Jean Madeline Institute Catalog

The Jean Madeline Aveda Institute (Institute) is committed to providing safety to all of its students, faculty and staff.

• If a crime happens to you or your property or if there is an emergency occurring on campus, contact the designated Campus Security Authority or any available administrator.
• The Institute will provide students, faculty, and staff with a copy of the  web site to access this report. Copies of the report may be obtained in the Campus Student Services Office.  Statistics will be gathered from the local police and compiled in the annual report. The report will show number of incidents only on campus and is divided into the following categories:

If you have concerns, questions or need information, please contact:The Institute has assigned a specific Campus Safety Authority in which any Campus Safety and Security concerns can be reported and addressed. The Institute has a working relationship with the Local Police Department who are able to support and provide services promptly in the event of an incident. We encourage accurate and prompt reporting of all crimes to the Campus Security Authority and local police.

Joan Reilly  Director/ Title IX Campus Security Authority Telephone: 215-238-9998 X 1121
Email: jreilly@jeanmadeline.com

• In addition to the required annual campus security report, The Institute will provide a timely warning to students and staff of any occurrences of the following crimes that are reported to local police agencies and/or the Campus Security Authority that are considered to represent a serious or continuing threat to our future professionals and staff. As soon as the Institute becomes aware of the crimes, students and staff will be notified in their next class. These crimes are: criminal homicide, forcible and non- forcible sex offenses, domestic violence, dating violence, stalking, robbery, aggravated assault, burglary, motor vehicle theft, arson, hate crimes including crimes involving bodily injury reported to local police agencies that show evidence of prejudice based on race, gender, religion, sexual orientation, ethnicity or disability, arrests for violations of liquor and drug law violations and illegal weapons possession, and persons not arrested but referred for disciplinary action for liquor, drug and weapons law violations.

Note: The Institute is not required to provide timely warnings with respect to crimes reported to a pastoral or professional counselor.

• The Institute will also provide timely warning to students and staff if a significant emergency or dangerous situation involving an immediate threat to the health and safety of students or staff occurs on the campus. The Institutes goal is to maintain a safe and nonviolent academic and working environment. Please notify a staff member immediately in case of a medical emergency or accident. All accidents must be reported to the Director and Campus Security Authority. In case of a bomb threat immediately contact the police or administrative personnel and evacuate the building as directed by the police or the administrative personnel. The Institute has an alarm monitored system that is directed to the Fire Department. Whenever a fire is detected, a continuous siren will sound. In all cases when the fire alarm sounds all future professionals and staff must instruct and assist all guests in evacuating and must also evacuate the building themselves. Re-enter the building only when the Fire Department or Security has given clearance. Floor plans are posted throughout the Institute; please familiarize yourself with the escape routes. In the event of severe weather warnings the building management will make a decision on when to evacuate team members, students, and guests.
• If a student wants to report crimes on a voluntary, confidential basis for inclusion in the annual disclosure of crime statistics, please contact the Campus Security Authority.
• Access to the building is only given to students during the normal class day. Any future professionals seeking access outside normal class time must have prior authorization from an administrator.
• We encourage students and staff to be responsible for your own security and the security of others. 
• The Institute does not have any off-campus locations and therefore all monitoring and recording of any criminal activity is conducted at the campus location.

Drugs and Alcohol Policy

• School policy prohibits the possession, use and sale of alcoholic beverages to anyone.
• School policy also prohibits the possession, use and sale of illegal drugs.
• School policy supports and enforces State underage drinking laws.

Any staff member or student violating this policy will be subject to disciplinary action up to and including termination or expulsion and referral for prosecution.

Students needing assistance may contact the below substance abuse resources:

• Substance Abuse Treatment Referral Service 1(800)662-4889
• Alcoholics Anonymous, Al-Anon & Alateen (215)  923-7900

New Campus Obligations under Violence Against Women Act (VAWA)

Under Title IX, discrimination on the basis of sex can include sexual harassment and sexual violence, which includes sexual assault, domestic violence, and stalking. Any Institute that receives federal funds may be held legally responsible when it knows about or ignores sexual harassment or sexual violence in its programs or activities. The Institute can be held responsible in court whether the harassment or violence is committed by a student or staff.

What is VAWA?

On March 7, 2013, President Obama signed into federal law the Violence Against Women Reauthorization Act of 2013 (VAWA), which is aimed at improving how colleges and universities in the U.S. address sexual violence. This new law imposes obligations for Colleges and Universities to revise their policies and practices to comply with new regulations that addresses and prohibits acts of violence such as, sexual assault, domestic violence, dating violence and stalking, and it clarifies the rights of victims. The new regulations also include:

• Reporting campus crime statistics beyond the crime categories that the Clery Act already mandates, to which now include incidents of domestic violence, dating violence and stalking, as well as crimes motivated by gender identity or national origin;
• Providing comprehensive educational prevention and awareness programs for incoming students and new employees, in addition to ongoing prevention and awareness campaigns for students, faculty and employees that identifies and defines sexual assault, rape, acquaintance rape, domestic violence, dating violence and stalking; and
• Conducting annual training for investigators and hearing officers who investigate and review reported offenses.
• In addition, both Title IX and VAWA legislation permits the Institute, to assist both the victim and the accused with:
  • An investigation
  • Counseling and medical services
  • Choosing a support person to accompany them throughout proceedings
  • Allowing the victim and the accused to attend another Campus
  • Academic support services

Jean Madeline Aveda Institute Title IX Policy

The Institute is committed to creating and maintaining a community where all individuals who participate at the Institute’s programs and activities can work and learn together in an atmosphere free of harassment, exploitation, or intimidation. Every member of the Institute should be aware that the Institute prohibits sexual harassment and sexual violence, and that such behavior violates both law and Institutional policy. The Institute will respond promptly and effectively to reports of sexual harassment and sexual violence, and will take appropriate action to prevent, to correct, and when necessary, to discipline behavior that violates this policy on Sexual Harassment and Sexual Violence. The Institute’s policy covers all members of the Institute, including students, employees, non- student or non-employee participants in the Institute’s programs. This Policy furthers the Institute’s commitment to compliance with the law and to the highest standards of ethical conduct.

Definitions

Sexual Assault

Sexual assault occurs when physical sexual activity is engaged without the consent of the other person or when the other person is unable to consent to the activity. The activity or conduct may include physical force, violence, threat, or intimidation, ignoring the objections of the other person, causing the other person’s intoxication or incapacitation through the use of drugs or alcohol, or taking advantage of the other person’s incapacitation (including voluntary intoxication).

Domestic Violence

Domestic violence is defined as means of any criminal offense involving violence or physical harm or threat of violence or physical harm, or any attempt, conspiracy, or solicitation to commit a criminal offense involving violence or physical harm, when committed by one cohabitant against another.

Domestic violence includes asserted violent misdemeanor or felony offenses committed by the victim’s current or former spouse, current or former cohabitant, person similarly situated under domestic or family violence law, or anyone else protected under domestic or family violence law.

Dating Violence

Dating violence is defined as violence by a person who has been in a romantic or intimate relationship with the victim. Whether there was such relationship will be gauged by its length, type, and frequency of interaction.

Stalking

Stalking is defined as a course of conduct directed at a specific person that would cause a reasonable person to fear for her, his, or others’ safety, or to suffer substantial emotional distress.

Consent

Consent is informed. Consent is an affirmative, unambiguous, and conscious decision by each participant to engage in mutually agreed-upon sexual activity.

Consent is voluntary. It must be given without coercion, force, threats, or intimidation.

Consent is revocable. Consent to some form of sexual activity does not imply consent to other forms of sexual activity. Consent to sexual activity on one occasion is not consent to engage in sexual activity on another occasion. A current or previous dating or sexual relationship, by itself, is not sufficient to constitute consent. Even in the context of the relationship, there must be mutual consent to engage in consent is withdrawn, the sexual activity must stop immediately.

Consent cannot be given when a person is incapacitated. A person cannot consent if she/he is unconscious or coming in and out of consciousness. A person cannot consent if she/he is under the threat of violence, bodily injury or other forms of coercion. A person cannot consent if her/his understanding of the act is affected by a physical or mental impairment.

Title IX Campus Security Authority

The Campus Security Authority provides a safe and confidential place for students, employees and visitors who desire information about and/or need help with issues involving sexual assault, dating/domestic violence and stalking.

The Campus Security Authority is responsible for receiving and conducting the administrative investigation of all reports of sexual assault filed on campus by students and employees, and is available to discuss options, explain Institute policies and procedures, and provide education on relevant issues.

The Campus Security Authority must receive annual training on the issues related to domestic violence, dating violence, sexual assault, stalking, and how to conduct an investigation and hearing process that protects the safety of victims and promotes accountability.

The Institute encourages all members (and visitors) of the Institute who experience sexual assault or other forms of interpersonal violence to report their incident. The Campus Security Authority will provide information about reporting options, psychological support and resources.

If you have concerns, questions or need information, you may contact:

Joan Berkery Director/ Title IX Campus Security Authority Telephone: 215-238-9998 X 1121
Email: jberkery@jeanmadeline.com

Violence on Campus

If a sex offense occurs while at the Institute, please contact the local Police Department, and report this immediately to the appointed Campus Safety Authority. The Aveda Institute will do everything possible to assist in this serious matter. If such a serious offense occurs, it is important to preserve evidence for proof of the criminal offense.

