INTIMIDATION OF OTHER STAFF MEMBERS

Employees of HEC should under no circumstances, threaten, intimidate, or exploit other workers by word or deed, or engage in behaviors that infringe on the rights, privileges and responsibilities of one’s colleagues. If an employee feels that s/he is the victim of intimidation or harassment s/he should report this immediately to his/her supervisor.

DANGEROUS BEHAVIOR

Employees of Hillcrest should under no circumstances engage in activities with colleagues or students that lead to physical or psychological harm, or in which there is a high risk of harm, including but not limited to carrying intoxicants or weapons of any type while on duty.

WEAPONS

Carrying a weapon or concealing a weapon on agency property, or in one’s vehicle on agency property, or at agency-related events, whether on-duty or otherwise, is prohibited and may lead to termination of employment.

WORKPLACE VIOLENCE POLICY

HEC strives to maintain a safe work environment for all students, staff and visitors and to prevent workplace violence. Accordingly, HEC has adopted the following guidelines to deal with intimidation, harassment, and acts or threats of violence that may occur on HEC property or otherwise involve an HEC employee.

All employees must treat others with courtesy and respect at all times. Employees are expected to refrain from verbal or physical fighting, “horseplay”, or other conduct that might be dangerous or otherwise injurious or harmful to others. Firearms, weapons, and other dangerous, hazardous, or illegal devises or substances are prohibited from the premises of HEC, any location where the employee is on-duty, or in the presence of students at any time.

Conduct that threatens, intimidates, or coerces another employee, student, visitor, vendor or the public occurring at any time, including off-duty periods, will not be tolerated. Any such conduct may result in discipline up to and including termination of employment.

Employees must immediately report all acts or threats of violence, both direct and indirect, as soon as possible to their immediate supervisor or a member of management at HEC. This provision includes threats by and/or directed to employees, students, visitors, vendors or members of the public. When reporting a threat of violence, employees should be as specific and detailed as possible.

HEC promptly and thoroughly investigates all reports of actual or potential threats, violence, or other inappropriate conduct. Employees should raise concerns and make reports without fear of reprisal or retaliation of any kind. No employee will be subject to any form of retaliation or discipline for lodging any good-faith report of actual or potential workplace violence. In the course of handling reports, HEC will strive to maintain confidentiality to the extent practicable under the circumstances.

HEC encourages employees who apply for or obtain a protective or restraining order to notify
Human Resources.

Anyone determined to be responsible for acts or threats of violence or other conduct that is found to be in violation of these guidelines may be subject to disciplinary action, up to and including immediate termination of employment.

LOST KEY POLICY – EXTERIOR DOORS

All campuses have lock and key systems for exterior doors to insure the safety and security of our staff and students. Lost or stolen keys present an immediate security risk to the entire campus community. Replacement of these keys is costly and time consuming and staff will be held accountable for keys signed out to them. Keys are considered property of HEC. Generally, loss of HEC keys by staff is addressed as follows:

• Should you lose a key, you will receive a written warning.
• Should you lose a key a second time, you will be suspended without pay for one day.
• Should loss occur again, the staff may be demoted or terminated.
• If you lose a key and find it within 24 hours, you must immediately report this to the
Program Director or designee.
• If you find the key later than 24 hours after reported loss, the disciplinary action will be
upheld.

If your employment with HEC should end, you will be required to return your key prior to your
last day of employment. Failure to do so may result in a deduction in your final check to offset the
costs associated with replacing the locks and/or distributing new keys.

SAFETY

At HEC student, staff and visitor safety are of primary concern.
Each work site has a Safety Committee. Staff are encouraged to participate in these committees
and to report any unsafe conditions or ideas regarding safety to their supervisors.

STAFF PARTICIPATION IN STUDENT ACTIVITIES

High profile/large participant activities should be supervised by a member of the Campus
Administration whenever possible.

Activity leader and participating staff will take the time (10 minutes) to warm up and stretch major muscle groups prior to the start of the activity.

Staff are required to attend the activities of their assigned students and to actively supervise students during all activities. Staff are not compelled to physically participate as players in sports related activities with students, but if staff chooses to play in the sport, they must engage in preparation for the sport (stretching, pre-teaching, etc.) with the students. Staff participating in sports related activities at any level is limited to therapeutic role modeling. Staff are not to engage in direct competitive athletic endeavors against students or other staff members.

Seasonal rules should be posted, when possible, in specific activity areas (i.e., softball rules/behaviors – softball field).

Emphasize:
• Therapeutic, not competitive environment
• Warm-up and stretching prior to activities.
• Pre-Teach – game & campus rules, expected behaviors, and hot tips to avoid behavioral pitfalls (i.e., use minimum equipment necessary).

CHILD ABUSE AND NEGLECT REPORTING POLICY

Child Abuse Policy

Following Massachusetts’s law, HEC prohibits any form of physical or sexual abuse of its students, and mandates all staff to report incidents of suspected child abuse.

Abuse: the non-accidental commission of any act by a caretaker, which causes or creates a substantial risk of harm or threat of harm to a child’s well being.

Neglect:
1. Failure by a caretaker, either deliberately or through negligence, to take actions necessary to
provide a child with minimally adequate food, clothing, shelter, medical care, supervision, or other essential care.

2. Serious physical injury (any non-trivial injury); death; malnutrition; and failure to thrive.

3. Serious emotional injury: an extreme emotional condition such as a severe state of anxiety, depression or withdrawal.

Child Abuse Reporting

1. Each and every one of the employees of HEC is required by law to report to their supervisor the awareness of any student who may be abused or neglected. Under M.G.L. Chapter 119, staff are categorized as mandated reporters, liable to civil or criminal action for failure to report a potentially abusive or neglectful situation or incident.

2. The term, mandated reporter, specifically addresses the fact that any person who works in a residential treatment center is required to report to DCF (Department of Children & Families). At HEC, once the staff member reports to the person in charge, the employee is then relieved of any liability and the liability for not reporting belongs to the person in charge, i.e. the Program Director.

3. Staff must immediately report to his/her supervisor any abusive behavior toward a student and complete a written report on the matter within 24 hours. The supervisor will ordinarily immediately notify his/her Program Director who, in turn, will notify without delay the
Executive Vice President. On the next business day, the Program Director will ordinarily submit
a brief written statement of concern to the Executive Vice President.

4. HEC requires the Program Director or, if absent, his/her administrative designee to immediately report to the Department of Children & Families (DCF).

5. At the time of the allegation, the staff person alleged to have abused a student would ordinarily be suspended without pay pending a full investigation.

6. If the charge of abuse in not supported by the DCF, the staff member may be considered exonerated and reinstated with back pay. Depending upon the circumstances, the employee may be subject to disciplinary action, including suspension without pay and re-training.

7. If the charge of abuse is supported, the staff person may be terminated from employment and may face legal sanctions.

8. Employees not reporting suspected abuse or neglect are subject to discipline up to and including dismissal.

9. DCF regulations provide the following pertinent definitions as guidelines for reporting:

A. Abuse – the non-accidental commission of any act by a caretaker, which causes or creates a substantial risk of harm or threat of harm to a child’s well-being

B. Neglect – Failure by a caretaker, either deliberately or through negligence, to take actions necessary to provide a child with minimally adequate food, clothing, shelter, medical care, supervision, or other essential care.

C. Serious physical injury (any non-trivial injury); death, malnutrition; and failure to thrive.

D. Serious emotional injury: an extreme emotional condition such as a severe state of anxiety, depression or withdrawal.

CONFIDENTIALITY POLICY

Hillcrest Educational Center staff, students and trainees will regard as confidential all information that might identity a person as a HEC client, as well as all information concerning events and conditions as they relate to particular clients. Staff and students will act in every instance to protect such material in accordance with the client’s wishes, and with applicable laws and regulations.

Staff are only authorized to see records of clients with whom they are involved in a service or supervisory capacity. Staff may look at other client case records only with the express permission of the client’s Program Director.

In general, staff will NOT disclose identified case information unless the client/parent/guardian has authorized disclosure in a written and signed release of information statement.

There are three exceptions to this policy (i.e., they do not require prior client release):
1. When reporting abuse or neglect as per State Law;
2. When preserving health or safety in an emergency;
3. When preventing the commission of a crime.

In any of these exceptional situations, staff must notify their immediate supervisor that they have disclosed, or intend to disclose, identified case information, and why.

Case records are the physical and legal property of HEC Staff will NOT automatically release records when subpoenaed. Instead, staff will check with their Program Directors who, on the basis of possible harm to the client, may seek to have the subpoena legally nullified. Staff will NOT release physical records, or components or copies of them to a client, a former client, or to a client or former client’s parent/guardian before securing approval from the Program Director.

On each occasion in which a staff removes a client record from either a campus Records Room or from long term storage, the staff must sign out each record being removed, and must sign the record back in upon return to the Records Room or to storage. Staff assumes responsibility for any case record in their possession, and unless they are responding to a court order, and with the knowledge and approval of their Program Director, staff must never remove a client record from a Hillcrest site or property.

Staff will avoid discussing current or former clients or clients’ families/guardians in non- professional settings. Staff WILL NEVER use client names or other identifying information in public conversation.

Staff may use client related information within the agency for treatment, training, or research purposes without special permission, as long as the use of that information is in compliance with any and all applicable Hillcrest policies (e.g., policies on research). However, proposals to use case information outside of the agency require the approval of the Executive Vice President.
This includes, but is not limited to student projects, published articles, and other public presentations.

Staff may videotape, photograph, audiotape or use one-way mirrors only with the written permission of the clients involved. At the time of admission the parent/guardian signs a release regarding treatment and/or publicity related to taping and photographing.

Members of the print or electronic media may not have access to clients or to any information about them, without prior approval by the client’s parent/guardian. Staff will clear all proposed media involvement with the CEO or Vice President prior to such involvement.

