Legacy Haven Academy Anti-Harassment and Non-Discrimination Policy

1. Purpose

Legacy Haven Academy Foundation (the "Academy") is committed to fostering a safe, inclusive, and respectful environment for all students, employees, volunteers, and visitors. This policy prohibits discrimination, harassment, and retaliation in all forms, ensuring compliance with federal, state, and local laws. As an educational institution serving vulnerable youth aged 10-18, including orphans and homeless students, the Academy aligns this policy with its mission to provide hope, purpose, and lifelong learning through principles of integrity, kindness, and respect (Legacy Haven Academy Foundation, n.d.). This policy supports the Academy's preparation for 501(c)(3) status by demonstrating adherence to good governance practices, including non-discrimination to maintain tax-exempt eligibility under Internal Revenue Code Section 501(c)(3) (Internal Revenue Service, 2025a). It complies with Title IX of the Education Amendments of 1972, which prohibits sex-based discrimination in education programs receiving federal funds (U.S. Department of Education, 2024a); Title VI of the Civil Rights Act of 1964, prohibiting race, color, or national origin discrimination (U.S. Department of Justice, 2025); Title VII of the Civil Rights Act of 1964 for employment (Equal Employment Opportunity Commission, 2024a); the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973 for disability discrimination (U.S. Department of Education, n.d.a; U.S. Department of Education, n.d.b); Arizona's Civil Rights Act (A.R.S. § 41-1461 et seq.), mirroring federal protections (Arizona Attorney General's Office, n.d.a); and Arizona Department of Education (ADE) requirements for anti-bullying and harassment policies (Arizona Department of Education, 2024a). Mohave County follows state and federal standards, with no unique local mandates beyond equal employment opportunity (EEO) in public entities (Mohave County, 2024).

2. Scope

This policy applies to all Academy activities, including on-campus, off-campus events, online interactions, and transportation. It covers students, employees (full-time, part-time, temporary), contractors, volunteers, vendors, and visitors. As a prospective school in Mohave County, Arizona, the Academy will extend these protections upon operations commencing, ensuring alignment with ADE oversight for educational institutions (Arizona Department of Education, 2024b).

3. Definitions

• Discrimination: Unlawful treatment based on protected characteristics, including race, color, religion, sex, national origin, age (40+ for employment), disability, genetic information, or veteran status (Equal Employment Opportunity Commission, 2024a; Arizona Attorney General's Office, n.d.a).
• Harassment: Unwelcome conduct based on protected characteristics that creates a hostile environment, interferes with performance, or denies benefits. This includes verbal, nonverbal, physical, or visual conduct (Equal Employment Opportunity Commission, 2024b). For schools, it encompasses bullying, intimidation, or hazing (A.R.S. § 15-341; Arizona Department of Education, 2023).
• Sexual Harassment (Title IX): Conduct on the basis of sex that is unwelcome, including quid pro quo, hostile environment, sexual assault, dating/domestic violence, or stalking (U.S. Department of Education, 2024a).
• Hostile Environment: Conduct severe, pervasive, and objectively offensive that denies equal educational or employment access (Equal Employment Opportunity Commission, 2024b).
• Retaliation: Adverse action against anyone reporting or participating in an investigation (U.S. Department of Labor, n.d.).

4. Prohibited Conduct

The Academy prohibits all forms of discrimination and harassment, including but not limited to:

• Derogatory jokes, slurs, or epithets.
• Unwelcome physical contact or advances.
• Display of offensive materials.
• Cyberbullying or online harassment.
• Bullying targeting perceived vulnerabilities, especially relevant for the Academy's at-risk student population (Arizona Department of Education, 2024c).

Employees and students must refrain from such conduct toward others, including peers, subordinates, or supervisors. Violations undermine the Academy's values and may result in disciplinary action up to termination or expulsion (Equal Employment Opportunity Commission, 2017).

5. Reporting Procedures

Reports must be prompt to enable effective response. Anyone may report:

• Informal: Discuss with a supervisor, teacher, or counselor for resolution.
• Formal: Submit to the Title IX Coordinator or Human Resources (HR) Director via email, phone, or written form. Anonymous reports are accepted but may limit investigation (U.S. Department of Education, 2024a).

Title IX Coordinator: Cree Dalene, Principal/Headmaster, admin@legacyhavenacademy.org. Designated per Title IX to oversee sex discrimination complaints (Arizona School Boards Association, n.d.a).

ADE requires schools to publicize reporting procedures annually (Arizona Department of Education, 2024b). The Academy will maintain a visible reporting poster and website notice.

6. Investigation Process

Upon receipt, the Coordinator or designee will:

1. Assess safety and provide interim support (e.g., no-contact orders).
2. Conduct a prompt, impartial investigation, interviewing parties and witnesses (typically 60 days max).
3. Apply preponderance of evidence standard (more likely than not).
4. For Title IX formal complaints: Offer supportive measures, live hearings (if applicable), and appeals (U.S. Department of Education, 2024a).

Investigations comply with EEOC guidelines for thoroughness and documentation (Equal Employment Opportunity Commission, 2024b). External investigators may be used for impartiality. Records are confidential, shared only on a need-to-know basis.

7. Confidentiality and Non-Retaliation

The Academy will protect confidentiality to the extent possible without impeding investigation. Retaliation is strictly prohibited and treated as a separate violation (A.R.S. § 41-1463.01; Equal Employment Opportunity Commission, 2024a). Whistleblower protections apply for good-faith reports (Council of Nonprofits, n.d.).

8. Corrective Actions and Discipline

Actions will be proportionate and remedial, considering severity and history:

• Students: Counseling, behavioral plans, suspension, or expulsion per ADE guidelines (A.R.S. § 15-341).
• Employees: Verbal/written warnings, training, demotion, or termination.
• Others: Contract termination or exclusion from premises.

The Academy prioritizes education and prevention over punishment where appropriate (Equal Employment Opportunity Commission, 2017).

9. Training and Education

Annual training is mandatory for all:

• Employees: EEOC-compliant sessions on recognizing/preventing harassment (Equal Employment Opportunity Commission, 2017).
• Students: Age-appropriate programs on respect and reporting, integrated into mentorship curriculum.
• Volunteers/Vendors: Orientation upon engagement.

Training includes Title IX specifics and will be documented for ADE and IRS compliance (U.S. Department of Education, 2024a; Internal Revenue Service, 2025b).

10. Grievance Procedures (Title IX Specific)

The Academy's grievance process ensures due process:

• Written notice to parties.
• Opportunity to present evidence.
• Objective evaluation.
• Timely resolution with remedies (e.g., academic adjustments).

This aligns with 2024 Title IX regulations (U.S. Department of Education, 2024a). Appeals are available within 10 days.

11. Policy Review and Contacts

This policy will be reviewed annually or as laws change. Questions: Contact HR Director or Title IX Coordinator at admin@legacyhavenacademy.org. Complaints may also be filed with ADE Civil Rights Office (Arizona Department of Education, 2024d) or EEOC (www.eeoc.gov).