Future Professionals who are victims of sex offenses may find help from the following list or others known to the future professional:

• National Sexual Violence Resource Center (NSVRC) (877)739.3895
• Rape, Abuse and Incest National Network (RAINN) (800)656-4673
• Rape Crisis Hotline (215)985-3333
• Philadelphia Police Special Victims Unit (215)685-3251

Individuals wishing to learn additional information about registered sex offenders may go to the State Police web site at www.pameganslaw.state.pa.us

Risk Reduction Tips

• Be aware of surroundings
• Be Assertive – Set and communicate sexual limits
• “No” MEANS “No” Say it clearly, loudly and mean it.
• Trust your instincts
• Get to know people
• Limit alcohol consumption so you are better able to assess your surroundings.
• When drinking alcohol in social settings, make arrangements with a friend to leave together. Do not stand by when you observe warning signs of potential sexual assault, get involved.

What To Do If You Or Another Individual Has Been Sexually Assaulted:

Important steps to take after an assault:

• Get to a place where you or the individual is safe from further attack and call the police
• Encourage the individual to report the assault to law enforcement
• Encourage the individual to seek medical attention
• Ask the Title IX Campus Security Authority for help
• Call a family member or someone that you or the individual trusts
• Do not wash, comb, or clean any part of your/their body. Do not change clothes if possible, so the hospital staff can collect evidence. Do not touch or change anything at the scene of the assault
• Go to the nearest hospital emergency room as soon as possible. You/They need to be examined, treated for any injuries, and screened for possible sexually transmitted infections (STIs) or pregnancy. The S.A.R.T. Nurse will collect evidence using a rape kit for fibers, hairs, saliva, semen, or clothing that the attacker may have left behind

Reporting a Sexual Assault to Police

The Institute encourages all members of the campus community who experience any form of sexual violence to report such incidents to Campus Security Authority. The decision to file a report with the Police Department or any local law enforcement agency lies within the discretion of the survivor. Whether or not a survivor chooses to report the incident to law enforcement there is support and help for the survivor. The Sexual Assault Resource Services Consultant/Team or the local rape crisis center will provide information, support, and referrals to a survivor no matter what course of action she/he chooses to take. The Sexual Assault Resource Services Consultant Team will explain the options and alternatives available to the survivor including:

• Filing a police report
• Obtaining aid through the Philadelphia Police Special Victims Unit
• ·Disciplinary options available within the Institute
• The availability of mediation
• Academic assistance

How to help a friend who has been assaulted

• Listen attentively and empathically to what they are saying – stay calm, be patient, and non judgmental. Let them tell you in their own word
• Don’t ask for details or specifics. Don’t Pry
• Validate the survivor’s feelings: their anger, pain, and fear
• Encourage the survivor, family, and significant others to seek professional help
• Be clear that the rape was not the survivor’s fault
• Accept that there may be changes in your relationship with the survivor
• Get support with your own feelings
• Be gentle, patient, and sensitive. Respect the time and space it takes to heal

Sex Offenses

The Institute will provide a written explanation of available rights and options, including procedures to follow, when the Institute receives a report that the student or employee has been a victim of domestic violence, dating violence, sexual assault, or stalking on campus.

The written information shall include:

• To whom the alleged offense should be reported
• Options for reporting to law enforcement and campus authorities, the right to be assisted by campus authorities in notifying law enforcement authorities if the complainant so chooses and the right to decline to notify such authorities
• The rights of complainants regarding orders of protection, no contact orders, restraining orders, or similar lawful orders issued by criminal or civil courts and the Institutes responsibilities regarding such orders
• The importance of preserving evidence as may be necessary to prove criminal domestic violence, dating violence, sexual assault, or stalking, or to obtain a protection order
• The existing campus and community services available for victims including counseling health, mental health, victim advocacy, legal assistance, and other services
• Options for, and available assistance to, change academic, living, transportation, and working situations, if requested by the complainant and if reasonably available, regardless of whether the victim chooses to report the crime to police or local law enforcement.
• Any applicable procedures for institutional disciplinary action

If a sex offense happens where both the accused and the accuser attend The Institute, both the accuser and the accused:

• Are entitled to the same opportunities to have others present during a disciplinary proceeding dismissal that may occur following a final determination of said proceeding regarding rape, acquaintance rape, or other forcible of non-forcible sex offenses
• The Institute will work with students to change an academic situation (i.e., allowing the student to take a leave of absence, allowing the student to enroll in a later program, etc.) if the change is requested by the victim and the change is reasonably available.

Please see the outlined “Investigation” details below for the procedures on how to proceed when a claim is made regarding sexual misconduct at the Aveda Institute. Please also see the subsequent forms that go along with the Investigation procedure

Investigations – step by step

When an informal or formal complaint is made, the Campus Security Authority should take immediate steps to stop the alleged conflict, protect those involved and begin investigations. Under many laws Institutes are legally obligated to investigate complaints (harassment, discrimination, retaliation, safety and ethical) in a timely manner. In addition, any appropriate corrective action is required to be taken by the Institute to ensure illegal actions/behaviors cease immediately.

Responsiveness to a complaint and an investigation will not only yield the best information and evidence, but it will also enhance both the investigator’s and the Institute’s credibility. Investigations can help the Campus Security Authority identify and resolve internal problems before they become widespread. Since every complaint has the potential to become a lawsuit, Campus Security Authority’s should investigate every case in a manner in which it can be presented to a court of law, if necessary. As potentially disruptive as investigations can be, they must be prompt, thorough and effective to ensure everyone’s protection. The following steps should be taken as soon as the Campus Security Authority receives a verbal or written complaint. See enclosed sample of Incident Complaint Form.

Step 1: Ensure confidentiality

The Campus Security Authority must protect the confidentiality of the accuser’s claims to the best of its ability. At the same time, the Campus Security Authority has to conduct a prompt and an effective investigation. Therefore, it may not be possible to keep all information gathered in the initial complaint, such as interviews and records, completely confidential. The Campus Security Authority should explain to the complaining party and all individuals involved in the investigation that all information gathered will remain confidential to the extent possible for a thorough investigation. It should also be explained that in order to conduct a prompt and effective investigation, some information will be revealed to the accused and potential witnesses, but that information will be shared only on a “need to know” basis. Have all parties sign a Confidentiality Agreement – enclosed.

Step 2: Provide interim protection

One of the first considerations may be the need to take immediate measures for the protection of the accuser or the alleged victim. It may be necessary to separate the alleged victim from the accused to guard against continued harassment or retaliation. Actions such as a schedule change, transfer or leave of absence may be necessary; however, the person(s) involved should not be involuntarily transferred or burdened. These types of actions could appear to be retaliatory and result in a retaliation claim. The Campus Security Authority and the accuser must work together to arrive at an amenable solution. Campus Security Authority’s may wish to seek legal advice prior to making any decisions.

Step 3: Select the investigator

The Campus Security Authority has been selected to investigate any claims made in regards to sexual misconduct within the Institute. The Campus Security Authority should possess all of the following:

• An ability to investigate objectively
• To have no “stake in the outcome.” They should not have a personal relationship with the involved parties. The outcome should not directly affect the investigator’s position within the company
• Skills that include prior investigative knowledge and working knowledge of employment laws
• Strong interpersonal skills in order to build a rapport with the parties involved and be perceived as neutral and fair
• Attention to details
• The right temperament to conduct interviews
• To be in a position to maintain confidentiality, be respected within the organization (since his or her conclusions will be used to make a determination), have the ability to act as a credible witness and, if internal, have the likelihood of continued employment with the company
• Receive yearly training on the subject of the investigation

Step 4: Create a plan for the investigation

An investigation must be planned to be effective and properly executed. A complete plan should include an outline of the issue, the development of a witness list, sources for information and evidence, interview questions targeted to get crucial information and details, and a process for retention of documentation (i.e. interview notes and evidence like e-mails, etc).

The use of all available resources will assist the investigator in developing a proper plan

INTERVIEW PLAN 

Day One

Allow time between interviews to type up notes and adjust to new information/evidence/witnesses. The interview plan may call for conducting interviews earlier or later as needed to allow enough time to gather all the information needed, but keeps the investigation flowing as efficiently as possible. Additional time may be necessary depending on the amount of witnesses and information provided. Interview accuser (to clarify details and gather evidence and witnesses)

• Read over interview notes and fill in details while still fresh Determine if it makes sense to interview accused next or some witnesses
• Next interview – potentially accused (get their side of story, gather evidence and witnesses)
• Complete notes and prepare for next interview
• Interview potential first witness and take time to complete interview notes
• Interview second witness and take time to complete interview notes
• Interview third witness and take time to complete interview notes
• Review notes for entire day and make plan for second day

Day Two

• Finish any additional witness interviews. Handle any follow-up interviews with accused, accuser or witnesses as needed to clarify information previously discussed or ask new questions about evidence/information disclosed after initial interview
• Review interview notes, evidence and credibility assessment Day Three
• Finish review of investigation process and establish the proposed recommendations for action.
• Discuss proposed resolution with administration Day Four
• Create any relevant disciplinary actions, warnings or memos
• Closure meeting with accused
• Closure meeting with accuser

Day Five

Write investigation report

Step 5: Interview questions See enclosed Interview of the Accuser, Interview of the Accused and Interview of Witnesses

Questions should be developed ahead of time in the planning stage, although additional questions will be added throughout the investigation as more evidence and information is shared. Good questions are relevant and designed to draw out facts without leading the interviewee; they should be open-ended to elicit as much information as possible.