LANGUAGE POLICY

All Hillcrest students have experienced varying degrees of trauma and most have serious issues with interpersonal relationships. Therefore, it is critically important for us to maintain a therapeutic environment of care in which students can feel as safe, comfortable and understood as possible. In order to satisfy this critical need for the Hillcrest students, Hillcrest requires all employees refrain from speaking languages foreign to any student in their presence.

Hillcrest recognizes that many of its staff speak languages other than English. It is perfectly acceptable to use whatever language they chose when in conversations outside of the presence of Hillcrest students. It is also acceptable to use a language other than English if the students in their presence are fluent in the same language (i.e. staff may speak Spanish in the presence of

Spanish-speaking students.) As always, employees must remain sensitive to their work environment and avoid interacting in any manner that could make co-workers feel uncomfortable or excluded.

PERSONAL INFORMATION SECURITY PROGRAM AND POLICY

In the ordinary course of its operations, Hillcrest Educational Centers, Inc. (the “Company”) obtains various forms of personal information pertaining to its employees, students, students’ families, donors, and other individuals. The Company takes seriously its obligation not to engage in or permit the inappropriate use or disclosure of such information. In addition, both federal and state laws impose specific requirements relating to certain forms of personal information that could be used to commit “identity theft” or fraud. The Company has adopted
this Personal Information Security Program and Policy in accordance with those federal and state law requirements. The entire contents of this policy can be found in the HEC – Policies & Procedures – Chapter 11.

REQUIREMENTS OF JOB PERFORMANCE

In order to provide our students with the best possible care and to ensure their safety and well being, staff are reminded of the following requirements:

All HEC staff must be awake, alert and attentive to their duties during their assigned work hours. Staff are not permitted to sleep during their breaks. You must report to your supervisor any staff person you discover sleeping on the job.

Only pre-approved electronic devices may be used while on duty. Overnight staff may have
TV’s on, if the TV’s are located in an area where staff can physically see children. If staff cannot
see children while watching TV due to TV’s location, then TV is prohibited. While on break, however, the TV can be watched.

Staff are not permitted to leave campus during their breaks without supervisory approval. When staff does leave campus during their shift after receiving supervisory approval, they must sign out and then back in on campus log.

On overnight shifts, room checks must be performed on a regular basis, according to campus policy and documented accurately.

Failure to comply with these directives will result in disciplinary action up to and including termination of employment.

PROFESSIONAL STANDARDS (Ethical Standards)

All employees of HEC are considered to be professionals in their respective positions and are expected to perform their duties in a professional manner, which reflects in a positive way on

themselves, their agency, and the students that they serve. HEC expects all of its employees to practice standards of performance, conduct, and behavior in the following manner:

Employees should give conscientious and consistent effort to their assigned jobs, and accept full responsibility for all duties related to that job, including punctuality and daily attendance.

Employees should treat co-workers and supervisors with courtesy and abide by the decisions of their supervisors. Employees may make suggestions, but the final decision or instruction given by their supervisors must be accepted and implemented.

Employees should work to the best of their abilities and maintain the best quality of work possible. Employees should communicate with their supervisors for clarification of job responsibilities or for further instruction, since the supervisors are accountable for their performance.

Employees’ conduct should be honest and above reproach, both on and off HEC property. Employees should avoid becoming involved in any activity that could be considered unacceptable or illegal in the community at large. Outside of work, others perceive employees as representatives of the organization. If any employees are not sure of the intent or application of any personnel policy or regulation, they should ask their supervisors for clarification or interpretation.

Equipment and property of HEC is available to staff on all sites, and should be treated with care and respect. While normal wear and tear is expected on equipment and property, when staff damages property or equipment due to negligence or deliberate destruction, they will be subject to disciplinary action. Other resources, such as books, tapes, etc., are available to staff, and it is expected that these materials are treated carefully, as with other equipment and property of HEC.

POLICY ON PROFESSIONAL BOUNDARIES
Staff are required to read and comply with the full policy which is found in Chapter 4, “Care of
Students”, of HEC Policies and Procedures.

By its very nature, residential care and treatment with children and adolescents sometimes involves intense interpersonal dynamics and some intensely intimate aspects of the lives of students. The nature of our work can result in complicated emotions and strong personal feelings and/or relationships among staff and students. The familiarity that develops between staff and residential students also contributes to a relationship that may be so comfortable at times that feelings and responses may be more personal than professional. However, nurturance, acceptance, encouragement, and support can and must be provided by staff while still maintaining professional boundaries.

Staff are expected to observe appropriate and professional conduct, including boundary maintenance, at all times. Failure to maintain professional conduct and to observe appropriate and professional boundaries will result in disciplinary action up to and including termination from employment.

Similarly, during any form of contact with a student’s family, guardian, or advocate, or with any representative an outside agency, staff are expected to act in a professional manner. For example, at no time during a professional contact may staff violate professional boundaries, form personal relationship or share personal information.

The best interests of the student, and associated Hillcrest policies and procedures, are the highest priorities, and the deciding factors in relationships between current/former staff and current/former students, and in possible boundary violations.

It is our responsibility, not the student’s, to maintain appropriate boundaries in our professional relationships with students. Initiation and or consent by the student for behavior that constitutes a boundary violation between staff and student is not an excuse or justification.

It is important that staff maintain a professional and personal support structure that provides for feedback and advice on the management of boundary issues as it impacts on their work with students and coworkers.

A staff’s termination of employment with Hillcrest, and/or the transfer or discharge of a student from Hillcrest Educational Centers’ care and treatment does not absolve staff’s responsibility to observe and respect professional boundaries and ethics.

POLICY ON STAFF CONTACT AND RELATIONSHIPS WITH STUDENTS
Staff are required to read and comply with the full policy which is found in Chapter 4, Care of
Students”, of HEC Policies and Procedures.

All contacts and relationships between staff and students, current and/or former, and their families, guardians and agencies, must be strictly professional in nature and function, regardless of the employment status of the staff (i.e., currently or formerly employed by HEC) or the placement status of the student (i.e., current or former student). This, in fact, is the only way to insure that staff – student contact and relationships are appropriate and therapeutic in nature.

Any and all desired contacts and/or relationships between current and/or former HEC staff and current and/or former HEC students (and their families, guardians and agencies) that are outside the parameters of the staff member’s role and/or job description, and which therefore might constitute personal relationship or contact, must be discussed in advance with the campus Program Director and/or the agency Executive Vice President or CEO and be determined by them to be in the best interest of the current or former student. Such desired relationships and/or contacts may only be conducted with the knowledge and approval of the campus Program Director and/or the agency Executive Vice President or CEO.

Any such relationship and/or contacts between current and/or former HEC staff and current and/or former HEC students (and their families, guardians and agencies) that are not approved in advance will be considered to be in violation of HEC policies, procedures and professional
ethics. Such an unapproved relationship and/or contact will be cause for disciplinary action for a current employee who engages in such action, up to and including termination from

Employment. Legal or administrative action or referral may be initiated against former employees who violate this policy or when there is reason to believe this policy has been violated.

CONFLICTS OF INTEREST

A conflict of interest occurs when:
• there is a risk that care, treatment and welfare of Hillcrest students or patient welfare will be compromised by a secondary interest of a personal, commercial, political, academic or financial nature.
• an employee’s outside employment, personal or private interests interfere or conflict with
the best interests of the students or the employee’s own professional responsibilities at
HEC.

The conflict may be actual, perceived or potential. A conflict of interest may affect care, clinical practice, education, administration or research. It may or may not lead to undesirable outcomes. However, a conflict of interest may exist whether or not an employee is actually swayed by and acts on the competing interest.

Priorities & Principals
Hillcrest has many employees, and these employees have numerous and sometimes complex
relationships with public and private entities. Therefore, the agency must be aware of any relationships involving personal or financial interest or gain that may compromise or appear to compromise the agency’s integrity, clients and/or services. As described below, staff must discuss with their supervisor or an agency administrator any questions or situation that may potentially pose a conflict of interest so that a constructive resolution to the matter can be achieved.

HEC employees, in all positions, departments and at all levels must understand that their professional priorities and responsibilities are first, to the students and second, to the integrity of the agency and the agency’s services. The professional behavior of all employees must be consistent with this understanding.

When ethical problems arise, if they are not managed effectively, the integrity of the organization and the objectivity of the organization’s services are at stake, and trust may be eroded at every level.

Managing Conflicts of Interest

On the organizational level:
Each year, HEC reviews its relationships with other care providers, educational institutions,
manufacturers, and payors to determine whether conflicts of interest exist and whether the relationships are consistent with law and regulation. Any conflicts of interest that are discovered during the annual review will be resolved decisively and in a timely fashion.

On the individual employee level:
All potential or actual conflicts of interest must be reported in a timely and complete fashion.

HEC staff who may have a conflict of interest should discuss the situation with their supervisor or an agency administrator. When a possible conflict of interest is discovered or reported, the facts of the situation will be thoroughly referred to and be objectively analyzed by an ad hoc Conflict of Interest Review Committee. The COIRC will determine if a conflict of interest, or the potentially damaging appearance of a conflict of interest may exist. If it is determined by the COIRC that a conflict of interest, or the potentially damaging appearance of a conflict of interest may or does exist, a plan will be developed and implemented by senior management to manage
or eliminate the conflict.

Conflict of Interest Review Committee
The COIRC is an ad hoc committee comprised of members of the senior and/or secondary management team who do not have any direct connection with possible COI.

The function of the COIRC is to review and evaluate the facts of a specific potential conflict of interest. Based on this review and evaluation, the COIRC will provide it s findings and any recommendations to Administration.

The President/CEO or his designee will select the members of the COIRC, some of whom may be drawn from the Human Rights and Organizational Ethics Committee.

INTERNAL INVESTIGATION POLICY AND PROCEDURES
Staff are required to read and comply with the full policy which is found in Chapter5, “Urgent
Events and Emergencies”, of HEC Policies and Procedures.

