether internal or external, solicitation is not allowed on campus without prior written approval.  Solicitation includes, but is not limited to, approaching someone with a request or plea, as well as setting up a table or other temporary structure for the same purpose.  No individuals or groups will be given permission to solicit on a door-to-door basis. 

Anyone requesting to set up tables in high-traffic areas must contact the appropriate Facility Operator to obtain written approval. Furthermore, all solicitations aimed toward students should be directed to Student Life for approval. Outside religious organizations are not allowed to solicit on campus without prior written approval from the Office of Spiritual Life. Religious student organizations are expected to conduct ministry in accordance with the Religious Council’s Guidelines. Any fliers, posters, banners, or other print material must comply with the University’s Posting of Signs and Banners Policy.

Events only open to members of a church, synagogue, mosque, or other religious body are not considered solicitation. However, if the Event is open to anyone or the religious group will invite guests from the University or local community, the Event must receive prior written approval from the Office of Spiritual Life.

b. University Images, Symbols, & Logos

Taking photographs or videos of the University campus (whether internal or external) is permitted for personal use only.  All commercial and political uses of such images are prohibited without the prior approval of University Communications. Similarly, use of unmanned aerial vehicles or drones while on University property is prohibited without prior approval. The logo and name of the University are registered trademarks and cannot be used without permission from the University.

The University recognizes the need for registered student groups and other University sanctioned organizations and individuals to be allowed creative freedom to communicate their activities, services, and ideas to the campus community. It is also considered important for said groups to use Furman University symbols and logos appropriately. Information on the display and/or use of University symbols and/or logos may be accessed here.

c. Visiting Campus

The University welcomes the public to visit its campus. Under no circumstances will the University be liable for any loss or damage to visitors’ property.

Vulnerable Persons on Campus Policy

I. Introduction

Subject to other policies, procedures and protocols, Furman University (“Furman” or the “University”) operates a variety of programs and activities that are specifically designed for Vulnerable Persons (as defined in Section III below) or in which Vulnerable Persons participate. The University also makes its facilities available to external groups that conduct programs designed for Vulnerable Persons or in which Vulnerable Persons participate. The University is committed to the safety of Vulnerable Persons participating in these programs and expects all persons interacting with them to exhibit exemplary behavior at all times, especially when interacting with Vulnerable Persons, and to foster and maintain an appropriate and secure environment. Abuse of and inappropriate activity involving Vulnerable Persons, whether sexual, physical or otherwise, is antithetical to the values and standards of the Furman community, is incompatible with the safe, healthy environment that the Furman community expects and deserves, and will not be tolerated. Accordingly, the University adopts this Vulnerable Persons on Campus Policy (“Policy”), which establishes:

• Procedures for the operation of programs involving Vulnerable Persons;
• Minimum standards of conduct for interacting with Vulnerable Persons;
• Mandatory reporting procedures in cases of abuse or neglect, suspected abuse or neglect, and situations involving inappropriate activity with a Vulnerable Person; and
• Sanctions for violations of this Policy.

All Covered Programs (as defined in Section III below) must be operated in accordance with South Carolina state laws, and all individuals are expected to understand such laws and ensure that they do not violate them. It is also the responsibility of each person to ensure that the University does not, through such person’s actions, violate applicable laws.

By operating a Covered Program, External Sponsors assume all responsibility for the supervision of Vulnerable Persons; compliance with laws, regulations, codes, and/or ordinances applicable to Covered Programs; and compliance with this Policy. By permitting an External Sponsor to operate a Covered Program on or in University Facilities, the University does not assume (1) responsibility for the supervision of Vulnerable Persons, (2) responsibility for the conduct of Vulnerable Persons, or (3) any liability arising out of and/or related to the operation of such Covered Programs.

II. Applicability

Individuals and entities covered by this Policy include, but are not limited to:

• All University departments, units, and registered student organizations.
• All University community members, including but not limited to:
  • Faculty;
  • Staff;
  • Administration;
  • Students; and
  • Volunteers.
• External groups and organizations including, without limitation, their employees, volunteers, third-party vendors, consultants, and contractors.
• Contractors, external consultants, workers hired through an outside employment agency, and workers employed through service vendors.

