Non-discrimination Policies

Diver­sity and Personal Respect

The Waverly School embraces diver­sity and values the integrity of the indi­vid­ual. Indi­vid­ual differ­ences of reli­gion, culture, socioe­co­nomic status, national origin, race, ethnic­ity, biolog­i­cal sex, gender iden­tity, gender expres­sion, sexual orien­ta­tion, phys­i­cal appear­ance, and ability are acknowl­edged and respected. Every member of the commu­nity strives to behave in a sensi­tive, open, and respectful manner.

A diverse student body is an essen­tial compo­nent of an expe­ri­en­tial educa­tion. Students are most able to under­stand, appre­ci­ate, and respect differ­ences in a setting that includes these differ­ences. Waverly seeks a diverse commu­nity in order to fulfill its mission to provide a strong, human­is­tic educa­tion for all students.

EEO State­ment

The Waverly School is an equal oppor­tu­nity employer dedi­cated to a policy of non-discrim­i­­na­­tion based on the race, color, creed, reli­gion, sex, gender, gender iden­tity, gender expres­sion, marital status, preg­nancy, trans­gen­der, trans­sex­u­al­ism, sexual orien­ta­tion, age, national origin, citi­zen­ship, primary language, mili­tary or veteran status, phys­i­cal hand­i­cap, disabil­ity, medical condi­tion, mental disabil­ity, genetic char­ac­ter­is­tic or infor­ma­tion, ances­try, or based on any other consid­er­a­tion made unlaw­ful by federal, state, or local laws.

Non-discrim­i­na­tion Policy as to Students

The Waverly School welcomes fami­lies and admits students of any race, color, national and ethnic origin to all the rights, priv­i­leges, programs, and activ­i­ties gener­ally accorded or made avail­able to students at the school. It does not discrim­i­nate on the basis of race, color, national and ethnic origin, sex, marital status, disabil­ity, and age in admin­is­tra­tion of its educa­tional poli­cies, admis­sions poli­cies, schol­ar­ship and loan programs, and athletic and other school-administered programs.

The follow­ing person has been desig­nated to handle inquiries regard­ing The Waverly School’s non-discrim­i­na­tion poli­cies, includ­ing its Title IX policy:

Heidi Johnson
Head of School
67 W. Belle­vue Dr.
Pasadena, CA 91105
626.792.5940
heidi@​thewaverlyschool.​org

For assis­tance related to Title IX or other civil rights laws, please contact OCR at OCR@​ed.​gov or 800 – 421-3481, TDD 800 – 877-8339.

Title IX Policy

Click here to down­load a PDF of our Title IX policy.

Consis­tent with Title IX of the Educa­tion Amend­ments of 1972 (“Title IX”), the Waverly School (the School”) does not discrim­i­nate on the basis of sex in its educa­tional programs and activ­i­ties, recruit­ment, admis­sions, course offer­ings, finan­cial aid, athlet­ics, or employment.

In addi­tion to this Title IX policy, the School has estab­lished sepa­rate poli­cies, that, among other things: (1) outline the School’s mandated report­ing guide­lines; (2) outline the School’s processes for manag­ing inter­per­sonal rela­tion­ships safely and appro­pri­ately; and (3) seek to prevent sex-based discrim­i­na­tion, harass­ment, and violence. Please see the School’s Student & Family Hand­book or Employee Hand­book, as applic­a­ble, for further infor­ma­tion about these policies.

Students, parents/​guardians, and employ­ees are also encour­aged to commu­ni­cate with the Head of School or the Assis­tant Heads of School with any ques­tions or concerns regard­ing these poli­cies. The School believes that open commu­ni­ca­tion about these sensi­tive topics is inte­gral to prevent­ing serious miscon­duct from occur­ring and is essen­tial to foster­ing a culture of personal respon­si­bil­ity, mutual account­abil­ity, and positive leadership.