Hillcrest is committed to providing safe and effective services to our students. Safety and effectiveness go hand in hand. In order for students to be able to concentrate on their treatment and education, they must feel safe and protected. In order for staff to be able to focus on the care, treatment and education of students, they must feel safe and protected.

Allegations and indications of abuse and neglect, student complaints and grievances related to abuse or neglect, accidents, injuries and medical emergencies are taken very seriously. These types of events result in a timely exploration and inquiry into the event, and in a timely, thorough and objective internal investigation, if indicated by the initial inquiry or by the nature of the
event itself.

All internal investigations are authorized by Hillcrest’s Executive Vice President or designee. Program Directors conduct or authorize preliminary explorations and inquiries into allegations/complaints/events.

Depending on the nature of the incident or event, staff alleged to have been involved in the incident or event may be suspended pending the results of the investigation. Payment for time suspended, or continuation of employment, would be determined, based on the outcome of the

JOB CATEGORIES

The types of employees at HEC are as follows:

Full-time employees – those employees whose regularly scheduled workweek is at least 36 hours. These employees are eligible to receive company benefits. Any employee wishing to reduce their weekly hours must submit their request in writing to their department head for consideration.

Part-time employees – those employees whose regularly scheduled workweek is at least 20 hours, but fewer than 36 hours. These employees do receive pro-rated company benefits.

On-call employees – those employees who are called to work a particular shift(s) on an as- needed basis who do not qualify for either full or part time status. These employees do not earn company benefits, but do receive differentials.

Temporary employees – those employees who are hired for brief continuous periods of time, especially during the holidays or summer, usually not to exceed three months. These employees do not earn company benefits.

ON-CALL STAFF EXPECTATIONS

HEC hires many on-call Child Care staff every year. On-call staff provides us with the relief we need when we have vacancies, and when full and part time staff take benefit time off. On-call staff are paid a set hourly rate because they do not have a set schedule, nor do they receive benefits. On-call staff hours may vary week to week and it is the staff’s responsibility to follow campus procedure to schedule hours that are mutually agreeable.

On-call staff are required to work a minimum of one regular shift each pay period and sign up for one “stand by” shift each pay period. On-call staff are encouraged to call more than
one campus to schedule hours, as long as they do not schedule more than 60 hours/week.

Should an on-call staff transfer to a full or part time position with benefits, the staff will be placed on the pay scale that is currently in effect for the new position, based on their educational level and experience.

Because HEC provides services for emotionally disturbed children and adolescents in a challenging work environment, we require that on-call staff schedule hours and receive training on a regular basis as outlined in the agreement.

Working a minimum number of hours each quarter and receiving 24 hours of training annually, helps us make sure that on-call staff are safe and that our students receive high quality care from staff who know them and who are properly trained.

If you are unable to fulfill the requirements for minimum hours worked each quarter, (one 8-hour shift per pay period) or if you do not receive the required number of training hours annually, we will consider you to voluntarily quit your position as an on-call staff at HEC.

VOLUNTEERS

Volunteers can be a great asset to a non-profit organization and are welcomed by HEC. Due to the fact that HEC deals with children and youth who are prime targets for abuse, volunteers are closely screened, supervised, and evaluated. Volunteers are required to follow all policies, procedures and guidelines of the organization and a Background Record Check must be completed prior to commencing their voluntary assignment.

STUDENT INTERNS

Interns, or individuals enrolled in accredited college programs leading to a degree, are welcome at HEC. Generally, an intern is enrolled in a course, which requires real experience in the field. Internships, practica, and fieldwork courses all qualify. Generally, a report or evaluation of the student’s performance is provided to the individual college or university. The intern is seen as an individual who is learning and implementing that learning under the supervision of a qualified staff member. At this time, internships are not paid positions. Stipends may be available, based on fund availability.

Due to the fact that HEC deals with children and youth who are prime targets for abuse, interns are closely screened, supervised and evaluated. Interns are required to follow all policies, procedures and rules of the organization including a Background Record Check, and must complete New Staff Orientation.

ADDITIONAL EMPLOYMENT

HEC expects its employees to put employment at HEC above any other employment the employee may have or obtain. Other employment is acceptable only to the extent that it does not interfere with, or diminish, the employee’s ability to perform their job responsibilities at HEC. This applies equally to an employee seeking overtime at any HEC site in as much as the election to work overtime cannot interfere with an employee’s ability to perform their job responsibilities.

PERSONNEL FILES

Personnel Files on each employee are maintained in the Human Resources Department. This file contains personnel records, evaluations, HEC correspondence, and correspondence from and to government agencies as well as other material.

The employee may comment in writing about material contained in the Personnel File and those written comments shall be attached to and made part of the material in their file.

Upon written request, the Personnel File will be available for examination by the employee. Said examination will be at a time convenient to the employee and the employer. Upon written request, the employee will be provided with a copy of his/her Personnel File at no charge, and the request will be completed within 5 business days of receipt of signed request.

CHANGE OF PERSONAL STATUS

Any change of status (address, telephone number, marital status, dependents, next of kin, etc.) should be reported to the Human Resources Department, in writing, within one week of such change. Many times, these changes of status affect benefits or beneficiaries. We have a limited amount of time (usually 30 days) to make changes with our benefit carriers, so we encourage staff to let us know immediately of any status change.

EMPLOYEE RIGHT NOT TO PARTICIPATE IN CARE AND SERVICES BASED ON CULTURAL/RELIGIOUS GROUNDS

HEC respects its staff member’s cultural values, ethics and religious beliefs and the effect these may have on the care and services provided. HEC will attempt to accommodate employees who give advance notification to their supervisor that they do not wish to participate in an aspect of care or service because of cultural values, ethics, or sincerely held religious beliefs.

Employees are informed during orientation that they may request not to participate in an aspect of care because of cultural values, ethics, or sincerely held religious beliefs. If an employee identifies an aspect of care or service in which he/she wishes not to participate, a request in writing is made. The request must include the cultural, ethical or religious reason, as well as the aspect of care or services from which the staff member wishes to be excused.

The supervisor will review the request to determine whether accommodation is possible. If accommodation is possible the supervisor will notify the employee and others who need to be involved in the accommodation. There will be an understanding that if the accommodation cannot be provided because of undue hardship, the employee will be expected to perform assigned job duties so as not to negatively affect delivery of care or services.

If an accommodation is not possible, the employee will be allowed to explore other job opportunities within the organization where accommodations might be possible. If an employee does not agree to render appropriate care or services in an emergency situation because of personal beliefs, the employee will be placed on a leave of absence from their current position and the incident will be reviewed.

HEC DRIVER CERTIFICATION

In order to insure the highest standards for safety and accountability while transporting students, HEC publishes the HEC Drivers List. Requirements for inclusion on this list include an initial driver’s license abstract review and a bi-annual driver’s license review.

All staff transporting HEC students in an HEC vehicle must be on the HEC Drivers list. Application for inclusion is mandatory for all new hires that currently possess a valid (Massachusetts, New York, Connecticut etc.) drivers license. The HEC driving privilege is valid for two years from the date of issue. The Driver’s Record Review is accomplished through normal channels during the hiring process. Initial training is conducted during On Site Orientation. After participation in the training session and successful review of the driver’s historical abstract, a staff members name will be placed on the list.

HEC has adopted the following recommendations from our insurance company for exclusion from the certified driver’s list:

1. Major Incident within the previous 3 years
2. 3 Minor Incidents within the previous 3 years
3. Any set of circumstances, combination of incidents or other matters warranting exclusion
from the list.

Re-certification for HEC license:
When a license approaches expiration, a staff member may reapply for the HEC license by
completing a request for insurance driving abstract review

Upon review and approval of the insurance abstract, the staff member will be approved for a 2- year extension to the HEC license. The monthly drivers list will include the staff member’s name, date of license issue and expiration date.

Upon review and approval of the original driver’s license abstract, and subsequent bi-annual review, driver license information will be placed in the employee’s personnel file.

Management/Supervisor/Maintenance Requirement:
All supervisors are required to have a HEC Driver’s License and will transport students, staff and provide other driving related services as requested by their supervisor using agency vehicles. Vehicles include cars, vans and trucks that do not require a special license to operate.

Supervisory staff must possess a valid Northeast region driver’s license and have successfully been awarded a Hillcrest Driver’s License. Supervisory staff who have a driver’s license but who have not successfully received a HEC license must provide a corrective action plan to the Program Director within 30 days of notification of failure to obtain HEC license. If the corrective action plan is approved by the PD, the staff will have 90 days to implement the corrective action plan and to obtain a HEC license.

Failure to comply with this directive will result in transfer to a position that does not require staff to drive HEC vehicles. Staff are required by policy to report to their supervisor, who will then report to HR, any driving infractions or accidents so that their HEC license can be re-evaluated.

Supervisors include:
Assistant Supervisors, Supervisors, Campus Administrators, Senior Management Team, Department Heads and Maintenance Staff.

MILEAGE REIMBURSEMENT

HEC will agree to reimburse the employee for pre-approved mileage when using a personal vehicle for HEC business. Reimbursement requests must be submitted on a monthly basis. Tolls will also be reimbursed if accompanied by a receipt. Mileage will not be paid for travel to and from the job site from home or to home from the job site. It is expected that the employee, for

his/her protection, will hold more than adequate liability insurance on his/her vehicle. A
minimum of $100,000/$300,000 is recommended.

WORK AT HOME POLICY
Under very controlled situations, Program Directors, with Executive Vice President approval, may allow professional staff the opportunity to work at home on specific assignments. Since Professional staff supervise or work directly with the students, these requests can only be handled on an occasional basis.

All requests should be made to the Program Director and must include an outline of the work to be done and the rationale for performing the work at home. At this time, the Program Director and the employee will set parameters for the amount of time the project will take. If the work is to be done at home during normal work hours, time normally involved in travel to and from the home will not be counted as work hours. If the project is to be done outside normal work hours, an agreement on flex time will be discussed.

