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@@ -7794,6 +7794,2409 @@ WPI also invites all employees to voluntarily self-identify themselves
 to the Office of Human Resources.  More information can be found on
 our website.
 
+\newpage
+
+---------------------------------------------
+
+# Chapter Ten - Faculty Conduct Policies {#chapter-10}
+
+## I. Policy on Faculty Conduct[^11]
+
+[^11]: This policy replaces and supersedes all previous Faculty Conduct
+Policies, including policy entitled "Worcester Polytechnic Institute
+Faculty Conduct Policy" approved by the Board of Trustees on May 11,
+2018.  The procedures outlined herein apply to conduct predating the
+implementation date unless a proceeding is pending under the old
+policy.  All faculty members and instructional staff not covered by
+this Policy should consult the Work Behavior/Discipline section of the
+Human Resources Employee Benefits and Policies Manual.
+
+(Approved by the Faculty, *February 7, 2019*)
+
+### 1. Introduction and Applicability 
+
+Members of the Worcester Polytechnic Institute ("WPI") faculty have
+traditionally conducted themselves in accordance with high standards
+of professional performance, ethical behavior and personal conduct.
+Nonetheless, from time to time it may be necessary to take action with
+respect to a faculty member who engages in conduct incompatible with
+the responsibilities of faculty membership or who fails to meet
+reasonable standards of performance or behavior. In recognition of
+this need, WPI has developed the following policy to respond to
+allegations of misconduct not covered by WPI's Research Misconduct
+Policy and WPI's Sexual Misconduct Policy and to inform members of the
+community of the appropriate channels for bringing such matters to the
+attention of WPI.  This Policy applies to tenured, tenure-track, and
+continuing full-time non-tenure track members of the WPI faculty,
+including the President, the Provost, the Vice Provost for Research,
+and the Academic Deans.
+
+### 2. Definitions 
+
+a. *Complainant.* The individual, department or entity alleging
+   misconduct.
+
+b. *Respondent.* The individual against whom an allegation of
+   misconduct is made.
+
+c. *Dean.* The Dean of the Respondent's School, department or program.
+
+d. *Investigator.* The individual responsible for conducting an
+   impartial investigation of the allegations of misconduct when the
+   process moves beyond the initial review.
+
+e. *Judicial Committee.* The panel of three faculty members and three
+   senior academic administrators responsible for determination of
+   responsibility and sanctions when the process moves beyond the
+   initial review.
+
+### 3. Grounds for Misconduct 
+
+Generally, grounds for misconduct are based on violations of
+professional ethics[^12] in carrying out one's responsibilities to: a)
+teaching and students; b) scholarship; c) the University; d)
+colleagues; and e) the community.  Nothing in this policy restricts a
+person's rights to privacy, academic freedom, free speech, and free
+expression including the right to speak out against a policy or action
+of the University.
+
+[^12]: See for example AAUP Statement on Professional Ethics.
+
+The ethical responsibilities and examples of violations in each
+category are described as follows: Teaching and Students: As teachers,
+professors encourage the free pursuit of learning in their
+students. They hold before them the best scholarly and ethical
+standards of their discipline. Professors demonstrate respect for
+students as individuals and adhere to their proper roles as
+intellectual guides and counselors. Professors make every reasonable
+effort to foster honest academic conduct and to ensure that their
+evaluations of students reflect each student's true merit. They
+respect the confidential nature of the relationship between professor
+and student. They avoid any exploitation, harassment, or
+discriminatory treatment of students. They acknowledge significant
+academic or scholarly assistance from them. They protect their
+academic freedom.  Examples of unacceptable behavior are:
+
+a. Failure to meet the responsibilities of instruction;
+
+b. Discrimination, including harassment against a student on grounds
+   described in
+   <https://www.wpi.edu/about/policies/equal-opportunity-anti-discrimination-harassment>
+   or any other arbitrary or personal reason, including disability;
+
+c. Violation of University instructional policies;
+
+d. Use of position of power to coerce the judgment or the conscience
+   of a student or to cause harm to a student for arbitrary or
+   personal reasons;
+
+e. Participating or deliberately abetting disruption, interference, or
+   intimidation in the classroom.
+
+*Scholarship:* Professors, guided by a deep conviction of the worth
+and dignity of the advancement of knowledge, recognize the special
+responsibilities placed upon them.  Their primary responsibility to
+their subject is to seek and to state the truth as they see it. To
+this end professors devote their energies to developing and improving
+their scholarly competence.  They accept the obligation to exercise
+critical self-discipline and judgment in using, extending, and
+transmitting knowledge.  They practice intellectual honesty. Although
+professors may follow subsidiary interests, these interests must never
+seriously hamper or compromise their freedom of inquiry.  This Policy
+covers misconduct related to scholarship only if it is not covered by
+the Research Misconduct Policy
+<https://www.wpi.edu/sites/default/files/docs/About-WPI/Policies/Research_Misconduct_Policy.pdf>.
+
+*The University:* As members of an academic institution, professors seek
+above all to be effective teachers and scholars.  Although professors
+observe the stated regulations of the institution, provided the
+regulations do not contravene academic freedom, they maintain their
+right to criticize and seek revision.  Professors give due regard to
+their paramount responsibilities within their institution in
+determining the amount and character of work done outside it.  When
+considering the interruption or termination of their service,
+professors recognize the effect of their decision upon the program of
+the institution and give due notice of their intentions.  Examples of
+unacceptable behavior are:
+
+a. Incitement of others to disobey University rules when such
+incitement constitutes a clear and present danger that violence or
+abuse against persons or property will occur;
+
+b. Unauthorized use of University resources or facilities on a
+significant scale for personal, commercial, political, or religious
+purposes;
+
+c. Forcible detention, threats of physical harm to, or harassment of
+another member of the University community, that interferes with that
+person's performance of University activities;
+
+d. Significant violations of institutional or departmental policies;
+
+e. Discrimination, including harassment against any employee,
+contractor, intern on grounds described in
+<https://www.wpi.edu/about/policies/equal-opportunity-anti-discrimination-harassment>
+or any other arbitrary or personal reason, including disability.
+
+*Colleagues:* As colleagues, professors have obligations that derive
+from common membership in the community of scholars.  Professors do not
+discriminate against or harass colleagues.  They respect and defend the
+free inquiry of associates, even when it leads to findings and
+conclusions that differ from their own.  Professors acknowledge
+academic debt and strive to be objective in their professional
+judgment of colleagues.  Professors accept their share of faculty
+responsibilities for the governance of their institution.  Examples of
+unacceptable behavior are:
+
+a. Making evaluations of the professional competence of faculty
+members by criteria not directly reflective of professional
+performance;
+
+b. Discrimination, including harassment against any employee,
+contractor, intern on grounds described in
+<https://www.wpi.edu/about/policies/equal-opportunity-anti-discrimination-harassment>
+or any other arbitrary or personal reason, including disability;
+
+c. Violation of University policies related to collegiality;
+
+d. Breach of established rules governing confidentiality in personnel
+procedures.
+
+*The Community:* As members of their community, professors have the
+rights and obligations of other citizens.  Professors measure the
+urgency of these obligations in the light of their responsibilities to
+their subject, to their students, to their profession, and to their
+institution. When they speak or act as private persons, they avoid
+creating the impression of speaking or acting for their college or
+university.  As citizens engaged in a profession that depends upon
+freedom for its health and integrity, professors have a particular
+obligation to promote conditions of free inquiry and to further public
+understanding of academic freedom.  Examples of unacceptable behavior
+are:
+
+a. Intentionally misrepresenting that one's personal views are the
+views, or position of the University;
+
+b. Illegal actions that clearly demonstrate unfitness to continue as a
+faculty member;
+
+c. Conduct not protected by academic freedom, free speech, and freedom
+of expression that significantly damages the University's reputation
+or mission.
+
+### 4. Sanctions 
+
+A finding of responsibility for faculty misconduct can result in a
+wide range of sanctions, depending on the circumstances of a
+particular case.  Sanctions must be commensurate with the seriousness
+of the misconduct.  Seriousness, and thus the sanction, will depend on
+the egregiousness of a particular action and may be affected by the
+Respondent's level of cooperation with the process set forth in this
+Policy, and persistence of behavior in the face of prior warnings,
+counseling or sanctions.  In some instances, a single instance of
+unacceptable activity by a faculty member may be severe enough to
+warrant sanctions, including dismissal.  In other instances, only a
+pattern of activity or the continuation of a particular activity or
+activities may warrant sanctions.
+
+The circumstances that may lead to disciplinary sanctions cannot be
+anticipated in precise terms and thus grounds for sanctioning faculty
+members are not made the subject of a precise or comprehensive
+statement.  The determination of appropriate sanctions will account
+for the following factors, including but not limited to:
+
++ the nature and circumstances of the misconduct;
+
++ the impact of the misconduct on the person who experienced the
+misconduct and the WPI community;
+
++ the disciplinary history of the Respondent and the Respondent's
+cooperation with the process set forth in this Policy;
+
++ the intent of the Respondent in committing the misconduct; and
+
++ any other mitigating or aggravating circumstances in order to reach
+a fair and appropriate resolution in each case.
+
+As with the definition of misconduct, it is not feasible or wise to
+automatically assign a specific sanction to particular misconduct.
+Examples showing the range of possible sanctions include, but are not
+necessarily limited to[^13]:
+
+[^13]: The referral of a faculty member to the Employee Assistance
+Program (see
+<https://www.wpi.edu/offices/talent/benefits-payroll-perks/benefits-matrix/employee-assistance-program>),
+training, counseling, or coaching is not considered a disciplinary
+sanction under this policy.
+
++ A letter of reprimand from the Dean to be placed in the personnel file
++ A formal apology from the Respondent
++ Remedial training or counseling
++ Supervision or oversight of professional activity for specified period of time
++ Reassignment of duties, facilities or support
++ Limitation of professional responsibilities for a specified period of time
++ Restitution of misappropriated funds
++ Withholding increases in compensation
++ Reduction of salary
++ Suspension for a specific time with pay
++ Suspension without pay
++ Termination of employment
+
+Sanctions of demotions in rank or revocation of tenure are only
+appropriate in cases where appointment, promotion, or tenure were
+obtained by fraud or dishonesty.
+
+### 5. General Matters
+
+a. All parties are encouraged to resolve disputes and disagreements in
+a mutually acceptable manner before this Policy is invoked.  After
+this Policy is invoked, allegations of misconduct may be resolved at
+any time by mutual agreement of the Respondent, the Complainant and
+the Dean.
+
+b. At all times, the parties shall cooperate with the process,
+preserve (and not delete or destroy) evidence, and provide information
+and materials as requested.
+
+c. The Respondent should be provided with reasonable updates and
+opportunities to respond.
+
+d. The Respondent shall be permitted the assistance of one (1) advisor
+or legal counsel during any investigative proceeding, including any
+related meeting, interview, or hearing. Advisors may communicate with
+their advisee but may not speak or otherwise communicate on behalf of
+a party.  Advisors are subject to the same confidentiality obligations
+applicable to others in attendance.
+
+e. The Respondent is entitled to the presumption of innocence, the
+opportunity to respond to allegations of misconduct, and the
+opportunity to present a defense and offer evidence. The standard of
+proof in deciding that misconduct has occurred should be based on a
+preponderance of the evidence standard. This standard requires the
+determination of whether it is more likely than not that a fact exists
+or a violation of this Policy occurred.
+
+f. Deadlines under this Policy may be extended upon a showing of
+reasonable cause.
+
+### 6. Initial Review of Allegations 
+
+a. Allegations of misconduct (a "Complaint") should be made in writing
+to the Dean of the School, department or program of the Respondent
+named in the Complaint. The fact that a Complaint has been received
+should be made known only to the Respondent and to other persons who
+need to know, based on the Dean's discretion.  It should be expected
+that the Dean will notify the Provost and/or the President about
+allegations of misconduct. "Because the Provost and President may be
+involved later in the process, they must each respect the integrity of
+the process as it moves forward."
+
+b. Upon receiving a Complaint, the Dean shall promptly send a copy of
+the Complaint and a copy of this Policy to the Respondent, and shall
+take appropriate action to obtain and secure relevant evidence.
+
+c. The Respondent shall have an opportunity to provide a written
+response to the allegations within ten (10) days of receiving the
+Complaint from the Dean.
+
+d. Once a Complaint has been received, the Dean may explore the
+possibility of a satisfactory resolution outside the scope of this
+Policy.
+
+e. If the Dean believes the alleged misconduct poses any risk to the
+community, the Dean may, in the Dean's discretion, impose appropriate
+interim sanctions up to and including suspension with pay and an order
+that the Respondent not enter WPI's property, or participate in WPI
+activities or programs.  The suspension shall become effective upon
+notification in writing to the faculty member.  The Secretary of the
+Faculty shall be informed of the suspension.  The Dean may revoke a
+suspension at any time.  If not revoked earlier, a suspension shall
+remain in effect until the final disposition of the process set forth
+in this Policy.
