Trust & Safety at Prenda

Title IX Policy

Published October 7, 2021 

Contents

1. Statement of Nondiscrimination

1.1 Sexual Harassment and Gender-Based Harassment

1.2 Dating Violence

1.3 Retaliation

1.4 Reporting Procedures

1.5 Investigation of Complaints

1.6 Confidentiality

1.7 Appeal

1. Statement of Nondiscrimination

Prenda, Inc. (“Prenda”) does not discriminate in its educational programs and services (including any career and technology education programs) on the basis of sex or gender, race, religion, color, national origin, age, or disability. Prenda complies with Title VI of the Civil Rights Act of 1964, as amended; Title IX of the Education Amendments of 1972; Title II of the Americans with Disabilities Act of 1990 (“ADA”), as amended, which incorporates and expands upon the requirements of Section 504 of the Rehabilitation Act of 1973, as amended; the Age Discrimination Act of 1975, as amended; and any other legally-protected classification or status protected by applicable law.

Any questions or concerns about Prenda’s compliance with these federal programs should be brought to the attention of the following persons designated as being responsible for coordinating compliance with these requirements, and for receiving and investigating complaints of alleged discrimination, harassment, and/or retaliation: 

Customer Empowerment & Support Director

amanda.kekic@prenda.co

2036 N Gilbert Rd., Ste 2-431

Mesa, AZ 85203

‍

1.1 Sexual Harassment and Gender-Based Harassment

In compliance with the requirements of Title IX, Prenda does not discriminate on the basis of sex in its educational programs or activities. Sexual harassment of a student, including harassment committed by another student, includes unwelcome sexual advances; requests for sexual favors; or sexually motivated physical, verbal, or nonverbal conduct when the conduct is so severe, persistent, or pervasive that it:

Affects the student’s ability to participate in or benefit from an educational program or activity, or creates an intimidating, threatening, hostile, or offensive educational environment;

Has the purpose or effect of substantially or unreasonably interfering with the student’s academic performance; orOtherwise adversely affects the student’s educational opportunities. 

Examples of sexual harassment of a student may include sexual advances; touching intimate body parts or coercing physical contact that is sexual in nature; jokes or conversations of a sexual nature; and other sexually motivated conduct, communications, or contact. 

Prenda also does not tolerate sexual harassment of a student by Prenda employees or contractors. Romantic, sexual, or inappropriate social relationships between students and Prenda employees or contractors are prohibited, even if they are consensual. 

Sexual harassment of a student by a Prenda employee or contractor includes both welcome and unwelcome sexual advances; requests for sexual favors; sexually motivated physical, verbal, or nonverbal conduct; or other conduct or communication of a sexual nature when: 

• A Prenda employee or contractor causes the student to believe that the student must submit to the conduct in order to participate in an educational program or activity, or that the employee or contractor will make an educational decision based on whether or not the student submits to the conduct; or
• The conduct is so severe, persistent, or pervasive that it:

o   Affects the student’s ability to participate in or benefit from an educational program or activity, or otherwise adversely affects the student’s educational opportunities; or

o   Creates an intimidating, threatening, hostile, or abusive educational environment. 

Gender-based harassment includes harassment based on a student’s gender, expression by the student of stereotypical characteristics associated with the student’s gender, or the student’s failure to conform to stereotypical behavior related to gender.Examples of gender-based harassment directed against a student, regardless of the student’s or the harasser’s actual or perceived sexual orientation or gender identity, may include, but not be limited to: 

•  offensive jokes, name-calling, slurs, or rumors; 
• physical aggression or assault; 
• threatening or intimidating conduct; 
• or other kinds of aggressive conduct such as theft or damage to property. 

‍

1.2 Dating Violence

Dating violence occurs when a person in a current or past dating relationship uses physical, sexual, verbal, or emotional abuse to harm, threaten, intimidate, or control the other partner. Examples of dating violence against a student may include physical or sexual assault, name-calling, put-downs, threats to hurt the student or the student’s family members or members of the student’s household, destroying property belonging to the student, threats to commit suicide or homicide if the student ends the relationship, attempts to isolate the student from friends and family, stalking, or encouraging others to engage in these behaviors. 

For the purposes of this policy, dating violence is considered prohibited harassment if the conduct is so severe, persistent, or pervasive that the conduct:

• Affects the student’s ability to participate in or benefit from an educational program or activity, or creates an intimidating, threatening, hostile, or offensive educational environment;
• Has the purpose or effect of substantially or unreasonably interfering with the student’s academic performance; or
• Otherwise adversely affects the student’s educational opportunities. 

1.3 Retaliation

Prenda prohibits retaliation against a student alleged to have experienced discrimination or harassment, including dating violence, or another student who, in good faith, makes a report, serves as a witness, or otherwise participates in an investigation. Examples of retaliation may include threats, rumor spreading, ostracism, assault, destruction of property, unjustified punishments, or unwarranted grade reductions. Unlawful retaliation does not include petty slights or annoyances. 

A student who intentionally makes a false claim, offers false statements, or refuses to cooperate with a Prenda investigation regarding discrimination or harassment is subject to appropriate discipline. 

1.4 Reporting Procedures

Any student who believes that he or she has experienced prohibited harassment or believes that another student has experienced prohibited harassment should immediately report the alleged acts to a teacher, counselor, the principal or designee, or other Prenda employee or contractor. Alternatively, a student may report prohibited harassment directly to the appropriate Coordinator identified in this Handbook.

A student shall not be required to report prohibited harassment to the person alleged to have committed the conduct. Reports concerning prohibited conduct, including reports against the Title IX Coordinator or ADA/Section 504 Coordinator may be directed to Prenda’s legal team. If a report is made directly to the legal team, the legal team shall appoint an appropriate person to conduct an investigation. 

1.5 Investigation of Complaints

After receiving a complaint of prohibited discrimination or harassment, Prenda may require the student to prepare a written report. Oral complaints will be reduced to written form. Upon receipt of a complaint, the appropriate Coordinator or other authorized Prenda official shall promptly authorize and undertake an investigation, and prepare a written decision regarding the complaint, including a determination of whether prohibited discrimination or harassment occurred.

When appropriate, Prenda may take interim action to avoid additional opportunities for discrimination or harassment. The investigation may consist of personal interviews with the person making the report, the person against whom the report is filed, and any others with knowledge of the circumstances surrounding the allegations. If the results of the investigation establish that prohibited discrimination or harassment occurred, Prenda shall promptly respond by taking appropriate disciplinary or corrective action reasonably calculated to address the discrimination or harassment and prevent its recurrence. Prenda may take disciplinary action based on the results of an investigation, even if it concludes that the conduct did not rise to the level of harassment prohibited by law or policy. 

1.6 Confidentiality

To the greatest extent possible, Prenda shall respect the privacy of the complainant, persons against whom a report is filed, and witnesses. Limited disclosures may be necessary in order to conduct a thorough investigation and comply with applicable law.  

1.7 Appeal

A student or parent who is dissatisfied with the outcome of the investigation may appeal through the Prenda grievance procedure. A student shall be informed of his or her right to file a complaint with the United States Department of Education Office for Civil Rights. 

‍