Director level positions with no direct care or supervisory responsibility may be granted more flexibility in the amount of time that work can be performed at home. Management staff will coordinate schedules with their supervisor and will agree to review the schedule as often as needed based on HEC needs. Under no circumstances will a regular schedule be created where a set number of hours are worked at home. The schedule must remain flexible to accommodate
the needs of the agency.

HEC will consider work at home arrangements, where operationally feasible, as a possible reasonable accommodation for otherwise qualified employees with a disability.

DAMAGE TO PERSONAL PROPERTY

HEC will not be responsible for the loss or damage of an employee’s personal property that is not necessary for the performance of their official duties (jewelry, unapproved electronic equipment, etc.).

In certain instances (torn clothing, broken eyeglasses, approved electronic equipment, etc.), HEC may pay for the repair or replacement of the item(s) providing the appropriate documentation is provided.

If you have personal property damaged by a student, WITHIN 48 HOURS OF THE INCIDENT
you must:
• Complete a report of property damage (including any witness statements);
• Attach the student incident report;

• Give the paperwork/documentation to your Program Director/Manager (or designee). Your Program Director/Manager (or designee) will determine the action the Agency may take.

DAMAGE TO PERSONAL VEHICLES

HEC will not be responsible for alleged damage to staffs’ personally owned vehicles while parked on HEC property unless there is documented evidence that a student under HEC’s care caused the damage to the staff’s vehicle.

If you believe your personally-owned vehicle has been damaged by a HEC student and it is during normal business hours (Monday to Friday, between 8:00 a.m. and 5:00 p.m.), WITHIN
48 HOURS OF THE INCIDENT you must:
• Provide documentation, in written form, by all staff that witnessed the incident;
• Complete a report of property damage as the owner of the vehicle;
• Attach the student incident report;
• Give all documentation to your Program Director/Manager (or designee).
• Program Director/Manager (or designee) will assist staff in providing or preparing any of the required documentation.
• Your Program Director/Manager (or designee) will forward all information to the Vehicle
Maintenance Manager.

If you believe your personally owned vehicle is damaged after normal business hours the Vehicle
Maintenance Manager must be contacted by leaving a message at (413) 637-2834, ext. 240.

An investigation will be conducted by the Vehicle Maintenance Manager and either HEC or its insurance carrier may respond to repair the damage if clear liability was established. (The Vehicle Maintenance Manager will supply a copy of the property damage incident documentation to the Business Office for filing with our insurance carrier if/as needed.)

If clear liability is established:

• The Vehicle Maintenance Manager will direct the employee to an approved automobile repair shop to receive an estimated repair cost;
• The repair shop will send the estimate directly to the Vehicle Maintenance Manager;
• The employee will be contacted by the Vehicle Maintenance Manager and be instructed to have the damage repaired within 60 days;
• The employee has the option of having the repairs done at the approved repair shop or at a repair shop of their choice, but at a cost not to exceed the original estimate from the
approved repair shop;
• If the employee opts to use a repair shop of their choice and the cost of the repairs is less
than the original estimate from the approved repair shop, HEC will pay only the actual cost incurred;
• Reimbursement for the damage repairs will be made directly to the repair shop and not to the employee;
• Damage not repaired within 60 days will not be paid for.

Damage that appears on vehicles, but is not witnessed by a staff, may not be covered by HEC.

Damage that appears on vehicles, but is not reported within 48 hours may not be covered by HEC.

FAMILY & MEDICAL LEAVE

Employee rights and responsibilities under the Family and Medical Leave Act:

Basic Leave Entitlement
FMLA requires covered employers to provide up to 12 weeks of unpaid, job-protected leave to eligible employees for the following reasons:

1. For incapacity due to pregnancy, prenatal medical care or child birth;

2. To care for the employee’s child after birth, or placement for adoption or foster care;

3. To care for the employee’s spouse, son or daughter, or parent, who has a serious health condition; or

4. For a serious health condition that makes the employee unable to perform the employee’s job.

Military Family Leave Entitlements
Eligible employees with a spouse, son, daughter, or parent on active duty or call to active duty status in the National Guard or Reserves in support of a contingency operation may use their 12- week leave entitlement to address certain qualifying exigencies. Qualifying exigencies may include attending certain military events, arranging for alternative childcare, addressing certain financial and legal arrangements, attending certain counseling sessions, and attending post- deployment reintegration briefings.

FMLA also includes a special leave entitlement that permits eligible employees to take up to 26 weeks of leave to care for a covered service member during a single 12-month period. A covered service member is a current member of the Armed Forces, including a member of the National Guard or Reserves, or a Veteran who became injured or ill within 5 years of discharge, who has a serious injury or illness incurred in the line of duty on active duty that may render the service member medically unfit to perform his or her duties for which the service member is undergoing medical treatment, recuperation, or therapy; or is in outpatient status; or is on the temporary disability retired list.

Benefits and Protections
During FMLA leave, the employer must maintain the employee’s health coverage under any
“group health plan” on the same terms as if the employee had continued to work. Upon return from FMLA leave, most employees must be restored to their original or equivalent positions with equivalent pay, benefits, and other employment terms.

Use of FMLA leave cannot result in the loss of any employment benefit that accrued prior to the start of an employee’s leave.

Eligibility Requirements
Employees are eligible if they have worked for a covered employer for at least one year, for
1,250 hours over the previous 12 months, and if at least 50 employees are employed by the employer within 75 miles.

Definition of Serious Health Condition
A serious health condition is an illness, injury, impairment, or physical or mental condition that involves either an overnight stay in a medical care facility, or continuing treatment by a health care provider for a condition that either prevents the employee from performing the functions of the employee’s job, or prevents the qualified family member from participating in school or other daily activities.

Subject to certain conditions, the continuing treatment requirement may be met by a period of incapacity of more than 3 consecutive calendar days combined with at least two visits to a health care provider or one visit and a regimen of continuing treatment, or incapacity due to pregnancy, or incapacity due to a chronic condition. Other conditions may meet the definition of continuing treatment.

Use of Leave
An employee does not need to use this leave entitlement in one block. Leave can be taken
intermittently or on a reduced leave schedule when medically necessary. Employees must make reasonable efforts to schedule leave for planned medical treatment so as not to unduly disrupt the employer’s operations. Leave due to qualifying exigencies may also be taken on an intermittent basis.

Substitution of Paid Leave for Unpaid Leave
Employees may choose or employers may require use of accrued paid leave while taking FMLA leave. In order to use paid leave for FMLA leave, employees must comply with the employer’s normal paid leave policies.

Employee Responsibilities
Employees must provide 30 days advance notice of the need to take FMLA leave when the need
is foreseeable. When 30 days notice is not possible, the employee must provide notice as soon as practicable and generally must comply with an employer’s normal call-in procedures.
Employees must provide sufficient information for the employer to determine if the leave may qualify for FMLA protection and the anticipated timing and duration of the leave. Sufficient
information may include that the employee is unable to perform job functions, the family
member is unable to perform daily activities, the need for hospitalization or continuing treatment
by a health care provider, or circumstances supporting the need for military family leave. Employees also must inform the employer if the requested leave is for a reason for which FMLA leave was previously taken or certified. Employees also may be required to provide a
certification and periodic recertification supporting the need for leave.

Employer Responsibilities
Covered employers must inform employees requesting leave whether they are eligible under FMLA. If they are, the notice must specify any additional information required as well as the employees’ rights and responsibilities. If they are not eligible, the employer must provide a reason for the ineligibility.

Covered employers must inform employees if leave will be designated as FMLA-protected and the amount of leave counted against the employee’s leave entitlement. If the employer determines that the leave is not FMLA-protected, the employer must notify the employee.

MASSACHUSETTS MATERNITY LEAVE ACT

Pursuant to Massachusetts state law, HEC grants an eight-week maternity leave, per child, following the ending of pregnancy for female employees who have completed the Introductory Period of employment. Such leave may, at the option of the employee, be paid leave deducted from any sick and/or vacation entitlement; otherwise the leave is unpaid. For those entitled to FMLA, the maternity leave will run concurrently with FMLA to the maximum extent permitted by both laws. Staff should set up an individual counseling session with Human Resources to review all applicable policies.

An employee on maternity leave shall notify the Program Director/Manager of her intention to return to her employment. Employees returning from a maternity leave of eight weeks or less will be returned to her previous, or a similar, position. Employees returning from a maternity

leave of up to twelve weeks under FMLA will be returned to their previous position, or to an equivalent position.

SMALL NECESSITIES LEAVE ACT

An employee who has worked for HEC for a minimum of a year, and has worked 1250 hours, may take a total of 24 hours unpaid leave each year (1) to participate in school or day-care activities that are directly related to the educational advancement of his or her child, (2) accompany his or her child to routine medical or dental appointments or (3) accompany an elderly relative to routine medical or dental appointments or other appointments for the elder’s care.

Covered relations under the “Small Necessities Act”: A son or daughter means a minor child who is the biological or legal child of the employee. An elderly relative is any person over the age of 60 years who is related by blood or marriage to the employee.

The 24-hour leave may be taken intermittently or on a reduced leave schedule. If an employee wishing to take Necessities Leave has accrued benefit time under HEC policy (e.g. vacation, sick, personal time), such time must be used concurrently with any time under SNLA. Additionally, paid benefit time used by an employee for any of the foregoing qualifying reasons will be counted against, (and thereby reduce), the employee’s leave entitlement under SNLA.

If the necessity for the leave is foreseeable, an employee is required to provide HEC with at least seven days’ notice before the date the leave is to begin. If the necessity for the leave is not foreseeable, then the employee must provide such notice as is practicable.

Upon request by HEC, an employee must provide written “certification” from an appropriate person or entity certifying the basis for the requested Necessities Leave. Such certification shall be in the form provided by HEC.

MILITARY AND NATIONAL GUARD LEAVE

Our military leave policy will remain in effect in accordance with state and federal law. Additionally, should an employee be called to active State service, HEC will supplement the difference in pay between the employee’s base pay (no overtime, differential, or stipend will be included) and the pay received by the state. The employee will be required to provide documentation (pay stub or similar) to receive this benefit. We believe that should an employee be called to federal service, the rate of pay will be higher than HEC pay, but should this not be the case, we will review each case individually.