Compli­ance Coordinator

The Compli­ance Coor­di­na­tor is respon­si­ble for admin­is­ter­ing and ensur­ing the School’s compli­ance with Title IX. In order to ensure compli­ance with Title IX in all facets of the School’s oper­a­tion, the Compli­ance Coor­di­na­tor will coor­di­nate with the School’s Admin­is­tra­tion to imple­ment and admin­is­ter this policy and the School’s related griev­ance proce­dures for resolv­ing Title IX complaints. The Compli­ance Coor­di­na­tor is also respon­si­ble for inves­ti­gat­ing complaints of sex-based discrim­i­na­tion, harass­ment, violence, or other alle­ga­tions regard­ing viola­tions of Title IX; working with law enforce­ment regard­ing such complaints when neces­sary; and ensur­ing that complaints are resolved promptly and appro­pri­ately to the extent possi­ble. The Compli­ance Coor­di­na­tor may dele­gate these duties to other school employ­ees or exter­nal inves­ti­ga­tors, as neces­sary and in his or her sole discre­tion, to ensure the prompt and appro­pri­ate reso­lu­tion of any complaint.

The Compli­ance Coor­di­na­tor (or his or her designee) may also meet with the School’s students, parents/​guardians, and/​or employ­ees regard­ing their rights and oblig­a­tions under Title IX and to address any ques­tions regard­ing the School’s compli­ance with such obligations.

Inquiries concern­ing this policy, Title IX, and any related issues of sex-based discrim­i­na­tion should be directed to the School’s Compliance Coordinator:

Name: Heidi Johnson
Title: Head of School
Office Address: 67 W. Belle­vue Drive, Pasadena, CA 91105 
Tele­phone Number: 626.792.5940
Email Address: heidi@​thewaverlyschool.​org

Sex-Based Harass­ment

The School prohibits sex-based harass­ment by students, employ­ees, or third parties when the conduct is suffi­ciently serious to deny or limit a student’s ability to partic­i­pate in or benefit from the School’s educa­tional programs and activ­i­ties; submis­sion to or rejec­tion of such conduct is made, either explic­itly or implic­itly, a term or condi­tion of admis­sion or employ­ment or the basis for an admis­sion or employ­ment deci­sion; or such conduct has the purpose or effect of unrea­son­ably inter­fer­ing with perfor­mance or creat­ing an intim­i­dat­ing, hostile, humil­i­at­ing, or sexu­ally offen­sive learn­ing or work environment.

Title IX prohibits several types of sex-based harass­ment. For the purposes of this policy, the follow­ing defi­n­i­tions apply. Sex-based harass­ment means unwanted conduct that is related to an indi­vid­u­al’s sex or the sex of another person. Sexual violence is a form of sex-based harass­ment and refers to phys­i­cal sexual acts perpe­trated against a person’s will or where an indi­vid­ual is inca­pable of giving consent (e.g., due to the individual’s age or use of drugs or alcohol, or because an intel­lec­tual or other disabil­ity prevents the indi­vid­ual from having the capac­ity to give consent). A number of differ­ent acts fall into the cate­gory of sexual violence, includ­ing rape, sexual assault, sexual battery, sexual abuse, and sexual coer­cion. Gender-based harass­ment is another form of sex-based harass­ment and refers to unwel­come conduct based on an individual’s actual or perceived sex, includ­ing harass­ment based on gender iden­tity or noncon­for­mity with sex stereo­types, and not neces­sar­ily involv­ing conduct of a sexual nature. All of these types of sex-based harass­ment are forms of sex-based discrim­i­na­tion prohib­ited by Title IX.

Harass­ing conduct may take many forms, includ­ing verbal acts and name-calling, as well as nonver­bal behav­ior, such as graphic and written state­ments, or conduct that is phys­i­cally threat­en­ing, harmful, or humil­i­at­ing. The more severe the conduct, the less need there is to show a repet­i­tive series of inci­dents to prove a hostile envi­ron­ment, partic­u­larly if the conduct is phys­i­cal. Indeed, a single or isolated inci­dent of sexual violence may create a hostile environment.

Sex-based harass­ment may occur between students, between students and employ­ees, between employ­ees, between students and third parties, and between employ­ees and third parties, regard­less of the genders of the victim and harasser.

Complaints and Investigation Process

The respon­si­bil­ity to inves­ti­gate complaints (and/​or desig­nate other indi­vid­u­als to conduct inves­ti­ga­tions) under this policy has been assigned to the Compli­ance Coor­di­na­tor. Students or employ­ees who expe­ri­ence or witness conduct in viola­tion of this policy should imme­di­ately report it to the Compli­ance Coor­di­na­tor or any member of the School’s Admin­is­tra­tion. Any member of the School’s Admin­is­tra­tion receiv­ing a complaint is required to imme­di­ately report it to the Compliance Coordinator.

