Frequently Asked Question about the Policy on Discrimination, Harassment, and Sexual Misconduct
The Office of Civil Rights and Title IX Compliance seeks to protect the civil rights of all University community members through outreach, education, and effective response and resolution. The University’s Policy on Discrimination, Harassment, and Sexual Misconduct and the Interim Policy on Title IX Sexual Harassment define what conduct is prohibited, explain available supportive measures and resources, and provides resolution processes to respond to discrimination, harassment, and sexual misconduct. To assist the University community in understanding these policies the Office of Civil Rights and Title IX Compliance prepared this list of frequently asked questions.
If you have additional questions, please contact the Office of Civil Rights and Title IX Compliance at OCR@northwestern.edu.
What is the Policy on Discrimination, Harassment, and Sexual Misconduct?
The Policy on Discrimination, Harassment, and Sexual Misconduct is the University’s policy that prohibits discrimination, harassment, and sexual misconduct that is not otherwise covered by the University’s Interim Policy on Title IX Sexual Harassment.
To whom does the policy apply?
The Policy on Discrimination, Harassment, and Sexual Misconduct applies to Students, defined under this policy as an individual who has gained admission to the University (Students); University employees, defined under this policy as all full-time and part-time faculty, University staff, student employees, wage employees (including temporary employees), professional research staff, and post-doctoral fellows (collectively Employees), and third parties, including University vendors, contractors, visitors, guests, volunteers, interns, and third parties.
What does the Policy on Discrimination, Harassment, and Sexual Misconduct prohibit?
The Policy on Discrimination, Harassment, and Sexual Misconduct prohibits the following conduct:
- Discrimination: Discrimination is adverse treatment of an individual based on one or more actual or perceived protected bases or characteristics listed in this policy. Discrimination is a violation of this policy when it results in adverse action or negatively impacts the terms and conditions of an individual’s employment or education or denies or limits participation in programs, services, or activities, except as permitted or required by law.
- Harassment: Prohibited harassment is unwelcome verbal, physical, written, or visual conduct or conduct using technology based on an actual or perceived protected characteristic that when based on the totality of circumstances is subjectively and objectively offensive and so severe or pervasive that it limits or denies a person’s ability to participate in or benefit from the education program or activity or has the purpose or effect of creating an academic or working environment that a reasonable person would consider to be intimidating, hostile, or offensive.
- Sexual Misconduct, including sexual assault, sexual exploitation, dating/domestic violence, stalking, and sexual harassment.
What are protected bases or characteristics?
The protected characteristics under the Policy on Discrimination, Harassment, and Sexual Misconduct are race, color, religion, creed, national origin, ethnicity, caste, sex, pregnancy, sexual orientation, gender identity, gender expression, parental status, marital status, age, disability, citizenship status, veteran status, genetic information, reproductive health decision making, height, weight, or any other classification protected by law.
Are discrimination and harassment based on antisemitism and Islamophobia prohibited under the Policy on Discrimination, Harassment, and Sexual Misconduct?
果冻传媒’s Policy on Discrimination, Harassment, and Sexual Misconduct prohibits discrimination and harassment based on protected categories, including race, national origin, religion, and ethnicity, which includes discrimination and harassment based on antisemitism and Islamophobia. This Policy encompasses Northwestern’s compliance with Title VI of the Civil Rights Act of 1964 (Title VI), and Northwestern considers the U.S. Department of Education’s guidance in complying with Title VI. Consistent with Executive Order 13899 and the January 29, 2025 Additional Measures to Combat Anti-Semitism Executive Order, Northwestern uses the definition of antisemitism endorsed by the International Holocaust Remembrance Alliance (IHRA), which states “Antisemitism is a certain perception of Jews, which may be expressed as hatred toward Jews. Rhetorical and physical manifestations of antisemitism are directed toward Jewish or non-Jewish individuals and/or their property, toward Jewish community institutions and religious facilities” and considers the examples that accompany the IHRA definition to the extent that any examples might be useful as evidence of discriminatory intent.