All appropriate benefits will remain in effect if the employee so chooses:

• Health and dental insurance at current contribution level
• Pension contribution (based on base pay employee would receive if working 40 hours).
• Disability and life insurance
• Supplemental insurances purchased by the employee

Vacation and sick accruals will stop during the leave, but hours may remain in the banks until the employee returns to work and may be used upon return. Should the employee choose to cash out vacation hours, the employee may do so.

Tuition reimbursement that is due will be “frozen” and will be payable upon return.
Please see the Family and Medical Leave section for additional information for Military and their
families.

Upon completion of qualifying military service, eligible employees will be reinstated to employment at HEC pursuant to the Uniformed Service Employment And Reemployment Act (USERRA) or other applicable law. Employees must comply with all required notification and return-to-work deadlines and requirements imposed by USERRA or other applicable law. Employees are encouraged to discuss these issues and requirements with Human Resources prior to deployment or other active duty.

SUMMER LEAVE POLICY FOR TEACHERS

Summer Leaves for teachers will be considered based on individual campus circumstances. Critical to the determination of approved leave is the individual campus ability to provide quality educational services and meet IEP needs during teacher absence. Teachers may request the summer off through our Unpaid Leave of Absence Policy, modified as follows:

A written request must be presented to your Principal and then must also be approved by the Program Director, the Director of Human Resources and the Vice President. The written leave policy states that benefits would be discontinued during leave unless you pay both employee and employer premiums, but for the purpose of teachers requesting Summer Leave, HEC will

continue to pay the employer portion of benefits during your leave. You would have to pay the employee share of the premiums for the entire summer prior to leave.

A vacation week is scheduled at the beginning and at the end of summer, but teachers who request Summer Leave would only be eligible to be paid for the week of vacation at the beginning of summer. Your salary will be reinstated beginning with the first day you return to full time teaching duties. Teachers requesting Summer Leave are making a commitment that they will return to their positions in the fall. Should a teacher not return from Summer Leave, they will be considered to have left in poor standing with the Agency.

To apply for leave:
Teachers must have one year full time teaching at HEC. Each program will determine the
number of requests that can be accommodated. If more requests are received than can be accommodated, the following criteria will be used in determining who is granted leave:
• seniority
• current performance
• leave requested and granted in previous years
• ability for program to cover position during leave

Teachers may request time off in the summer of a few days or a week, which will be unpaid. Requests must be in writing and approved by the Principal, Program Director and HR Director by June 30th each year. Approval will be based on ability to cover position during absence, employee performance, and seniority.

UNPAID LEAVE OF ABSENCE

Employees may be granted an unpaid leave of absence at the discretion of HEC for compelling reasons. A request must be presented to the appropriate supervisor and subsequent written approval of the Program Director and the Vice President received.

To continue medical benefits and other paid benefits during an unpaid leave of absence (except leave that is granted under the FMLA), the employee must pay all premiums, that is the employee and the employer share.

Employees on unpaid leave of absence do not accrue vacation or sick time during the leave. An unpaid leave of absence will be granted for a very specific period of time, generally
not to exceed one month (30 days). Applications for leave extensions must be made in writing
and approved prior to the end of the previously granted leave.

HEC will consider an unpaid leave of absence, in addition to any leave to which the employee may otherwise be entitled under the FMLA or other applicable law, as a possible reasonable accommodation for otherwise qualified employees with a disability.

RETURN TO WORK POLICY – FIT FOR DUTY

It is imperative that HEC be assured each employee is able to safely handle the essential job functions outlined in their job description as well as the ability to safely perform a physical intervention with a student.

If an employee is out of work for two or more consecutive days and/or accidentally injured outside of work and/or under doctor’s care for one or more days due to a non-routine illness, injury or disease he/she may be required to submit to a fitness for duty physical examination before being allowed to return to work. This examination will assure HEC and the employee he/she is able to perform the essential job functions safely. An independent occupational medical provider will perform the fitness for duty evaluation and will be paid for by HEC. It is the assessment of the occupational medical provider that will be the determining factor of the employee’s ability to perform the essential job functions safely.

Failure to submit to a mandated physical examination will result in HEC assuming you have voluntarily resigned your position.

VACATION

Staff hired prior to 8/1//2009 should contact Human Resources if you have questions about your vacation accrual.

Staff Hired Post 8/1/2009 – other than teachers, clinicians and nurses

New hire – 6 months no vacation accrual
6 months – 1 year Accrue 1 week
1st Anniversary Accrue 2 weeks
4th Anniversary Accrue 3 weeks
6th Anniversary Accrue 4 weeks

Staff regularly scheduled 20 hours or more per week receive pro-rated vacation.

Teachers will receive 6 weeks of pre-scheduled vacation time off in accordance with the school calendar.

Clinicians and Nurses will accrue 3 weeks of vacation upon hire but are not allowed to use their time until completing 6 months of employment unless approved by Program Director/Manager. The vacation accrual will increase to 4 weeks on their 6th anniversary as indicated above.

Housatonic Academy Time Off Rules
The Housatonic Academy follows the Pittsfield Public School calendar with some modifications.
HA also has a summer program. Teachers have designated vacation time off per the Housatonic
Academy calendar, and do not accrue vacation or floating holiday hours.

All other staff at Housatonic Academy must use their vacation or floating holiday hours when they take time off. Staff will not accrue enough time off to be paid for all the scheduled vacation at HA, and are expected to either schedule hours at other campuses, or go unpaid, if they do not have enough benefit time to use that payperiod.. It is your responsibility to call the schedulers at the other campuses to book hours for the HA vacations. A list of schedulers and phone numbers is available from Human Resources, 499-7924.

Some Housatonic Academy professional and administrative positions are exempt from this requirement, since their duties continue even when students are not present.

Staff will not be allowed to take vacation time off other than at the HA scheduled vacation times, unless it is an emergency situation. Staff must have pre-approval from the Director, before scheduling vacation other than at HA vacation times.

Staff are expected to report for work when there are snow days. Since our students come from many school districts, not all schools close and we may have students at HA even if Pittsfield Public Schools are closed due to snow.

VACATION CARRYOVER

Staff are allowed to carry one week of vacation into the new Fiscal Year. Hours beyond one week will be forfeited on the date of vacation reduction (i.e., use it or lose it). The date of vacation reduction will vary from year to year depending on the payroll cycle. Staff will be notified in advance of the date of vacation reduction.

VACATION DONATION POLICY

Employees are allowed to donate accrued vacation hours to another staff if the donation is approved by the supervisor. If you choose to donate vacation hours to another staff, you must complete the Vacation Donation Form found on your campus or in Human Resources. Accrued sick time cannot be donated. It is important for staff to understand that the donation is nonrefundable. Completed forms should be returned to the Payroll Manager for processing.

SICK TIME (also see Attendance and Punctuality Standards)

Earned Sick Leave Policy

Accrual of Sick Leave

 All employees of Hillcrest Educational Center, Inc. (the “Company”) are eligible to accrue paid sick leave. Current eligible employees begin to accrue sick leave under this policy on July 1, 2015.  Thereafter, eligible employees begin to accrue sick leave on their first day of work and may begin using accrued leave after they have been employed for 90 days. Sick leave accrues at a rate of 1 hour per 30 hours worked.

Full-time salaried employees are presumed to work 40 hours per week for accrual purposes, unless their job specifies a lower number of hours per week. Employees can accrue a maximum of 40 hours of sick leave per benefit year. For purposes of sick leave, the benefit year begins on July 1 and ends on June 30.  Once an employee has accrued 40 hours of earned sick time during the benefit year, they do not continue to accrue more hours of earned sick time regardless of the additional hours they work. Sick leave is paid at the employee’s current regular pay rate, on the same schedule as regular wages are paid, and does not include commissions, bonuses, overtime, holiday pay, or any other premiums.

No more than 40 hours of earned, unused sick leave may be carried over from one calendar year to the next.  No payment will be made for earned, unused sick leave upon separation from employment.

Interaction with Other Types of Leave

 If any time off covered under this policy is also covered under the Company’s FMLA, Parental Leave, SNLA leave, or other leave of absence policies, sick time shall run concurrently with such leave. Employees may choose, and the Company may also require employees, to use earned sick time to receive pay for absences under other leave policies if those absences would otherwise be unpaid.

 Use of Sick Leave

 An employee may use sick leave to:

1. Care for the employee’s child, spouse, parent, or spouse’s parent who is suffering from a physical or mental illness, injury, or medical condition that requires home care, professional medical diagnosis or care, or preventative medical care;

2. Care for the employee’s own physical or mental illness, injury, or medical condition that requires home care, professional medical diagnosis or care, or preventative medical care;

3. Attend the employee’s routine medical appointment or a routine medical appointment for the employee’s child, spouse, parent, or spouse’s parent;

4. Address the psychological, physical or legal effects of domestic violence; or

5. Travel to and from an appointment, pharmacy, or other location related to the purpose for which the sick leave was taken.

Employees may use earned sick leave in hourly increments.  Any sick leave taken will run concurrently with time off provided under other state and federal laws that allow employees to take leave for the purposes listed above.

Notification of Use of Sick Leave

Employees must give the Company notice of any use of sick leave.

For pre-scheduled or foreseeable absences, employees must give notice seven days in advance.

If the absence is not foreseeable, the employee must provide notice to the supervisor on duty (1) hour before the start of the employee’s shift. If one (1) hours’ notice is not reasonable due to an accident or sudden illness, notice must be provided as soon as practicable.

If an employee is unable to provide notice personally, the employee’s spouse, adult family member, or other responsible representative may provide notice. For multi-day absences from work, employees must notify the Company of the expected duration of the leave or, if unknown, provide notice on a daily basis.

Sick leave will not excuse lateness for work unless used for an allowable purpose listed above.