Complaints may be reported orally or by using the School’s Title IX Complaint Form (PDF). The Title IX Complaint Form may be obtained from the Head of School.

Upon receipt of a complaint, the Compli­ance Coor­di­na­tor (or his or her designee) will promptly conduct an inves­ti­ga­tion in such a way as to main­tain confi­den­tial­ity to the extent prac­ti­cal under the circum­stances. The Compli­ance Coor­di­na­tor (or his or her designee) will conduct the inves­ti­ga­tion in compli­ance with the School’s Title IX Grievance Procedures.

Any student or employee who is found to have harassed another student or employee will be subject to disci­pli­nary action (up to and includ­ing expul­sion and/​or termi­na­tion of employ­ment). The School will also take appro­pri­ate correc­tive action to address harass­ment by third parties.

Prohi­bi­tion Against Retaliation

Retal­i­a­tion or reprisal by any student or employee against complainants, witnesses, or any other indi­vid­ual who reports alle­ga­tions of sex-based harass­ment, discrim­i­na­tion, and/​or violence or provides infor­ma­tion to assist in an inves­ti­ga­tion is strictly prohib­ited. Indi­vid­u­als who believe they have been retal­i­ated against in connec­tion with such action should imme­di­ately report such conduct to the Compliance Coordinator.

Any student or employee who is found to have retal­i­ated against a student or employee in connec­tion with a good- faith report of sex-based harass­ment or discrim­i­na­tion will be subject to disci­pli­nary action (up to and includ­ing expul­sion and/​or termi­na­tion of employment).

Title IX Grievance Procedures

Click here to down­load a PDF of our Title IX Griev­ance Proce­dures.
Click here to down­load a PDF of our Title IX Complaint Form.

In compli­ance with Title IX of the Educa­tion Amend­ments of 1972 (“Title IX”), The Waverly School (the School”) does not discrim­i­nate on the basis of sex in its educa­tional programs and activ­i­ties, recruit­ment, admis­sions, course offer­ings, finan­cial aid, athlet­ics, or employment.

The School has adopted a Title IX Policy and these Title IX Griev­ance Proce­dures which apply to all students, employ­ees, volun­teers, inde­pen­dent contrac­tors, vendors, and members of the School commu­nity. The Title IX Policy and Griev­ance Proce­dures shall apply to conduct that occurs on the School’s campus, at School-spon­sored events, and to events on or off campus that have suffi­cient ties to the School.

The purpose of this docu­ment is to outline the steps the School will take to provide the prompt and equi­table and reli­able reso­lu­tion of student and employee complaints under the School’s Title IX Policy. These proce­dures apply only to complaints alleg­ing sex-based discrim­i­na­tion, harass­ment, and/​or violence prohib­ited by Title IX and as outlined in the School’s Title IX Policy. For all other complaints, please consult the rele­vant poli­cies in the School’s Parent/​Guardian, Parent/​Student, or Employee Hand­books, as applicable.

Sex-Based Harass­ment

The School prohibits sex-based harass­ment by students, employ­ees, or third parties when the conduct is suffi­ciently serious to deny or limit a student’s ability to partic­i­pate in or benefit from the School’s educa­tional programs and activ­i­ties; submis­sion to or rejec­tion of such conduct is made, either explic­itly or implic­itly, a term or condi­tion of admis­sion or employ­ment or the basis for an admis­sion or employ­ment deci­sion; or such conduct has the purpose or effect of unrea­son­ably inter­fer­ing with perfor­mance or creat­ing an intim­i­dat­ing, hostile, humil­i­at­ing, or sexu­ally offen­sive learn­ing or work environment.