All of the aforementioned persons and entities must comply with Section IV(B)’s conduct requirements when interacting with Vulnerable Persons and Section IV(C)’s reporting requirements. However, Section IV(A)’s operational requirements do not apply to individuals who may have incidental contact with Vulnerable Persons but who do not work with Vulnerable Persons in a Covered Program.

III. Definitions

1. “Background Screening” means (1) a search for sex-related offenses in an individual’s counties of residence for the past seven years; (2) a search of the state registry of sex offenders; and (3) a search for criminal activity in the individual’s states of residence for the past seven years.
2. “Care, Custody, or Control” means an Internal or External Sponsor’s intentional decision to assume primary responsibility for supervision of Vulnerable Persons at any point throughout an activity or event designed for Vulnerable Persons or in which Vulnerable Persons participate.  By way of example, an Internal or External Sponsor does not, in general, assume Care, Custody, or Control of Vulnerable Persons at events open to the public, K-12 school field trips led and accompanied by teachers, and other events or activities where parents, legal guardians, or other chaperones or adults not affiliated with the University are expected to accompany Vulnerable Persons. (In such cases, such adults must supervise the Vulnerable Persons and are prohibited from leaving the Vulnerable Persons unsupervised on or in University Facilities. Similarly, employees or alumni that bring their children or other Vulnerable Persons to campus for any reason other than participation in a Covered Program (e.g., short-term and informal reasons such as job shadowing or temporary child care necessitated by reasons beyond the employee’s control) must supervise them and are prohibited from leaving them unsupervised on or in University Facilities.)
3. “Covered Program” means any event or activity (1) operated, conducted, or organized by an (i) Internal Sponsor, regardless of the location of the event or activity, or (ii) an External Sponsor using University Facilities; (2) in which Vulnerable Persons participate; and (3) during which the Internal or External Sponsor assumes Care, Custody, or Control of Vulnerable Persons. This definition excludes:
   • University admissions-related activities for prospective students, regardless of the campus department or unit that is organizing the activity, including visits by prospective students and student athletes; and
   • Research protocols involving Vulnerable Persons as human subjects that are subject to the requirements of the University’s Institutional Review Board.
4. “External Sponsor” means the external entity, group, organization, or person that uses University Facilities in operating the Covered Program. For the avoidance of doubt, External Sponsors must comply with all requirements applicable to External Sponsors under this Policy, regardless of whether a University employee may be involved with, or connected to, the External Sponsor’s Covered Program. For example, University coaches are required to operate summer athletic camps through a separate legal entity. Where the summer athletic camp is a Covered Program under this Policy, the Covered Program is operated by an External Sponsor regardless of the University employee’s involvement, and the External Sponsor must comply with all applicable requirements of External Sponsors under this Policy.
5. “Internal Sponsor” means the University academic or administrative unit or registered student organization operating the Covered Program.
6. “Program Administrator” means the person the Internal or External Sponsor has designated as responsible for the day-to-day decision-making and supervision of the Covered Program and Program Staff.
7. “Program Staff” means an individual aged 18 and older, paid or unpaid, who may routinely interact with, supervise, chaperone, be responsible for, or otherwise oversee Vulnerable Persons in a Covered Program.  Covered Programs may not be staffed by individuals under the age of 18.
8. “Recurring Covered Program” means a Covered Program operated, conducted, or organized by an Internal Sponsor that occurs more than once per calendar year.
9. “University Facilities” means property owned or leased by the University.
10. “Vulnerable Person” means any person (1) under the age of 18 who is not enrolled, or has not been accepted for enrollment, at the University as a full-time student; or (2) who is 18 years or older who has a physical or mental condition that substantially impairs such person from adequately providing for their own care or protection who is not enrolled, or has not been accepted for enrollment, at the University as a full-time student.

