Employment Policies and Procedures – Page 2

Employee Conflict of Interest

CCS administrative staff should avoid situations where their own interests materially conflict with their obligations to CCS, or create the perception of a conflict. All decisions and actions by administrative staff in the course of their professional responsibilities are to be made consistent with their obligations to CCS.

Generally, a conflict of interest arises when an administrative staff member has a personal or financial interest in a transaction or event – or is a party to a transaction or event – that might adversely affect his or her judgment in performing professional or employment duties for CCS. Examples of potential conflicts of interest include, but are not limited to, the following:

Engaging in any business with, or employment by, an employer that is in competition or in conflict with any transaction, activity, or objective of CCS.
Engaging in business with or employment by a supplier of goods or services to CCS without prior approval of CCS.
Using equipment, supplies, or services owned or provided by CCS in conjunction with any external work, without obtaining prior agreement in writing from CCS.
Making use of any confidential information acquired through employment with CCS for personal profit or advantage, or the advantage of a third-party.
Publicly associating CCS or its prestige with an outside business interest for personal gain.

Administrative staff members who believe they have a financial, personal or professional interest that is (or could potentially become) a conflict of interest must fully disclose the nature of the potential conflict in writing to the Director of Human Resources. All decisions concerning whether a conflict of interest exists are within the sole discretion of CCS.

Confidentiality

Due to the nature of the College’s work, you may be privy to confidential information. Certain information is required to be confidential by law, while other material must remain confidential in order to comply with contracts or good professional practice.

If you have access to confidential information, you must not disclose it to anyone inside or outside the College unless express authorization has been obtained from the College. If you have any questions about the confidentiality of the work you perform or the information that you receive, either in written or verbal form, please contact your supervisor or the director of Human Resources.

Equal Opportunity, Discrimination and Harassment

The College for Creative Studies subscribes to the principle of equal opportunity in its employment, admissions, and educational programs and activities and strives to provide an educational environment and workplace free from unlawful harassment or discrimination. The College is committed to an inclusive community that respects and values all its members, including students, faculty, and staff. This Policy on Prohibited Discrimination, Harassment, and Sexual Misconduct (including Title IX) (“Policy”) prohibits discrimination, including harassment, because of age, race, color, national origin, religion, sex, sexual orientation, gender identity, gender expression, marital status, disability or any other characteristic protected by law. This prohibition includes discrimination and harassment based on the perception of an individual’s protected status, even if that perception is incorrect. It also prohibits misconduct related to protected status discrimination and harassment specifically, domestic violence, dating violence, and stalking. The Policy applies to the administration of employment and educational policies, practices, programs, and activities.

The Policy also prohibits retaliation against an individual: (1) who files a complaint or report of discrimination, harassment, or related misconduct; (2) against whom a complaint is filed; (3) who participates in the reporting, investigation, or adjudication of possible violations of this Policy; or (4) who engages in good faith opposition to what the individual reasonably believes to be discrimination, harassment, or related misconduct under this Policy. The Policy should be read in a way consistent with all applicable federal and state laws addressing discrimination, harassment, and related misconduct.

This Policy specifically prohibits sexual misconduct, including sexual assault, sexual harassment, gender- based harassment, sexual exploitation, stalking, domestic violence, and dating violence. In some cases, this conduct is also prohibited by or included in Title VII of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, and/or the Violence Against Women Reauthorization Act of 2013. Sexual misconduct represents a serious breach of the College’s commitment to fostering a positive educational and working environment. An individual who violates this Policy may also be subject to criminal prosecution and civil litigation in addition to College disciplinary procedures. As described in the annual security report (see “Sexual Assault/Dating Violence Awareness and Prevention Programs”), with the intent of ending sexual misconduct, the College conducts primary prevention and awareness programs for all incoming students and new employees and ongoing prevention and awareness campaigns for students and employees.

The Office for Institutional Equity and Inclusion is responsible for administering this Policy and its implementing procedures. The Title IX Coordinator is the College’s designated Coordinator for Title IX of the Education Amendments of 1972; the Dean of Students is the Coordinator for Section 504 of the Rehabilitation Act of 1973 for educational matters and for the Age Discrimination Act of 1975; and the Human Resources Director is the Section 504 Coordinator for employment matters.

Americans With Disabilities Act

The Americans with Disabilities Act (ADA) is meant to provide fair and equitable treatment of the disabled through non-discriminatory practices and reasonable accommodations.

The ADA protects people who are disabled – defined as anyone with a physical or mental impairment that substantially limits one or more major life activities. The law protects both job applicants and employees.

CCS supports and follows the provisions of the Americans with Disabilities Act and Michigan law, as stated in the law. It is CCS’s policy not to discriminate against any qualified employee or applicant with regard to any terms or conditions of employment because of such individual’s disability or perceived disability so long as the employee can perform the essential functions of the job. In addition, CCS provides reasonable accommodation for qualified individuals with a disability in accordance with the ADA and other applicable laws, except where such an accommodation is unreasonable or would create an undue hardship on CCS. Reasonable accommodation may also be provided to pregnant employees, even where they do not qualify as disabled under the ADA or state law.

Employees with a disability who believe they need a reasonable accommodation to perform the essential functions of their job should contact Human Resources. Requests for accommodation should be made as soon as possible after the need is known. Under Michigan law, the request for reasonable accommodation must be made in writing within 182 days of knowing of the need for such accommodation.

Employees who believe they or another employee have been treated in violation of this policy should follow the reporting procedure set forth above in the College’s Policy on Equal Opportunity, Discrimination and Harassment.