Documentation and Verification of Use of Sick Leave

 The Company will never request documentation to explain the nature of an illness or the details of any domestic violence for which an employee has taken leave under this provision. If an employee receives such a request from a manager or supervisor, the employee should not respond to the request and should report it to Human Resources.

The Company may, however, require employees to submit written verification that they have used earned sick time for allowable purposes.  Employees will utilize the Employee Verification Regarding Authorized Use of Earned Sick Time Form to document the allowable purpose of their sick time used.  Circumstances for which employees using sick time will be asked by to complete this form include, but are not limited to:

• Immediately before or after a scheduled vacation
• On or immediately before or after an HEC recognized holiday
• When attendance is a documented performance issue
• When an employee has exhausted their sick time balance
• On a date that the employee has put in for time off and it has been denied

When an employee’s use of earned sick time results in an absence of more than 24 consecutive work hours (or three consecutive work days), the Company may also require a written certification from the employee’s health care provider that he or she used sick time for an allowable purpose.  In addition, the Company may require certification from a health care provider for sick leave taken within two weeks of an employee’s scheduled termination date or after four unforeseeable and undocumented absences within a three-month period.

If an employee is absent for more than 24 consecutive work hours for reasons related to domestic violence, the Company may request documentation concerning the need for earned sick time. In such cases, the employee may provide:

• A restraining order issued by a court;
• A police record documenting the abuse;
• Documentation that the perpetrator of the abuse has been convicted of assault, battery, rape or another “crime against the person” under Massachusetts law, where the victim was a family or household member;
• Medical documentation of the abuse;
• A statement provided by a counselor, social worker, health worker, member of the clergy, shelter worker, legal advocate or other professional who has assisted the employee in addressing the effects of the abuse; or
• A signed written statement from the individual attesting to the abuse.

The Company will not disclose any evidence of domestic violence without the consent of the employee.

If the Company requires certification or documentation concerning the use of earned sick leave, the employee must provide it within seven days of the sick leave for which such certification or documentation is required. If the employee fails to do so, without reasonable justification, the Company may recoup the amount paid for earned sick leave from the employee’s future pay. The Company may also delay or deny the future use of an equivalent amount of earned sick time until such certification or documentation is provided.

Misuse of Sick Leave

Any employee who misuses earned sick leave by taking it for a purpose that is not consistent with the allowable purposes listed above will be subject to discipline up to and including termination. The Company will not base any adverse employment action, including denying use or delaying payment of earned sick leave, on an employee’s lawful use of sick leave.

HOLIDAYS

All full time employees who receive benefits are entitled to 4 HEC recognized holidays annually:

New Year’s Day
Independence Day
Thanksgiving Day
Christmas Day

Non-exempt staff that work on the holiday will be paid time and a half for the hours worked, and will also be paid holiday pay (max of 8 hours – prorated for part time staff)

Benefited Staff who do not work the holiday will receive holiday pay for the HEC recognized holiday.

If a holiday falls during an employee’s vacation, that employee will not be charged a vacation day, but will instead receive holiday pay.

FLOATING HOLIDAYS

Full time staff with benefits will earn 40 hours of floating holiday time annually. 8-hours will be placed in the Floating Holiday bank on July 1st and 32-hours will accrue throughout the remainder of the fiscal year. . (FH hours are pro rated for part time staff with benefits.)

1. Floating holiday hours will accrue in a FH Bank.

2. The FH bank will be capped at 48 hours; there will be no accruals until the bank is reduced by staff use of the hours. (pro-rated for part time staff)

3. Staff may carryover FH hours from one fiscal year to the next.

4. Staff may use FH time in hour increments if approved by their supervisor.

5. Teachers will not accrue FH hours because the school schedule allows for teacher paid time off during other traditional holidays. They are able to use the one 8-hour floating holiday at their discretion with supervisor approval.

6. Floating holidays has no cash value at time of termination, and will not paid out.

PERSONAL TIME

Employees, on July 1 annually, will receive a 16 hour deposit of personal time;   Reasons for personal time include those described in the “Small Necessities Act” and also include time off to attend to business or their personal matters that can only be attended to during an employee’s shift.  Personal days are not intended to be used as additional vacation days.

Employees are expected to give 3 days notice when requesting personal time off since the intent is for time to be used for planned events.  In case of emergency, requests with less than 3 days notice may be granted and will be reviewed on a case-by-case basis.

LONG TERM ILLNESS BANK

This account can be used to cover time off from work that results from a qualified FMLA or, Worker’s Compensation leave, or due to disability event. (These events are described individually in other sections in this manual.)

At the end of each Fiscal Year the sick bank will be reduced to a maximum of 2 weeks. Sick hours over two weeks will be rolled into the Long Term Illness Bank. This bank has no cash value at time of termination, and will not be paid out.

The maximum number of hours in the LTI Bank will be 480.

BEREAVEMENT

Staff who receive benefits will be granted bereavement leave for up to 5 paid, scheduled working days (maximum of 40 hours) within seven consecutive days following the death of a husband, wife, mother, father, stepfather, stepmother, son, daughter, or significant other, at the discretion of the Program Director or Department Head. (Pro-rated for part time staff)

Staff who receive benefits will be granted paid bereavement leave for up to 3 working days (maximum of 24 hours) within seven consecutive days following the death of a brother, sister, grandfather, grandmother, mother-in-law, father-in -law, son-in-law, sister-in-law, brother-in- law, or any relative living in the same household, at the discretion of the Program Director or Department Head.

Documentation may be required to access this benefit.

JURY DUTY

Full and part time benefited employees who are called to jury duty must provide HEC with appropriate paperwork. HEC will pay the employee for regularly scheduled work hours that were spent at jury duty for up to three (3) days. If the employee remains on jury duty beyond 3 days, HEC will supplement the employee’s pay by the difference between their regular pay and the
pay they are receiving from the court system.

Night Shift Employees:
If you are called for jury duty and you work the night shift, you do not have to work the night
prior to jury duty, or any nights that you are scheduled during your active jury duty. Your supervisor must enter that you are on jury duty in e-time, and you will need to submit the proper documentation to payroll. If you serve on jury duty and it ends before 4 p.m., you are required to report to work for your scheduled shift that night. However, every attempt will be made to allow you to use personal or vacation time if you prefer not to work the night jury duty ends. You

should give your supervisor or campus designee as much advance notice as possible if you do not want to work that shift so they can find a replacement for you.

SNOW DAYS

As HEC is never closed due to bad weather conditions, all employees are expected to work their scheduled hours. If, due to weather conditions, an employee expects to be late for work or does not believe that it will be possible to get to work, s/he has the responsibility of notifying his/her supervisor, in advance of being late or absent. Any work time missed due to weather conditions will either be rescheduled by the employee with the supervisor’s approval during the same work

week, or be taken as personal or vacation leave.

STAFF TRAINING & DEVELOPMENT

Hillcrest Educational Centers’ Workforce Learning Department provides a learning and development process that promotes quality of programs, student and family successes, and professional and personal growth of staff. The training delivered meets or exceeds federal, state and agency compliance requirements, as well as accreditation standards.

New Staff Orientation:
All staff are required to attend and successfully complete New Staff Orientation prior to assuming their respective duties and responsibilities of their position at Hillcrest Educational Centers. New Staff Orientation is intended to welcome the employee and provide them with an introduction to the organization and the services it provides, as well as comply with the training and development requirements of federal and state regulatory agencies and accreditation bodies. New Staff Orientation is comprised of four main components including Federal, State and Agency Compliance Training, Skills for Life and Crisis Prevention/Intervention Training, and First Aid, CPR, and AED Certification.

Following New Staff Orientation, all staff participate in an on site orientation program on the campus/site to which they are assigned. The purpose of on site orientation is to acquaint the new staff with the physical setting of the site, introduce them to key on site personnel, review safety procedures specific to the site, provide a description of the programs and services, discuss the population served, review the routines and schedules of the site, deliver additional compliance training topics, and cover the specific duties and responsibilities of the new staff’s respective jobs.

On Going Compliance Training:
All direct care staff are required to participate in at least 24 hours of training each year. On going mandatory training includes all federal, state and agency compliance topics, as well as accreditation required topics. The frequency and length of time for on going
mandatory training is based on regulation or standard. Specific job duties and responsibilities require additional on going mandatory training in areas identified by regulation or standards.

HEC staff that does not fulfill in-service training requirements may be subject to disciplinary action up to and including termination.

LEARNING MANAGEMENT SYSTEM TRAINING

Hillcrest Educational Centers provides learning activities to support employee development to meet the needs of individuals served, to enhance professional skills and assist in career development goals.

As part of our commitment to staff learning and development, we provide online courses within a learning management system (LMS). Employees are given access to online courses via a secure user name and password.

Mandatory Training and Education
Hillcrest Educational Centers requires mandatory training for all employees that meet or exceed
licensing regulations and accreditation standards. Mandatory training and other agency requirements are listed with specific due dates on the employee’s training plan. Employees access their training plan within the learning management system.

All mandatory training is expected to be completed on or before the “required by” date. Non-exempt (generally hourly) employees will be paid their regular rates for completion of online learning. Residential staff are expected to complete their online learning within their short week. Opportunities will be made available for night staff to complete their on line training during the shift. Non-exempt staff must have supervisory pre-approval to complete online learning that will generate overtime pay. Exempt employees may complete the training outside their regular scheduled hours, at their discretion, but will not receive any additional compensation or time off.

Timely completion of training will be part of an employee’s performance evaluation. Employees will not be eligible for raises, promotions or other compensation until all required training is completed. Completion of required training does not guarantee raises, promotion or other compensation or in any way alters the “at will” status of employment.

Recommended Training and Education
A supervisor may recommend specific online courses as a performance improvement activity or
as part of an employee’s professional development or the employee may request permission to take specific courses. Time spent on online courses that are taken with supervisory pre-approval will be compensated as described in the Mandatory Training and Education section of this
policy.