IV. Policy Details

1. Operational Requirements for Covered Programs
   1. Approval
      1. Internal Sponsors
         1. Internal Sponsors desiring to operate a Covered Program must obtain approval from the Vice President (or that Vice President’s designee) with authority over the Internal Sponsor.
      2. External Sponsors
         1. External Sponsors desiring to operate a Covered Program using University Facilities must obtain approval in accordance with the University’s Use of University Space Policy. When seeking approval, External Sponsors must indicate whether its desired use of University Facilities involves assuming Care, Custody, or Control of Vulnerable Persons. As a condition of approval, External Sponsors must execute the appropriate facility use contract, which shall require the External Sponsor to comply with this Policy and maintain liability insurance satisfactory to the University’s Office of Risk Management.
         2. In addition to any other insurances required by  the University’s Office of Risk Management and/or by contract, External Sponsors must obtain and maintain, at their sole cost and expense, the policies and minimum limits listed in this Section IV(A)(1)(b). At the time of registration of the Covered Program, the External Sponsor must provide to the University’s Office of Risk Management a certificate of insurance evidencing the policies and minimum limits listed in this Section IV(A)(1)(b) and naming the University as an additional insured.
            1. General Liability - $1,000,000 per occurrence; $2,000,000 aggregate; and
            2. Sexual Harassment/Abuse - $1,000,000 per occurrence; $2,000,000 aggregate.
   2. Registration
      1. Initial Registration of Covered Programs
         1. Following approval under Section IV(A)(1) above, Internal and External Sponsors must register all Covered Programs with the University’s Office of Risk Management at least 30 days in advance of the start of the Covered Program. For purposes of compliance with this Policy, a Covered Program is not registered until the Internal or External Sponsor receives written confirmation of registration from the University’s Office of Risk Management. The Program Administrator is responsible for registering the Covered Program.
      2. Recurring Covered Programs - Internal Sponsors Only
         1. All Internal Sponsors must complete an initial registration of Recurring Covered Programs. (For the avoidance of doubt, this requirement applies to Recurring Covered Programs in operation prior to the University’s adoption of this Policy.)
         2. Before December 31 of each calendar year, Internal Sponsors must notify the University’s Office of Risk Management via e-mail, copying the appropriate Vice President or the Vice President’s designee identified in Section IV(A)(1)(a), that it is renewing its Recurring Covered Program.
   3. Background Screening
      1. Non-Student University Employees
         1. In accordance with the University’s Criminal History Background Checks Policy, the University performs Background Screenings of all new non-student hires as a condition of their employment with the University.
         2. All University employees serving as Program Administrators and Program Staff must have successfully completed a Background Screening no more than three years before the start of a Covered Program to qualify to serve in their respective roles.
         3. The Internal or External Sponsor is responsible for (1) coordinating with Human Resources to ensure compliance with the Background Screening requirement; and (2) the costs of all Background Screenings required by this Policy that are subsequent to the initial Background Screening of new hires. External Sponsors may also use a third-party vendor to complete the Background Screening requirement.
      2. University Students
         1. All University students serving as Program Administrators and Program Staff must have successfully completed a Background Screening no more than three years before the start of a Covered Program to qualify to serve in their respective roles.
         2. The Internal or External Sponsor is responsible for (1) coordinating with Human Resources to ensure compliance with the Background Screening requirement; and (2) the costs of all Background Screenings required by this Policy. External Sponsors may also use a third-party vendor to complete the Background Screening requirement.
      3. All Other Third Parties
         1. All other third parties (i.e., a person not employed by, or a student of, the University) serving as Program Administrators and/or Program Staff in a Covered Program must successfully complete a Background Screening no more than 180 days prior to the start of the Covered Program. For the avoidance of doubt, employees of on-campus vendors are third parties for purposes of this Section IV(A)(3)(c)(i).
