Title IX Coordinator:
Name: Michael L Reynolds
Phone: 815.159.3500
Email: mreynolds@firstinstitute.edu

Non-Discrimination, Harassment & Sexual Misconduct Policy

First Institute is an equal opportunity institution providing educational and employment opportunities, programs, and services, and therefore prohibits discrimination, harassment and retaliation. First Institute complies with all requirements of the regulations implementing Title VI, Title IX, Section 504 of the Rehabilitation Act of 1973, the Age Discrimination in Employment Act of 1975, the Campus SaVE Act of 2013 and the Illinois Preventing Sexual Violence in Higher Education Act of 2015 and the Illinois Human Rights Act. This policy applies equally to all members of the First Institute community: students, faculty, administrators, staff, contract employees and visitors.

First Institute does NOT discriminate on the basis of race, color, religious beliefs, national origin, sex, sexual orientation, gender identity, gender expression, pregnancy, parental status, marital status, age, disability, citizenship, veteran status or any other characteristic protected by federal, state or local law.

Individuals who experience discrimination or harassment may respond to the experience in many different ways, including feeling confused, vulnerable, out of control, embarrassed, angry, or depressed. First Institute has information available in the Student Services Office on various resources to assist individuals who have experienced discrimination or harassment, to address the effects of the incident, and to help them determine whether and how to make a formal complaint about the incident.

First Institute is committed to fostering and maintaining an educational environment which is safe, secure and free from all forms of sexual misconduct. Any act involving sexual harassment, violence, coercion, and intimidation will not be tolerated. Specifically, First Institute strictly prohibits the offenses of domestic violence, dating violence, sexual assault, and stalking.

Retaliating against an individual who has reported or filed a complaint alleging discrimination, harassment, sexual misconduct or participated as a witness in such an investigation is strictly prohibited. Retaliation is a separate cause for complaint and individuals are encouraged to report such conduct in a timely manner. Individuals with supervisory duties, who disregard, fail to investigate adequately, or delay investigation of discrimination claims also violates this policy.

All reports of discrimination, harassment, sexual misconduct and/or retaliation shall be promptly made to the Title IX Coordinator. The Director of Student Services serves as the Title IX/ADA/504 Coordinator, Campus Security Authority and oversees implementation of the institutions policy on Discrimination, Harassment, and Sexual Misconduct.

Michael L Reynolds, Title IX Coordinator/ Campus Director,

790 McHenry Avenue Crystal Lake, IL 60014 (815) 459-3500 x 306

email: mreynolds@firstinstitute.edu


This policy covers discrimination in employment and in access to educational opportunities. Discrimination is defined as adverse treatment of an individual based on that individual’s membership in one or more of the protected groups listed above. Therefore, any member of the campus community, guest, or visitor who acts to deny, deprive, or limit the educational, employment, housing and/or social access, benefits, and/or opportunities of any member of the campus community on the basis of their actual or perceived membership in the protected classes listed above is in violation of the institutions policy on discrimination. Discriminatory and harassing behavior is unacceptable and will not be tolerated. Incidents of discrimination will be met with appropriate disciplinary action, up to and including separation or dismissal from the school. When brought to the attention of First Institute, any such discrimination will be appropriately remedied by the institution according to the procedures outlined in this policy.


Retaliating against an individual who has reported or filed a complaint alleging discrimination or participated as a witness in such an investigation is strictly prohibited. Retaliation is a separate cause for complaint and individuals are encouraged to report such conduct in a timely manner. Individuals with supervisory duties, who disregard, fail to investigate adequately, or delay investigation of discrimination claims also violates this policy.


First Institute prohibits harassment against any employee, student, visitor, or guest on the basis of any class protected by law and identified above. This policy is not meant to inhibit or prohibit educational content or discussions inside or outside of the classroom that include controversial or sensitive subject matters. The sections below describe the specific forms of prohibited harassment under the school’s policy.