Elective Training and Education
The learning management system provides a library of professional online courses on a variety of behavioral health and human service topics. Employees may, at their own discretion, take online courses for professional development or personal interest at no cost. Employees choosing to take online courses at their own discretion, as electives, must do so on their own time and will not be compensated for their time.

LEARNING MANAGEMENT SYSTEM USE POLICY

HEC employs the use of a Learning Management System to perform workforce learning functions including, but not limited to, scheduling of in-person and on-line coursework, delivery of on-line coursework and reporting of compliance with state, federal, agency, and accreditation required training.

Prior to accessing the Learning Management System all staff are required read, sign and agree to abide by the Hillcrest Education Centers Learning Management System Use Policy.
Employees must agree to the following:
• I am responsible for any actions that are conducted using my Hillcrest Educational
Centers Learning Management System account.
• I will not allow anyone else, including but not limited to, family members, friends,
classmates, and/or colleagues, to use my account, or take the course tests on my behalf.
• I also agree that I will abide by the following guidelines:
• Never disclose my user name or password.
• Never use another person’s user name or password.
• Always sign off the system when finished and will never leave a terminal unattended while I am logged onto the learning management system.
• Never allow anyone who does not have an authorized user name and password to access any of the on line courses. Material may be copyrighted, and therefore it may be illegal to
copy or use the material outside of our organization.

Enforcement
Acts, or the condoning of acts, which achieve or attempt to achieve the unauthorized use of
Hillcrest Educational Centers Leaning Management System resources, or the unauthorized use or copying of data is prohibited. Examples of unauthorized use or copying include but are not limited to, attempts to alter systems, attempts to circumvent systems protection features, attempts to alter or destroy course and test data, attempts of unauthorized access or copying of course and test data or software, attempts to release data or software that has not been previously authorized.

Failure to abide by the Hillcrest Educational Centers Learning Management System Use Policy will result in discipline up to and including termination of employment.

EVALUATION POLICY

New staff are evaluated after completion of the introductory period, and annually thereafter.

Human Resources will notify Program Directors monthly of evaluations that are due.
Supervisors must access the training database to determine if staff has met training requirements.
The training record must be attached to the evaluation and returned to the Human Resources
Department for tracking and filing.

 

MANDATORY MEETINGS

Employees are paid for attending mandatory meetings.

BENEFITS

Eligibility:
Employees who are regularly scheduled to work 30 or more hours per week (on a continuous
basis) are eligible for HEC benefit plans. Insurance costs, if any, are pro-rated for these part time staff.

New hires are eligible for our benefit plans on their 91st day of employment. In addition, HEC offers an annual open enrollment period, which eligible employees can enroll onto the insurance plans offered by HEC. Eligibility to enroll at other times due to qualifying events, is possible.

Insurances:
HEC offers, and contributes to, a portion of the premiums for health and dental insurance.

HEC offers and pays 100% of the cost of group life insurance, accidental death and dismemberment insurance, and long-term disability insurance.

The Consolidated Omnibus Reconciliation Act (COBRA):
COBRA provides for the continuation of health and dental insurances when an employee
would otherwise lose existing health/dental coverage due to an employment separation or other qualifying reason. COBRA benefits are administered through a third party administrator.

Supplemental Insurances:
HEC offers supplemental life insurance, guarantee issue, up to $200,000, accidental death and
dismemberment, and short-term disability, available at the employee’s cost.

Retirement 403(b)
HEC offers a retirement plan to help employees save for their retirement. Employees are able to
join and make contributions upon hire. HEC may make a discretionary contribution.

For more information regarding your benefits, please contact Human Resources or refer to the
Benefit Guide located in the Human Resources Folder on HECNet.

WORKERS’ COMPENSATION

HEC provides workers’ compensation insurance for all employees. WC covers employees who have sustained an injury in the course of their employment.

Employees are required to file an ART form with their supervisor and the WC Administrator within 24 hours of the occurrence of any injury or physical assault sustained on the job (in addition to the appropriate student incident report paperwork). Failure to do so may result in a negative outcome to an employee’s claim and may result in disciplinary action.

Injured employees must report to the nurses’ station for evaluation and, if necessary, referral from the Worker’s Compensation Administrator to an outside medical provider.

Full time staff who have completed their probationary period will be compensated by HEC at the rate of 60% of their hourly rate for normally scheduled work hours that would have occurred in the first five calendar days of lost time, one time per year, due to injuries on the job. Otherwise employees may use benefit time starting with Long Term Illness, then Sick, then Vacation hours, to supplement the above payment, but cannot exceed 40 total hours in a week. HEC will pay a maximum of 5 days for lost time from multiple incidents, in a 12-month period.

The physician who treated the employee for the injury and HEC’s occupational health provider must clear all employees, by providing a fitness for duty note, to return to work, who have been absent from work due to an injury.

When an employee is receiving Workers’ Compensation benefits and is eligible for FMLA, HEC
will hold the position for the duration of FMLA, subject to applicable requirements of that law.

If the employee is eligible for modified duty, HEC will support modified duty up to 45 days per a rolling 12 month period (either single occurrence, or the sum of days from more than one modified duty situation). Modified duty is not guaranteed and will depend on availability of modified duty work. Slight modifications of the 45-day maximum will be considered if supported by medical documentation and does not otherwise pose an undue financial or operational hardship to HEC.

Employees will not be paid for overtime when they are in the Emergency Room or doctor’s appointment if hours exceed their regular shift.

If You are Out on Worker’s Compensation:

If you are receiving workers’ compensation benefits from the insurance company and are no longer receiving a check from HEC, you are responsible for paying your share of your medical insurance premium, if you are also on approved FMLA leave.

Employees receiving workers’ compensation benefits who are not receiving a check from HEC, do not earn sick or vacation time. They will be responsible for medical and dental insurance premiums per the rules of FMLA and COBRA.

If you are not eligible for FMLA or you are unable to return from FMLA, you will be offered health insurance at 100% cost (plus administrative fees) through the COBRA option.

If You are Eligible For and Have Been Offered Modified Duty:
HEC will make every effort to accommodate employees who have sustained an injury while in the scope of their duties for a total of forty-five (45) calendar days per calendar year. (see General Policy, #7).

Any aggravation of pre-existing injuries will also be capped at forty-five (45) calendar days per calendar year. While on light duty, their weekly hours will not exceed forty (40). This 40 hours includes any benefit time the employee may have used that week such as holiday or vacation pay.

Any employee who is working in a restricted capacity will accrue sick and vacation leave at their normal rate and will continue to pay their regular % of insurance premiums(s).

At the discretion of the Worker’s Compensation Administrator and Program Director, overtime may not be available for thirty (30) days from the release of the employee to full duties. While we will make every effort to find modified duty work for staff who are injured, we cannot promise that we can accommodate all modified duty requests.

If you choose not to work modified duty, you must use your LTI, then sick, then vacation hours
– worker’s compensation will not pay your benefits.

EDUCATIONAL SUPPORT (Tuition Assistance Program)

All full and part time staff with benefits are eligible to apply for tuition assistance after one year of employment with HEC. Teachers may apply for assistance during their first year of employment. Teachers are limited to 12 credits each year, and all other staff are limited to 3 credits per semester. Educational Support policy, reimbursement procedures, maximum amount of reimbursement, application and sign off forms are available in Human Resources.

Staff are expected to commit to staying at HEC one year beyond the date of completion of the course, or they will be responsible for repaying HEC the amount reimbursed. Staff who resign or move to on-call status before the end of one year will be expected to reimburse HEC for the tuition or have it deducted from their paycheck as agreed upon at the time the application for tuition reimbursement was completed. This expectation does not, however, alter the at-will nature of employment at HEC.

DIRECT DEPOSIT

HEC offers a direct deposit plan for its employees. This plan allows employees to deposit their paychecks directly into the bank account(s), which they designate. Occasionally, due to technical problems or after a Monday holiday, money will not be deposited directly into your bank accounts until Wednesday (remember that HEC’s payday is Tuesday). HEC offers direct deposit as a service to you and will not be held responsible for penalties as a result of a late deposit into your account.

EMPLOYEE ASSISTANCE PROGRAM (EAP)
HEC provides employees with free, confidential, personal counseling through an Employee
Assistance Program. Employees are introduced to this plan at New Staff Orientation, and EAP representatives visit each campus and can meet with staff on, or off, campus if necessary. Participation in this program is voluntary and confidential.

CREDIT UNION
All employees of HEC are eligible to participate in the Greylock Credit Union in Pittsfield, MA. Information may be obtained by calling (413) 443-5114.

WELLNESS PROGRAM

Wellness is a critical component of our overall commitment to employee health and well-being. With this in mind we have developed and implemented a comprehensive wellness program focusing on a variety of wellness initiatives. These initiatives may include health risk assessments, wellness expos, and a variety of employee-sponsored clubs such as biking, hiking, kayaking, yoga and more.

Our mission is to increase the knowledge, activity level, and commitment to foster a culture of personal health and well being in the Hillcrest Community.

PAYDAY

The regular payday for employees of HEC is every other Tuesday. Employees are paid for the time worked (and benefit time used) during the 14-day period ending the Tuesday before payday.

TIME WORKED

Each employee is responsible for accurately reporting and recording the hours that they work on a daily basis. Any falsification or misrepresentation of hours worked will result in disciplinary action up to and including termination.

DAYLIGHT SAVINGS TIME

When Daylight Savings Time begins in the spring, staff working the overnight shift on that night will work one less hour and be paid for one less hour.

In the fall, when Daylight Savings Time ends, staff working the overnight shift on that night will work one extra hour and be paid for one extra hour. If the total hours worked including the extra hour worked is more than 40, time over 40 hours is at time and a half for non-exempt staff.

PAY INCREASES

On an annual basis, the Board of Directors determines a pay raise, if any, for each position at HEC, based on the financial status of the organization and the rate adjustment given to HEC by the Commonwealth of Massachusetts.