+
+f. Upon receipt of a Complaint, the Dean shall review the Complaint
+and determine whether the allegations in the Complaint would,
+presuming the allegations to be true, meet the definition of
+misconduct as set forth in this Policy. If, presuming the allegations
+to be true, the Complaint does not meet the definition of misconduct,
+the Dean shall dismiss the Complaint.  Otherwise, the process will
+move forward as set forth herein. In either case, the Dean will
+promptly provide written notice of the decision and rationale to the
+Respondent and the Complainant.
+
+g. If the Dean concludes that the process should move forward, the
+Dean shall appoint three unbiased faculty members from outside of the
+Respondent's home department to:
+
+    i. Review the written Complaint and meet with the Complainant to
+    get their version of the alleged misconduct and relevant events;
+
+    ii. Review the written response from the Respondent and meet with
+    the Respondent to get their version of the relevant events;
+
+    iii. Assess whether the behavior alleged constitutes a violation
+    of this Policy and is sufficiently credible and specific so that
+    potential evidence of such misconduct may be identified.
+
+    iv. Prepare a written report summarizing the process and
+    information reviewed and, based on the criteria described in
+    [Section 7.g) iii](link) above, recommend to the Dean whether the
+    process under this Policy should continue or whether the Complaint
+    should be dismissed. The report should identify the names of the
+    Complainant and the Respondent, contain a description of the
+    allegations, explain why the faculty members recommend that the
+    Complaint should be dismissed or that the process should continue
+    under this Policy, and reflect the numerical vote (but not the
+    names) of the three faculty members.  The report shall be sent to
+    the Dean.
+
+h. The Dean will consider the faculty's recommendation and then decide
+whether the process under this Policy should continue or whether the
+Complaint should be dismissed.  When the allegations are within the
+faculty's area of primary responsibility (i.e., curriculum, subject
+matter and methods of instruction, research and those aspects of
+student life which relate to the educational process), the Dean should
+normally accept the faculty's decision.  In rare instances and for
+compelling reasons, however, the Dean may reject the faculty's
+determination.  Regardless of the decision, the Dean shall state in
+writing the basis for the decision and promptly send a copy of both
+the Dean's report and the report written by the three faculty members
+to the Complainant and the Respondent.  In all cases, the Dean shall
+also send a copy the of the Dean's report to the three faculty
+members.  If the Dean decides that the process should continue, then
+the Dean's report will include a sufficiently detailed description of
+the allegations, the portions of this Policy that are alleged to have
+been violated, and any interim measures in place about which either
+party should be made aware. This written notice does not constitute a
+finding or a determination of responsibility.  If the Dean decides that
+the process should continue, the Dean shall also provide a copy of
+both reports to the Provost, and the matter shall proceed as described
+below.
+
+i. The Dean shall make the decision about whether the Complaint will
+proceed under this Policy within sixty (60) days following the Dean's
+receipt of the Complaint.  The Dean may extend this deadline for a
+reasonable time if necessary under the circumstances.  The Dean shall
+notify all parties of any extensions.
+
+### 7. The Investigative Phase 
+
+a. Within ten (10) days after receipt of the Dean's decision to
+continue the process under this Policy, the Provost and the Secretary
+of the Faculty shall collaborate in good faith, concerning the
+appointment of an unbiased, qualified Investigator.  Following such
+good faith collaboration, the Provost and the Secretary of the Faculty
+shall agree upon and appoint an unbiased, qualified Investigator
+(e.g. Title IX coordinator or qualified investigator from outside the
+university) charged with responsibility for conducting a prompt, fair,
+and impartial investigation of the alleged conduct and presenting
+evidence to the Judicial Committee (described below).  The Provost
+and/or the Secretary of the Faculty may consult with the Office of
+General Counsel, the Vice President of Human Resources, and/or such
+other persons who would be helpful in selecting the appropriate
+Investigator.  If the Secretary of the Faculty and the Provost cannot
+agree on an Investigator, the President shall select one after
+reviewing the Secretary of the Faculty's and the Provost's
+recommendations. The Provost will promptly provide the Respondent with
+the name of the Investigator. As soon as possible, but no later than
+three (3) calendar days after delivery of the identity of the
+Investigator, the Respondent should inform the Provost (in writing) of
+any potential conflicts of interest about the selected
+Investigator. The Provost will collaborate in good faith with the
+Secretary of the Faculty in considering the nature of the potential
+conflict and in determining if a change is necessary. Following such
+good faith collaboration, the Provost shall determine if a change is
+necessary. The Provost's decision regarding any conflicts with the
+Investigator is final.
+
+b. The investigation conducted by the Investigator should focus on the
+violation(s) alleged in the Complaint. The investigation will include
+the review of documentation or other items relevant to the reported
+conduct as well as separate interviews with the Complainant, the
+Respondent, and any witnesses whom the Investigator believes will
+provide necessary and relevant information.  The Respondent will have
+the opportunity to provide the Investigator with written notice of the
+names and contact information of potential witnesses with whom they
+would like the Investigator to speak, together with a brief
+explanation of how the persons, documents, and/or items are relevant
+to the reported conduct. The Respondent may also provide the
+Investigator with any documentation or other items they would like to
+be considered. The Investigator will exercise discretion in
+determining what information and questions to consider and which
+potential witnesses will be interviewed.
+
+c. The purpose of the investigation is not to look for evidence of
+misconduct unrelated to the allegations in the Complaint.  To the
+contrary, the investigation should focus on the violation(s) alleged
+in the Complaint.  However, if in the normal course of gathering
+evidence, the Investigator discovers evidence of other potential
+violations of this Policy that are separate from or in addition to the
+allegations in the original Complaint, then the Investigator should
+inform the Dean (in writing) of the new allegation.  The Dean shall
+notify the Respondent of the additional potential violations and give
+the Respondent ten (10) days to provide a written response to the
+additional potential violations. This deadline may be extended by the
+Dean as necessary under the circumstances.  The Dean will treat any
+new unrelated allegation as a separate Complaint starting at Section 6
+of this Policy (Initial Review of Allegations).
+
+### 8. Procedures Following the Investigative Phase
+
+a. *The Investigative Report:* After the investigation is completed, the
+Investigator will deliver an Investigative Report to the Dean.  The
+Investigative Report shall:
+
+    i. include a clear Statement of Charges that specifies the conduct
+    that allegedly violates this Policy, the particular section(s) of
+    this Policy allegedly violated, the time period when the conduct
+    allegedly occurred, and any other information necessary to give
+    the Respondent fair notice of the charges and alleged violations;
+
+    ii. include a summary of the information presented during the
+    investigation including a section where the Investigator points
+    out relevant consistencies or inconsistencies (if any) between
+    different sources of information;
+
+    iii. not include a recommendation or a determination as to whether
+    the Respondent has committed misconduct or what sanctions may be
+    appropriate.  These determinations will be made by the Judicial
+    Committee (see below).
+
+b. *Review by the Respondent:* Within five (5) business days of
+receiving the Investigative Report, the Dean will provide the
+Respondent with a copy of the Investigative Report.  The Respondent
+shall respond in writing to the Statement of Charges included in the
+Investigative Report. The Respondent will also have an opportunity to
+submit written comments to the Dean about the Investigative Report
+within five (5) business days of receiving the Report.  The time to
+submit written comments may be extended if the Dean concludes, in
+his/her sole discretion, that additional time is warranted.  After
+reviewing the submission, if any, from the Respondent, the Dean may
+determine that additional investigation is required, in which case the
+Investigator will supplement the Investigative Report and submit a
+final Investigative Report to the Dean.  Any submissions made by the
+Respondent, as well as any other documentation deemed relevant by the
+Investigator, will be attached to the Investigative Report.  Within
+three (3) business days of receiving the final Investigative Report,
+the Dean will provide the Respondent with a copy of the final
+Investigative Report.
+
+c. *Convening the Judicial Committee:* After receipt of the final
+Investigative Report, the Provost and the Secretary of the Faculty
+shall appoint a six member Judicial Committee ("Committee") comprised
+of three senior administrators and three faculty members from outside
+the Respondent's home department.
+
+    i. The faculty members shall be selected from the elected members
+    of the Faculty Review Committee (FRC) and the elected faculty
+    members of the Campus Hearing Board (CHB).
+
+    ii. The senior administrators shall be selected from a pool of
+    senior academic administrators.  Once the Committee has been
+    appointed, the Dean shall notify the Respondent in writing of the
+    names of the members of the Committee.  Within five (5) days, the
+    Respondent may challenge the composition of the Committee based on
+    alleged bias or conflict of interest.  If a challenge is raised,
+    the remaining members of the Committee shall determine whether
+    bias or a conflict exists.  If a bias or conflict is found, the
+    Provost and the Secretary of the Faculty shall select a
+    replacement from the pool of elected FRC and CHB members or from
+    other academic administrators, as appropriate.
+
+d. *Roles and Responsibilities of the Judicial Committee:* Within ten
+(10) days following the establishment of the Committee (and the
+resolution of any challenge(s) based on bias or conflict of interest),
+the Committee should meet and select one faculty member and one senior
+academic administrator to serve as Co-Chairs.
+
+The Judicial Committee will obtain the Investigative Report from the
+Dean and convene to review the Investigative Report.  The Judicial
+Committee, in its discretion, may request the Investigator to attend a
+Judicial Committee meeting and answer questions.  The Judicial
+Committee, in its discretion, may request the Investigator to conduct
+additional investigation on specific points.  In addition, the
+Judicial Committee must interview the Complainant and the Respondent
+(where those individuals are available and willing to be interviewed)
+and, in its discretion, may request to speak with any other individual
+identified in the Investigative Report as well as any other individual
+with relevant information including individuals identified by the
+parties.
+
+The Judicial Committee may request the parties that participated in
+the investigation to appear at a hearing to answer questions posed by
+the Judicial Committee. The Respondent should indicate whether the
+Respondent waives the holding of a hearing.  If a hearing is to take
+place, then:
+
+    i. The Committee Co-Chairs should promptly set a schedule for the
+    hearing and the other disclosures and responses addressed in this
+    section. The hearing schedule may take place over several days, as
+    necessary.  Before setting the schedule, the Committee Co-Chairs
+    should discuss the proposed schedule with the Respondent.  Once
+    the schedule is set, the Committee Co-Chairs may allow reasonable
+    extensions of time upon request.
+
+    ii. The Committee Co-Chairs shall provide the Respondent with
+    copies of all materials the Committee intends to use at the
+    hearing and the names of witnesses expected to testify.
+    Thereafter, the Committee Co-Chairs may supplement these materials
+    as necessary with adequate notice given to the Respondent.
+
+    iii. The Respondent shall provide the Committee Co-Chairs with
+    copies of all materials the Respondent intends to use at the
+    hearing and the names of any witnesses expected to
+    testify. Thereafter, the Respondent may supplement these materials
+    as necessary with the permission of the Committee Co-Chairs.
+
+At the hearing:
+
+    i. The Respondent shall have an opportunity to present the
+    Respondent's defense to the Committee including any documents,
+    witnesses or other evidence.  The Respondent should be allowed,
+    within reasonable limits set by the Committee Co-Chairs, to
+    question witnesses.
+
+    ii. The Committee will not be bound by rules of evidence
+    applicable in a court of law, and may admit any evidence which, in
+    its opinion, is of probative value in deciding the issues
+    involved. If any facts are in dispute, the Committee shall
+    determine the order in which evidence is offered at the hearing
+    and the process for questioning witnesses.
+
+The Committee shall conclude its review of the case (including the
+hearing) and make a decision within sixty (60) days after the
+establishment of the Committee (and the resolution of any challenge(s)
+based on bias or conflict of interest).  All findings and
+determinations of responsibility and sanctions will be made based on a
+preponderance of the evidence standard. This standard requires the
+determination of whether it is more likely than not that a fact exists
+or a violation of this Policy occurred.
+
+Upon reaching a determination by majority vote (4 to 2, 5 to 1, or 6
+to 0), the Committee shall provide a written report to the Dean, the
+Provost, the Respondent and the Complainant consisting of: (i) the
+Committee's factual findings; (ii) a decision as to whether the
+Respondent committed misconduct; (iii) any sanction; and (iv) the
+rationale for these decisions addressing the merits of any reasonable
+explanation or defense provided by the Respondent; and (v) the
+numerical vote of the Committee without identifying individual votes.
+
+In the case of a tie vote (3 to 3), the Committee shall deliver its
+report (with its factual findings, with appropriate rationale both for
+and against a finding of responsibility, and without a determination
+of responsibility and sanctions) to the President.  The Committee's
+report shall indicate that the vote was tied and whether the three
+faculty members all voted to find the Respondent not responsible.  The
+President will have access to all written reports and materials
+relevant to the case.  In all such cases, the President shall consider
+the matter and consult with the Judicial Committee and the Secretary
+of the Faculty before making a decision.
