Policy on Nondiscrimination and Equal Opportunity

Policy Number: 107

Governance and Legal

The permanent link for this policy is: https://policies.northeastern.edu/policy107/

I. Purpose and Scope

Northeastern University is committed to providing a living, learning and working environment free of discrimination and harassment. This policy applies to members of the university community, who, for purposes of this policy, include students, faculty, staff, affiliates, volunteers, contractors, and visitors, as well as to applicants for admission and employment with the university. This policy applies to conduct that occurs on university property or while participating in university programs or activities. It also applies to conduct that occurs off university property or outside of university programs or activities, including on social media, if such conduct limits or denies the ability of community members to participate in university programs or activities.

II. Definitions

For the purposes of this policy and related procedures:

A. Discrimination

Means inequitable treatment based on a person’s actual or perceived protected characteristics, excepting any treatment permitted or required by law.

Discrimination also includes, but is not limited to, Discriminatory Harassment. Discriminatory Harassment is unwelcome conduct based on a person’s actual or perceived protected characteristic(s) that is either:

subjectively and objectively offensive and so severe or pervasive that it limits or denies the person’s ability to participate in or benefit from the university’s education or employment programs or activities; or
done by an employee or other community member of the university who explicitly or implicitly conditions the provision of an aid, benefit, or service of the university on the person’s participation in the unwelcome conduct.

Unwelcome conduct includes, but is not limited to, verbal abuse, graphic or written statements, physical assault, or other conduct that may be threatening, harmful or humiliating.

Whether unwelcome conduct creates or contributes to a hostile environment will be determined based on the totality of the circumstances, which may include the following:

The context, nature, scope, frequency, duration, and location of the conduct;
The identity, number, age, and relationships of the persons involved;
Whether the unwelcome conduct is directed at a single person from multiple other people; and
The extent to which the conduct limits or denies a person’s access to the university’s education or employment programs or activities.

Unwelcome conduct need not always be targeted at a particular person to create or contribute to a hostile environment.

Discrimination and Discriminatory Harassment may be based on a person’s actual or perceived protected characteristics. This means that a person could be discriminated against or harassed based on their own protected characteristics or based on someone else’s perception that the person has a particular protected characteristic. Discrimination and Discriminatory Harassment may also be based on a person’s association with someone else who has a protected characteristic.

Discrimination and Discriminatory Harassment can occur even if the alleged harasser is a member of a protected class.

B. Protected Characteristics

Protected characteristics include:

Race;
Color;
Religion;
Religious Creed;
Genetic Information;
Sex (including pregnancy or pregnancy related conditions, sex stereotypes, and sex characteristics);
Gender;
Gender Identity;
Gender Expression;
Sexual Orientation;
Age;
National Origin;
Ancestry, including shared ancestry (such as, but not limited to, Jewish, Israeli, Palestinian, Muslim, Arab, and/or South Asian descent, citizenship, or association);
Ethnicity;
Citizenship or country of residence;
Disability status; or
Veteran and Military status

Additional characteristics protected under state, provincial, or other applicable law may be treated as protected under this policy for conduct occurring in that jurisdiction.

C. Supervisor

Means any person who has authority to undertake or recommend tangible employment decisions affecting an employee or academic decisions affecting a student; or to direct an employee’s work activities or a student’s academic activities. Examples include faculty members to whom work-study students report or employees who, from time to time, monitor other employees’ performance or direct their work.

D. Retaliation

Means any adverse act against a person who in good faith makes a report, serves as a witness, participates in an investigation or adjudication process regarding an alleged violation of this Policy, requests a reasonable accommodation, modification, or adjustment for a disability, or acts to oppose discriminatory practices. Retaliation includes threatening, intimidating, harassing, coercing or any other conduct that would discourage a reasonable person from engaging in activity protected under this policy. Retaliation does not include good-faith actions lawfully pursued in response to a report of an alleged violation of a university policy.