         2. At least 14 days before the start of the Covered Program, the External Sponsor must certify to the University in writing that it performed a Background Screening of all third-party Program Administrators and Program Staff no more than 180 days prior to the start of the Covered Program, and that the results of the Background Screening do not bear adversely on the Program Administrators’ and/or Program Staff’s ability to provide for the safety and well-being of Vulnerable Persons. Without limiting the generality of the foregoing, individuals that have been charged with, or convicted of, sexual offenses, crimes of violence, or other crimes against Vulnerable Persons may not serve as Program Administrators or Program Staff.
   4. Training
      1. All Program Administrators and Program Staff must complete training, including, at a minimum, the following topics within one year of the start of a Covered Program:
         1. Child abuse (including sexual abuse) awareness and prevention;
         2. Reporting suspected child abuse and neglect; and
         3. The requirements of this Policy.
      2. In addition to the above training requirements, all Covered Programs for which athletics is the primary activity must have an appropriate number of Program Administrators and/or Program Staff that are certified in first aid and CPR. The University may also require first aid and CPR certification for other Covered Programs based on the information submitted at the time of approval under Section IV(A)(1) or registration under Section IV(A)(2).
      3. The University provides training required by this Policy to its employees according to the following schedule:
         1. For Title IX Coordinators and members of the Furman University Police Department, within 30 days of hire and biennially thereafter;
         2. For all other employees, within 6 months of the date of hire and biennially thereafter; and
         3. For new members to the Board of Trustees, within 6 months of joining the Board of Trustees.
      4. Internal and External Sponsors must ensure that all Program Administrators and/or Program Staff have received the training required by this Section IV(A)(4) no more than one year before the start of a Covered Program. Internal and External Sponsors may request from the University’s Office of Risk Management a link to a training module that meets the above requirements. External Sponsors may develop their own training program so long as it includes, at a minimum, the above requirements.
      5. At least 30 days before the start of the Covered Program, Internal and External Sponsor must certify to the University in writing that all Program Administrators and Program Staff have met the above training requirements.
   5. Assumption of Risk and Release of Liability Forms
      1. Internal and External Sponsors must obtain a signed Assumption of Risk and Release of Liability Form from a parent or legal guardian of Vulnerable Persons participating in Covered Programs. Internal and External Sponsors may obtain this form from the University’s Office of Risk Management.
      2. On or before the second day of the Covered Program, Internal and External Sponsors must deliver signed copies of the Assumption of Risk and Release of Liability Form to the University’s Office of Risk Management.
   6. Supervision of Vulnerable Persons
      1. Staffing. In compliance with applicable industry standards (e.g. standards set by the American Camp Association), as well as applicable laws, regulations, codes, and/or ordinances, Internal and External Sponsors shall determine the appropriate number of Program Staff by taking into account all aspects of a Covered Program including, but not limited to, the number and age of the participants, the activities involved, whether the Covered Program includes travel or a residential component, and the experience of Program Staff. Internal and External Sponsors shall provide the University’s Office of Risk Management with an explanation of their staffing plan that takes into account factors, including, but not limited to, those set forth in this Section IV(A)(6). The University’s Office of Risk Management may, in its sole discretion, reject and/or require modification of the Internal or External Sponsor’s staffing plan.
      2. Accounting for Vulnerable Persons. Internal and External Sponsors must establish a procedure for checking Vulnerable Persons in and out of the Covered Program. Internal and External Sponsors are responsible for ensuring Vulnerable Persons leave the Covered Program only with their parent(s), legal guardian(s), or someone authorized in writing by the same.
      3. Overnight Supervision. The following additional requirements apply to Covered Programs that include a residential component requiring overnight supervision:
         1. Except in the case of an emergency, Program Administrators and Program Staff may not enter a Vulnerable Person’s room, bathroom facility, or similar area unless accompanied by another Program Administrator or Program Staff.
         2. Except in the case of a Program Administrator or Program Staff that is a Vulnerable Person’s parent or legal guardian, Vulnerable Persons and Program Administrators and/or Program Staff may not share the same room.