+
+    i. If the three faculty members on the Judicial Committee did not
+    all vote to find the Respondent not responsible then the President
+    shall make a final written decision with supporting reasons about
+    whether the Respondent committed misconduct and any sanctions to
+    be imposed.  The President's final written decision shall be
+    delivered to the Provost, the Complainant, the Respondent, and the
+    Judicial Committee.  The Respondent, the Complainant, and the
+    Provost shall also receive the Judicial Committee's written
+    report.
+
+    ii. If the three faculty members on the Judicial Committee did all
+    vote to find the Respondent not responsible and the President
+    agrees with the faculty position, then the President will notify
+    the Judicial Committee, the Dean, the Provost, the Complainant and
+    the Respondent that the Respondent has been found not responsible.
+    The Respondent, the Complainant, and the Provost shall also
+    receive the Judicial Committee's written report.
+
+    iii. If the three faculty members on the Judicial Committee did
+    all vote to find the Respondent not responsible and the President
+    disagrees with the faculty position, then the President will state
+    the reasons for doing so, in writing, to the Judicial Committee
+    and the Respondent and shall provide an opportunity for a response
+    from the Respondent before transmitting the Judicial Committee's
+    report and the supporting materials relevant to the matter, to the
+    Board of Trustees. The Board's review will be based on the
+    supporting materials relevant to the case, and it will provide the
+    opportunity for argument, oral or written or both, at the hearing,
+    by the parties and one of the faculty members on the Judicial
+    Committee, or by their representatives. If the Board is inclined
+    to find the Respondent responsible, then the Board shall state the
+    basis for its inclination in writing and return the proceedings to
+    the Judicial Committee for reconsideration. The Committee will
+    then reconsider, taking into account the Board's comments and
+    receiving new evidence, if necessary. The Board of Trustees will
+    make a final decision only after study of the Committee's
+    reconsideration.  The Board's final written decision shall be
+    delivered to the President, the Provost, the Complainant, the
+    Respondent, and the Judicial Committee.  The Respondent shall also
+    receive the Committee's written report.
+
+### 9. Appeals
+
+a. The Respondent may appeal any finding of misconduct and any
+sanction to the President within two (2) weeks after the Respondent
+received notification of the decision.  If the Respondent is appealing
+from a decision made by the President (where the Committee vote had
+been tied) then the appeal should be directed to the Chair of the
+Board of Trustees.  The President (or Board Chair) will have access to
+all written reports and materials relevant to the case.
+
+b. Before the President (or Board Chair) decides the appeal, the
+President (or Board Chair) shall consult with the Judicial Committee
+Chair and the Secretary of the Faculty. The President (or Board Chair)
+should issue a decision within thirty (30) days of receiving the
+appeal.  The President's (or Board Chair's) decision shall be final in
+all cases except cases involving a sanction of termination of
+employment or revocation of tenure.
+
+c. If the President (or Board Chair) imposes a sanction of termination
+of employment or revocation of tenure, the Respondent may appeal the
+finding of misconduct and the sanction to the full Board of Trustees
+within two (2) weeks after the President (or Board Chair) notifies the
+Respondent of the imposition of the sanction.  If the Respondent
+appeals to the full Board, the Chair of the Board (or Board Vice-Chair
+in a case where the appeal was decided by the Chair), following good
+faith collaboration with the Secretary of the Faculty, shall appoint a
+committee of five (5) faculty members (who have not had prior
+involvement in the case) who will make a recommendation regarding the
+finding of misconduct and the sanction imposed. The faculty committee
+will have access to all written reports and materials relevant to the
+case. The faculty committee will summarize the basis for its
+recommendation in a written report to the Board Chair (or Board
+Vice-Chair) within thirty (30) days.  The Board Chair (or Board
+Vice-Chair) should issue a written decision within thirty (30) days of
+receiving the faculty committee's report. The Board Chair's (or
+Vice-Chair's) decision shall be final.
+
+d. Other than interim institutional actions which may already be in
+effect, any finding of misconduct, and the imposition of any sanction,
+will be stayed while an appeal is pending before the President or the
+Board of Trustees.
+
+e) If a faculty member is dismissed or suspended without pay, the
+faculty member's salary ends at a future time to be determined by the
+Board of Trustees.
+
+### 10. Provisions Common to the Misconduct Review Process
+
+a. *No Bias or Conflicts of Interest:* To the maximum extent
+practicable, steps should be taken to ensure an impartial and unbiased
+process, including participation of persons who have no conflicts of
+interest that could affect their ability to be objective and unbiased.
+
+In cases where allegations of misconduct have been brought against the
+Dean or the Provost, or where there is a claim of bias or conflict of
+interest involving the Dean or the Provost, then the President shall
+resolve any questions of bias or conflict of interest and adjust the
+process as necessary. The President's decision on such questions shall
+be final.  In cases where allegations of misconduct have been brought
+against the President, or where there is a claim of bias or conflict
+of interest involving the President, then the Provost shall resolve
+any questions of bias or conflict of interest and adjust the process
+as necessary.
+
+In the case when allegations have been brought against the Secretary
+of the Faculty, the Chair of the Committee on Governance will play the
+role of the Secretary of the Faculty in this policy.
+
+b. *Duty of Honesty:* Any person who knowingly makes a false statement
+- either explicitly or by omission - in connection with any part of
+the process will be subject to separate disciplinary action.  A false
+or unfounded report of misconduct determined to have been made in bad
+faith and dishonesty is a serious offense.  Such offenses should
+themselves be investigated under the appropriate WPI policy and may
+lead to disciplinary action, up to and including termination of
+employment or other affiliation with WPI.  A report made in good faith
+is not considered false merely because the evidence does not
+ultimately support the allegation of violation of the Policy.
+
+c. *Good Faith Participation by the Parties and Witnesses:* The
+investigation is a neutral fact-gathering process.  Although
+participation in the process is not required, the Complainant, the
+Respondent, and all witnesses are expected to participate in good
+faith in the process set forth in this Policy, and they may be
+required by WPI to attend meetings related to the process.  Any person
+who knowingly interferes with the reporting, investigation, or
+resolution of matters under this Policy may be subject to separate
+and/or additional disciplinary action.
+ 
+d. *Confidentiality:* Proceedings concerning misconduct often raise
+difficult issues for those making the allegations, for those who are
+the subject of the allegations, and for those responsible for
+reviewing the allegations.  Review of the allegations should therefore
+be conducted promptly and with care and sensitivity.  All participants
+in the review process under this Policy are expected to maintain
+confidentiality to protect the privacy of all involved, to the extent
+possible and as permitted by law.  Participants should keep in mind
+the effect that allegations can have on reputations, even if the
+allegations are not sustained by the proceedings.
+
+e. *No Retaliation:* Retaliation is typically a significant adverse
+action taken against an individual because the individual participated
+in a review process.  Retaliation is a serious offense.  No one shall
+be retaliated against for participating in a review of a misconduct
+allegation in good faith as a Complainant, a witness, a factfinder, or
+investigator or in any other capacity.  Reasonable efforts should be
+made to counter potential or actual retaliation against these
+complainants, witnesses and committee members. A complaint of
+retaliation may be investigated and may lead to disciplinary action,
+up to and including terminating the individual's relationship with
+WPI.
+
+f. *Record Keeping:* The Provost should receive and maintain all
+records relating to proceedings under this Policy including all
+notices to and from the parties, all written reports, all decisions,
+all appeals by the parties, and all decisions involved in the appeals
+process under this Policy.
+
+g. *Special Measures:* If there is no finding of misconduct, the
+University should make reasonable and practical efforts as appropriate
+to restore the reputation of the Respondent.  Any such concerns by the
+Respondent should be directed to the Provost for follow up with other
+administrators as appropriate.
+
+
+## II. WPI Policy on Research Conduct
+
+(Approved by the Faculty, *December 12, 2017*)  
+(Approved by the Board of Trustees, *December 15, 2017*)
+
+### Introduction
+
+The integrity of the University and its academic endeavors require
+that teachers, researchers, advisors and other members of its
+community be dedicated to maintaining the highest ethical standards in
+their professional activities.  Unethical behavior in research and
+scholarship strikes at the heart of the scholarly and educational
+enterprise. A shared understanding of expectations and
+responsibilities is, therefore, critical - not only to the quality of
+the research enterprise but also to the collegial life of this
+community.
+ 
+Supervisors must enforce the highest standards for conducting research
+and creating and maintaining records of the research.  The risk of
+misconduct increases in an environment where there is a lack or
+deficiency of supervision.  Specifically, faculty supervisors,
+principal investigators, laboratory and center directors and
+Department Heads, should clearly articulate standards and protocols
+for research, scholarship, and creative work, through discussion and
+review of research, and, when possible, with written guidelines and
+training that adhere to best practices.
+
+In recognition of the need to maintain the highest standards in
+research conduct, WPI has developed the following policy to respond to
+allegations of research misconduct[^14] and to inform members of the
+community of the appropriate channels for bringing such matters to the
+attention of the University.[^15]  This policy applies to Research
+Activities conducted at WPI or by WPI faculty, staff, fellows,
+students.
+
+[^14]: This policy is based upon the federal regulations governing
+research misconduct in connection with United States Public Health
+Service ("PHS")-supported activities and will be interpreted and
+applied so as to be in compliance with those regulations.  WPI has
+also determined that this policy will be applied as the minimum
+standard to all allegations of research misconduct, regardless of the
+funding source(s) or whether the scholarly activity is funded.
+Institutional response to research misconduct allegations in areas not
+PHS-supported will follow the same general principles except for the
+actual involvement of PHS.  In the event another research sponsor has
+additional requirements beyond those covered by this policy, all
+research funded by that source will be subject to those additional
+requirements.
+
+[^15]: This policy replaces the prior policy entitled "Policy and
+Procedure for Removal of Tenured Faculty Member for Cause" adopted in
+1969 as it relates to matters concerning research misconduct.  This
+policy also replaces the Research Misconduct Policy passed by the
+Board of Trustees on December 13, 2013 and the Research Misconduct
+Policy passed by the Faculty on January 23, 2014.
+
+The appropriate institutional response to research misconduct will
+vary with the facts and circumstances of each case. In addition to
+requiring correction of the research record, WPI has recourse to a
+variety of disciplinary actions against individuals whose conduct
+violates this policy, including, in severe cases and following
+applicable procedures, expulsion of a student, termination of an
+employee, or revocation of tenure.
+
+The procedures described in this policy are consistent with
+requirements that apply to the review and reporting of allegations of
+research misconduct arising in the context of certain federally
+sponsored research.  This Policy should be reviewed and updated
+periodically in order to ensure compliance with applicable legal
+requirements.
+
+### Students
+
+If a student is involved in the review of an allegation of Research
+Misconduct (whether as a Complainant, as a Respondent, or as a person
+from whom information about allegations is obtained), fact finders and
+investigators must seek guidance from the Office of the Vice Provost
+for Research regarding the legal and policy requirements that may
+apply.
+
+Except as they may be subject to the requirements of grants, sponsored
+research or research funded by a governmental authority, allegations
+of Research Misconduct committed by students will be addressed in
+accordance with provisions of the Student Code of Conduct dealing with
+Student Academic Dishonesty.
+
+### Definitions
+
+Research Activities are proposing, conducting, processing, reviewing,
+or reporting the results of research or other scholarly inquiry.
+
+Research Misconduct is Fabrication, Falsification, or Plagiarism in
+Research Activities or Deliberate Interference.  It does not include
+honest error or differences of opinion.
+
++ *Fabrication* is making up data or results and recording or
+reporting them.
+
++ *Falsification* is manipulating research materials, equipment, or
+processes, or changing or omitting data or results such that the
+research is not accurately represented in the Research Record.
+
++ *Research Record* is the record of data or results that embody the
+facts resulting from scientific or other scholarly inquiry and
+includes, but is not limited to, research proposals, laboratory
+records (both physical and electronic), progress reports, abstracts,
+theses, oral presentations, internal reports, and journal articles.
+
++ *Plagiarism* is the appropriation of another person's ideas,
+processes, results, or words without giving appropriate credit.
+
++ *Deliberate Interference* is intentionally causing material harm to
+the research or scholarly work of others, and may include damaging or
+destroying the property of others, such as research equipment or
+supplies; disrupting active experiments; or altering or deleting
+products of research, including data and program codes.
+
+*Complainant* is an individual who reports allegations of Research
+Misconduct.
+
+*Respondent* is an individual who is the subject of allegations of
+Research Misconduct at WPI.
+
+*WPI Advisor* is a WPI community member of the Respondent's choice, not
+the Respondent's family member or subordinate, who may participate and
+provide support to a Respondent in any meeting in connection with a
+review under this Policy.  The role of the WPI Advisor is to provide
+support and guidance, not to be a substitute for the Respondent, who
+is the primary participant.
+ 
+*Preponderance of the Evidence* is proof by information that, compared
+with the information opposing it, leads to a conclusion that the fact
+at issue is more probably true than not.