Bias-Related Harassment

This policy prohibits any form of harassment on the basis of actual or perceived membership in a protected class, by any member or group of the campus community, which unreasonably interferes with an individual’s work or academic environment.

Sexual Harassment

First Institute, Inc. does not tolerate sexual harassment by any student, employee or vendor. Sexual harassment is unwelcome sexual- or gender-based verbal, written, online, and/or physical conduct. Anyone experiencing sexual harassment on the campus is encouraged to report it to First Institute’s Title IX Coordinator/Campus Director.

Sexual harassment is in part defined as the following:

Unwelcome verbal or physical conduct of a sexual nature, whether at work or off premises, if offensive to a reasonable person.

Making submission to or rejection of such verbal or physical conduct the basis for employment advancement, or any academic decisions that affect the employees and the students.

Creating an intimidating, hostile or offensive environment (quid pro quo).

Sexual harassment creates a hostile environment and may be disciplined when it is sufficiently severe, pervasive, persistent, or objectively offensive that it has the effect of unreasonably interfering with, denying, or limiting employment opportunities or the ability to participate in or benefit from the institutions educational programs.

Sexual Misconduct

First Institute is committed to fostering and maintaining an educational environment which is safe, secure and free from all forms of sexual misconduct. Any act involving sexual harassment, violence, coercion, or intimidation will not be tolerated. This policy prohibits any form of sexual misconduct committed by any person upon any other person, regardless of the sex, gender, sexual orientation, and/or gender identity of those involved. This policy prohibits all forms of sexual misconduct. This broad term includes, but is not limited to, acts of sexual harassment, sexual violence, sexual coercion, sexual threats or intimidation, domestic violence, dating violence, sexual assault, stalking, and cyber-stalking. These acts have a real impact on the lives of victims. They not only violate a person’s feelings of trust and safety, but they can also substantially interfere with a student’s education. The following are types of prohibited sexual misconduct under this policy.

Sexual Harassment (as defined above)

Non-Consensual Sexual Intercourse

Defined as any sexual penetration or intercourse (anal, oral, or vaginal) however slight with any object by a person upon another person that is without consent and/ or by force. Sexual penetration includes vaginal or anal penetration by a penis, tongue, finger, or object, or oral copulation by mouth-to-genital contact or genital-to mouth contact.

Non-Consensual Sexual Contact

Defined as any intentional sexual touching however slight with any object by a person upon another person that is without consent and/or by force. Sexual touching includes any bodily contact with the breasts, groin, genitals, mouth, or other bodily orifice of another individual or any other bodily contact in a sexual manner.

Dating Violence

Violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the victim; The reporting party’s statement and with consideration of the length of the relationship, the type of relationship, and the frequency of interaction between the persons involved in the relationship.

For the purpose of this definition –

Dating violence includes, but is not limited to, sexual or physical abuse or the threat of such abuse;

Dating violence does not include acts covered under the definition of domestic violence.

Domestic Violence

Domestic violence is any act of violence committed a) by a current or former spouse or intimate partner of the victim; b) by a person with whom the victim shares a child in common; c) by a person who is cohabitating with or has cohabitated with the victim as a spouse or intimate partner; d) by any person who is or has been engaged in a dating relationship with the victim or does or has shared a residence with the victim; or e) by any other person against an adult or youth victim who is protected from that person’s acts under Illinois law. Any person who hits, chokes, kicks, threatens, harasses, or interferes with the personal liberty of another family or household member has broken Illinois Domestic Violence law. Under Illinois law family or household members are defined as

family members related by blood;

people who are married or used to be married;

people who share or used to share a home, apartment, or other common dwelling;

people who have or allegedly have child in common or a blood relationship through a child in common; people who are dating or engaged or used to date, including same sex couples; and

people with disabilities and their personal assistants.