For the avoidance of doubt, Vulnerable Persons unaffiliated with a Covered Program are prohibited from residing overnight in residence halls.

1. Use of the University Swimming Pool.
   1. The University does not guarantee that its swimming pool will be available for use in connection with a Covered Program. The University will not make the swimming pool available for use unless its Campus Recreation & Wellness department is able (through reasonable efforts) to staff the swimming pool with an appropriate number of lifeguards.
   2. Program Administrators interested in reserving the University’s swimming pool must contact the Campus Recreation & Wellness department. Internal and External Sponsors will be responsible for all costs associate with use of the University’s swimming pool, including, but not limited to, the cost of staffing the swimming pool with an appropriate number of lifeguards. Internal and External Sponsors must ensure that (1) the parents or legal guardians of the Vulnerable Persons have granted permission for the Vulnerable Persons to use the University swimming pool; (2) all Vulnerable Persons pass a swimming test before using the pool; and (3) all Vulnerable Persons follow all applicable policies and rules during their use of the pool. For the avoidance of doubt, Internal and External Sponsors and Vulnerable Persons participating in their Covered Programs may not use the University swimming pool with the express permission of Campus Recreation & Wellness.
2. Prohibited Areas of Campus. Unless otherwise approved by the University’s Office of Risk Management, Vulnerable Persons are explicitly prohibited from entering University teaching and research labs where hazardous chemical, biological, and/or radiological materials are present and/or hazardous activities are taking place.
   1. Transportation. In the event the Internal or External Sponsor provides transportation of Vulnerable Persons in connection with a Covered Program, the Internal or External Sponsor must comply with the University’s Driver Qualification and Vehicle Safety Policy. Additionally, Internal and External Sponsors must ensure:
      1. The Internal or External Sponsor has received written approval from the University’s Office of Risk Management to provide transportation;
      2. The Vulnerable Person’s parent or legal guardian grants written permission for transportation of the Vulnerable Person; and
      3. At least two Program Staff and/or Program Administrators are present in the vehicle, unless at least three Vulnerable Persons will be in the vehicle at all times throughout the transportation.
   2. Exemption Requests.  Internal Sponsors may request partial or full exemptions from the requirements of this Section IV(A) if sources other than this Policy (e.g. state laws or regulations, an accrediting agency, or a contractual agreement) require the Covered Program to meet individual requirements of this Section IV(A). All such requests must be submitted in writing to the University’s Office of Risk Management and explain the basis for the request. The University’s Office of Risk Management may grant or deny the request, or, in the University’s Office of Risk Management’s discretion, refer the request to the Space Usage Committee.
3. Conduct Requirements For Program Administrators and Program Staff
   1. Maintain Appropriate Boundaries. When interacting with Vulnerable Persons in Covered Programs, Program Administrators and Program Staff must be particularly aware of, and maintain, appropriate physical and emotional boundaries. Program Administrators and Program Staff must not engage in any behavior - including speech, gestures, depictions, or physical contact - that exploits, abuses, or harasses Vulnerable Persons.
   2. Physical Contact. A Vulnerable Person or bystander may misinterpret intentions when physical contact occurs between Program Administrators or Program Staff and a Vulnerable Person. Accordingly, physical contact must be rare, limited in nature, and should occur only when necessary or appropriate. Program Administrators and Program Staff must be aware of how physical touch with Vulnerable Persons can be received or perceived and show prudent discretion in determining whether physical contact would be an appropriate expression of greeting, care, concern, instruction, or celebration.

Forms of physical contact with a Vulnerable Person that are generally acceptable include high fives, handshakes, fist bumps, or pats on the back or shoulder.

Types of physical contact that must be avoided include, but are not limited to, tickling, rough-housing, wrestling, piggyback rides, any type of massage, any form of unwanted affection, and any other form of physical contact that an individual has indicated is unwanted.

1. Discipline. Although at times, limit-setting with Vulnerable Persons may be necessary for safety reasons, Program Administrators and Program Staff are prohibited at all times from physically disciplining a Vulnerable Person. Similarly, speech, gestures, or other behaviors that are bullying, demeaning, belittling, hurtful, or meant to embarrass or that make gratuitous reference to the Vulnerable Person’s physical development or appearance are prohibited.
2. One-On-One Meetings. One-on-one meetings with a Vulnerable Person should be avoided, but if necessary, must be held in a public area, in a room where the interaction can be (or is being) observed, or in a room with the door left open. Program Administrators and Program Staff must make a reasonable effort to have another Program Administrator or Program Staff present when meeting with a Vulnerable Person one-on-one. If a private, one-on-one meeting with a Vulnerable Person cannot otherwise be avoided, the Program Administrator should be notified about the meeting at the same time as the interaction or as soon as is reasonably practicable thereafter.