+
+*Impartial and Unbiased Persons* are those who do not have unresolved
+personal, professional, or financial conflicts of interest with those
+involved with the inquiry or investigation.
+
+### Duty to Report
+
+Each member of the WPI community has a responsibility to report any
+conduct that they believe in good faith to be Research Misconduct at
+WPI. There may be circumstances in which, prior to taking that action,
+it would be appropriate for the Complainant to discuss any concerns
+with the prospective Respondent. Consultation and guidance is always
+available from the Vice Provost for Research or from senior academic
+officers (e.g. Deans, Department Heads, laboratory Directors), who
+themselves are bound by a Duty to Report.
+
+All allegations of Research Misconduct, wherever initially received,
+must be conveyed promptly to the Vice Provost for Research. A
+supervisor who becomes aware of possible Research Misconduct, either
+from the supervisor's own observations or because of reports, has a
+responsibility to bring allegations of Research Misconduct directly to
+the Vice Provost for Research in order to ensure that proper
+procedures are followed.
+
+If a supervisor feels that the Vice Provost for Research is not the
+appropriate official to whom to report allegations in a particular
+case, the allegations may be reported to the Provost. If a Complainant
+reports allegations to a supervisor and the supervisor fails to
+forward the allegations to the Office of the Vice Provost for Research
+or the Provost, then the Complainant should report the allegations to
+the Vice Provost for Research or the Provost directly.
+
+### Standard of Proof for a Finding of Research Misconduct
+
+In order to enter a finding of Research Misconduct, WPI must determine
+by a preponderance of the evidence that:
+
++ the Respondent engaged in Research Misconduct; and
++ the Research Misconduct marked a significant departure from accepted
+  practices of the relevant academic community; and
++ the Respondent committed the Research Misconduct intentionally,
+  knowingly, or recklessly.
+
+### Assessment and Review Process
+
+#### Initial Assessment
+
+Upon receipt of an allegation of Research Misconduct, within 5
+business days the Vice Provost for Research will conduct an initial
+assessment of the allegations, to determine whether the alleged
+misconduct falls within the scope of this Policy. The Vice Provost for
+Research may appoint an impartial fact finder with appropriate
+expertise to conduct this initial assessment and to make a
+recommendation to the Vice Provost for Research.
+   
+If the Vice Provost for Research determines that the allegations do
+not fall within this Policy, the Vice Provost for Research will either
+close the matter or refer it to another office at WPI with authority
+or responsibility over the matter.
+
+If the Vice Provost for Research determines that the allegations do
+fall within this Policy, the Vice Provost for Research will initiate a
+two-stage review process under this Policy.  The decision of the Vice
+Provost for Research to initiate or not to initiate a review is final.
+
+#### Subsequent Two-Stage Review Process
+
++ The first stage of review (the "Inquiry") under this Policy consists
+of preliminary fact-finding stage to decide whether to recommend to
+the Provost a further, formal review.  The Inquiry should begin within
+30 days after the Vice Provost for Research's initial assessment of
+the allegations.  Once initiated, the Inquiry normally must be
+completed within 60 calendar days.
+
++ If after the Inquiry, there is a decision by the Provost to initiate
+a further review, WPI will proceed to a second stage of review (the
+"Investigation"), which entails a formal review leading to a
+recommendation to the Provost whether or not WPI should make a finding
+of Research Misconduct and, if so, what the appropriate sanction
+should be.  If a formal investigation is warranted, it shall begin
+within 21 days of the conclusion of the Inquiry, and it is normally to
+be completed within 120 days once it has begun.
+
+#### Interim Institutional Actions
+
+At any point in the process, the Vice Provost for Research may
+institute appropriate interim institutional actions to protect the
+community, public health, federal or other governmental funds and
+equipment, and the integrity of the Public Health Services (PHS)
+supported research process. For such actions, the Vice Provost for
+Research should state the basis for such decision in a document
+maintained with records relating to the case and provided to the
+Respondent.
+
+### First Stage of Review: Inquiry
+
+The Inquiry consists of information gathering and fact-finding to
+determine as a preliminary matter whether an allegation of Research
+Misconduct warrants further, formal review. The Inquiry should begin
+within 30 days, if called for, after the Vice Provost for Research's
+initial assessment of the allegations.
+
+The Vice Provost for Research will appoint three impartial fact
+finders to conduct the Inquiry. If necessary, fact finders may be
+found from outside the WPI community. At this time, the Vice Provost
+for Research will provide written notice to the Respondent that an
+Inquiry has been initiated. The written notice ordinarily summarizes
+the allegations under review and advises the Respondent of the right
+to select a WPI Advisor to support the Respondent in the course of the
+proceedings. The Respondent will be given an opportunity to respond,
+in writing, to the Vice Provost for Research within 10 days following
+the Respondent's receipt of the allegation.  The Respondent may, in
+lieu of a WPI Advisor, have legal counsel for assistance or support
+during the Inquiry stage of the process.
+
+Either before or when the Respondent is notified, the Office of the
+Vice Provost for Research will promptly take all reasonable and
+practical steps to obtain custody of all the records and other
+evidence needed to conduct proceedings under this Policy and will
+sequester them in a secure manner.  The Office of the Vice Provost for
+Research will provide Respondent with reasonable, supervised access to
+the records or, when appropriate, copies of the records.  The Office
+of the Vice Provost for Research may seek additional records or other
+materials that may be potentially relevant during the course of the
+review.
+
+Oversight for the Inquiry process will be provided by the Office of
+the Vice Provost for Research.  The Inquiry should, to the extent
+reasonably possible, be limited to a review of documentary materials,
+including the Respondent's written response to the allegations. The
+fact that an Inquiry has been initiated should be made known only to
+the Respondent and other persons with a need to know.
+  
+At the conclusion of the Inquiry, the Inquiry Committee will prepare a
+draft written report summarizing the process and information reviewed
+and recommending whether to proceed with an Investigation. The draft
+Inquiry report should identify the name and position of the
+Respondent, a description of the allegations, the PHS support (if
+any), including the specific grant or contract, and should explain why
+the allegations do or do not warrant an investigation.
+ 
+A recommendation to proceed should be based on whether there are
+reasonable grounds to conclude that the allegations may have substance
+and that Research Misconduct may have occurred based on the
+information reviewed.  In either case, the Respondent will be given a
+copy of the draft Inquiry report and an opportunity to respond within
+a reasonable time period set by the Vice Provost for Research. Such
+response will be reviewed by the Inquiry Committee before finalizing
+the Inquiry report.  In addition, any comments provided by the
+Respondent will be included as an appendix to the final Inquiry
+report.  The final Inquiry report should state the number (but not the
+names) of the members of the Inquiry Committee who voted that an
+allegation warrants further review.  The final Inquiry report will be
+forwarded to the Vice Provost for Research.
+
+The Vice Provost for Research will review the Inquiry report and may
+ask the fact-finding committee for additional review or explanation.
+If this additional review by the fact-finding committee results in
+revisions to the report, the Respondent will have a further
+opportunity to submit written comments before any supplemental final
+Inquiry report is resubmitted to the Vice Provost for Research.
+
+The Vice Provost for Research will submit a final Inquiry report to
+the Provost along with a written recommendation whether or not to
+proceed with an Investigation.  The Provost will then decide whether
+or not to proceed with an Investigation.  Before the Provost decides
+to proceed with an investigation, the Provost shall consult with the
+fact-finding committee and with the Secretary of the Faculty.  If a
+majority of the Inquiry Committee voted not to proceed with an
+Investigation, but the Provost decides that there should be an
+Investigation, then the Provost should state the basis for such
+decision in a document maintained with records relating to the
+Investigation.
+
+Following these consultations, the Vice Provost for Research will send
+written notice to the Respondent of the Provost's decision whether or
+not to proceed with an Investigation. The Complainant, if known, will
+be informed whether an Investigation will or will not be initiated.
+ 
+The Inquiry, including preparation of the final Inquiry Report and the
+decision of the Provost on whether an investigation is warranted, must
+be completed within 60 calendar days of initiation of the Inquiry,
+unless the Vice Provost for Research determines that circumstances
+clearly warrant a longer period. If the Vice Provost for Research
+approves an extension, the inquiry record must include documentation
+of the reasons for exceeding the 60 day period.
+
+Within 30 days of a finding by the Provost that an investigation is
+warranted, the Provost shall provide ORI (and any other funding agency
+or authority required to be notified) with a copy of the Inquiry
+report, regardless of the vote of the Inquiry Committee.
+
+### Second Stage of Review: Investigation
+
+If a formal investigation is warranted, it shall begin within 21 days
+of the conclusion of the Inquiry.  The Vice Provost for Research
+initiates the Investigation by requesting the Secretary of the Faculty
+(SOF) and the Chair of the Faculty Review Committee (FRC) to appoint a
+five member investigation committee ("the Committee") to be selected
+from elected FRC members who have the expertise to evaluate the
+particular issues and evidence involved in the alleged misconduct.
+The faculty members must be unbiased toward the Complainant,
+Respondent and witnesses.  (If there are not five unbiased elected FRC
+members with the required expertise, then the SOF and FRC chair will
+appoint the required number of qualified faculty from outside the
+FRC. If the Respondent or Complainant is either the SOF or FRC Chair,
+then the other will appoint the Committee.)  The Committee shall elect
+its own Chair who shall be responsible for determining the manner in
+which the witness interviews and other procedures will be conducted by
+the Committee.
+ 
+The Vice Provost for Research will provide written notice to the
+Respondent that the Investigation has been initiated. The written
+notice will:
+
++ summarize the allegations;
++ advise the Respondent of the Respondent's right to the support of a
+  WPI Advisor or legal counsel in the Investigation; and
++ identify the members of the investigation Committee. 
+
+The Respondent may challenge the composition of the Committee, if s/he
+believes that one or more of its members is biased.  The remaining
+members of the Committee shall determine whether bias exists and
+otherwise act to ensure its own credibility.  The Committee shall
+request that the Chair of the FRC and the Secretary of the Faculty
+replace a committee member when appropriate.
+
+The Investigation consists of a formal examination and evaluation of
+all relevant information to determine if Research Misconduct occurred.
+The Investigation will typically include an examination of all
+relevant documentation and interviews of individuals who may have
+relevant information about the research in question.  The
+Investigation Committee may review the Inquiry findings but is not
+bound by the findings of the Inquiry.
+
+Oversight of the Investigation and specific guidance as it proceeds
+will be provided by the Office of the Vice Provost for Research.
+
+As the Investigation proceeds, the Office of the Vice Provost for
+Research should provide the Respondent with reasonable updates and
+opportunities to respond to information obtained in the investigation.
+
+Throughout the Committee Investigation process, the Respondent is
+entitled to the presumption of innocence, and:
+
++ shall have the opportunity to respond to allegations of Research
+  Misconduct;
++ shall have the opportunity to present a defense;
++ shall have the opportunity to offer witnesses to be interviewed by
+  the Committee; and
++ may, in lieu of a WPI Advisor, have legal counsel for assistance or
+  support.
+
+Once the Investigation is completed, the Committee will prepare a
+draft written report offering a judgment based on the evidence as to
+whether the Respondent has committed Research Misconduct, and if so,
+its level of severity.  If the Committee determines Respondent has
+committed Research Misconduct, it shall also recommend disciplinary
+action.  The report should summarize the facts and analysis that
+support those conclusions, addressing the merits of any reasonable
+explanation or defense provided by the Respondent, and including the
+numerical vote of the Committee without identifying individual votes.
+
+The Respondent will be provided with a copy of the draft Investigation
+report with an opportunity to respond within a reasonable time period
+set by the Vice Provost for Research. Such response will be considered
+by the Committee before the Committee takes a final vote, makes its
+final recommendation for disciplinary action, and issues its final
+Investigation report.  In addition, any comments provided by the
+Respondent will be included as an appendix to the final Investigation
+report. The final Investigation report will be forwarded to the Vice
+Provost for Research.
+
+The Vice Provost for Research will review the Investigation report and
+may ask the Investigation Committee for additional review or
+explanation. If this results in revisions to the report, the
+Respondent will have a further opportunity to submit written comments
+before any supplemental final Investigation report is resubmitted to
+the Vice Provost for Research.
+
+The Vice Provost for Research will submit the final Investigation
+report to the Provost and the Respondent along with a written
+recommendation whether or not WPI should make a finding of Research
+Misconduct. If the Vice Provost for Research recommends a finding of
+Research Misconduct, he or she will also recommend disciplinary
+actions to be taken. Before the Provost makes a finding of Research
+Misconduct, the Provost shall consult with the Committee and with the
+Secretary of the Faculty.
+ 
+If the Provost finds that Research Misconduct has been committed, the
+Provost shall decide on appropriate disciplinary actions, which may
+include, but are not limited to, formal reprimand, suspension,
+expulsion, revocation of degree, change in WPI status, revocation of
+tenure and termination of employment.  If a majority of the
+Investigation Committee voted that the Respondent did not commit
+Research Misconduct but the Provost decides that the Respondent did,
+or if the Provost decides on a disciplinary action that is different
+than the action recommended by the Investigation Committee, then the
+Provost should state the basis for such decisions in a document
+maintained with records relating to the investigation.