• Tell the person(s) involved that you appreciate their time and cooperation.
• Determine the nature of what we are investigating
• Reiterate the matter under investigation is serious, and the Institute has a commitment/obligation to investigate this claim
• No conclusion will be made until all of the facts have been gathered and analyzed
• Any attempts to influence the outcome of the investigation by discussing it with others, retaliation against anyone who participates, providing false information or failure to be forthcoming can be the basis for corrective action up to and including termination
• Take written statements from those interviewed (who were at or near the scene of the incident, or involved in the investigation)
• Ask open ended questions such as who, what, where, why, when and how

Step 6: Conduct interviews

Once the appropriate investigator has been selected, an investigation plan has been developed, and interview questions have been developed, interviews can be conducted. The investigator should inform all parties involved of the need for an investigation and the urgency for confidentiality, and then explain the investigation process.

The investigator should focus on being impartial and objective in order to gather and consider relevant facts. Prevention from pushing the investigation in any particular direction is imperative. The investigator should never offer any opinion or say anything to interviewees that will discredit his or her impartiality. Objectivity must be maintained with every interview.

Taking notes, looking for inconsistencies, looking for opportunities for more evidence and names of other potential witnesses should be a consideration as well. Asking the person(s) involved to write down what happened may help to find inconsistencies. There may be a disparity between what the person(s) involved are willing to write and what they told you in the interview.

Credibility determinations: Interviews provide differing accounts and even conflicting versions of the events. Be aware that the issue is very personal to the person(s) involved. Because of the personal and emotional nature of the issue, their individual perception of what happened can be clouded by personal interests or, possible termination, they may even lie. Investigators must consider the credibility of the individuals being questioned during an investigation and use techniques (i.e. inherent plausibility, ability, demeanor, motive, motive to falsify, corroboration, past behavior and past accusations) in assessing credibility.

Follow Up with Other Possible Sources of Evidence

• Sexual visuals in the workplace
• Time cards or calendars
• Telephone records
• Travel logs
• Timing of the incident, e.g., just before or after a performance appraisal, just before or after the accused is rejected by the accuser or vice versa
• Prior performance evaluations
• Personnel files
• Physical evident, such as the layout of an office, lighting, relative locations of the parties
• Notes, letters, handwriting samples
• E-mail, voice mail
• Physical impossibility, e.g., the accused was in a meeting/on the telephone/out of town during the alleged incident

Step 7: Make a decision

Through the investigation, the investigator must be careful not to jump to any conclusions before all of the facts are available. Once the interviews are conducted, other necessary procedures, such as evidence collection, are completed. When any credibility issues have been resolved, the investigator will evaluate all the information for a formal recommendation. The investigator and/or member of management, as well as legal counsel, should make the final determination of any actions that are warranted based on the investigative report. The investigator must consider all of the parties involved as well as company processes, not just whether the accused is guilty, in the final determination.

Inconclusive Investigation

In some cases, the evidence does not conclusively indicate whether or not the allegation(s) was founded or unfounded. If such a situation exists, all parties of the investigation should be notified in writing that the Institute has completed a thorough investigation but has been unable to establish either the truth or falsity of the allegation(s). However, the Institute will take appropriate steps to ensure that the persons involved understand the requirements of the Institutes policies and appropriate law, and the Institute will monitor the situation to ensure compliance in the future.

Step 8: Closure of investigation

(Discussed separately, in a private meeting) Once a decision is made, the investigator should:

Notify both the accuser and the accused of the outcome simultaneously in writing. It is important to let the complainant know that the Institute took the complaint seriously and took appropriate action. Ensure the complainant agrees that he/she has been properly heard and understood, even if he or she is not in agreement with the results. Set a timeframe to follow up with the complainant to ensure there are no other issues and that he or she is settling back into the environment. Encourage communication and follow up until the complainant is comfortable again. Finally, remind all parties to preserve confidentiality.

Violation Founded. (Discussed separately, in a private meeting)

Where a violation is founded, the accuser and/or witness should be notified of the findings and that specific or corrective actions will be taken. No details about the nature or extent of disciplinary or corrective actions will be disclosed to the accuser and/or witness, unless there is a compelling reason (e.g., personal safety).

Inform the accused that a determination has been made and discuss the corrective measures that will be taken.

It is important to take immediate and appropriate corrective action. Disciplinary measures should be proportional to the seriousness of the offense. In some cases, disciplinary action may be as simple as an apology from the accused or as extreme as termination.

Examples of Disciplinary Actions:

• Required apology to be given to the accuser
• Oral and written warning
• Training or counseling
• Transfer or reassignment
• Monitoring of accuser to ensure that the matter stops
• Discharge

Violation Unfounded. (Discussed separately, in a private meeting)

In this situation, all parties of the investigation should be notified that the Institute thoroughly investigated the allegation(s) and found that the evidence did not support the claim.

Step 9: Develop written summary investigation results

If operating on the premise that every investigation of a serious nature could potentially be heard and reviewed by a court, the investigator will want to consider preparing a final investigative report. Keep a clear paper trail of the evidence, such as examining documentation of previous behavior and incidents. The investigator should have a clear record of everything done, any findings as well as other steps taken during the investigation. It is also necessary to document interviews with the accused, the accuser and witnesses. Investigators should ensure their notes from interviews are as factual as possible, have as much relevant information as possible, are dated and indicate the duration and time of the interview.

The final report will summarize

• The incident or issues investigated including dates
• Parties involved
• Key factual and credibility findings including sources referenced
• Institutional policies and/or guidelines and their applicability to the investigation
• Specific conclusions
• Party (or parties) responsible for making the final determination
• Issues that could not be resolved and reasons for lack of resolution
• Actions taken

The goal of the document is to ensure that if a court, jury or government agency were to review it, they would conclude that the Institute took the situation seriously, responded immediately and appropriately, and had a documented good-faith basis for any actions taken during or as a result of the investigation.

Monitor treatment of the Accuser

Ensure that he/she is not subjected to any type of retaliation by the accused or others in the Institute and that any other harm caused by the accused is corrected.

Retention of Investigative Reporting’s:

The Institute will retain records relative to the Company-initiated investigation for a period of five years, unless otherwise advised by the Human Resources Department.

Forms

Investigation Confidentiality Agreement

I, ___________________________________________, (name) understand that I am a party to an investigation being conducted at _________________________________ (Institute) and that all information disclosed to and by me is considered confidential under the Institute’s Confidentiality Policy.

As stated in the Confidentiality Policy, internal company business is to be discussed with coworkers/classmates only an as-needed basis and is not to be disclosed to any external parties, except as authorized by company officials or as required by law to governmental authorities.

I also understand that if I make an unauthorized disclosure of information on this investigation during my employment/enrollment with _______________________________ (Institute). I will be subject to disciplinary action, including termination.

If I disclose unauthorized information on this investigation after my employment ceases with the company, I may be held liable by individuals involved in this investigation.

Agreed to by: _________________________________________ (Signature)

Printed name: ____________________ Date: _____________________________

October 2014

Incident Complaint Form

Date of Event: __________________ (If more than one event, please report each event on a separate form.)

Where did the specific event occur?

How would you describe the circumstances?

Please explain the events that occurred?

Were there any witnesses to this specific event? (If yes, please provide their names)

How did you feel?

What would be your desired outcome as a result of the investigation?

_______________________________________ Name – Signature

________________________________________ Date

Notification of Investigation Memorandum

DATE:

TO:

FROM:

RE: Upcoming Investigation

Please be informed that you may be contacted by ______________________ in the next week as part of a workplace investigation that is being conducted as a result of a complaint of a violation of Institutional policy.

Our Institutional policy is committed to careful and thorough investigation of any such complaints. Accordingly, we expect our employees/future professionals to cooperate to the fullest extent possible, providing accurate information as requested in the investigative process.

Please understand that due to the sensitive nature of the process, this investigation will be conducted in a manner that protects the privacy of all involved to the greatest extent possible. In order to maintain the integrity of the investigation, you are asked to refrain from discussing the investigation with your fellow employees/classmates.

If you have any questions regarding the investigative process, please feel free to contact me. Thank you for your cooperation.

Investigatory Leave Notice

Date

Name

Address

Address

Dear (name):

This is (to notify you/confirm in writing) that you are being placed on investigatory leave in accordance with [Policy #/name)] commencing (date).

The reason you are being placed on investigatory leave is to allow the department time to review the allegation(s) that (briefly and in general terms describe the allegation).

We will be scheduling a meeting with you in order to discuss this matter. Please email me at (email address) with your current contact number(s) and any corrections to your address so that we may contact you to schedule this meeting.

This investigation will be kept as confidential as possible. You are not to contact co-workers/classmates or other potential witnesses during this leave with the exception of (your manager/HR/investigator/union rep). You are not to disclose or further discuss information regarding this investigation to others outside of (the investigator/me/HR/rep). Failure to maintain confidentiality may result in discipline up to and including termination of employment/enrollment. If you need to contact anyone regarding work issues or come to the (Department/Office of) for any reason during the period of investigatory leave, please make arrangements through (your supervisor/me/other) at (telephone number and email address). Any questions regarding this letter please direct to (name) at (phone number and/or email).

Sincerely, Name Title Company

Investigation Resolution

Expected Outcome of Complainant:

Although my signature on this document does not constitute an admission of guilt, I do acknowledge that the complainant perceived my actions as being offensive. My signature on this form is my agreement that I will cease-and-desist the actions that are perceived as being offensive.