 For activities that require private one-on-one meetings such as, but not limited to, tutoring, auditions, or lessons when the parent or guardian is not present, one-on-one meetings are permissible for the relevant portion of the activity so long as the Vulnerable Person’s parent or guardian has been informed of the one-on-one nature of the instruction, has been given the option to be present, and has given written consent to the one-on-one nature of the activity.

1. Drug and Alcohol Use; Other Prohibited Items. When interacting with Vulnerable Persons, the possession and/or use of illegal drugs and the use of tobacco products or alcohol is prohibited. Program Administrators and Program Staff are prohibited from providing a Vulnerable Person with alcohol, drugs, tobacco products, inappropriate videos, pornography, or other such items.
2. Gifts. Program Administrators and Program Staff shall not accept gifts from, or give gifts to, Vulnerable Persons unless they are consistent with, and in furtherance of, the objectives of the Covered Program.
3. Communicating with Vulnerable Persons. Communication with Vulnerable Persons when they are not participating in the Covered Program is only allowed for the purpose of conducting University business or otherwise furthering Covered Program-related objectives. Program Administrators and Program Staff may not call, text, or engage with Vulnerable Persons using personal devices, email, or social media, and may not engage with Vulnerable Persons about any personal subjects unless otherwise consistent with the Covered Program’s mission and objectives.

For the protection of all concerned, the key safety concept is transparency. Program Administrators and Program Staff shall use limited means of electronic communications (University phones and email), and they must include the parent or legal guardian on any communication with a Vulnerable Person.

1. Photographing and/or Recording Vulnerable Persons. Program Administrators and Program Staff may not photograph, film, or otherwise record a Vulnerable Person without the prior written consent of the Vulnerable Person’s parent or legal guardian and may only be done for purposes consistent with the mission and objectives of the Covered Program.
2. Behavior of Vulnerable Persons. Program Administrators and Program Staff are to monitor the behavior of Vulnerable Persons to prevent interruptions to University business or instruction.
   1. Reporting Abuse and Inappropriate Activity Involving Vulnerable Persons
      1. Reporting is Mandatory. All persons must report any instances of abuse or neglect, suspected abuse or neglect, or any situations involving inappropriate activity with a Vulnerable Person, including violations or suspected violations of the conduct requirements set forth in Section IV(B) above, and including any instances involving the Vulnerable Person’s parent, legal guardian, or custodian/caretaker.

In addition to the requirements of this Section IV(C), all persons are required to report any instances of Sexual Misconduct (as that term is defined in the University’s Sexual Misconduct Policy), or suspected Sexual Misconduct,  involving Vulnerable Persons to the University’s Title IX Office.

