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Overview of the College of the Holy Cross Sexual Misconduct Policy1

I. Statement of Values

The College of the Holy Cross is a community of trust based in the Jesuit tradition whose existence depends on strict adherence to standards of conduct set by its members. Among these are standards regarding human sexuality, any expression of which must affirm the integrity and dignity of oneself and others. Sexual misconduct, in all forms, violates the sanctity of the human body and spirit and will not be tolerated within the College community. The College is committed to providing an environment of well-being, learning, and accountability for its members by preventing the occurrence of sexual misconduct and addressing its effects.

II. Commitment to Non-Discrimination

The College of Holy Cross rejects and condemns all forms of harassment, wrongful discrimination, retaliation and disrespect and is committed to sustaining a welcoming environment for everyone and especially for those vulnerable to discrimination on the basis of race, religion, color, national origin, age, marital or parental status, veteran status, sex, disability, genetic information, sexual orientation or gender identity. It is the policy of the College to adhere to all applicable state and federal laws prohibiting discrimination. The College does not discriminate unlawfully in admission to, access to, treatment in or employment in its programs and activities on the basis of a person’s race, religion, color, national origin, age, marital or parental status (including pregnancy and pregnancy-related conditions2), veteran status, sex, disability, genetic information, sexual orientation, gender identity or any other legally protected status, while reserving its right where permitted by law to take action designed to promote its Jesuit and Catholic mission.

Unlawful discrimination, harassment, including, but not limited to sexual violence and sexual misconduct, and retaliation are prohibited and will not be tolerated at the College. Such behavior violates College policies and may result in disciplinary action, up to and including termination or dismissal from the College. To review the College’s policies regarding discrimination and harassment and related investigation and resolution procedures, please see the following links: Sexual Misconduct Policy and discriminatory harassment policy.

The College has designated the Director of Human Resources and the Title IX Coordinator to oversee its compliance with state and federal non-discrimination and equal opportunity laws including, but not limited to the Title IX Coordinator with respect to the Title IX of the Education Amendments Act of 1972 (Title IX) and the Director of Human Resources with respect to Section 504 of the Rehabilitation Act of 1973 (504) and the Americans with Disabilities Act of 1990 (ADA). Anyone with questions, concerns or complaints regarding discrimination, discriminatory harassment or retaliation may contact the Director of Human Resources or the Title IX Coordinator.

David Achenbach, Director of Human Resources
College of the Holy Cross
1 College Street
O’Kane Hall, Room B72
Worcester, MA 01610

III. How the College Will Address Sexual Misconduct

The College’s commitment to non-discrimination includes an assurance that the College will not tolerate discrimination or harassment on the basis of sex, sexual orientation or gender identity, including, but not limited to sexual violence, dating or domestic violence, or stalking, or retaliation, in its community. The College follows through on that commitment, in part, through the implementation of a Sexual Misconduct Policy that defines prohibited conduct and the process by which the College will address such conduct in different circumstances. The College’s Sexual Misconduct Policy is composed of several components

The Sexual Misconduct Policy applies to all College community members, and all members of the College community are responsible for being familiar with and abiding by the Sexual Misconduct Policy at all times.

The College will also provide additional relevant resources for the community on the Title IX website. While separate from the Policy, these additional resources are part of the College’s ongoing efforts to ensure an environment free of discrimination on the basis of sex.

IV. Role of the Title IX Coordinator and the Title IX Team

The Title IX Coordinator is charged with coordinating the College’s program to comply with Title IX. This includes leading the College’s efforts to respond to reports of conduct that could trigger the Sexual Misconduct Policy. The Title IX Coordinator is also available to meet with any individual to provide information about the implementation of the Sexual Misconduct Policy (including the availability of interim measures, the investigation, and the resolution/sanction process), as well as discussing other resources within the College community and beyond. The Title IX Team, including the Title IX Coordinator, Deputy Title IX Coordinators, and/or other qualified members of the College community, will assist, as necessary, with these efforts.

The College’s Title IX Coordinator is:

Tracy Kennedy
Director of Title IX Initiatives and Title IX Coordinator
Hogan Campus Center, Room 505


Where the Title IX Coordinator is listed as the designated point of contact for any role in the Sexual Misconduct Policy, he or she may designate a Deputy Title IX Coordinator or another appropriate member of the College community to assume the role at issue, as necessary. Each of these individuals are available to receive a report from any member of the College community who believes the Sexual Misconduct Policy has been violated. The Deputy Title IX Coordinators can also assist others, including Responding Parties and witnesses in understanding the College’s Sexual Misconduct Policy and procedures.

The College’s Deputy Title IX Coordinators are:

Cheryl Rogers
Assistant Director of Title IX Initiatives
Hogan Campus Center, Room 522
phone: (508) 793-2536

Alan Hurley
Associate Director of Human Resources/Benefits
Human Resources, O'Kane Room 72

Paul Irish
Associate Dean of Students
Hogan Campus Center, Room 109

Ellen Keohane
Chief Information Officer
Smith Hall, Room 101

Rose Shea
Senior Associate Director of Athletics/Senior Woman Administrator
Luth Athletic Complex, Room 243B


V. College Resources and Other Community Resources

There are several departments within the College community that can be called upon to respond to incidents of behavior that could be subject to the Sexual Misconduct Policy and can serve as supports to individuals in many different ways. These resources are available to both Complaining Parties and Responding Parties. Please see College and Community Resources.

VI. To Print This Policy


(1) This amended Sexual Misconduct Policy, including but not limited to the Process for Resolving Complaints of Sexual Misconduct, are effective as of September 5, 2018. Complaints made or claims reported prior to September 5, 2018 will generally be reviewed under the prior Sexual Misconduct Policy, unless otherwise determined by the Title IX Coordinator, in his/her sole discretion, with respect to continuing or ongoing violations or other pertinent circumstances.

(2)This includes the right to reasonable accommodations in connection with pregnancy or a condition related to pregnancy including, but not limited to, lactation, or the need to express breast milk for a nursing child.  Please see the Reasonable Accommodation Procedures for Employees, Applicants for Employment and Third Parties (PDF) for further information.