Sexual Assault

Sexual assault is any type of sexual contact or behavior that occurs without the explicit consent of the recipient. Falling under the definition of sexual assault are sexual activities as forced sexual intercourse, forcible sodomy, child molestation, incest, fondling, and attempted rape. This includes the attempt or act of rape (sexual intercourse without the consent or with a child under the age of thirteen, by a stranger, an acquaintance or an intimate), forced sodomy (forced oral or anal sex), or the forced penetration by a foreign object either animate, such as a finger, or inanimate. Non-penetration sexual assault includes the act of touching an unwilling person’s intimate parts such as genitalia, anus, groin, breast, or buttocks, or the clothing covering these parts, or forcing an unwilling person to touch another’s intimate parts. The above acts constitute sexual misconduct when they are committed against a person’s will as evidenced by refusal of consent or through the use of force, threat, manipulation, or intimidation, or against a person who, by virtue of mental incapacity or physical helplessness, is unable to give or withhold consent. This includes, but is not limited to, incapacity or helplessness caused by alcohol or other drugs. Intoxication of the assailant shall not diminish the assailant’s responsibility for the sexual assault.


Consent is a clear, affirmative, unambiguous and freely given agreement to engage in a specific sexual activity and is demonstrated verbally or through actions that clearly indicate a willingness to engage in the specific sexual activity. Consent for a specific activity does not imply consent for any other activity. Use of alcohol, drugs, or other intoxicants does not diminish one’s responsibility to obtain consent.

Professional Counseling /Advising Services

First Institute does not employ professional counselors on staff; however, in the event that a student demonstrates behaviors/thoughts consistent with issues related to an emotional or psychological issue, physical or sexual abuse, or substance abuse, the student will be referred to Student Services to further explore options for local counseling and/or abuse programs. If a student is seeking assistance outside of school hours, he/she is advised to contact the McHenry County Crisis Program (800) 892-8900 or Zacharias Sexual Abuse Center for Lake County 24 hr support line at (847) 872-7799 www.zcenter.org.

If a student believes they have been the victim of a sexual assault outside of school hours, he/she is advised to call 911.

Educational Programs

First Institute provides educational programs to promote the awareness of discrimination, harassment, rape, acquaintance rape, dating violence, domestic violence, sexual assault, and stalking. New students are provided with online training program that prepares students to confront and prevent sexual assault and substance abuse. In addition to First Institute’s on-going programs to promote awareness, the Crystal Lake Police Department and Lake County Sheriff’s Office provide safety presentations with information on crime prevention awareness for sexual assault, theft, and vandalism, as well as education on personal safety. The Care Center in Crystal Lake, a division of the NW Center Against Sexual Assault and the Illinois Coalition Against Sexual Assault (ICASA) provides training workshops to First Institute students on Dating Violence and Sexual Assault biannually.

Institutional Response to Reports of Sexual Misconduct

It is the policy of First Institute that, upon learning that an act of sexual misconduct has taken place, immediate action will be taken to address the situation. First Institute encourages the reporting of sexual misconduct that is prompt and accurate. This allows the institution to quickly respond to allegations and offer immediate support to the victim. When an incident of sexual misconduct, domestic violence, dating violence, sexual assault or stalking is reported, First Institute will provide victims with written notice of available options, resources, remedies and services available such as counseling, health, mental health, victim advocacy, legal assistance, visa and immigration assistance, and other services available in the community to victims of domestic violence, dating violence, sexual assault, and stalking. The standard of evidence used in informal or formal investigations and institutional disciplinary hearings will be the preponderance of the evidence. After an incident of sexual assault, dating violence, domestic violence, and/ or stalking the victim should consider seeking medical attention and/or law enforcement assistance as soon as possible. Although First Institute strongly encourages all members of its community to report violations of this policy to law enforcement, it is the victim’s choice whether or not to make such a report.

Procedures for Disciplinary Action

The institutional disciplinary procedures will provide a fair, prompt, and impartial process from investigation to final result. The investigation and any hearing will be conducted by those who receive annual training on issues related to sexual misconduct, VAWA crimes, how to conduct an investigation, and a hearing process that protects victim safety and promotes accountability.