1. How to Report.
   1. Abuse or Neglect.
      1. Imminent Danger. If the Vulnerable Person is in imminent danger (a threat to the Vulnerable Person’s life) you must immediately call the Furman University Police Department at extension 2111 (864-294-2111). If you experience difficulty reaching dispatch using extension 2111 (864-294-2111), hang up and dial 911 immediately. As soon as possible after reporting the imminent danger to the Furman University Police Department, you must notify the University’s Office of Risk Management..
      2. No Imminent Danger. If the Vulnerable Person is not in imminent danger, you must report it as soon as possible to the Furman University Police Department at extension 2111 (864-294-2111) and notify the University’s Office of Risk Management. Examples of conduct that must be reported under this Policy, but may not place Vulnerable Persons in imminent danger, include, but are not limited to:
         1. Physical abuse: hitting, spanking, shaking, slapping, and/or unnecessary restraints;
         2. Verbal abuse: degrading, threatening, and/or cursing;
         3. Sexual abuse: inappropriate touching, indecent exposure, and/or sexualized conversations;
         4. Mental abuse: shaming, humiliation, and/or cruelty; and
         5. Neglect: unreasonable withholding of food, water, shelter, and/or reasonable medical attention.
      3. Campus Conduct Hotline. Persons aware of suspected abuse or neglect, or violations of the conduct requirements set forth in Section IV(B) above, may also report such instances using the Campus Conduct Hotline at 866-943-5787.
      4. Reporting to the Department of Social Services or Law Enforcement. Certain University employees (those identified in S.C. Code § 63-7-310(A)) are also required by state law to report to either the Department of Social Services (when the alleged perpetrator is the child’s parent, guardian, or other person responsible for the child) or to local law enforcement in the county where the child resides or is found (when the alleged perpetrator is someone other than the child’s parent, guardian, or other person responsible for the child) when, in their professional capacity, they receive information giving them reason to believe that a child has been or may be abused or neglected (as defined in S.C. Code § 63-7-20). All University employees are expected to know and abide by state laws applicable to child protection, including those set forth in Title 63 of the South Carolina Code; this subsection restates only a small portion of such laws.
   2. Other Inappropriate Activity.
      1. Program Staff must report to the Program Administrator any inappropriate activity or suspected inappropriate activity, including violations or suspected violations of the conduct requirements set forth in Section IV(B) above. Program Administrators must then report  the inappropriate activity or suspected inappropriate activity, including violations or suspected violations of the conduct requirements set forth in Section IV(B) above, to the University’s Office of Risk Management.
      2. Program Administrators and Program Staff may also report suspected inappropriate activity using the Campus Conduct Hotline at 866-943-5787.
      3. Program Administrators and Program Staff must report any conduct that may constitute a crime to the Furman University Police Department at 864-294-2111.
   3. Retaliation Prohibited. No person making a good faith report under this Section IV(C) will be retaliated against by the University in the terms and conditions of their employment or educational programs or activities.
2. Sanctions for Violation of this Policy. Sanctions for violation of this Policy include, but are not limited to:
   1. Disciplinary action up to and including termination in the case of University employees;
   2. Disciplinary action under the student code of conduct in the case of University students;
   3. Loss of volunteer status in the case of volunteers;
   4. Trespass order barring the offending person from University Facilities;
   5. Suspension or termination of the use of University Facilities; and Criminal investigation and prosecution.

Whistleblower Policy

This Whistleblower Policy (this “Policy”) is effective as of May 20, 2019 and applies to all Employees (as such term is defined herein) of Furman University, a nonprofit corporation organized under the laws of the State of South Carolina (the “University”).

I.  Purpose

The University is committed to the highest possible standards of ethical, moral, and legal business conduct and to maintaining an environment in which Employees can report Misconduct without fear of retaliation. In connection with this commitment to integrity and open communication, this Policy aims (1) to provide a means by which Employees may raise concerns regarding unethical conduct, violations of the University’s policies, or illegal practices (including but not limited to questionable accounting or the reporting of fraudulent financial information), (2) to facilitate cooperation in any official inquiry or investigation by any court, agency, or other law enforcement or governmental body, and (3) to reassure Employees that they will be protected from harassment, discrimination, reprisals, or victimization for reporting such concerns.

II.    Definitions

For purposes of this Policy, the following terms shall have the meanings set forth below:

1. The term “Complainant” means a person who reports a concern pursuant to the procedures set forth in this Policy.
2. The term “Employee” means and includes all employees of the University, including but not limited to part-time employees, temporary employees, and any person under an employment contract or similar arrangement with the University, and shall, for purposes of this Policy only, include trustees of the University and volunteers.
3. The term “Good Faith” refers to a report made without malice or consideration of personal benefit where the Complainant has a reasonable basis to believe that the report is true; provided, however, that a report does not have to be proven true in order to be made in Good Faith.  Good Faith is lacking when a report made under this Policy is known to be malicious, reckless, or false.
4. The term “Misconduct” includes (i) any violation of any of the University’s policies, (ii) any violation of any federal, state, or local laws, regulations, or ordinances, or (iii) any unethical behavior or practice (including but not limited to questionable accounting or the reporting of fraudulent financial information).