Title IX prohibits several types of sex-based harass­ment. For the purposes of these griev­ance proce­dures, the follow­ing defi­n­i­tions apply. Sex-based harass­ment means unwanted conduct that is related to an indi­vid­u­al’s sex or the sex of another person. Sexual violence is a form of sex-based harass­ment and refers to phys­i­cal sexual acts perpe­trated against a person’s will or where an indi­vid­ual is inca­pable of giving consent (e.g., due to the individual’s age or use of drugs or alcohol, or because an intel­lec­tual orother disabil­ity prevents the indi­vid­ual from having the capac­ity to give consent). A number of differ­ent acts fall into the cate­gory of sexual violence, includ­ing rape, sexual assault, sexual battery, sexual abuse, and sexual coer­cion. Gender-based harass­ment is another form of sex-based harass­ment and refers to unwel­come conduct based on an individual’s actual or perceived sex, includ­ing harass­ment based on gender iden­tity or noncon­for­mity with sex stereo­types, and not neces­sar­ily involv­ing conduct of a sexual nature. All of these types of sex-based harass­ment are forms of sex-based discrim­i­na­tion prohib­ited by Title IX.

Harass­ing conduct may take many forms, includ­ing verbal acts and name-calling, as well as nonver­bal behav­ior, such as graphic and written state­ments, or conduct that is phys­i­cally threat­en­ing, harmful, or humil­i­at­ing. The more severe the conduct, the less need there is to show a repet­i­tive series of inci­dents to prove a hostile envi­ron­ment, partic­u­larly if the conduct is phys­i­cal. Indeed, a single or isolated inci­dent of sexual violence may create a hostile environment.

Sex-based harass­ment may occur between students, between students and employ­ees, between employ­ees, between students and third parties, and between employ­ees and third parties, regard­less of the gender of the victim and harasser.

Complaint Process

All complaints regard­ing sex-based discrim­i­na­tion, harass­ment and/​or violence expe­ri­enced by students or employ­ees in viola­tion of Title IX shall be submit­ted to the School’s Compliance Coordinator:

Name: Heidi Johnson
Title: Head of School
Office Address: 67 W. Belle­vue Drive, Pasadena CA 91105
Tele­phone Number: 626.792.5940
Email Address: heidi@​thewaverlyschool.​org

Step 1: Reporting Complaints

Complaints may be reported orally or by submit­ting the School’s Title IX Complaint Form (PDF) to the Compli­ance Coor­di­na­tor. The Title IX Complaint Form may be obtained from the Head of School.

The complaint, whether reported orally or in writing, shall contain infor­ma­tion that describes the conduct that has allegedly occurred and caused the viola­tion of the School’s policy and Title IX prohi­bi­tions against sex-based discrim­i­na­tion, harass­ment, and/​or violence and iden­ti­fies the complainant, respondent(s), and any witnesses to the alleged conduct.

Complaints may be reported by employ­ees or students (or on their behalf) as detailed above. While the School encour­ages the report­ing indi­vid­ual to reveal his or her name to facil­i­tate inves­ti­ga­tion, complaints reported anony­mously will be inves­ti­gated to the fullest extent possi­ble under the circumstances.

Step 2: Deter­min­ing Applic­a­bil­ity of Procedures

Upon receipt of a complaint, the Compli­ance Coor­di­na­tor will review the infor­ma­tion provided to deter­mine whether the matter falls within the scope of these proce­dures. Within ten (10) days after receipt of a complaint, the Compli­ance Coor­di­na­tor will either begin an inves­ti­ga­tion or inform the complainant in writing that the conduct alleged in the complaint is not within the scope of these proce­dures and an inves­ti­ga­tion will not be conducted. If the matter does not involve alle­ga­tions of sex- based discrim­i­na­tion, harass­ment, or violence within the scope of these proce­dures, the Compli­ance Coor­di­na­tor will forward the matter to the appro­pri­ate School admin­is­tra­tor to handle a review in accor­dance with applic­a­ble School poli­cies and procedures.

Step 3: Investigation

If the complaint falls within the scope of these proce­dures, the Compli­ance Coor­di­na­tor will initi­ate an inves­ti­ga­tion. The Compli­ance Coor­di­na­tor may conduct the inves­ti­ga­tion or desig­nate other school employ­ees or an exter­nal inves­ti­ga­tor (the Inves­ti­ga­tor”) to assist with an inves­ti­ga­tion, as neces­sary, in his or her sole discre­tion. The Compli­ance Coor­di­na­tor will advise the parties of the name of the Inves­ti­ga­tor assigned to the complaint. To the extent prac­ti­ca­ble, the Inves­ti­ga­tion shall include inter­views with all the parties iden­ti­fied in the complaint as well as other witnesses, students, or employ­ees whom the Inves­ti­ga­tor deter­mines may provide infor­ma­tion rele­vant to address­ing the complaint. Both the complainant and respondent(s) will have an oppor­tu­nity to iden­tify witnesses to be inter­viewed and provide docu­men­ta­tion or other rele­vant evidence for review by the Inves­ti­ga­tor. The Inves­ti­ga­tor may take any addi­tional actions as neces­sary to complete the investigation.