Are anti-Israeli, Anti-Arab, or Anti-Palestinian discrimination and harassment prohibited by the Policy on Discrimination, Harassment, and Sexual Misconduct?
Yes. The Policy on Discrimination, Harassment, and Sexual Misconduct includes national origin and ethnicity as protected characteristics.
How does the University determine whether conduct meets the definition of harassment?
In determining whether conduct is sufficiently severe or pervasive so as to meet the University’s definition of harassment, the Office of Civil Rights and Title IX Compliance examines the context, nature, scope, frequency, duration, and location of the incidents, as well as the relationships of the persons involved. A person’s subjective belief that behavior is intimidating, hostile, or offensive does not make that behavior prohibited harassment under this Policy. The behavior must create a hostile environment and/or substantially interfere with access to a University program or activity from an objective perspective.
What are examples of conduct that may violate the University’s Policy on Discrimination, Harassment, and Sexual Misconduct?
As noted above, under the Policy on Discrimination, Harassment, and Sexual Misconduct, conduct constitutes harassment when, based on the totality of circumstances, the conduct is based on an actual or perceived protected characteristic and is subjectively and objectively offensive and so severe or pervasive that it limits or denies a person’s ability to participate in or benefit from the education program or activity or has the purpose or effect of creating an academic or working environment that a reasonable person would consider to be intimidating, hostile, or offensive. When making a determination as to whether the alleged conduct violates this University policy, the Office of Civil Rights and Title IX Compliance examines the context, nature, scope, frequency, duration, and location of the incidents, as well as the relationships of the persons involved. The following are instructive examples of conduct that may violate the Policy on Discrimination, Harassment, and Sexual Misconduct definition of harassment, if they otherwise meet the criteria specified above.
- Verbal abuse or use of racist, anti-Semitic, or anti-Arab slurs or hostile behavior, which could include insulting, teasing, mocking, degrading, or ridiculing another person or group regardless of whether the person is actually a member of the group;
- Defacing an individual’s property with hateful symbols, such as a swastika or noose;
- Inappropriate physical contact, comments, questions, advances, jokes, epithets, or demands based on one or more actual or perceived protected characteristics;
- Physical assault, intimidation, or stalking on the basis of one or more actual or perceived protected characteristics; or
- Displays or electronic transmission of derogatory, demeaning, or hostile materials related to one or more actual or perceived protected characteristics
The following are instructive examples of conduct that may violate the Policy on Discrimination, Harassment, and Sexual Misconduct definition of discrimination, if they otherwise meet the criteria specified above.
- Not allowing a student to join or participate in a student organization based upon their religious belief or because they wear symbols or styles of dress associated with their religion;
- Refusing to allow a student or employee to participate in a program, class, or meeting based upon their national origin;
- Not offering a job to a person based on their age;
- Not recommending a person for promotion based on their gender identity.
How does the University consider academic freedom and free expression when determining whether conduct constitutes discrimination or harassment?
Unlawful discrimination, harassment, sexual misconduct, and retaliation against members of the Northwestern community are not protected expression or the proper exercise of academic freedom. The University will consider academic freedom in the investigation of reports of discrimination, harassment, sexual misconduct or retaliation that involve an individual’s statements or speech. The Office of Civil Rights and Title IX Compliance will review every report of harassing conduct to evaluate whether such reported conduct creates or created a hostile environment. Even protected speech or expression may in some cases create a hostile environment in the University community. In such cases, the University may be constrained in its ability to impose disciplinary measures but will in appropriate cases respond in a manner calculated to restore access to the University’s programs and activities to affected individuals and, where not inconsistent with its commitment to academic freedom and free expression, eliminate the harassment.
Does the Policy on Discrimination, Harassment, and Sexual Misconduct protect me from exposure to all uncomfortable or challenging conversations?