_________________________________________________________________________________ Signature of Accused Date

I am satisfied my complaint has been acknowledged and that actions taken by the respondent are satisfactory to me.

_________________________________________________________________________________ Signature of Complainant Date

Interview of the Accuser

Date: _____________________
Meeting with – Name: ________________________________ Investigated by – Name: _____________________________

Foundation Questions: (some may or may not apply here)

1. Who committed the alleged inappropriate behavior?
2. What exactly happened?
3. How did you react?
4. Did you ever indicate that you were offended or somehow displeased by the act or offensive treatment?
5. When did the incident occur, or is it ongoing?
6. Where did the incident occur?
7. Who else may have seen or heard the incident?
8. Have you discussed the incident with anyone?
9. How has the behavior affected you and your job?
10. Did you seek any medical treatment or counseling as a result of the incident?
11. When did you first learn of the Institutes Title IX Policy? (If not provide a written copy of the policy and note below).
12. Is there anyone else who may have relevant information?
13. Do you have any other relevant information?
14. What action do you want the Institute to take?
15. (After reviewing notes, always ask if there is anything else):

Close the Interview:

• Direct the accuser to maintain confidentiality within the Institute. Encourage him/her to report to you if she/she experiences any further problems
• Remind the accuser of the Institutes duty to investigate by talking with other witnesses, as appropriate
• Advise if a date has been set as a goal for concluding the investigation

Interview of Witnesses

Date: _____________________
Meeting with – Name: ________________________ Investigated by – Name: ___________________________ Introduction

• Express appreciation for the witness’s time and cooperation
• Explain the nature of what is being investigated
• Note that the matter under investigation is serious and that the Institute has a commitment/obligation to investigate this claim
• Emphasize that no conclusion will be made until all of the facts have been gathered and analyzed
• Stress that any attempt to influence the outcome of the investigation by discussing it with others, retaliation against anyone who participates, providing false information or failure to be forthcoming can be the basis for corrective action up to and including termination
• Examine/consider motivation due to “political” alliances of witnesses

Foundation Questions for Witnesses:

1. Please describe any inappropriate or offensive behavior that you have experienced or witnessed. What did you see or hear? When did this occur? How often did it occur?

2. Are you aware of behavior by the accused toward the accuser or toward others in the workplace?

3. What did the accuser tell you? When did he or she tell you this?

4. Do you know if the accuser reported the concern to Administration?

5. Upon knowledge of the incident(s), did you report it to Administration?

6. Do you have any notes, physical evidence or other documentation regarding the incident(s)?

7. Do you know of any other relevant information?

8. Are there other persons who have relevant information?

Close the Interview:

• Direct the witness to maintain confidentiality within the Institute about the investigation, so that the results will be as reliable as possible
• Encourage him/her to report to you if she/she experiences any further problems
• Remind the witness of the Institutes duty to investigate by talking with other witnesses, as appropriate
• Advise if a date has been set as a goal for concluding the investigation

Interview of the Accused

Date _________________________

Meeting with – Name: ________________________________

Investigated by – Name: ______________________________

Introduction (with a view toward finding out what happened):

• Provide detailed allegations to the accused to allow complete and fair answers
• As required by EEOC guidelines, release the name of the accuser to the accused. You are not required to release the name of a witness to the alleged accused unless a witness has given accusing information during their statement
• Ask the accused for their witnesses to current and past events
• After reviewing notes, always ask if there is anything else
• Keep good notes of interviews, responses, dates/times, efforts, results, actions and refusals.

Assume all documents will be seen by a jury

• Access credibility and resolve factual disputes, or determine you don’t need to and can act on another reasonable basis. Keep secondary performance issues separate from this investigation 1. What is your response to the allegations?

1. Do you agree or disagree with the allegations?
2. If the accused claims that the allegations are false, ask why the accuser might lie.
3. Are there witnesses to support alleged accusers’ version of the story?
4. Are there any persons who might have relevant information?
5. Are there any notes, physical evidence, or other documentation regarding the incident(s)?
6. Does he/she have any other relevant information?

Close the Interview:

• Direct the accused to maintain confidentiality within the Institute about the investigation, so that the results will be as reliable as possible
• Encourage him/her to report to you if she/she experiences any further problems
• Remind the accused of the Institutes duty to investigate by talking with other witnesses, as appropriate
• Advise if a date has been set as a goal for concluding the investigation

See below for Clery Act Disclosures of Campus Security Policy and Crime Statistics

Clery Act Information

Queen Village Campus Crime Statistics

University City Campus Crime Statistics

Neshaminy Mall Campus Crime Statistics

Jean Madeline Institute Annual Safety and Security Report 

Including Clery Act Disclosures of Campus Security Policy and Crime Statistics

Including Calendar Year 2022, 2023, 2024 Crime Statistics

Published September 24th, 2025

To maintain compliance with Jeanne Clery Disclosure of Campus Security Policy and Crime Statistics Act (“Clery Act”), Higher Education Act (“HEA”) requirements, and related statutes and regulations, and in an effort to continuously promote and improve safety and security measures on campus, the Jean Madeline Aveda Institute (“Institute”) collects and publishes information regarding the Institute’s security policies, services and crime statistics. Once collected, the information is presented annually in this Annual Safety and Security Report (“Report”) to prospective and current students, faculty and staff and to the public by the Institute’s Campus Security Survey Administrator. Any questions about this report should be directed to Joan Reilly, Corp. Director of Compliance, who serves as the Campus Security Survey Administrator at (215) 238-9998 x 1123 [jreilly@jeanmadeline.edu].

I. COMPLETION AND DISSEMINATION OF THE REPORT

Prior to October 1 of each year, the Institute compiles this Report based on crime, arrest and referral information obtained from local law enforcement agencies and as reported to the Institute’s designated campus security authorities (Campus Security Survey Administrator, School Director and Title IX Coordinator). All crime statistics contained in this Report are for Clery Act reportable crimes occurring on the Institute’s campus, as defined by 34 C.F.R. § 668.46(a), and on public property, including thoroughfares, streets, sidewalks, and parking facilities, within the campus or immediately adjacent to or accessible from the campus. The Report also includes the Institute’s current policies required pursuant to 34 C.F.R. § 668.46 and the Violence Against Women Reauthorization Act of 2013 (VAWA), Pub. Law 113-4.

The Institute distributes this Report to all enrolled students and current employees via a notice by campus mail and/or electronic mail or text notifying them that the current version of the Report has been posted to the Institute’s web site at www.jeanmadeline.edu, select Safety and Security Report under the About tab where you can download the Annual security Report. (*The exact web address where the report can be found is listed below.)

A paper copy of the Report will be provided upon request by contacting Joan Reilly, Corp. Director of Compliance, who serves as the Campus Security Survey Administrator at (215) 238-9998 x 1123 [jreilly@jeanmadeline.edu]. The Admissions Department provides written notice to all prospective students prior to enrollment regarding the availability and location of the Report. The Human Resources Department provides all prospective employees with information regarding the availability and location of the Report. All prospective employees may receive a copy of the Report by calling the Human Resource Office at (215) 238-9998. In addition, a copy of the current Report is made available to the public on the Institute’s website as indicated above.

The crime statistics contained in this Report, as reported annually to the U.S. Secretary of Education, can also be viewed by searching the Institute’s name at http://nces.ed.gov/collegenavigator/

II. POLICIES FOR REPORTING AND RESPONDING TO CRIMES AND EMERGENCIES

A. STUDENT, FACULTY AND STAFF REPORTING PROCEDURES

1. Reporting Emergencies

“Emergency” includes any dangerous situation involving immediate threat to the health or safety of students, faculty, staff or guests occurring on or near the campus, including fire.

Upon observing or involvement in any type of emergency, students, faculty, staff and guests should

immediately notify the Institute Director or other available Institute staff for purposes of expediting the Institute’s activation of its Emergency Response and Evaluation Procedures as set forth in Section II.B.3.

2. Reporting Crimes

Crimes that should be reported to the School Director by students, faculty and staff include: criminal homicide, murder and non-negligent manslaughter, manslaughter by negligence, rape, fondling, incest, statutory rape, dating violence, domestic violence, stalking, robbery, aggravated assault, burglary, motor vehicle theft, arson, drug and alcohol violations, and illegal weapons possession. Where there is any question about whether an incident is a crime, a report should be made to the School Director for assistance in determining the nature of the incident. Witnesses or victims of crimes may report crimes on a confidential basis for inclusion in the Institute’s annual crime statistics reporting.

Upon observing or involvement in any type of crime on campus or on public property, including thoroughfares, streets, sidewalks, and parking facilities, within the campus or immediately adjacent to or accessible from the campus:

 A student should immediately notify the Institute Director or the nearest available Institute faculty or staff. All Institute faculty and staff are trained to notify the Campus Security Survey Administrator or Institute Director (or his/her on-site designee) immediately of all crimes reported to them by students.

 Faculty and staff should immediately notify the Institute Director or his/her on-site designee.

The Institute strongly encourages individuals to report all crimes in an accurate and timely manner to local law enforcement agencies. Upon written request, the Institute will disclose to the alleged victim of a crime of violence (as that term is defined in section 16 of title 18, United States Code), or a non-forcible sex offense, the report on the results of any disciplinary proceeding conducted by the Institute against a student who is the alleged perpetrator of such crime or offense. If the alleged victim is deceased as a result of such crime or offense, the next of kin of such victim shall be treated as the alleged victim for purposes of this paragraph.