The Inves­ti­ga­tor will main­tain docu­men­ta­tion of all proceed­ings related to the inves­ti­ga­tion, which may include, but is not limited to, notes or tran­scripts from witness inter­views, evidence provided by witnesses or involved parties, audio record­ings, or written find­ings of fact.

Step 4: Closure of Complaint

The Inves­ti­ga­tor will provide written notice of the results of the inves­ti­ga­tion, includ­ing the Investigator’s find­ings and conclu­sions (based on the prepon­der­ance of the evidence) support­ing the deter­mi­na­tion, promptly after the complaint is resolved, to the complainant and respon­dent, and in the case of minor students to their parents/​guardians. The written notice shall also advise the parties of their right to appeal an adverse deci­sion to the Compli­ance Coor­di­na­tor (or his or her designee).

If the Inves­ti­ga­tor deter­mines that the prepon­der­ance of the evidence supports the alle­ga­tions of discrim­i­na­tory conduct, the Inves­ti­ga­tor, in consul­ta­tion with the Compli­ance Coor­di­na­tor, shall also provide recom­men­da­tions for: (a) imme­di­ately ending the discrim­i­na­tory conduct; (b) ways to remedy the effects of the discrim­i­na­tory conduct on the complainant, and if applic­a­ble, the School commu­nity; and (c) steps to be taken to prevent the recur­rence of any discrim­i­na­tory or harass­ing conduct found to have occurred.

The School will strive to complete inves­ti­ga­tions, includ­ing issuance of written notice of the Investigator’s find­ings and conclu­sions to the complainant and respon­dent, in as timely and effi­cient a manner as possi­ble within sixty (60) days of receipt of a complaint. However, this time­frame may be extended based on factors such as, but not limited to, sched­ule and avail­abil­ity of witnesses, holi­days or semes­ter breaks includ­ing summer break, and complex­ity of the complaint. If an inves­ti­ga­tion cannot be completed within sixty (60) days of receipt of the complaint, then the Inves­ti­ga­tor will notify the complainant and respon­dent of that fact and provide a time­frame for complet­ing the inves­ti­ga­tion. Both parties will be given peri­odic updates through­out the investigation process.

Step 5: Appeal Rights

Any party not satis­fied with the result of a Title IX inves­ti­ga­tion or the suggested recom­men­da­tions of the Inves­ti­ga­tor and/​or Compli­ance Coor­di­na­tor may submit a written appeal to the Compli­ance Coordinator/​Head of School (or his or her designee). Appeals shall be decided by the Chair of the Board of Trustees (or his or her designee).

The written appeal shall state the nature of the disagree­ment with the result of the inves­ti­ga­tion, the reasons support­ing the appeal, and how the outcome would be changed by recon­sid­er­a­tion of the deter­mi­na­tion. The Chair of the Board of Trustees (or his or her designee) will consider all issues presented by the appeal­ing complainant, respon­dent, or their parent/​guardian and the rele­vant docu­men­ta­tion. The Chair of the Board of Trustees (or his or her designee) will issue a written deter­mi­na­tion within a reason­able time­frame after receipt of the appeal.

Confi­den­tial­ity

Confi­den­tial­ity will be main­tained to the great­est extent prac­ti­ca­ble during the complaint and inves­ti­ga­tion process. Any infor­ma­tion gath­ered during the inves­ti­ga­tion will only be shared with those who the Compli­ance Coor­di­na­tor deter­mines have a need-to-know, except in limited circum­stances, includ­ing but not limited to, when the School is required by law to report the infor­ma­tion, in order to further an inves­ti­ga­tion and/​or stop a discrim­i­na­tory prac­tice, or when such disclo­sure is neces­sary to protect the health, safety, or well-being of members of the School community.