+
+The Vice Provost for Research will provide written notice of the
+Provost's decision to the Respondent. The Complainant, if known, will
+be informed whether there was a finding of Research
+Misconduct. However, WPI officials will not notify the Complainant of
+any disciplinary action taken. The Vice Provost for Research will send
+the final report to ORI (and any other funding agency or authority
+required to be notified), regardless of the vote or the disciplinary
+action recommended by the Investigation Committee.
+
+The Investigation is to be completed within 120 days of beginning it,
+including conducting the Investigation, preparing the report of
+findings, providing the draft report for comment and sending the final
+report to ORI.  However, if the Vice Provost for Research determines
+that the Investigation will not be completed within this 120-day
+period, the Vice Provost for Research will submit to ORI a written
+request for an extension, setting forth the reasons for the delay.
+
+### Appeals 
+
+The Respondent may appeal any finding of Research Misconduct, and any
+sanction other than termination of employment or revocation of tenure
+to the President within two weeks after the Provost notifies the
+Respondent of the imposition of the sanction.  The grounds of any
+appeal of a finding of Research Misconduct shall be limited to two
+instances:
+
+a. when there are alleged procedural violations that are substantial
+and material and which would have changed the outcome of the case; and
+
+b. when the Investigation Committee voted that the Respondent did not
+commit Research Misconduct but the Provost finds that Research
+Misconduct has occurred.
+
+Before the President decides the appeal, the President shall consult
+with the Provost and the Secretary of the Faculty.  The President
+should issue a decision within thirty days of receiving the appeal.
+The President's decision shall be final.
+
+If the Provost imposes a sanction of termination of employment or
+revocation of tenure, the Respondent may appeal the sanction to the
+Board of Trustees within two weeks after the Provost notifies the
+Respondent of the imposition of the sanction (or within two weeks
+after the President decides an appeal of a finding of Research
+Misconduct based on grounds a) or b) described above.  If the
+Respondent appeals to the Board, the Chair of the Board, in
+collaboration with the Secretary of the Faculty, shall appoint a
+committee of five faculty members who will make a recommendation
+regarding the sanction imposed by the Provost. The faculty committee
+will have access to all written reports and materials relevant to the
+case. The faculty committee will summarize the basis for its
+recommendation in a written report to the Board Chair within thirty
+days.  The Board Chair should issue a written decision within thirty
+days of receiving the faculty committee's report. The Board Chair's
+decision shall be final.
+
+Other than interim institutional actions which may already be in
+effect, any finding of Research Misconduct, and the imposition of any
+sanction imposed by the Provost, will be stayed while an appeal is
+pending before the President or the Board of Trustees.
+
+### Special Measures
+
+The Provost has the authority to mitigate the effects of the
+misconduct, including withdrawing WPI's name and sponsorship from
+pending abstracts and papers, notifying individuals known to have
+relied upon research that was affected by the misconduct, and taking
+formal steps to correct or retract publications and the Research
+Record.
+
+If there is no finding of Research Misconduct, all reasonable and
+practical efforts if requested and as appropriate, should be made to
+protect and restore the reputation of the Respondent.  All reasonable
+and practical efforts should be made to protect or restore the
+position and reputation of any complainant, witness or committee
+member and to counter potential or actual retaliation against these
+individuals.
+
+### Provisions Common to Misconduct Review Process
+
+#### No Conflicts of Interest
+
+To the maximum extent practicable, steps should be taken to ensure an
+impartial and unbiased process, including participation of persons
+(including fact-finders and investigators) who: (1) have sufficient
+expertise to carry out a thorough evaluation of the relevant
+information; and (2) have no real or perceived unresolved personal,
+professional, or financial conflicts of interest with those involved
+with the inquiry or investigation that could affect their ability to
+be objective reviewers.
+
+In cases where the Provost has a conflict of interest, the President
+shall serve in the Provost's role.  In cases where the Vice Provost
+for Research has a conflict of interest, the Provost will serve in
+that role.  In cases where allegations of Research Misconduct have
+been brought against the Vice Provost for Research, the Provost or the
+President, then the process outlined in this policy will be adjusted
+accordingly to avoid any conflicts of interest.  The President shall
+resolve any questions of bias or conflict of interest.  The
+President's decision on such questions shall be final.
+
+#### Confidentiality
+
+Proceedings concerning Research Misconduct often raise difficult
+issues for those making the allegations, for those who are the subject
+of the allegations, and for those responsible for reviewing the
+allegations.  Review of the allegations should therefore be conducted
+promptly and with care and sensitivity.
+
+All participants in the review process under this Policy are expected
+to maintain confidentiality to protect the privacy of all involved, to
+the extent possible and as permitted by law.  Participants should keep
+in mind the effect that allegations can have on reputations, even if
+the allegations are not sustained by the proceedings.  Thus, only
+those people with a need to know should be informed of a complaint.
+
+#### No Retaliation
+
+No one shall be retaliated against for participating in a review of a
+misconduct allegation in good faith as a Complainant, a witness, a
+factfinder, or investigator or in any other capacity.  Reasonable
+efforts should be made to counter potential or actual retaliation
+against these complainants, witnesses and committee
+members. Retaliation is typically a significant adverse action taken
+against an individual because the individual participated in a review
+process.  Retaliation is a serious offense.  A complaint of
+retaliation may be investigated and may lead to disciplinary action,
+up to and including terminating the individual's relationship with
+WPI.
+
+#### False Accusations or Testimony
+
+A false or unfounded report of misconduct determined by the Institute
+to have been made in bad faith and dishonesty in the context of an
+Inquiry or Investigation are serious offenses.  Such offenses may
+themselves be investigated and may lead to disciplinary action, up to
+and including termination of employment or other affiliation with WPI.
+
+#### Duty to Cooperate and Preserve and Produce Information 
+
+All members of the WPI community must cooperate with efforts to review
+allegations of Research Misconduct.
+
+While the destruction or absence of, or failure to provide upon
+request, information relating to allegations of Research Misconduct is
+not misconduct per se, such failure may be considered to be evidence
+supporting a finding of Research Misconduct when the evidence shows
+the Respondent had relevant information and intentionally, knowingly,
+or recklessly destroyed it; had the opportunity to maintain the
+information but did not do so; or maintained the information and
+failed to produce it in a timely manner in connection with a Research
+Misconduct proceeding, with the result that the Respondent
+significantly departed from accepted practices of the relevant
+academic community.
+
+#### Record Keeping
+
+The Office of the Vice Provost for Research is the custodian of
+records relating to proceedings under this Policy.
+
+#### Notice to Sponsors
+
+To the extent a sponsor requires notification from WPI that research
+it funded has become the subject of proceedings under this Policy, the
+Vice Provost for Research will supply that notification.  In addition,
+the Vice Provost for Research will give applicable sponsors written
+notice of any decision of the Provost entering a finding of Research
+Misconduct at WPI.
+
+
+## III. WPI Sexual Misconduct Policy[^16]
+
+[^16]: This Policy supersedes all WPI policies dealing with Sexual
+Misconduct including the "Sexual Misconduct Policy" in the Student
+Responsibilities and Code of Conduct, the "Sexual Harassment Policy"
+in the WPI Employee Benefits and Policies Manual, and the "Sexual
+Harassment Policy" in the Faculty Handbook.
+
+(Approved by the Faculty, *May 8, 2018*)  
+*Approved by the Board of Trustees, *May 11, 2018*)
+
+### Introduction: WPI's Commitment to a Campus Free from Sexual Misconduct
+
+WPI is committed to maintaining a learning and working environment
+that is free from sexual misconduct, remedying the effects of such
+misconduct when it occurs, and preventing its re-occurrence. The
+prohibition of sexual misconduct applies to everyone at WPI, including
+all faculty members (including academic administrators), staff members
+(including non-academic administrators), students, trustees, alumni
+and all visitors to the WPI campus.[^17]
+
+[^17]: Probationary staff, part-time employees, visitors, and
+employees subject to a letter of appointment or a collective
+bargaining agreement may be subject to a different disciplinary
+process in accordance with applicable policies and terms of their
+appointment.
+
+### Application of this Policy
+
+This Policy applies whenever sexual misconduct occurs: a) on WPI
+property; or b) off WPI property if: i) the sexual misconduct was in
+connection with a WPI or WPI-recognized program or activity; or ii)
+the sexual misconduct may have the effect of creating a hostile
+environment for a member of the WPI community.
+
+### Definitions
+
+#### a. Sexual Misconduct
+
+"Sexual misconduct" is prohibited under this Policy.  Sexual
+misconduct is a broad term that includes sexual harassment, sexual
+assault, sexual exploitation, gender motivated stalking, relationship
+abuse, engaging in certain inappropriate relationships, and
+retaliation against a person reporting sexual misconduct or
+participating in any investigation or proceeding related to this
+policy, all as defined below. This definition of sexual misconduct
+includes sexual assault (e.g. rape, fondling, incest, or statutory
+rape) as defined by the Clery Act, a federal law on campus safety and
+security. Sexual misconduct can occur between individuals who know
+each other, individuals who do not know each other, individuals who
+have an established relationship, and individuals who have previously
+engaged in consensual sexual activity. Sexual misconduct can be
+committed by persons of any gender identity, and it can occur between
+people of the same or different sex. Use of alcohol or other drugs
+will not excuse any behavior that violates this policy.
+
+1. *Sexual Harassment*
+
+Sexual Harassment is unwelcome conduct of a sexual nature, including
+sexual advances, requests for sexual favors, or other verbal,
+nonverbal, or physical conduct of a sexual nature, when:
+
+    Submission to such conduct is made either explicitly or implicitly
+    a term or condition of an individual's employment or academic
+    standing;
+
+    Submission to or rejection of such conduct by an individual is
+    used as the basis for significant employment decisions (such as
+    advancement, performance evaluation, or work schedule) or academic
+    decisions (such as grading or letters of recommendation) affecting
+    that individual;
+
+    The conduct is sufficiently severe or pervasive that a reasonable
+    person would consider it intimidating, hostile, or abusive and it
+    adversely affects an individual's educational, work, or living
+    environment.
+
+A partial list of examples of conduct that might be deemed to constitute sexual harassment if sufficiently severe or pervasive include:
+
+    Examples of verbal sexual harassment may include unwelcome conduct
+    such as sexual flirtation, advances or propositions or requests
+    for sexual activity or dates; asking about someone else's sexual
+    activities, fantasies, preferences, or history; discussing one's
+    own sexual activities, fantasies, preferences, or history; verbal
+    abuse of a sexual nature; suggestive comments; sexually explicit
+    jokes; turning discussions at work or in the academic environment
+    to sexual topics.
+
+    Examples of nonverbal sexual harassment may include unwelcome
+    conduct such as displaying sexual objects, pictures, or other
+    images; invading a person's personal body space, such as standing
+    closer than appropriate or necessary or hovering; displaying or
+    wearing objects or items of clothing which express sexually
+    offensive content; making sexual gestures with hands or body
+    movements; looking at a person in a sexually suggestive or
+    intimidating manner; or delivering unwanted letters, gifts, or
+    other items of a sexual nature.
+
+2. *Sexual Assault*
+
+Sexual assault is any intentional sexual contact or activity that
+occurs without the consent of any individual involved.
+
+3. *Sexual Exploitation*
+
+Sexual Exploitation is purposefully taking sexual advantage of another
+person without consent.  Examples of sexual exploitation include:
+
++ Sexual voyeurism, such as watching a person undressing, using the
+  bathroom or engaged in sexual activity without the consent of the
+  person observed.
+
++ Taking pictures or video or an audio recording of another person
+  engaging in sexual activity or exceeding the boundaries of consent
+  (such as allowing another person to hide in a closet and observe
+  sexual activity or disseminating sexual pictures without the
+  photographed person's consent).
++ Engaging in sexual activity with another person while knowingly
+  infected with human immunodeficiency virus (HIV) or other sexually
+  transmitted disease (STD) without informing the other person of the
+  infection.
++ Administering alcohol or drugs (such as "date rape" drugs) to
+  another person without their knowledge or consent.
+
+4. *Gender-motivated Stalking*
+
+Stalking is defined as a pattern of actions or course of conduct
+directed at a specific person over time that would cause a reasonable
+person to feel fear. This policy covers those instances where the
+stalking of a person is motivated by the person's real or perceived
+gender, sex, or sexual orientation. For the purposes of this
+definition, "course of conduct" means two or more acts, including, but
+not limited to, acts in which the stalker directly, indirectly, or
+through third parties, by any action, method, device, or means,
+follows, monitors, observes, surveils, threatens, or communicates to
+or about a person, or interferes with a person's property.