B. INSTITUTIONAL RESPONSE PROCEDURES

1. Response to Reports of Crime or Emergency

Upon receipt of a report of a crime or emergency, the Institute Director or his/her on-campus designee will:

 Immediately assess, based on his/her own judgment or after consultation with other Institute employees, whether the situation warrants contacting 911 and/or following the emergency response and evacuation procedures contained in Section II.B.3.

 Immediately assess, based on his/her own judgment and/or after consultation with other Institute employees or the local police, whether a “timely warning” to the campus community should be issued pursuant to the Timely Warning policy in Section II.B.2.

 With regard to a reported incident that is or may be a sex offense, immediately contact the Institute’s Title IX Coordinator who has authority to evaluate and respond to the reported sex offense in accordance with the Institute’s Sexual Harassment and Sex Offenses Policies and Procedures contained in Section X.

 For all reported crimes, the Institute Director will contact the Campus Security Survey Administrator within 24 hours of the incident to provide all available and relevant information including the date, time, location, and description of the incident.

 The Institute Director will cooperate with the Campus Security Survey Administrator and/or Title IX Coordinator to investigate and gather any additional information necessary to determine whether the incident must be reported in the crime statistics contained in this Report.

2. Timely Warning of Reported Crime

In the event that a situation arises, either on or off campus, that, in the judgment of the Institute Director, constitutes an ongoing or continuing threat to students and employees, including with regard to any crime reportable pursuant to the Clery Act, a campus wide “timely warning” will be issued. Depending on the circumstances of the crime, especially in all situations that could pose an immediate threat to the students and employees, the Institute will post a warning via one or more of the following means of communication: social media, email or text message and/or verbal or written notice.

Anyone with information warranting a timely warning should report the circumstances to the Institute Director or his/her on-campus designee.

3. Emergency Response and Evacuation Procedures

In the case of a significant emergency or dangerous situation involving an immediate threat to the health or safety of students, employees, or clients occurring on campus or on public property, including thoroughfares, streets, sidewalks, and parking facilities within the campus or immediately adjacent to or accessible from the campus, as confirmed by the Institute Director or their on-campus designee after consultation with others as appropriate, such that it is deemed necessary to close, evacuate or lock down all or portions of the Institute’s buildings, the following procedures are implemented:

The emergent situation will be assessed by the Institute Director, or in his/her absence, his/her on-site designee, in cooperation with other individuals or law enforcement as appropriate. Should the determination be made that the situation justifies total or partial closure, evacuation or lockdown of

the school, a call will immediately be made to 911. A determination will be made relative to characteristics of emergency as to what segment of the campus community must be notified and what portions of the campus will be evacuated or locked down.

In the event the building needs to be evacuated or locked down for any reason, maps of the evacuation route have been posted in each office, common areas, clinic and classroom.

The Institute will, without delay, and taking into account the safety of the students, staff, faculty, guests and the community, determine the appropriate content of the notification and initiate the emergency notification system to the appropriate segment or segments of the campus community, unless the notification will, in the professional judgment of responsible authorities, compromise efforts to assist victims or to contain, respond to, or otherwise mitigate the emergency.

The notice regarding the evacuation, closure or lockdown will be disseminated to the campus community by one or more of the following: verbal on-site announcement, activation of a fire alarm, email, text or other means appropriate to quickly notify the relevant segment of the campus community of the need to evacuate or lock down the institution. The Institute Director will notify the local police, fire or other appropriate first responder to assist with the emergency.

The procedure for disseminating emergency information to the larger community includes notice to the local police and or fire department, and, where appropriate, the local media.

The Institute tests its emergency response and evacuation procedures at least once annually on an announced or unannounced basis. When tests are conducted, the Institute publicizes its emergency response and evaluation procedures to students, faculty, and staff, including making available a copy of this policy. The Institute maintains documentation of each test exercise including date and time performed and whether announced or unannounced will be completed immediately following testing.

III. SCHOOL CLOSURES – NON-EMERGENCY

Upon a decision by the Institute Director, after consultation with other Institute officials as appropriate, to close a campus for any reason, including for weather related reasons, the Institute will use email and text message as the primary means to communicate this information to faculty, staff and students as soon as possible after the closure decision is made.

IV. POLICY STATEMENT ADDRESSING COUNSELORS AND COUNSELING SERVICES

There are no Pastoral or Professional Counselors on Campus. Crisis, Mental Health and Victim Resource Hotline numbers are posted in the student break areas as well as listed in the Student Catalog should students need to contact these agencies. Section X of this policy addresses the Institute’s policies with respect to support services and confidentiality of victims of sexual violence.

V. ACCESS POLICY, SECURITY OF CAMPUS FACILITIES, AND SECURITY CONSIDERATIONS USED IN THE MAINTENANCE OF CAMPUS FACILITIES

The Institute does not maintain residential facilities and does not have any officially recognized student organizations with non-campus locations. Campus Buildings are open to staff, faculty and/or students during business hours; UC Campus: Tuesday – Friday 8:30am to 9:45pm, Saturday 8:30am to 5:00pm.

QV Campus: Tuesday – Saturday 8:30am – 5:00pm. NMY Campus: Tuesday & Thursday 8:30am to 8:30pm, Wednesday, Friday & Saturday 8:30am to 5:00pm

During non-business hours access to each Campus is by key or fingerprint and a security code only or by admittance via a designated staff member for the purpose of staff use, maintenance or cleaning. Security cameras are posted in main areas and doorways for monitoring purposes.

VI. CAMPUS LAW ENFORCEMENT AND RELATED POLICIES

The Institute does not employ security personnel or campus police. Institute employees have no authority to arrest or detain any individual. The Institute will assist in notifying appropriate law enforcement authorities if a student requests assistance in contacting police. Students, faculty, and staff are encouraged to accurately and promptly report all crimes and public safety related incidents to the Institute, as set forth in Section II.A, and to notify local police.

If you are a victim of or witness to a crime and do not want to pursue action through the Institute’s procedures or the criminal justice system, the Institute encourages you to consider reporting the incident to the Institute Director or his/her designee for the limited purpose of permitting the Institute to include the incident in its crime statistic reporting without revealing your identity. With such information, the Institute can keep an accurate record of the number of similar incidents, determine where there is a pattern of crime with regard to a particular location, method, or assailant, and alert the campus community to potential danger. The Institute will make best efforts, to the extent permitted by law, to maintain the privacy of that information and to comply with the Family Educational Rights and Privacy Act of 1974 (FERPA). Police reports are public records under state law, the Institute cannot hold reports of crime obtained from police records in confidence. Policies with respect to victims of sexual violence are contained in Section X.

VII. SECURITY AWARENESS AND CRIME PREVENTION PROGRAMS

During new student and new employee (faculty and staff) orientations, individuals are informed of the Institute’s current security and crime prevention policies and practices as well as the protection of personal safety and prevention of crime. Such orientations may include a Power Point presentation and/or review of the policies contained in this Report and the Student Manual. The presentations include training required by Title IX of the Higher Education Act regarding preventing and responding to sexual harassment/violence, among other topics as contained in Section X. Should time be of the essence regarding security awareness, information may be released to the Campus community through the timely warning procedures contained in this Report.

VIII. POLICY ON POSSESSION, USE AND SALE OF ALCOHOLIC BEVERAGES AND ILLEGAL DRUGS

All Institute property has been designated “drug free” and the Institute is committed to full compliance with the Drug Free Workplace Act and the Drug-Free Schools and Communities Act regulations as contained in 34 C.F.R. Part 86.

Students and employees are prohibited from the unlawful manufacture, distribution, dispensing, possession or use of a controlled substance or alcohol anywhere on the Institute’s property including grounds, parking areas, anywhere within the building, or while participating in any school sponsored or school related activities. The use and abuse of alcohol and other drugs can seriously impair performance. Students or employees who violate this standard will be subject to disciplinary action up to and including expulsion or termination of employment.

As a condition of enrollment or employment, students and employees must abide by the standards contained in this policy or the Institute will take one or more of the following actions within thirty days with respect to any student or employee who violates this standard:

reporting the violation to law enforcement officials;

taking appropriate disciplinary action against such student or employee, up to and including expulsion or termination of employment; and

requiring such student or employee to participate in a substance abuse rehabilitation program approved for such purposes by a federal, state, local health, law enforcement or other appropriate agency.

The possession, sale or the furnishing of alcohol and/or illegal drugs on the Institute’s campus or during Institute sponsored activities is also governed by state and federal laws. The unauthorized possession, sale, manufacture or distribution of any controlled substance is illegal under both state and federal laws. The possession of alcohol by anyone under 21 years of age in a public place or a place open to the public is illegal under state law. The enforcement of federal and state alcohol/illegal drugs laws on-campus is the primary responsibility of the local police department and violators may be subject to arrest, criminal prosecution, fine and/or imprisonment. The Institute may refer violation of prescribed conduct to appropriate authorities for prosecution in connection with federal and state laws.

In accordance with law, the Institute conducts reviews at least biennially to determine the effectiveness of this policy to ensure consistent enforcement of applicable drug and alcohol related statutes, ordinances, and institutional policies against students and employees found to be in violation. Annual Review reports and supporting documents will be maintained by the Institute and made available upon request.