Interim Measures During Complaint Process

The School will take steps to strive to ensure equal access to its educa­tional programs and activ­i­ties and protect the complainant as appro­pri­ate, includ­ing taking interim measures before the final outcome of an inves­ti­ga­tion, once it has notice of a complaint. The School will notify the complainant of his or her options to avoid contact with the respon­dent and/​or change his or her acad­e­mic and extracur­ric­u­lar activ­i­ties, living, trans­porta­tion, dining, and working situ­a­tion as appro­pri­ate. Other interim measures will be based on the complaint and may be based on a variety of consid­er­a­tions, such as: any specific need expressed by the complainant; the ages of the indi­vid­u­als involved; the sever­ity or perva­sive­ness of the alle­ga­tions; any contin­u­ing effects on the complainant; whether the complainant and the respon­dent share class, trans­porta­tion, or extra-curric­u­lar activ­i­ties; and whether any other measures have been taken to protect the complainant.

The School will ensure that the complainant is aware of his or her rights under Title IX and any other avail­able resources that may be applic­a­ble, such as acad­e­mic support, coun­sel­ing, and health and mental health services.

Rela­tion­ship of These Proce­dures and Time­lines to Law Enforcement Activities

Though the School has juris­dic­tion over all Title IX complaints, nothing in these proce­dures should in any way be deemed to discour­age the complainant from report­ing acts subject to these proce­dures, includ­ing acts of sexual violence, to local law enforcement.

In the event that an alle­ga­tion includes behav­ior or actions that are under review by law enforce­ment author­i­ties, the school will consider whether contin­u­ing its own inves­ti­ga­tion will inter­fere with a crim­i­nal inves­ti­ga­tion. The School may defer its inves­ti­ga­tion to avoid compro­mis­ing the crim­i­nal process, but once it is clear that any such concerns have passed or can be miti­gated, the School will promptly resume its investigation.

In the event the School elects to delay temporar­ily the fact-finding portion of a Title IX inves­ti­ga­tion while local law enforce­ment offi­cials are inves­ti­gat­ing, the School may impose interim measures to protect the complainant during that time. The School will also continue to update the parties on the status of the inves­ti­ga­tion and inform the parties when the School resumes its Title IX investigation.

Right to Addi­tional Complaint Procedures

The School’s Title IX Policy and Griev­ance Proce­dures are designed to prevent and address sex-based discrim­i­na­tion, harass­ment, and violence under Title IX promptly and appro­pri­ately. These griev­ance proce­dures are not intended to be the exclu­sive remedy for such viola­tions. School commu­nity members, complainants, respon­dents, and their parents/​guardians are enti­tled to pursue addi­tional avenues of recourse, which may include report­ing or filing charges with appro­pri­ate legal, state, and federal agen­cies, initi­at­ing civil action, or report­ing perceived crim­i­nal conduct to the appro­pri­ate author­i­ties, includ­ing but not limited to:

Cali­for­nia Depart­ment of Fair Employ­ment and Housing
320 West 4th Street, 10th Floor
Los Angeles, CA 90013

or

U.S. Depart­ment of Educa­tion Office for Civil Rights
San Francisco Office
50 United Nations Plaza
Mail Box 1200, Room 1545
San Fran­cisco, CA 94102

Retal­i­a­tion

Retal­i­a­tion or reprisal by any student or employee against complainants, witnesses, or any other indi­vid­ual who reports alle­ga­tions of sex-based harass­ment, discrim­i­na­tion, and/​or violence or provides infor­ma­tion to assist in an inves­ti­ga­tion is strictly prohib­ited. Indi­vid­u­als who believe they have been retal­i­ated against in connec­tion with such action should imme­di­ately report such conduct to the Compliance Coordinator.

Disci­pli­nary Action

The Compli­ance Coordinator/​Head of School (or his or her designee) will admin­is­ter or initi­ate disci­pli­nary action against anyone found to have engaged in discrim­i­na­tory conduct or retal­i­a­tion in connec­tion with an inves­ti­ga­tion under these procedures.

The School recog­nizes that false accu­sa­tions, espe­cially of sex-based harass­ment, discrim­i­na­tion, and/​or violence may have serious effects on inno­cent persons. Any indi­vid­ual found to have made false accu­sa­tions of sex-based harass­ment, discrim­i­na­tion, and/​or violence may also be subject to appro­pri­ate disciplinary action.