III. Policy

A. Prohibition on Discrimination

Northeastern University prohibits Discrimination and Discriminatory Harassment on the basis of protected characteristics. All forms of Discrimination and Discriminatory Harassment within the university community are unacceptable and will be addressed appropriately.

The university also prohibits Retaliation against those who, in good faith, make reports or cooperate in the investigation or adjudication process under this policy and the related resolution procedures, or who act to oppose discriminatory practices.

B. Reporting Discrimination

The university’s Nondiscrimination and Equal Opportunity Report Resolution Procedures detail the university’s processes for reporting and resolving reports of Discrimination, Discriminatory Harassment, or Retaliation under this policy. Please note that reports of sex- and gender-based harassment and discrimination, including sexual assault, sexual exploitation, domestic violence, intimate partner violence, dating violence, stalking, and retaliation, are governed by the University’s Policy on Sexual and Gender-Based Harassment and Title IX and separate procedures referenced in that policy.

Members of the Northeastern community are encouraged to report instances of Discrimination, Discriminatory Harassment, or Retaliation as outlined in this policy to the Office for University Equity and Compliance (OUEC) using the contact information below. Members of the university community and third parties can report a potential violation of this policy by a university student, staff or faculty member, volunteer, vendor, contractor or visitor, or by units, departments, organizations recognized by or affiliated with the university, or other organizational components of the university. Supervisors (except those in roles designated as confidential resources) are required to report promptly to OUEC instances or allegations of conduct that may constitute Discrimination, Discriminatory Harassment, or Retaliation that are disclosed to, observed by, or otherwise known to them.

Discrimination, Discriminatory Harassment, or Retaliation can be reported to the OUEC in any of the following ways:

Using OUEC’s online Discrimination Report Form
Emailing OUEC@northeastern.edu
Making a verbal report or hand-delivering a written report to the OUEC’s main office at 125 Richards Hall on the Boston campus
Mailing a report to: Office for University Equity and Compliance, 360 Huntington Avenue, 125 Richards Hall, Boston, MA 02115

Northeastern also provides an anonymous compliance hotline for members of the university community, which is managed by an independent, third-party company. For more information or to make a report, visit northeastern.ethicspoint.com or call 1-855-350-9390. The university will make reasonable efforts to address anonymous reports; however, without specific information, the university’s ability to address or resolve a matter may be limited.

C. Other Responsibilities

Members of the university community are expected to be reasonably available to investigators and other administrators acting to implement this policy and to be truthful and forthcoming. If parties decline to participate and/or respond in a timely manner, OUEC may take any action it deems necessary and appropriate to address the situation based on the information available. Failure to cooperate in the review of a report of Discrimination or Retaliation may be grounds for disciplinary action up to and including separation from the university.

IV. Additional Information

This policy is available online at https://policies.northeastern.edu/policy107/ and the related Nondiscrimination and Equal Opportunity Report Resolution Procedures are available at https://ouec.northeastern.edu/equal-opportunity-complaint-procedure/and in the Office for University Equity and Compliance, which is located in 125 Richards Hall on the Boston campus.

In addition to the university reporting options outlined above, reports of Discrimination may also be filed with the appropriate government agency. The contact information for agencies in each of Northeastern’s campus locations in the United States is listed in Appendix 1.

The university reserves the right to address any behavior which it considers inappropriate or inconsistent with university expectations, policies, standards or values, even though such behavior may not rise to the level of Discrimination under this policy or under applicable law. Nothing in this policy is intended to limit the authority of the university to take appropriate action against any person who violates other university rules or policies.

V. Contact Information

Inquiries regarding the university’s nondiscrimination policies and procedures may be directed to the university’s Assistant Vice President for University Equity and Compliance:

Office for University Equity and Compliance
360 Huntington Avenue, 125 Richards Hall
Boston, MA 02115
Phone: (617) 373-4644
OUEC@northeastern.edu