Academic Accommodations

First Institute is committed to ensuring the safety and well-being of the victim. A student who has been a victim of sexual misconduct may request an academic accommodation after a report of sexual misconduct. Any individual who makes a request will receive an appropriate and reasonable accommodation. Possible requests include the ability to change academic schedules or work schedules, withdraw from or retake a class without penalty and access to academic support such as tutoring services. Pursuant to Title IX, in most cases of sexual violence or sex discrimination, First Institute will endeavor, to the extent practicable, to change the schedule of the accused student prior to changing the schedule of the victim.


No member of the First Institute community shall retaliate, intimidate, threaten, coerce or otherwise discriminate against a person who files a Title IX complaint, serves as a witness, or assists or participates in a Title IX proceeding in any manner. Participants who experience retaliation should report the incident to the Title IX Coordinator/Campus Director who is also the Title IX Coordinator. First Institute prohibits any form of retaliation against any individual for reporting, providing information, exercising one’s rights or responsibilities under this policy, or otherwise being involved in the process of responding to, investigating, or addressing allegations of sexual assault, dating violence, domestic violence or stalking.


Following a final determination of an institutional disciplinary procedure for cases discrimination, harassment or sexual misconduct including rape, acquaintance rape, dating violence, domestic violence, sexual assault or stalking, sanctions or protective measures may be imposed including SUSPENSION and/or EXPULSION from the school. Employees who violate this policy will be subject to discipline according to the applicable school policies and procedures, up to and including TERMINATION OF EMPLOYMENT.

External Sources

A complainant may choose to file a complaint with the following state and federal agencies: Office for Civil Rights (OCR) – Chicago Office U.S. Department of Education, Citigroup Center 500 W. Madison Street, Suite 1475 Chicago, IL 60661-4544 Phone: (312) 730-1560 Fax: (312) 730-1576 TTY: (800) 877-8339. Customer Service Hotline #: (800) 421-3481 Email: OCR.Chicago@ed.gov Web: www.ed.gov/ocr

Illinois Department of Human Rights 100 West Randolph Street- 10th Floor- Intake Unit Chicago, IL 60601 Phone:(312) 814-6200 Fax: (312) 814-1436 TTY: (866) 740-3953 Web:

Title IX Training

First Institute Title IX personnel are unbiased and free from conflicts of interest. Title IX personnel include the Title IX Coordinator, any investigator, any decision-maker, and any person who facilities an informal resolution (such as mediation). First Institute provides training to Title IX personnel as follows:

  • Title IX’s definition of “sexual harassment”
  • The scope of the school’s education program or activity
  • How to conduct an investigation and grievance process.
  • How to serve impartially, including by avoiding prejudgment of the facts at issue
  • Avoiding conflicts of interest and bias
  • Decision-makers also receive training on any technology to be used at a live hearing, and on issues of relevance of questions and evidence, including when questions and evidence about a complainant’s sexual predisposition or prior sexual behavior are not relevant
  • Investigators receive training on issues of relevance to create an investigative report that fairly summarizes relevant evidence

Training Materials

First Institute is required to post all the training materials for all Title IX personnel on our website. The trainings below are the materials used to train our Title IX Coordinators, Investigators, Decision-Makers, and anyone who facilitates our informal resolution process. Training materials:

  • Must not rely on sex stereotypes,
  • Must promote impartial investigations and adjudications of formal complaints of sexual harassment,
  • Must be maintained by the school for at least 7 years,
  • Must be publicly available on the school’s website; if the school does not maintain a website the school must make the training materials available upon request for inspection by members of the public.

Title IX Training Materials
Thompson Coburn LLP An Introduction to Managing Title IX Sexual Harassment on Campus
Thompson Coburn LLP Formal Complaints of Title IX Sexual Harassment
Thompson Coburn LLP Title IX Investigations & Informal Resolutions
Thompson Coburn LLP Title IX Hearings
Thompson Coburn LLP Title IX Determinations
Thompson Coburn LLP Title IX Appeals