+
+Stalking can take many forms. Examples include, but are not limited
+to, two or more instances of the following conduct (that also meet the
+definition of stalking above): following a person; appearing at a
+person's home, class or work; continuing to contact a person after
+receiving requests not to; leaving written messages, objects, or
+unwanted gifts; vandalizing a person's property; photographing a
+person; and other threatening, intimidating, or intrusive
+conduct. Stalking may also involve the use of electronic media such as
+the internet, social networks, blogs, cell phones, texts, or other
+similar devices (often referred to as cyber-stalking). Such conduct
+may include, but is not limited to, non-consensual communication,
+telephone calls, voice messages, emails, texts, letters, notes, gifts,
+or any other communication that are repeated and undesired.
+
+5. *Relationship Abuse*
+
+Relationship abuse is defined as behavior that serves to exercise
+control and power in an intimate relationship. The behaviors can be
+physical, sexual, psychological, verbal and/or emotional. Relationship
+abuse can occur between current or former intimate partners who have
+dated, lived together, have a child together, currently reside
+together on or off campus, or who have otherwise connected through a
+past or existing relationship. It can occur in opposite-sex and
+same-sex relationships.
+
+Examples of relationship abuse include but are not limited to:
+attempting to cause or causing bodily injury by hitting, slapping,
+punching, hair pulling, kicking, sexual assault and/or other forms of
+unwanted physical contact that cause harm; knowingly restricting the
+movements of another person; isolating or confining a person for a
+period of time; controlling or monitoring behavior; being verbally
+and/or emotionally abusive; and exhibiting extreme possessiveness or
+jealousy.
+
+6. *Sexual or Romantic Relationships in the Workplace or Academic Environment*
+
+*With undergraduate students.*  Except in rare and unusual circumstances
+involving preexisting relationships, sexual and romantic relationships
+between WPI employees3 and undergraduate students are inappropriate
+and are prohibited.
+
+*With graduate students.*  Implicit in the area of professionalism is
+the recognition by those in positions of authority that in
+relationships with graduate students there is always an element of
+power and consent to a romantic relationship that may not be valid
+where either person in the relationship has direct or indirect power
+or control over any aspect of the other person's academic or
+employment environment.  Therefore, sexual and romantic relationships
+between employees and graduate students are prohibited where there is
+a supervisory relationship between the employee and the graduate
+student.
+
+*With supervisees.* It is incumbent upon members of the WPI community
+to refrain from abusing, and seeming to abuse, the power with which
+they are entrusted, because relationships between supervisors
+(including TA's and RA's) and supervisees are fundamentally asymmetric
+in nature, may be the product of subtle or not-so-subtle coercion, or
+may lead to favoritism for the subordinate.  If a student employee
+(i.e. TA, RA, PLA, undergraduate student assistant, or work-study
+student) is assigned to a course and has a preexisting sexual or
+romantic relationship with one of the enrolled students, he or she is
+obligated to inform the instructor of the course so that alternative
+arrangements can be made.
+
+7. *Retaliation*
+
+Retaliation means any materially adverse action or threat taken or
+made against an individual, including through third parties and/or
+legal counsel, for making a report of misconduct or participating in
+any investigation or proceeding related to this policy. Retaliation
+includes threatening, intimidating, harassing, or any other conduct
+that would discourage a reasonable person from engaging in activity
+protected under this policy, such as seeking services, receiving
+interim protective measures and accommodations, and/or reporting
+misconduct. Retaliation includes maliciously and purposefully
+interfering with, threatening, or damaging the academic and/or
+professional career of another individual before, during or after the
+investigation and resolution of a report of misconduct under this
+policy in response to and/or on account of the report of
+misconduct. This provision only applies to reports made or information
+provided in good faith, even if the facts alleged in the report are
+determined not to be accurate.
+
+#### b. Consent
+
+1. *What is Consent?*
+
+Consent is the positive, unambiguous, and voluntary agreement to
+engage in specific sexual activity throughout a sexual encounter.
+Consent must be an informed, deliberate and voluntary decision to
+engage in mutually acceptable sexual activity. It is the
+responsibility of the person who initiates sexual activity to make
+sure consent is received from any other person(s) involved.  WPI
+recognizes that there are a wide variety of sexual interactions, that
+there is no single way to communicate consent, and that context
+matters. At all times, each party is free to choose where, when, and
+how they participate in sexual activity. Accordingly, when evaluating
+whether sexual activity was consensual, WPI will consider the entirety
+of the sexual interaction and the relevant circumstances.
+	
+Consent is active not passive. Individuals should be able to clearly
+articulate why and how they believed they received consent and what
+they considered to be indications of consent as they engaged in sexual
+activity.  Consent must be received for each sexual act.  It is
+important to remember:
+
++ Consent to one sexual act does not constitute or imply consent to
+  another act.
++ Previous consent does not imply consent to future sexual activity.
++ Consent cannot be assumed based on the parties' relationship or
+  sexual history.
++ Consent can be withdrawn at any time before or during sexual
+  activity.
+
+2. *What is Not Consent?*
+
+Consent may not be inferred from silence, passivity or a lack of
+objection. The absence of a negative response, such as silence or a
+failure to resist, does not equal consent. Some behaviors and comments
+that do not indicate affirmative consent include but are not limited
+to:
+
++ "I don't know"
++ "Maybe"
++ A head shake
++ Lack of objection
++ Not fighting back
++ A verbal "no" that may sound indecisive or insincere
+         
+3. *Consent Can Never Be Given By:*
+
++ *Someone who is incapacitated.* It is a violation of this Policy to
+engage in sexual activity with a person who an individual knew or
+should have known was incapacitated. A person can be incapacitated
+through the use of drugs, alcohol or any other intoxicating substance,
+medications or when they are unconscious, asleep or otherwise unaware
+that sexual activity is occurring.
+
++ *Someone under the legal age of consent.*  The legal age of consent
+in the Commonwealth of Massachusetts is sixteen (16).
+
++ *Someone who is mentally disabled or cognitively impaired.*  It is a
+violation of this Policy to engage in sexual activity with a person
+whose mental disability or cognitive impairment renders them incapable
+of giving consent and the disability/impairment is known or should
+have been known to the non-disabled sexual partner.
+
+4. *Consent and the Use of Alcohol or Drugs*
+
+The use of alcohol or drugs does not relieve an individual of the
+obligation to obtain consent before initiating and/or engaging in
+sexual activity.
+
+### Obligations of Employees to Report Sexual Misconduct
+
+#### a. Responsible Employees 
+
+1. All employees (except Confidential Resource Advisors; identified
+below) who learn of a violation of this Policy involving students are
+required to immediately report such information to the Title IX
+Coordinator or a Deputy Coordinator.
+
+2. All supervisors (except Confidential Resource Advisors) who learn
+of a violation of this Policy are required to immediately report such
+information to the Title IX Coordinator or Deputy Coordinator.
+
+3. Employees will receive regular training in their duty to report
+sexual misconduct.
+
+#### b. Confidential Resource Advisors
+
+The following employees, who will receive regular training, may serve
+as confidential advisors for students and are not required to report
+violations of this Policy:
+
+1. Employees of Student Health Services.
+2. Employees of the Student Development and Counseling Center. 
+3. A chaplain or religious advisor working at WPI.
+4. WPI Ombudspersons and any other individual with appropriate
+   training who is specifically appointed by WPI for the purpose of
+   serving as a confidential resource advisor.
+
+### Resources Available in Cases of Sexual Misconduct
+
+Anyone who has experienced sexual misconduct or is aware of someone
+who may have been the victim of sexual misconduct is strongly
+encouraged to report such misconduct and to take advantage of
+resources available on campus and in the community.
+
+a. Reporting Sexual Misconduct Immediately After a Sexual Assault If
+you or someone you know has recently been assaulted:
+
+    + Go to a safe place as soon as you can.
+
+    + In an emergency, call campus police at 508-831-5555, or 5555
+    from a campus phone or via a blue light phone on campus.  If it is
+    not an emergency, then call the WPI Police Department at
+    508-831-5433.
+
+    + *Seek medical attention.* The WPI Student Development and
+    Counseling Center offers counseling appointments to all students.
+    The Emergency Room at UMass Medical Center offers services and
+    support for people who have experienced sexual assault.  WPI
+    Police can provide students with an escort to the hospital.
+
+    + Try to preserve all physical evidence.
+
+    + If you are the victim of a sexual assault, try not to wash your
+    face or hands, bathe, brush your teeth, drink or eat, douche, or
+    change clothes if you can avoid it. If you do change your clothes,
+    put all clothing you were wearing at the time of the assault in
+    individual paper bags (not plastic).  It is important to preserve
+    as much evidence as possible should you later decide to press
+    criminal charges.
+
+b. Reporting Sexual Misconduct to the Title IX Coordinator and or Deputy Title IX Coordinators
+
+The Title IX Coordinator plays an integral role in carrying out the
+University's commitment to provide a positive learning, teaching and
+working environment free from sexual misconduct and
+discrimination. Any student, faculty member, or staff member who has
+concerns about sexual misconduct is encouraged to seek the assistance
+of those listed below. They will provide information on resources for
+assistance and options to address concerns. Those options may vary
+depending on the nature of the situation, whether the individuals
+involved are students, faculty, or staff members, the wishes of the
+individuals involved regarding confidentiality, and whether the
+individuals involved prefer to proceed formally or informally.
+
+During business hours, anyone who has experienced sexual misconduct or
+is aware of someone who may have been the victim of sexual misconduct
+may contact the Title IX Coordinator or any Deputy Title IX
+Coordinator.  Contact information for the Title IX Coordinator and
+Deputy Coordinators can be found [HERE](link).
+
+c. Reporting Sexual Misconduct Anonymously
+
+If you are concerned about a visitor, student, faculty, or staff
+member who may have experienced a Title IX violation or may have
+committed a Title IX violation, you may report the situation
+anonymously by clicking [HERE](link).  In that case, you will not be
+contacted and will remain anonymous.  If you wish, you may include
+your contact information, so we may contact you if we have additional
+questions.
+
+NOTE: This is not a system to use for emergencies.  In case of an
+emergency, regardless of time of day, in which someone's well-being is
+in jeopardy, please contact Campus Police at +1-508-831-5555.
+
+### Initial Steps and Investigation of Reports of Sexual Misconduct
+
+#### a. Initial Steps
+
+All reports of alleged sexual misconduct will be referred to the Title
+IX Coordinator.  Within five business days of receiving such a report,
+the Title IX Coordinator or their designee[^18] will take several
+initial steps. These initial steps will include, but are not limited
+to, the following:
+
+[^18]: As necessary and appropriate, the Title IX Coordinator may
+designate a Deputy Title IX Coordinator or another qualified person to
+assume the Title IX Coordinator's responsibilities under this Policy.
+
+    1. Encouraging the person who has allegedly experienced sexual
+    misconduct (the "Complainant")[^19] to meet with the Title IX
+    Coordinator to discuss the nature and circumstances of the
+    reported conduct.  If the person who has reported the alleged
+    sexual misconduct is not the person who has experienced the sexual
+    misconduct, then the person who has made the report should have
+    the opportunity to meet with the Title IX Coordinator to discuss
+    the nature and circumstances of the reported conduct.
+
+[^19]: Throughout this Policy, the term "Complainant" refers to the
+person who experienced sexual misconduct regardless of who reported
+the misconduct.
+
+    2. Notifying the Complainant about their rights and options under
+    this Sexual Misconduct Policy, including the right to report and
+    the right to decline to report the matter to campus police and/or
+    to local law enforcement, the options for reporting to WPI, and
+    the availability of medical treatment, counseling, and other
+    resources, both on and off campus.
+
+    3. Meeting with the person who has allegedly committed sexual
+    misconduct (the "Respondent") to explain the allegation and to get
+    their version of events, and providing that person with the option
+    and adequate opportunity to provide a written response to the
+    allegations.  The Respondent should be notified about their rights
+    under this Sexual Misconduct Policy, and about the availability of
+    counseling and other on- and off-campus resources.
+
+    4. If the Complainant requests that the process not move forward,
+    the Title IX Coordinator will weigh that request against WPI's
+    obligation to address any risk of harm to the Complainant or other
+    individuals in the community, and the nature of the incident or
+    conduct at issue.  If, following the receipt of an alleged
+    violation of this Policy, the person who allegedly experienced
+    sexual misconduct declines to participate in the investigation or
+    resolution process or requests that the process not proceed, the
+    Title IX Coordinator may decide to close the investigation or
+    choose to continue the process without the person's participation.
+
+    5. Assessing the reported conduct to determine whether the
+    circumstances warrant appropriate interim measures including, but
+    not limited to, no-contact orders, interim suspension of a
+    student, deadline extensions, reassignment of housing, or placing
+    an employee on paid leave prior to completing an
+    investigation. Failure to comply with an interim measure may lead
+    to additional disciplinary action.