III.    Policies and Procedures

1. Official Investigations. The University encourages its Employees to provide truthful information in official inquiries or investigations.
2. Reporting Misconduct. The University encourages its Employees to raise Good Faith concerns about suspected Misconduct by the University itself, by its Employees, or by others on its behalf.
   1. Purpose. This Policy is intended to be used for serious and sensitive issues that cannot be addressed by another University policy. Ordinarily, reports of Misconduct should be made under the University’s grievance procedures. If an Employee believes that those procedures have not adequately addressed a concern or believes that the grievance procedures are unable to address a concern, the individual may follow the procedures set forth in this Section III.2.
   2. Reporting Options. Complainants may report concerns relating to Misconduct in of the following ways:
      1. By contacting the Complainant’s supervisor; or
      2. In the event the Complainant is not comfortable sending a report to his or her supervisor, by contacting the University’s Vice President for Finance and Administration (the “VP”) or the confidential and anonymous Campus Conduct Hotline (866-943-5787).
      3. Reports should describe in detail the specific facts demonstrating the basis for the belief that Misconduct has occurred.
   3. Timing. The University encourages its Employees to report Misconduct as soon as possible so that timely action may be taken.
3. How the Report Will Be Handled. All reports made under this Policy will be taken seriously. The University has designated the VP to coordinate any necessary action in response to a report of Misconduct (if the VP is implicated in the report, he or she shall recuse him- or herself from the proceedings, and the President of the University shall select an appropriate officer of the University to continue the proceedings). The VP shall determine whether an investigation is appropriate and, if so, the form that such investigation will take. The determination will depend on the nature and gravity of the report; some concerns may be resolved by agreed action without the need for a full investigation. Where appropriate, a prompt, discreet, and independent investigation of the report may be undertaken. All Employees have a duty to cooperate in any investigation made under this Policy. Any Employee who may be implicated in the report shall not participate in any deliberation or investigation regarding the report, except, where appropriate, to present information on his or her own behalf. The VP shall determine the appropriate action to be taken following the investigation.
4. Report to Complainant. When practicable and appropriate under the circumstances, Complainants will be given the opportunity to receive follow-up on their reports, including but not limited to an acknowledgment that the report was received, an indication of how the matter will be dealt with (including but not limited to whether further investigations will follow), and an estimate of the time that it will take for a final response.
5. Report to Audit Committee. The VP will prepare and present at each meeting of the Audit Committee of the Board of Trustees a report regarding the reports received pursuant to this Policy and the actions taken by the University in response.
6. Retention of Records. The University will maintain a record regarding the report and will retain it in accordance with its document retention and destruction protocols.

IV.    Safeguards

1. Discrimination, Retaliation, or Harassment. The University strictly prohibits any discrimination, retaliation, or harassment against any Employee who makes a report in Good Faith, participates in any investigation of a report under this Policy, or provides information in any official inquiry or investigation. Employees who believe they have been subjected to any discrimination, retaliation, or harassment for having submitted a report, for participating in an investigation relating to such a report, or for providing information in any official inquiry or investigation should immediately relay the concern through the channels provided in Section III.2.2 of this Policy. Any complaint of such discrimination, retaliation, or harassment will be promptly and thoroughly investigated and, if substantiated, appropriate disciplinary action will be taken, up to and including termination.
2. Confidentiality. Reasonable efforts will be made to protect the Complainant’s identity to the extent permitted by applicable law, rule, or regulation and consistent with the University’s need to conduct an investigation into the report.
3. False Allegations. This Policy presumes that a Complainant will act in Good Faith when reporting Misconduct. The University reserves the right to discipline Employees who make bad faith, knowingly false, malicious, reckless, or vexatious reports, or who otherwise abuse this Policy.
4. Anonymous Allegations. The University encourages Complainants to attach their names to reports because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified.

V.    Modifications and Amendments

The University may modify or amend this Policy from time to time as it may deem necessary and appropriate.