IX. ALCOHOL AND SUBSTANCE ABUSE EDUCATION

At least on an annual basis, students, faculty and staff are provided with a copy of the Institute’s Policy on Possession, Use and Sale of Alcoholic Beverages and Illegal Drugs, in Section VIII, the Institute’s alcohol and substance abuse programs, described in Section IX, health and safety concerns with drug abuse, and counseling and assistance resource information. New students, faculty and staff are provided this information during orientation. In addition, annually students are provided this information by means of the current Student Manual and material posted on campus. Current faculty and staff are provided this information during their annual review.

The Institute may also refer students, faculty or staff in violation of the Institute’s policy to substance abuse education or rehabilitation programs as a condition of continued enrollment or employment.

X. POLICY REGARDING SEXUAL HARASSMENT AND SEX OFFENSES

Jean Madeline Aveda Institute’s policy prohibits harassment or discrimination based on race, religion, creed, national origin, ethnicity, ancestry, color, sex, military or veteran status, physical or mental disability, mental condition, marital status, age, sexual orientation, gender, gender identify, or expression, genetic information or any other basis protected by federal, state or local law. Additionally, in accordance with Title IX of the Education Amendments of 1972, the Institute prohibits discrimination based on sex, which includes harassment and sexual violence, and the Institution has jurisdiction over Title IX complaints.

The Institute is committed to ensuring an educational environment free from all forms of sex discrimination, including sexual misconduct of all types. Students, faculty and staff should be aware that discrimination and/or other harassment based on sex, gender identity or sexual orientation is unacceptable. The Institute prohibits dating violence, domestic violence, sexual assault, and stalking as defined below. To fulfill its educational mission, the Institute has designated the [Title IX Coordinator] as its designated representative to coordinate the Institute’s compliance with Title IX of the Education Amendments of 1972, as amended and the Clery Act. Students, faculty or staff who feel that they have been the victim of sex harassment, sex discrimination, sexual violence or other sexual misconduct should contact the Title IX Coordinator at (215)238-9998 x 1123 – Joan Reilly, email: jreilly@jeanmadeline.edu and follow these procedures. For grievances other than those related to Title IX, students should follow the procedure outlined in the [Section 504 Internal Grievance Procedure] in the Student Manual.

It is the responsibility of all persons within the Institute to work to ensure an educational environment free from sexually violent and/or harassing behavior. All members of the Institute (student and staff) are expected to report incidents of sexual harassment, sexual violence or assault and harassment based on sexual orientation.

A. Sexual Harassment and Sexual Violence

Sexual harassment and acts of sexual violence, including sexual assault, domestic violence, dating violence and stalking are prohibited by the Institute and will not be tolerated. All members of the Institute community (students, faculty and staff) are encouraged to promptly and accurately report incidents of sexual harassment and sexual violence. This allows the Institute to quickly respond to the allegations and offer immediate support to the victim.

Allegations will be investigated promptly and thoroughly as provided by this policy, and both the victim and the accused will be afforded equitable rights during the investigative process. The Institute will include information on crimes of sexual violence in its Clery Act Annual Security Report in a manner that protects the identity of the victim.

Any student who feels that he or she is the victim of sexual harassment including sexual violence has the right to seek redress of the grievance pursuant to this policy. The Institute provides these procedures for reviewing and resolving such complaints. Substantiated accusations may result in disciplinary action against the offender, up to and including termination of the employee’s employment or the student’s enrollment. In addition, complainants who make accusations of sexual harassment in bad faith may be subject to equivalent disciplinary action.

B. Key Definitions

Sexual harassment is defined as unwelcome advances, requests for sexual favors, other verbal or physical sexual conduct, or any other offensive unequal treatment of an employee, student, or group of employees or students that would not occur except for their sex when:

1. The advances, requests or conduct have the effect of interfering with performance of duties or studies or creating an intimidating, hostile, or otherwise offensive work or academic environment.

2. Submission to such advances, requests or conduct is explicitly or implicitly a term or condition of an individual’s employment or academic achievement or advancement.

3. Submission to or rejection of such advances, requests or conduct is used as a basis for employment or academic decisions.

Sexual Harassment is a violation of Section 703 of Title VII of the Civil Rights Act of 1964 as amended in 1972, (42 U.S.C. S2000e, et. seq.), and Title IX of the Education Amendments of 1972 (20 U.S.C. 1691, et. seq.) and is punishable under both federal and state laws. Forms of sexual harassment include, but are not limited to, sexist remarks or behavior, constant offensive joking, sexual looks or advances, repeated requests for dates, unwelcome touching, promise of reward for sexual favors. Students, faculty or staff who experience sexual harassment should be encouraged to make it clear to the alleged offender that such behavior is offensive. However, failure to comply with this provision does not defeat the School’s investigation of the allegation.

Sexual violence means physical sexual acts perpetrated against a person’s will or where a person is incapable of giving consent. A number of acts fall into the category, including sexual assault or harassment based on sexual orientation, domestic violence, dating violence, and stalking. Alleged sexual violence against another may also constitute a crime resulting in an additional, independent law enforcement investigation falling outside of this Grievance Policy. These acts will not be tolerated at the Institute as such acts are inappropriate and create an environment contrary to the goals and mission of the Institute. Any such acts will be thoroughly investigated and will subject an individual to appropriate disciplinary sanctions and/or possible action by appropriate law enforcement agencies.

Sexual assault includes rape, acquaintance rape, fondling, incest, and statutory rape, as well as other forms of nonconsensual sexual activity.

Domestic violence means a felony or misdemeanor crime of violence committed by a current or former spouse or intimate partner of the victim, a person with whom the victim shares a child in common, a person who is cohabitating with or has cohabitated with the victim as a spouse or intimate partner, a person similarly situated to a spouse of the victim under domestic or family violence laws of the jurisdiction in which the crime of violence occurred, or any other person against an adult or youth victim who is protected from that person’s act under the domestic or family violence laws of the jurisdiction in which the crime of violence occurred.

Dating violence means a violence act committed by a person who is or has been in a social relationship of a romantic or intimate nature with the victim and where the existence of such a relationship shall be determined based on the reporting party’s statement and with consideration of the following factors: the length of the relationship, the type of relationship, and the frequency of interaction between the persons involved in the relationship. Dating violence includes, but is not limited to, sexual or physical abuse of threat of such abuse and dating violence does not include acts covered under the definition of domestic violence.

Stalking means “engaging in a course of conduct (two or more acts including but not limited to acts in which the stalker directly, indirectly, or through third parties, or by any action, method, device or means, follows, monitors observes, surveils, threatens or communicates to or about a person or interferes with his or her property that is directed at a specific person and would cause a reasonable person to fear for his or her safety or the safety of others or suffer substantial emotional distress. Reasonable persons mean a reasonable person under similar circumstances and with similar identities to the victim. Substantial emotional distress means significant mental suffering or anguish that may, but does not necessarily, require medical or other professional treatment or counseling.

Consent means voluntary agreement to engage in sexual activity by verbal agreement or active and willing participation in sexual activity. Someone who is incapacitated or under the age of consent under state law cannot consent. Past consent does not imply future consent. Silence or an absence of resistance does not imply consent. Consent to engage in sexual activity with one person does not imply consent to engage in sexual activity with another. Consent may be withdrawn at any time. Coercion, force, or threat of either invalidates consent.

C. Reporting Sexual Offenses

Upon observing or involvement in any type of sexual misconduct on campus or on public property, including thoroughfares, streets, sidewalks, and parking facilities, within the campus or immediately adjacent to or accessible from the campus, students, faculty and staff should report the incident to the Institute’s Title IX Coordinator – Joan Reilly at (215)238-9998 Ext 1123, email – jreilly@jeanmadeline.edu

A report may be made to either or both the police and the Title IX Coordinator. The Title IX Coordinator is responsible for the Institute’s compliance with Title IX of the Education Amendments of 1972. In this role, the Title IX Coordinator administers the review, investigation and resolution procedures for reports of sexual misconduct. Where there is any question about whether an incident is a sex offense, a report should be made to the Institute for assistance in determining the nature of the incident.

Requests for Confidentiality: Reports about sex offenses do not have to be formal signed complaints.

The Institute is committed to protecting the confidentiality of victims and will work closely with individuals who wish to obtain confidential assistance regarding an incident of sexual misconduct and will maintain the privacy of information to the extent permitted or required by law, even if the victim does not specifically request confidentiality. A victim’s personally identifying information will not be included in any publically available recordkeeping, including Clery Act reporting and disclosures such as this Annual Security Report.

These documents are maintained in a locked file cabinet that only permitted staff has access to. Memoranda describing any formal reprimand or disciplinary action for violating this policy will be placed in a student’s permanent academic file and an employee’s permanent personnel file. In some cases, the Institute may need to disclose some information about a victim to a third party to provide necessary accommodations or protective measures. The Title IX Coordinator and the Institute Director will meet to weigh the victim’s confidentiality against the impact on the school being able to provide these necessary accommodations or protective measures. Should it be deemed necessary, they will determine what information about the victim should be disclosed and who it needs to be disclosed to. The victim will be notified regarding which information will be shared, with whom it will be shared and why prior to the Institute sharing the information.

Prohibition on Retaliation: The Institution is prohibited from retaliating against individuals who file a report regarding a sex offense.

Victims of Assault/Violence: If you are a victim of a sexual violence, your priority should be to get to a place of safety. You should then obtain any necessary medical treatment. Information about the alleged offense should be provided to the Institute’s Title IX Coordinator as soon as possible. Time is a critical factor for evidence collection and preservation. Evidence may assist in proving that the alleged criminal offense occurred or may be helpful in obtaining a protection order.