No. The free interchange of ideas is vital to the University’s primary function of discovering and disseminating ideas through research, teaching, and learning. Uncomfortable and challenging conversations—including the expression of unpopular or disagreeable views—are a normal part of University life. When Northwestern interprets and applies the Policy on Discrimination, Harassment, and Sexual Misconduct, it does so with an awareness of the University’s commitment to academic freedom and open inquiry, which means that the University encourages reasoned dissent and the free exchange of ideas, beliefs, and opinions, including on controversies such as the Arab-Israeli and Israeli-Palestinian conflicts.
Ordinarily, it will not violate the University policy for members of the community to make controversial statements in the course of academic work or in scholarship; express disagreement with another person’s political views; or criticize a government’s policy or the political leaders of a country. However, where such statements are made on the basis of others race, national origin, religion, or ethnic characteristics, and otherwise meet the definitions of prohibited harassment, such statements may be prohibited.
Is there a way to address harassing conduct if it is not based on a protected characteristic?
The University’s Student Code of Conduct prohibits intimidation, which is defined as subjecting another person or group to abusive, demeaning, harassing, humiliating, intimidating, threatening, or violent behavior that substantially affects the ability of the person or group to learn, work, or live in the University environment. Intimidation may occur in person, via written or electronic means, or through a third party. For purposes of this policy, the defined behavior must meet both a subjective standard (i.e., does this person or group believe they were subject to Intimidation?) and an objective standard (i.e., would a reasonable person in the same or similar circumstances believe they were subject to Intimidation?). A single severe incident or a pattern of persistent behavior may constitute Intimidation. The Office of Community Standards is responsible for reviewing and responding to reports of intimidation and can be contacted at community-standards@northwestern.edu. For employees, including faculty and staff, the Guidance on Civility and Mutual Respect may apply. Employees who may have experienced conduct in contradiction to this guidance, should contact the Office of Human Resources or the Office of the Provost.
How does the Student Code of Conduct definition of Intimidation relate to the Policy on Discrimination, Harassment, and Sexual Misconduct?
Harassment under the Policy in Discrimination, Harassment, and Sexual Misconduct requires the alleged conduct to be based upon an actual or perceived protected characteristic, such as religion or national origin. The Student Code of Conduct definition of intimidation does not require the alleged conduct to be based upon any protected characteristic. Both the Intimidation definition and the Harassment definition may apply to the conduct. The Office of Civil Rights and Title IX Compliance and Office of Community Standards will coordinate the response if both policies apply.
Who may submit a report of discrimination or harassment?
Anyone may submit a report; however, the Office of Civil Rights and Title IX Compliance will communicate directly with the individual directly affected or targeted by the alleged conduct in determining resolution options and offering support.
Can I speak with someone without filing a report?
Yes. You may speak with a staff member without filing a report with the University. To schedule a time to speak to a staff member in the Office of Civil Rights and Title IX Compliance call (847) 467-6165 or email OCR@northwestern.edu. You may also meet in person with a staff member at the office located at 1800 Sherman Ave., Suite 4500, Evanston, IL 60201. We recommend contacting the Office of Civil Rights and Title IX Compliance to schedule an in-person meeting.
How do I submit a report?
Reports may be submitted to the Office of Civil Rights and Title IX Compliance by completing an online form:
- For reports of discrimination or harassment:
- For reports of sexual misconduct:
Reports may also be submitted by contacting the Office of Civil Rights and Title IX Compliance by phone at (847) 467-6165 or in person at 1800 Sherman Ave., Suite 4500, Evanston, IL 60201.
Will the university start an investigation if I report anonymously?
The University’s ability to address conduct reported by anonymous sources may be significantly limited. However, the Office of Civil Rights and Title IX Compliance reviews every report of harassing conduct to evaluate whether such reported conduct creates or created a hostile environment.
Where can I find additional details about the complaint resolution process?
The Policy on Discrimination, Harassment, and Sexual Misconduct describes the available resolution processes, including alternative resolution and formal resolution. The Resource Guide on the Policy on Discrimination, Harassment, and Sexual Misconduct provides further explanation of resolution options and available support.