+
+    6. Assessing whether the behavior alleged constitutes a violation
+    of this Policy and is sufficiently credible and specific so that
+    potential evidence of such misconduct may be identified.  If the
+    Title IX Coordinator determines that the reported conduct would
+    not trigger this Policy, they will advise both the Complainant and
+    the Respondent in writing, and based on the information gathered
+    may also refer the reported conduct to the appropriate
+    administrator or department for handling consistent with any other
+    applicable policy.  If the Title IX Coordinator determines that
+    the reported conduct does fall under this Policy, then the case
+    will proceed to the Investigation Phase, as described below.
+
+#### b. The Investigation Phase
+
+1. *Notice of an Investigation:* If it is determined that an
+investigation is required, the Title IX Coordinator will send a
+written notice to the Complainant (or "party") and to the Respondent
+(or "party") (collectively, the "parties").  The notice will include a
+sufficiently detailed description of the allegations, the portions of
+this Policy that are alleged to have been violated, and any interim
+measures in place about which either party should be made aware. This
+written notice does not constitute a finding or a determination of
+responsibility.
+
+The notice will also state that if either party requires any kind of
+accommodation due to disability pursuant to the ADA or Section 504 of
+the Rehabilitation Act, it is the responsibility of that party to make
+the Title IX Coordinator aware of the need for an accommodation.  The
+Title IX Coordinator will work with each of the parties and as
+applicable, Office of Disability Services (for students) and/or the
+504 Coordinator (for employees) to ensure that appropriate
+accommodations are available.
+
+2. *Information about Advisors:* Each party may have a single advisor
+present during any investigative proceeding, including any related
+meeting, interview, or hearing.  Any person may serve as an advisor,
+including an attorney.  Each party must provide the name and contact
+information of their advisor to the Title IX Coordinator within five
+business days of receiving notice of an investigation. Advisors may
+communicate with their advisee but may not may not speak or otherwise
+communicate on behalf of a party.  Advisors are subject to the same
+confidentiality obligations applicable to others in attendance.
+
+3. *Designation of Role of the Investigator:* The Title IX Coordinator
+shall designate at least one unbiased, qualified investigator(s)[^20]
+to conduct a prompt, fair, and impartial investigation of the reported
+conduct and prepare a report of investigative findings (the
+"Investigative Report").[^21] More than one investigator may be
+designated or the investigation may be conducted by the Title IX
+Coordinator.  Investigator(s) need not be employees of WPI.  The Title
+IX Coordinator will provide each of the parties with the name of the
+Investigator(s). As soon as possible, but no later than three (3)
+calendar days after delivery of the identity of the Investigator(s),
+the parties should inform the Title IX Coordinator (in writing) of any
+potential conflicts of interest about the selected Investigator(s).
+The Title IX Coordinator will consider the nature of the potential
+conflict and determine if a change is necessary.[^22] The Title IX
+Coordinator's decision (in appropriate collaboration with the
+Secretary of the Faculty, as described in footnote 9) regarding any
+conflicts regarding the investigator(s) is final.
+
+[^20] The investigator shall be deemed "qualified" if the individual
+has received training in conducting Title IX investigations and has
+the requisite professional experience to conduct the investigation.
+
+[^21] If the Respondent is a faculty member, the Title IX Coordinator
+will collaborate with the Secretary of the Faculty, in appointing the
+Investigator and in rendering a decision regarding any potential
+conflicts of interest involving the investigator.
+
+[^22] If the Respondent is a faculty member, the Title IX Coordinator
+will collaborate with the Secretary of the Faculty in making a
+decision about whether or not to disqualify an Investigator when the
+faculty member objects based on a potential conflict of interest.  If
+a party raises an objection based on a potential conflict of interest
+involving the Title IX Coordinator serving as investigator, the role
+of the Title IX Coordinator in deciding about whether a conflict
+exists, and whether another investigator should be designated, will be
+assumed by the President.
+
+4. *Nature of the Investigation:* The investigation will include
+separate interviews with the Complainant (unless that person chooses
+not to participate in the investigation), the Respondent, and any
+witnesses whom the Investigator(s) believe will provide necessary and
+relevant information. The investigation will include the review of
+documentation or other items relevant to the reported conduct.
+
+5. *Identification of Potential Witnesses and Documentation:* The
+parties will have the opportunity to provide the Investigator(s) with
+written notice of the names and contact information of potential
+witnesses with whom they would like the Investigator(s) to speak
+together with a brief explanation of how the persons, documents,
+and/or items are relevant to the reported conduct. The parties may
+also provide the Investigator(s) with any documentation or other items
+or questions they would like to be considered or posed to any witness
+or the other party. The Investigator(s) will exercise discretion in
+determining what information and questions to consider and which
+potential witnesses will be interviewed.
+
+6. *Participation in the Investigation:* Participation in the process
+(by providing information to the Investigator(s), responding to
+questions from the Investigator(s), responding to information provided
+by a party or a witness, etc.) is not required, but the Investigation
+will proceed even if a party or witness declines to
+participate. During the investigation, the parties will have an equal
+opportunity to participate. If a party initially declines but then
+later in the Investigation decides to participate, the Investigator(s)
+may consider that timing when determining the credibility of the
+information/evidence offered and the weight to give that
+information/evidence.
+
+7. *Investigation Prohibitions:* The Investigator(s) will not gather
+or consider information related to either party's sexual history with
+other persons except as relevant to the alleged violation, as
+determined in the sole discretion of the Investigator(s).
+
+8. *Coordination with Law Enforcement:* The Investigator or designee
+may contact any law enforcement agency that is conducting its own
+investigation to inform them that a WPI investigation is also in
+progress; to ascertain the status of the criminal investigation; and
+to determine the extent to which any evidence collected by law
+enforcement may be available to WPI in its investigation. At the
+request of law enforcement, the Investigator may delay the
+investigation temporarily while an external law enforcement agency is
+gathering evidence. The Investigator will generally resume the
+investigation when notified that law enforcement has completed the
+evidence-gathering stage of its criminal investigation.
+
+#### c. Optional Informal Resolution Procedure
+
+At any time prior to convening a Judicial Panel (defined below), a
+Party may contact the Title IX Coordinator to request an informal
+resolution of a complaint.  All parties and the Title IX Coordinator
+must agree to informal resolution for this option to be used. If the
+Title IX Coordinator determines that informal resolution is
+appropriate, the Title IX Coordinator will attempt to reach a
+resolution.  The allegation will be deemed resolved when the parties
+expressly agree to an outcome that is acceptable to them and is
+approved by the Title IX Coordinator in consultation with other
+appropriate administrators.
+
+### Procedures Following the Investigative Phase of a Title IX Investigation
+
+#### a. The Investigative Report
+
+After the Investigation Phase, the Investigator(s) will deliver an
+Investigative Report to the Title IX Coordinator.  The Investigative
+Report should include a description of the alleged sexual misconduct,
+and a summary of the information presented during the Investigation
+Phase including a section where the Investigator(s) point out relevant
+consistencies or inconsistencies (if any) between different sources of
+information.  The Investigative Report will not include a
+recommendation or a determination as to whether a party has violated
+the Sexual Misconduct Policy or what sanctions may be appropriate.
+These determinations will be made by the Judicial Panel, as described
+below.
+
+#### b. Review by the Parties
+
+Within five (5) business days of receiving the Investigative Report,
+the Title IX Coordinator will provide each party with a copy of the
+Investigative Report.  Each party will have an opportunity to submit
+written comments to the Title IX Coordinator about the Investigative
+Report within five (5) business days of receiving the report.  The
+time to submit written comments may be extended if the Title IX
+Coordinator concludes, in his/her sole discretion, that additional
+time is warranted.  After reviewing the submissions, if any, from the
+parties, the Title IX Coordinator may determine that additional
+investigation is required, in which case the Investigator will
+supplement the Investigative Report and submit a final Investigative
+Report to the Title IX Coordinator.  Any submissions made by either
+party, as well as any other documentation deemed relevant by the
+Investigator(s), will be attached to the Investigative Report.  Within
+three (3) business days of receiving the final Investigative Report,
+the Title IX Coordinator will provide each party with a copy of the
+final Investigative Report.
+
+#### c. Convening the Judicial Panel
+
+The Title IX Coordinator will convene a five-member Judicial Panel
+(the "Judicial Panel") from a previously established pool of WPI
+faculty members elected by the Faculty to the Campus Hearing Board,
+staff members and students trained to decide sexual misconduct
+cases. The process for selecting staff members and students for the
+pool and the training process for all members of the pool is set by
+the Title IX Coordinator in collaboration with the Dean of Students
+Office, the Secretary of the Faculty, and the Human Resources
+Department.  Students will only serve on panels where the Respondent
+is a student.  If the Respondent is a student, the Judicial Panel
+should include a student member unless either party elects not to have
+a student serve on the Judicial Panel.  If the Respondent is a faculty
+member, the Judicial Panel should include at least three faculty
+members. If the Respondent is a staff member, the Judicial Panel
+should include at least three staff members. The Title IX Coordinator
+will provide the parties with the names of the persons assigned as the
+Judicial Panel members for their case.  As soon as possible, but no
+later than three (3) business days after delivery of the identity of
+the assigned Judicial Panel members, the parties should inform the
+Title IX Coordinator in writing of any conflicts of interest regarding
+the members assigned to the Judicial Panel. If a conflict of interest
+is raised regarding any of the individuals assigned to the Judicial
+Panel, the Title IX Coordinator will consider the nature of the
+conflict and determine if different individuals should be assigned to
+the Judicial Panel.  The Title IX Coordinator should consult with
+other WPI personnel (and shall collaborate with the Secretary of the
+Faculty in the case of any conflict of interest raised by a faculty
+member who is a party in the case or with respect to a proposed
+Judicial Panel member who is a faculty member) to assess any conflicts
+of interest. The Title IX Coordinator's decision (in appropriate
+collaboration with the Secretary of the Faculty) regarding any
+conflicts is final.  The Title IX Coordinator will then submit the
+Investigative Report to the Judicial Panel members who will set a
+schedule for the Judicial Panel to convene a hearing or hearings.
+
+#### d. Training Members of the Judicial Panel
+
+Proper training is a vital aspect of the integrity of the judicial
+process.  Therefore, all members of the Judicial Panel shall receive
+appropriate orientation and training, in keeping with applicable law
+and national best practices. Training and orientation shall be
+overseen and approved by the Title IX Coordinator.
+
+#### e. Role and Responsibilities of the Judicial Panel
+
+The Judicial Panel will obtain the Investigative Report from the Title
+IX Coordinator and convene to review the Investigative Report.  The
+Judicial Panel, in its discretion, may request the Investigator(s) to
+attend a Judicial Panel meeting and answer questions.  The Judicial
+Panel, in its discretion, may request the Investigator(s) to conduct
+additional investigation on specific points.  The Judicial Panel must
+request the parties that participated in the investigation to appear
+and answer questions posed by the Judicial Panel.  In addition, the
+Judicial Panel, in its discretion, may request to speak with any
+individual identified in the Investigative Report as well as any other
+individual with relevant information including individuals identified
+by the parties.
+
+In general, a Complainant, witness, or Respondent who had the
+opportunity to participate during the Investigation but elected not to
+participate will not be permitted to participate verbally in the
+hearing or submit documents prior to the hearing. The Judicial Panel
+may permit a Complainant, witness, or Respondent who did not
+participate in the Investigation to participate in the hearing upon a
+showing of good cause. Exceptions of this nature are expected to be
+rare. The possibility of a law enforcement investigation or criminal
+court proceedings will generally not be considered good cause for an
+exception. In general, documents that have not been submitted during
+the Investigation may not be presented to the Judicial Panel, although
+the Judicial Panel may permit documents to be submitted that were not
+part of the Investigation upon a showing of good cause. The Judicial
+Panel may, however, consider the fact that the documents were not
+provided during the Investigation when determining the credibility of
+the information/evidence offered and the weight to give that evidence.
+
+The Judicial Panel will decide by majority vote whether the Respondent
+is responsible for violating the Sexual Misconduct Policy, whether
+sanctions are appropriate and, if so, what those sanctions shall be.
+The Judicial Panel should state the basis for such decisions in a
+document maintained with records relating to the case.
+
+#### f. Standard of Proof
+
+All findings and determinations of responsibility and sanctions will
+be made using a preponderance of the evidence standard. This standard
+requires the determination of whether it is more likely than not that
+a fact exists or a violation of the Sexual Misconduct Policy occurred.
+
+#### g. Rights of the Parties
+
+Throughout the process, the parties shall have:
+
++ the presumption of innocence;
++ the opportunity to present evidence and respond to allegations of
+  sexual misconduct;
++ the opportunity to present a defense; and
++ the opportunity to offer witnesses to be interviewed by the
+  Investigator and questioned by the Judicial Panel.  Neither party
+  will be permitted to question or cross-examine the other party
+  during any hearing held by the Judicial Panel.