The Institute strongly advocates that a victim of sexual assault or violence report the incident to police in a timely manner and, if requested to do by the victim, the Institute will assist the victim in contacting the police. Filing a police report will not obligate the victim to prosecute, nor will it subject the victim to scrutiny or judgmental opinions from officers. The victim is not required to contact the police in order to pursue the Grievance Procedure contained in this policy or for the Institute to conduct an independent investigation under this section. Filing a police report will:

 ensure that a victim of sexual assault receives the necessary medical treatment and tests, at no expense to the victim;

 provide the opportunity for collection of evidence helpful in prosecution, which cannot be obtained later (ideally a victim of sexual assault should not wash, douche, use the toilet, or change clothing prior to a medical/legal exam); and

 assure the victim has access to free confidential counseling from counselors specifically trained in the area of sexual assault crisis intervention.

When a victim contacts the Police Department, the local Police Sex Crimes Unit will be notified as well. The victim may choose for the investigation to be pursued through the criminal justice system. A representative from the Institute will guide the victim through the available options and support the victim in his or her decision. Various counseling options are available through the Rape and Sexual Abuse Center and the Victim Intervention Program of the local Police Department. The Institute does not issue order of protection. A temporary protection order or a civil protection order can be obtained through the Domestic Relations Court. A protection order can also be obtained through the Municipal Court Division of the criminal court. The Institute will comply with protection orders as required by law.

D. Responding to Sex Offenses

The Institute’s Title IX Coordinator has primary responsibility for receiving, evaluating and investigating sexual misconduct reports and for maintaining accurate Clery Act crime statistics. The Title IX Coordinator is responsible for informing the Campus Security Survey Administrator within 24 hours after receiving a sex offense report for purposes of maintaining accurate Clery Act crime statistics.

Once the Title IX Coordinator receives a sex offense report, the following steps will be followed:

1. The Title IX Coordinator will immediately assess whether the information in the sex offense report warrants a timely warning and, if so, will contact the Institute Director immediately to execute that procedure.

2. The Title IX Coordinator will, within 24 hours of receipt of the report, provide the individual making the report of an alleged sex offense with:

a. a copy of this policy;

b. information on the availability of the Institute’s formal investigatory procedures (see Formal Investigatory and Disciplinary procedures below);

c. information about local victim support resources (off-campus) for victims including existing counseling, health, mental health, victim advocacy, legal assistance, visa and immigration assistance, student financial aid and other services available to victims;

d. information on the right to report the incident to local police and the fact that the Institute procedure and criminal proceeding may occur simultaneously; and

e. options to facilitate changes to transportation, working, academic and/or living situations, if requested, while an informal or formal investigation is pending. The Institute will seek to maintain the confidentiality of the identity of the victim and any accommodations or protective measures provided to the victim, to the extent that maintaining such confidentiality would not impair the Institute’s ability to provide the accommodations or protective measures. These steps will be taken by the Institute regardless of whether the victim chooses to file a formal complaint.

3. Inform the complainant of their right to file a separate criminal complaint for allegations relating to sexual violence. The Institute will comply with a victim’s request for assistance in notifying authorities.

4. For incidents other than allegations of sexual violence, undertake, with permission of or at the request of the complainant, to resolve the conflict informally by informing the individual alleged to have caused the grievance that the complaint has been filed; seek to find out the facts; and, if both parties desire it, arrange a meeting to try to resolve the differences. All individuals who are involved in an investigation as the accused, accuser or witness have a duty to keep all information confidential to the extent permitted by law. Persons who violate the confidentiality rights of other individuals may be subject to disciplinary action.

In the event that an attempt at informal resolution of the problem is unsuccessful, or if the complainant or the Institute deems that informal resolution is undesirable or not permitted by law, the Title IX Coordinator will stop the informal resolution process and assist the complainant in filing of a formal complaint or self-initiate a formal investigation.

E. Formal Investigatory and Disciplinary Options

All reports of sexual violence received by the Title IX Coordinator must be resolved through this formal investigatory and disciplinary procedure. The Institute is committed to providing a fair, prompt and impartial process from investigation initiation to final result. If a victim discloses an incident but wishes to maintain confidentiality or request that no formal investigation be conducted or disciplinary action taken, the Institute must weigh that request against its obligation to maintain a safe environment. When the Institute honors the complainant’s request for confidentiality, the complainant must understand that the Institute’s ability to meaningfully investigate the incident and pursue disciplinary action against the accursed may be limited. In the case of sexual violence, the Institute may be required to formally investigate and, if appropriate, pursue disciplinary action under this policy. If the Institute determines it cannot maintain the victim’s confidentiality, it will so inform the victim prior to initiating the investigation and will, to the extent possible, share as limited information as possible in an effort to protect the victim’s identity. The Institute may not require a victim to participate in a formal investigation or hearing that it is initiated.

Any student, faculty or staff, or group of same, alleging that an act of sexual harassment or violence has taken place has the right to seek redress of the grievance by means of these formal procedures. In order to ensure availability of witnesses and fresh memories of the alleged discriminatory event, all grievances or investigations covered by these formal procedures should be filed as promptly as possible after the alleged discriminatory conduct. While informal resolution of the conflict is always open to the aggrieved party, an attempt at informal resolution is not a prerequisite to filing a formal grievance or to the Institute’s obligation to investigate a reported event.

To initiate this procedure, a student, faculty member or staff should direct a written complaint to the Title IX Coordinator that states in detail the nature of the complaint, any relevant dates, and the names of any potential witnesses, and any request for confidentiality. In a situation deemed to be an emergency by the Title IX Coordinator, the Institute will issue a Timely Warning and the individual alleged to have caused the grievance or complaint may be temporarily transferred or put on leave pending the outcome of the case. The Title IX Coordinator need not wait for the conclusion of a criminal investigation or criminal proceeding to begin an investigation where warranted.

After report of the grievance, the Title IX Coordinator will:

1. Provide the complainant with a copy of this policy and information about local victim support resources. Victims of sexual violence will be provided information about evidence preservation.

2. Provide options to facilitate changes to transportation, working, academic and/or living situations, if requested, while an informal or formal investigation is pending, including the option to issue a no-contact order.

3. Inform the complainant of their right to file a separate criminal complaint for allegations relating to sexual violence and that the Institute can assist the victim in doing so if requested.

The Title IX Coordinator will initiate an investigation within ten days of receipt of the formal grievance to determine whether there is a reasonable basis for taking action. At a minimum, this investigation will consist of interviewing the complainant, the individual alleged to have caused the grievance, and any witnesses to the conflict. Within 30 days, the Title IX Coordinator must prepare a written report recommending one of three actions:

1. Concluding that the complaint is without merit and that no further action is warranted.

2. Recommending efforts to bring about an informal resolution under this policy if warranted and permitted by law.

3. Initiation of a formal grievance hearing to evaluate possible disciplinary action against the individual alleged to have caused the grievance.

Hearing Procedure

A Grievance Committee composed of the Title IX Coordinator and one other senior level management personnel who has received annual training on sexual violence and Title IX investigative procedures will be convened to review the Title IX Coordinator’s recommendations and to receive any oral or written testimony from the complainant, the individual alleged to have caused the grievance, and any relevant witnesses from both parties and any other relevant evidence. The standard of evidence used in the hearing will be “preponderance of the evidence.” Meaning that the Institute will evaluate whether it is more likely than not that the alleged conduct occurred. Both the complainant and the alleged perpetrator will be afforded equal and timely access to any information that will be used at the hearing. No party may have their lawyer present at any stage of the proceedings before the Grievance Committee but may be assisted in the process by a support person of their choice including an attorney. In all cases, the Title IX Coordinator will maintain regular communications with both the accuser and accused and provide both parties with equal opportunity to provide information, witness statements, evidence, and other information that may be necessary for the Title IX Coordinator and the Grievance Committee to fully evaluate the alleged offense. The Committee will decide:

1. Whether the complaint is without merit and that no further action is warranted.

2. What, if any, remedial action is necessary.

3. The nature, scope and timing of any proposed disciplinary action against the alleged perpetrator.

The determination of the merits of the complaint by the Grievance Committee will be final. The Institute will inform both parties simultaneously of its final determination.

The Title IX Coordinator will, barring extenuating circumstance, complete the investigation and make a determination regarding any necessary discipline of accused and remedies to accuser within 60 days of the date that the report is first received by the Title IX Coordinator.

The School Director will determine if the incident is indicative of systemic issue related to the sex offense and, if so, work with Institute staff to recommend changes to Institute policies, procedures or training to prevent re-occurrence.

Disciplinary Options

Penalties: Substantiated accusations of sexual violence may result in disciplinary action against the offender, up to and including termination of the employee’s employment or the student’s enrollment. Other potential penalties include: suspension (Major Standard Violation) pending the outcome of the investigation, community service, probation, no-contact order, or violence prevention training. In case of any formal proceedings against either a student accused of violating this Policy or an employee brought before a Grievance Committee proceeding, the penalties shall be as proposed by the Grievance Committee. In addition, complainants who make accusations of sexual harassment in bad faith may be subject to equivalent disciplinary action.

Complaint Record and Notice of Outcome: All proceedings and records will be confidential to the extent permitted by law. However, both parties will be notified, in writing, concurrently about the outcome of the complaint by the Grievance Committee. Memoranda describing a reprimand will be placed into the files of any student or employee in the event disciplinary action is taken against one of the parties. At the request of the individual alleged to have caused the grievance, a memorandum recognizing a finding of non-harassment or nondiscrimination will be placed into the file of the student or employee.

F. Education and Training

In an effort to promote a safe environment and to prevent acts of sexual misconduct, the Institute engages in primary prevention, awareness, bystander intervention and risk reduction training regarding sexual violence, including dating violence, domestic violence, sexual assault and stalking. The Institute educates the student community about this policy, sexual violence prevention and related Institute policies during all orientations held for new students upon the onset of a class. The Title IX Coordinator and persons serving on the Grievance Committee will receive annual training on issues related to sexual violence. The Title IX Coordinator is responsible for training current students and all Institute faculty and staff about the Institute’s Title IX policies and conducting the new student training. The Institute also provides ongoing prevention and awareness training for current students and staff at least annually.

Bystander Intervention and Risk Reduction

All crimes, including crimes of sexual violence, can be prevented through steps by the campus community to reduce risk of being a victim of a crime and by intervening before a crime has occurred where there is a reasonable belief that a crime may occur. The Institute urges members of the campus community to take steps to reduce their changes of being a victim of a crime including by: locking doors, securing items of value, walking in pairs at night, avoiding impairment caused by alcohol or drugs and other self-protective steps. In addition, if you witness what you believe to be a situation that may lead to the commission of a crime, the Institute urges all members of the campus community to call 911 or to contact an Institute employee immediately. In addition, members of the campus community may be able to interrupt the commission of a crime of sexual violence by intervening in the situation on a potential victim’s behalf where the intervention is not likely to pose harm to the intervenor. The Institute urges all members of the campus community work together to promote a safe campus environment for everyone. The Institute includes training on bystander intervention and risk reduction in all primary and ongoing training for students and staff.

G. Additional Information

Questions regarding this policy should be directed to the Title IX Coordinator. In addition, the U.S. Department of Education Office of Civil Rights (“OCR”) investigates complaints of unlawful harassment of students in educational programs or activities. This agency may serve as a neutral fact finder and will attempt to facilitate the voluntary resolution of disputes with the parties. For more information, visit the OCR website at: http://www.hhs.gov/ocr/.

XI. POLICY STATEMENT ADDRESSING SEX OFFENDER REGISTRATION INFORMATION.

In accordance with the Campus Sex Crimes Prevention Act of 2000, the Clery Act and the Family Educational Rights and Privacy Act of 1974, the local Police Department provides a link to the PA State Police Sex Offender Registry. The Institute is required to inform students and employees about where law enforcement information provided by a State concerning registered sex offenders may be obtained. The law also requires sex offenders already required to register in a State to provide notice of each institution of higher education in that State at which the person is employed, carries a vocation, or is a student. In the State of PA, convicted sex offenders must register with the Sex Offender and Crimes Against Minors Registry maintained by the Department of State Police. The PA State Police Department is responsible for maintaining this registry. Follow the link below to access the registry: https://www.psp.pa.gov/Pages/default.aspx

https://jeanmadeline.edu/documents/Disclosures.pdf

Effective Date: May 4, 2026
Last Updated: May 4, 2026

Jean Madeline Institute (“Jean Madeline,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information you provide through our website, request information forms, admissions inquiries, and other online interactions.

This Privacy Policy explains what information we collect, how we use it, how we protect it, and when we may disclose it.

1. Information We Collect

We may collect information that you voluntarily provide to us through our website, online forms, and admissions-related communications, including:

• Name
• Email address
• Phone number
• Mailing address
• Program interests
• Campus preferences
• Information you provide when requesting information, scheduling a tour, beginning an application, or otherwise contacting us

We may also collect limited technical information automatically when you use our website, such as browser type, device type, IP address, pages visited, and general website usage data.

2. How We Use Your Information

We may use the information we collect to:

• Respond to your requests for information
• Contact you about our programs, admissions process, tours, events, financial aid information, and student services
• Provide customer service and support
• Improve our website, communications, and user experience
• Maintain internal records and admissions-related communications
• Send important administrative, service, or transactional messages
• Comply with legal, regulatory, accreditation, and institutional obligations

If you provide your phone number or email address through our website or admissions forms, we may contact you by phone, email, or text message regarding your interest in Jean Madeline Institute, subject to applicable law.

3. How We Protect Your Information

We implement reasonable administrative, technical, and organizational safeguards designed to protect the personal information you provide through our website.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security.

4. Disclosure of Information

We do not sell your personal information.

We do not share your personal information with third parties except in the following limited circumstances:

• With service providers acting on our behalf to operate our website, process inquiries, support admissions communications, host systems, or provide related institutional services
• When disclosure is required to comply with applicable law, regulation, legal process, or governmental request
• When disclosure is necessary to protect our rights, safety, property, users, or others
• In connection with an organizational transaction such as a merger, acquisition, restructuring, or transfer of assets, where permitted by law

Any authorized service providers are expected to use personal information only for the services they perform for us and to protect it appropriately.

We do not sell or disclose student or prospective student personal information to third parties for their own independent marketing purposes.

5. Cookies and Website Analytics

Our website may use cookies or similar technologies to support site functionality, understand general website traffic patterns, and improve user experience.

These technologies may collect limited technical and usage information. You may be able to adjust your browser settings to refuse cookies, although some website features may not function properly as a result.

6. Third-Party Links

Our website may contain links to third-party websites, tools, scheduling systems, social media platforms, or other services. These third-party sites operate independently and have their own privacy policies and practices.

We are not responsible for the privacy practices, content, or security of third-party websites or services.

7. Online-Only Scope

This Privacy Policy applies to information collected through our website and other online forms or digital interactions that reference this Privacy Policy. It does not necessarily apply to information collected offline or through separate institutional records, enrollment agreements, financial aid documentation, or student files, which may be governed by separate policies, notices, or legal requirements.

8. Your Choices

You may opt out of promotional email communications at any time by using the unsubscribe link included in the message.

Where text messaging is used, you may opt out by replying STOP, if available.

Opting out of promotional messages does not prevent us from sending important non-marketing communications related to your inquiry, application, admissions process, enrollment, or other administrative matters.

9. Children’s Privacy

Our website and admissions services are not directed to children under the age of 13, and we do not knowingly collect personal information online from children under 13 without appropriate authorization where required by law.

10. Your Consent

By using our website or submitting information through our online forms, you consent to the collection, use, and disclosure of information as described in this Privacy Policy.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the revised version on this page and update the effective date above.

Your continued use of the website after changes are posted constitutes your acknowledgment of the updated Privacy Policy.

12. Contact Us

If you have questions about this Privacy Policy, please contact:

Jean Madeline Institute
PO Box 789
Fort Washington, PA 19034
Phone: 215-238-9998
Email: info@jeanmadeline.edu

The Office of Student Financial Aid at JMI operates within federal and state guidelines and other standards of individual aid programs. 

FINANCIAL AID CODE OF CONDUCT 

This code of conduct is intended to ensure that the relationships between providers of education loans and other forms of financial aid to students of JMI and its representatives with whom we deal with are free from all conflicts of interest, actual and perceived. Students of or, in appropriate cases, their parents, shall be the sole beneficiaries of all forms of financial aid. 

PRINCIPLES OF ETHICS 

• Prohibits employees of the Office of Financial Aid (or employee or agent who otherwise has responsibilities with respect to education loans) from recommending external lenders to students or their parents. Does not maintain a preferred lender list; 
• Prohibits employees of the Office of Financial Aid (or employee or agent who otherwise has responsibilities with respect to education loans) from refusing to process loan applications through any lender a student or parent chooses; 
• Prohibits revenue-sharing – an arrangement between the institution (officers, employees, or agents) and a lender under which the lender makes Title IV loans to students attending the institution (or to the families of those students); 
• Prohibits employees of the Office of Financial Aid (or employee or agent who otherwise has responsibilities with respect to education loans) from soliciting or receiving any gift worth more than nominal value from a lender, guaranty agency or loan servicer; 
• Prohibits employees of the Office of Financial Aid(or employee or agent who otherwise has responsibilities with respect to education loans) to accept from a lender, or an affiliate of any lender, any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans; 
• Prohibits the institution from steering borrowers to particular lenders or delaying loan certifications. For any first-time borrower, the institution may not assign, through the award packaging or other methods, the borrower’s loan to a particular lender. In addition, may not refuse to certify, or delay the certification of any loan based on the borrower’s selection of a particular lender or guaranty agency; 
• Prohibits offers of funds for private loans may not request or accept from any lender, any offer of funds or funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises to the lender for a specific number of Title IV loans made, insured, or guaranteed, a specific loan volume, or a preferred lender arrangement. 
• Prohibits the institution from requesting or accepting from any lender any assistance with call center staffing or financial aid staffing, except that a lender may provide professional development training, educational counseling materials (as long as the materials identify the lender that assisted in preparing the materials), or staffing services on a short-term, nonrecurring basis during emergencies or disaster; and 
• Prohibits employees of the Office of Student Financial Aid & Scholarships, (or any employee or agent who otherwise has responsibilities with respect to education loans) who serves on an advisory board, commission, or group established by a lender or guarantor (or a group of lenders or guarantors) from receiving anything of value from the lender, guarantor, or group, except for reimbursement for reasonable expenses incurred by the employee for serving on the board. 
• Disclose to the administration of JMI any involvement with or interest in any entity involved in any aspect of student financial aid. 

Accreditation – Jean Madeline Institute

• Full time cosmetology disclosure
• Part time cosmetology disclosure
• Teacher Training disclosure