+
+##### h. Sanctions
+
+A finding of responsibility for Sexual Misconduct can result in a wide
+range of sanctions, depending on the circumstances of a particular
+case.  When the Respondent is a student, examples of sanctions include
+community service, counseling, probation, suspension from residence
+hall, suspension from the university for one or more terms, expulsion
+from WPI.  When the Respondent is a staff member or a faculty member,
+examples of sanctions include community service, counseling,
+probation, reassignment of duties, suspension with pay, suspension
+without pay, and termination of employment at WPI.  In deciding an
+appropriate sanction, the Judicial Panel shall consider the following
+factors:
+
++ the nature and circumstances of the misconduct;
++ the impact of the misconduct on the person who experienced Sexual
+  Misconduct;
++ the disciplinary history of the Respondent;
++ any other mitigating or aggravating circumstances in order to reach
+  a fair and appropriate resolution in each case.
+
+### Notification of Decision
+
+Upon reaching a determination of responsibility by majority vote, the
+Judicial Panel will provide a written notification of its decision to
+the Title IX Coordinator.  The written notification will consist of a
+statement of the allegations, the Judicial Panel's factual findings, a
+decision as to whether the Respondent committed Sexual Misconduct, any
+sanction, and the rationale for these decisions.  This written
+document shall be maintained with records relating to the case.  The
+Title IX Coordinator will forward to the parties simultaneously (i)
+the Judicial Panel's written notification described above; and (ii)
+the procedures for either party to appeal. The Title IX Coordinator
+will also inform other WPI officials as necessary and appropriate.
+
+### Appeals[^23]
+
+[^23]: All Appellate Officers, including the President and Board Chair,
+will receive Title IX training.
+
+All appeals (in Section "a" below) and special appeals (in Section "b"
+below) should be delivered to the Title IX Coordinator who will
+transmit the appeal to the appropriate Appellate Officer.
+
+#### a. Appeals Available to Either Party
+
+Within seven (7) business days following the delivery of the notice of
+the Judicial Panel's determination of responsibility and sanction,
+either Party may appeal the decision and/or sanction to the
+appropriate Appellate Officer.  If the Respondent is a student, the
+Appellate Officer is the Vice President for Student Affairs.  If the
+Respondent is a faculty member, the Appellate Officer is the Provost
+(unless the Respondent is a full-time faculty member who the Judicial
+Panel has determined should be dismissed or suspended, in which case
+Section b. below applies). If the Respondent is a staff member, the
+Appellate Officer is the Vice President of Talent and Chief Diversity
+Officer.
+
+If potential bias or conflict of interest is raised by either party
+regarding the Appellate Officer, the President will consider the
+nature of the potential bias or conflict (and, before deciding the
+matter, shall collaborate on the matter with the Secretary of the
+Faculty in the case of any conflict of interest raised by a party who
+is a faculty member) to assess any conflicts of interest and determine
+if a different individual should be assigned the role of Appellate
+Officer.  The Appellate Officer shall not be involved in the appeal
+until the President has resolved any questions of conflict of
+interest.
+
+The party submitting the appeal must set forth in detail the grounds
+for appeal and must identify or attach all materials to be considered
+in the appeal process.  The Title IX Coordinator will provide a copy
+of the appeal submitted by one party to the other party, and the other
+party may submit any additional materials that they wish to have
+considered in the appeal process within seven (7) business days of
+receipt of the appeal.
+
+Within 14 business days after receiving an appeal (including
+additional materials, if any), the Appellate Officer will decide the
+merits of the appeal.  In deciding the appeal, the Appellate Officer
+should rev iew evidence considered by the Judicial Panel and may also
+consult with the Investigator(s), the Judicial Panel, or any other
+individual that the Appellate Officer deems appropriate.[^24] In a
+case where the Appellate Officer overturns a decision of the Judicial
+Panel, the Appellate Officer shall first consult with the
+Investigator(s), the Judicial Panel, and any other individual that the
+Appellate Officer deems appropriate.
+
+[^24]: Because the President may have a role in the appellate process
+involving full time faculty members facing suspension or dismissal,
+the appellate officer shall not communicate with the President
+regarding a full-time faculty member's appeal.
+
+Sanctions may be imposed, in full or in part, while an appeal is
+pending.
+
+The decisions concerning responsibility and sanction, if any, and
+reasoning of the Appellate Officer(s) will be provided in a written
+document and will be final, except for circumstances that permit a
+Special Appeal, as described below.  The written document shall be
+maintained with records relating to the case.
+
+The Appellate Officer will forward the written document to the Title
+IX Coordinator, and the Title IX Coordinator will inform the parties
+simultaneously of the outcome of the appeal by forwarding to them the
+Appellate Officer's written document.
+
+#### b. Special Appeals with respect to a Respondent who is a Full-Time Faculty Member Involving a Recommended Sanction of Dismissal or Suspension
+
+The following appeal process applies in two cases:
+
+1. As the sole method of appeal of a determination by a Judicial Panel
+that a Respondent who is a full-time faculty member should be
+dismissed or suspended; and
+
+2. As an appeal of a determination by the Appellate Officer that a
+Respondent who is a full-time faculty member should be dismissed or
+suspended when that determination was made on appeal of a Judicial
+Panel's decision not to impose such sanctions on the Respondent.
+
+Such appeals appeal will be subject to the following procedure:
+
+The Respondent may appeal (both the finding of responsibility and the
+sanction) to the President within fourteen days after the Title IX
+Officer notifies the Respondent of the imposition of the sanction by
+the Judicial Panel or within fourteen days after the Appellate Officer
+imposes a sanction of suspension or dismissal on the first appeal.
+The appeal to the President should state why the Respondent believes
+the determination of responsibility and/or the sanctions were
+inappropriate. The appeal must also set forth in detail the grounds
+for appeal and must identify or attach all materials to be considered
+in the appeal process.  The Title IX Coordinator will provide a copy
+of the appeal to the Complainant (if that person has not declined to
+participate in the investigative and judicial case).  The Complainant
+may submit a response to the Title IX Coordinator within five days of
+receiving a copy of the appeal.  The Title IX Coordinator will forward
+that response to the President.
+
+Before the President decides the appeal, the President should consult
+with the previous Appellate Officer (if there were one) and the
+Secretary of the Faculty.  The President should issue a decision
+within thirty days of receiving the appeal.  If the decision will take
+longer than thirty days, the President should inform the parties of
+the additional time necessary to render a decision.  The decisions
+concerning responsibility and sanction, if any, and reasoning of the
+President will be provided in a written document.  The written
+document shall be maintained with records relating to the case.
+
+The President will forward the written document to the Title IX
+Coordinator, and the Title IX Coordinator will inform the parties
+simultaneously of the outcome of the appeal by forwarding to them the
+President's written document.
+
+If the President decides to impose a sanction of dismissal or
+suspension, the Respondent may appeal the sanction to the Board of
+Trustees within fourteen days after the Respondent is notified of the
+President's decision.  If the Respondent appeals to the Board, the
+Chair of the Board, in collaboration with the Secretary of the
+Faculty, shall appoint a committee of five faculty members who will
+make a recommendation regarding the sanction imposed. The faculty
+committee will have access to all written reports and materials
+relevant to the case. The faculty committee will summarize the basis
+for its recommendation in a written report to the Board Chair within
+thirty days.  The Board Chair should issue a written decision within
+thirty days of receiving the faculty committee's report.  If the
+decision will take longer than thirty days, the Board Chair should
+inform the parties of the additional time necessary to render a
+decision.  The decision and reasoning of the Board Chair will be
+provided in a written document.  The written document shall be
+maintained with records relating to the case. The Board Chair will
+forward the written decision document to the Title IX Coordinator, and
+the Title IX Coordinator will inform the parties simultaneously of the
+outcome of the appeal by forwarding to them the Board Chair's written
+document.
+
+The Board Chair's decision shall be final.
+
+### Timeframe for Completing the Investigation and Disciplinary Process
+
+WPI will endeavor to complete the investigation and disciplinary
+Judicial Panel process, if any, within sixty (60) days of the delivery
+of the written notice of investigation to the parties.  This period
+does not include the time for any appeal.  Timeframes set forth in
+this Policy may be extended for good cause.  WPI's overarching goal is
+that the process should be prompt, fair, and impartial.
+
+### Additional Matters
+
+#### a. No Conflicts of Interest
+
+To the maximum extent practicable, steps should be taken to ensure an
+impartial and unbiased process, including participation of persons
+(including investigators) who: (1) have sufficient qualifications and
+training to carry out a thorough evaluation of the relevant
+information; and (2) have no unresolved personal, professional, or
+financial conflicts of interest with those involved with the inquiry
+or investigation that could affect their ability to be objective
+reviewers.
+
+In cases where the Title IX Coordinator has a conflict of interest, a
+Deputy Title IX Coordinator appointed by the President will serve in
+the Title IX Coordinator's role.  In cases where the Appellate Officer
+has a conflict of interest, the President shall appoint another
+Appellate Officer..  In cases where allegations of Sexual Misconduct
+have been brought against the Title IX Coordinator, the Vice President
+for Talent/Chief Diversity Officer, the Provost, or the President,
+then the process outlined in this policy will be adjusted accordingly
+to avoid any conflicts of interest.  Except in cases involving the
+President, the President shall resolve any questions of bias or
+conflict of interest.  The President's decision on such questions
+shall be final.
+
+#### b. Duty of Honesty
+
+Any person who knowingly makes a false statement - either explicitly
+or by omission - in connection with any part of the process will be
+subject to separate disciplinary action.  A false or unfounded report
+of misconduct determined by WPI to have been made in bad faith and
+dishonesty is a serious offense.  Such offenses will themselves be
+investigated under the appropriate WPI policy and may lead to
+disciplinary action, up to and including termination of employment or
+other affiliation with WPI.  A report made in good faith is not
+considered false merely because the evidence does not ultimately
+support the allegation of violation of the Policy.
+
+#### c. Good Faith Participation by the Parties and Witnesses
+
+The investigation is a neutral fact-gathering process.  Although
+participation in the process (providing information to the
+Investigator(s), responding to questions from the Investigator(s),
+responding to information provided by a party or a witness, etc.) is
+not required, the Complainant, the Respondent, and all witnesses are
+expected to participate in good faith in the process set forth in this
+Policy, and they may be required by WPI to attend meetings related to
+the process.  Any person who knowingly interferes with the reporting,
+investigation, or resolution of matters under this Policy may be
+subject to separate and/or additional disciplinary action
+
+#### d. Duties of Promptness and Care
+
+Proceedings concerning Sexual Misconduct often raise difficult issues
+for those making the allegations, for those who are the subject of the
+allegations, and for those responsible for reviewing the allegations.
+Review of the allegations should therefore be conducted promptly and
+with care and sensitivity.
+
+#### e. Duty of Confidentiality
+
+The University will administer any complaint of sexual misconduct
+using the process described in this Policy while providing the utmost
+degree of privacy and confidentiality possible under the circumstances
+of each matter and as permitted by law.  All participants in the
+review process under this Policy are expected to maintain
+confidentiality to protect the privacy of all involved, to the extent
+possible and as permitted by law.  Participants should keep in mind
+the affect that allegations can have on reputations, even if the
+allegations are not sustained by the proceedings.  Thus, only those
+people with a need to know should be informed of a complaint.  Any
+participant in the process set forth in this Policy who violates their
+duty of confidentiality may be subject to discipline under the
+appropriate WPI policy.
+
+#### f. Recording the Proceedings
+
+The parties are not permitted to make video, audio, or other
+electronic, photographic, or digital recordings of any meetings or
+proceedings held under the Sexual Misconduct Policy or these
+procedures or the Investigative Phase.  The Title IX Coordinator may
+make exceptions to this prohibition in limited circumstances if he or
+she concludes, in his or her sole discretion, that a recording is
+warranted, and upon written request of the party seeking the recording
+that explains the need for the recording.
+
+#### g. Record Keeping
+
+The Title IX Coordinator should receive and maintain all records
+relating to proceedings under this Policy including all notices to and
+from the parties, all reports of Investigators, all decisions by a
+Judicial Panel, all appeals by the parties, and all decisions by
+Appellate Officers and others involved in the appeals process under
+this Policy.
+
+#### h. Special Measures
+
+If there is no finding of Sexual Misconduct, the University should
+make reasonable and practical efforts as appropriate to restore the
+reputation of the Respondent.  Any such concerns by the Respondent
+should be directed to the Title IX coordinator for follow up with
+other administrators as appropriate.
+
+#### i. Information about Title IX
+
+Such information, including about filing a complaint with the
+Department of Education related to this Policy, may be obtained from
+the Office of Civil Rights at the United States Department of
+Education, 400 Maryland Avenue, SW Washington, DC 20202-1100;
+800-421-3481 TDD: 800-877-8339; OCR@ed.gov.
+
+#### j. More information
+
+More about Title IX at WPI may be found at
+<https://www.wpi.edu/offices/title-ix>.
+
+#### k. Evaluation
+
+The Title IX Coordinator shall annually evaluate the effectiveness of
+the Policy with respect to meeting the needs of Complainants and
+Respondents during the process.
+
 ---------------------------------------------
 
 # Footnotes