PROFESSIONAL DIRECT CARE RATE

The professional YDP rate is paid to exempt staff when they are mandated to work as direct care staff to maintain ratio, or if they are mandated to work because of agency or campus wide
staffing shortages. Professional staff may also sign up to work as direct care staff on a voluntary basis. The professional childcare rate is reviewed annually. For information on the current rate
for professional staff, please contact Human Resources.

If exempt staff use sick, vacation, or holiday time during their regular week, they will receive their regular rate of pay for direct care work done in the same pay period up to a total of
40 work hours. Over 40 work hours will be at the professional rate.

DIFFERENTIALS

Direct Care Staff who work other than Monday – Friday day schedules are eligible for differential pay.

Academic Day Shift No Differential
Residential Shift
Overnight Shift 3:00 p.m. to 11:00 p.m.
11:00 p.m. to 9:00 a.m. .75/hour
.50/hour
Weekend Shift Starts at 3:00 p.m. Friday
Ends at 9:00 a.m. Monday $1.00/hour

Differentials may be combined so that staff working the weekend on Residential or Night shift will receive the Weekend Differential and the Differential for either Night or Residential.

OVERTIME

General Guidelines:
A non-exempt employee shall be compensated at the rate of one-and-one half times his/her regular rate of pay for overtime work performed in excess of forty hours per week. An employee’s failure to do so, or an employee working without proper authorization, will result in discipline, up to and including termination of employment.

No overtime will be authorized for new full time employees until they have completed three full weeks of work.

Employees may not exceed 20 hours of direct care overtime work during a regular workweek, unless the campus Program Director or APD has given prior approval.

Voluntary overtime will be allotted on a first come first serve basis, after on-call and non- overtime staff have been used, with the following considerations: The balance and effectiveness of staffing; fair distribution of hours to all of those in need of extra time; seniority.
When possible, a sign-up sheet shall be posted to accommodate those seeking overtime hours. These guidelines shall be followed unless changes are approved by staff at the APD level or
higher.

Mandatory overtime due to shift staffing shortage:

At various times throughout the year, overtime may be mandated due to a shift staffing shortage. In the event a staff must be mandated to stay, the following guidelines apply:

1. Overtime may be mandated for the following positions: Youth Development Professionals
(YDP’s), Assistant Supervisors, and Supervisors.

• Residential staff – will not be mandated on Saturday or Sunday nights due to having worked a 14-hour day. They may volunteer to work a weekend overnight with

administrator approval. If there is no other option the administrator will come in and cover the weekend overnight shifts.

• Overnight staff – may be mandated on school days, but should be released as teachers, clinicians and administrators arrive. Overnight shift may be mandated on weekend mornings, but every effort should be made to release them by noon, even if the administrator must come in and cover.

• Day staff – is always eligible to be mandated for the subsequent residential shift.

• On-Call and overtime staff – are not subject to the mandate procedure.

A “rolling list” with all employees’ names (in the above categories) based on seniority will be created to determine the order in which employees will be mandated. The least senior employee will be at the top of the list. Once mandated, the employee’s name will go to the bottom of the list.

When possible, those staff at the top of the mandate list will be given at least 24 hours’ notice that they are now at the top of the list and expected to work the next mandated shift.

It is the employee’s responsibility to be present for any and all assigned overtime shifts. Failure to do so will be viewed the same as failing to show for a regular shift and will result in disciplinary action up to an including termination.

Mandatory overtime due to campus-wide staffing shortage:

In some circumstances when the mandated policy above is not sufficient to cover our staffing needs, or when a crisis situation is presented, the following guidelines apply:
In addition to the “rolling list” above, all employees will be asked to volunteer to work overtime. If the number of volunteers stepping forward is insufficient, all other positions on the campus
may be mandated to work overtime. The methodology for scheduling and assignments will be
determined by the Program Director/Manager.

Staff required to work the mandated overtime will be notified as soon as possible.

As stated above, it is the employee’s responsibility to be present for any and all assigned overtime shifts. Failure to do so will be viewed the same as failing to show for a regular shift and will result in disciplinary action up to an including termination.

BREAKS

If operationally acceptable, employees are allowed to take breaks during their workday. HEC
follows Federal and Massachusetts labor law regarding meal breaks.

MEALS

All HEC employees who are campus based are allowed to eat meals that are served during their normal work schedule. Day staff are allowed to have lunch, residential staff are allowed to have dinner, and overnight staff are allowed to have a meal during their shift. Staff who work the long shift on the weekend are allowed to have two meals.

BENEFIT DATE

The employee’s benefit date (used for benefit calculation) is defined as the anniversary of his/her date of hire. An employee’s benefit date will change if an employee changes status from full to part-time, or vice versa. All benefits except retirement are based on this date. If an employee leaves HEC but returns within 1 year, the benefit date will be adjusted (see Adjusted Service Date).

The Human Resources Department (HR) fills all staff positions and candidates will be chosen on the basis of education, experience and ability to perform the essential functions of the position. HEC shows no preference regarding the employment of relatives of its staff or Board of Directors. A sincere effort is made to be impartial and select candidates with the best qualifications.

REASONABLE ACCOMMODATION

HEC is committed to providing equal access to employment opportunities for otherwise qualified individuals with a handicap or disability. Hillcrest Educational Centers vigorously supports the federal Americans with Disabilities Act and related state laws, and is committed to hiring and offering reasonable accommodations to its applicants and. If you feel that you need assistance in performing any of the essential functions of your job or would like to discuss a workplace accommodation please contact your supervisor, or a member of the Human Resources Department.

Human Resources and supervisory staff use job descriptions and existing personnel policies to define criteria for all hiring, and to set performance expectations. These practices are applied without discrimination and in accordance with applicable state and federal regulations.

HIV AND RELATED MEDICAL CONDITIONS

Pursuant to applicable state law, HEC does not discriminate against employees, applicants or students solely because they are infected with HIV or affected by any of the medical conditions associated with HIV infection.

HEC will not require serology testing or any type of information concerning HIV status from employees or prospective employees as a condition of employment.

PREPLACEMENT PHYSICAL, TUBERCULOSIS SCREEN, FUNCTIONAL CAPACITY EVALUATION

All successful candidates, after receiving a conditional offer of employment, will undergo a pre- employment physical, fully paid for by HEC, which will determine if the candidate is able to perform the essential functions of the position for which they are being offered, with or without reasonable accommodation. During this medical exam a tuberculosis test will be administered and the employee will return 48-72 hours later to have the test read. The employee will also be offered the opportunity to receive the Heptivax Vaccine, which is a series of three shots that will provide immunization against Hepatitis B. The follow up for the remaining two shots will be scheduled during the initial visit. All employees are eligible to receive the Heptivax Vaccine at a later date, even if they refuse the initial offer of the vaccine. Candidates must successfully complete the physical and tuberculosis screening to be eligible for employment.

BACKGROUND RECORD CHECKS

To ensure the safety and security of our students and staff at HEC, as a condition of employment with our agency, all employees, interns and volunteers (current and prospective) are subject to an intensive background record check (BRC). This check includes all criminal history (CORI – Criminal Offender Record Information) verified through the Criminal History Systems Board
and any substantiated/supported reports related to abuse or neglect documented through the Department of Children & Families (DCF). In addition to CORI and DCF, we also conduct a national criminal check, sexual offender check, and social security verification.

This policy also follows the regulations of the Department of Early Education and Care (DEEC) who is the licensing agency for Hillcrest. The DEEC regulations state that HEC is prohibited from confirming an offer of employment until the satisfactory completion of both a CORI and a DCF Background Record Check of the candidate. Further, the regulations prohibit a candidate from commencing employment beyond new staff orientation until after the candidate is cleared as a result of the CORI check. Staff may not have unsupervised contact with students until they are DCF cleared.

Policy
It is the policy of HEC, to ensure that all candidates for employment are subject to a background
record check (BRC) prior to confirming an offer of employment. In addition, all current employees of HEC will also undergo a background record check at a time period not to exceed three (3) years or at any time HEC determines appropriate due to information surfacing regarding an employee’s circumstance.

Confidentiality/Privacy
HEC respects the sensitive and confidential nature of this information and has implemented several safeguards to ensure the integrity of the process.
All “adverse findings” related to a completed BRC are stored in a confidential locked file in
Human Resources.

Only certain HEC employees, known as “Reviewers with Hiring Authority” or “Reviewers with
Access”, that have been cleared through DEEC will have access to this information.

Only general information related to the BRC process such as the BRC Consent Form, Government Issued Photo ID, and the BRC submittal form, will be stored in the employee’s personnel file.

Process (external candidates):
At time a conditional offer of employment is extended, successful candidates will complete and
sign the BRC Consent Form and provide a Government Issued Photo ID.

It is the expectation of HEC, that all BRC results will be received prior to being scheduled for New Staff Orientation. However, due to the time constraints of the record checking process, combined with the needs of the agency, exceptions may be made by allowing a new employee to participate in New Staff Orientation before all results (CORI/DCF) are received.

If, at the conclusion of New Staff Orientation, a new employee has not been “CORI-cleared” (meaning that either there has been a finding of “no record” or HEC has not granted discretionary approval review of the findings) the employee will not be able to continue their employment with HEC and the conditional offer will be rescinded.

If, at the conclusion of New Staff Orientation, a new employee has been “CORI-cleared” (defined above) but HEC has not received the results of the DCF record check, at the discretion
of HEC, the new employee may be able to begin at the campus and may be counted in ratios but
they may not have any unsupervised contact with children. This condition must be documented in writing by H.E.C., addressed to the employee and placed in their BRC file and will only be utilized as an interim measure with limited duration.

If the candidate’s CORI information reveals an outstanding warrant for a disqualifying offense, or DCF information indicates that there is an open 51B investigation, then the candidate must be notified that they are not eligible for a position with HEC

In the event adverse findings are received regarding the CORI or DCF component of the BRC, then a Discretionary Review must take place (see below). This may include an open case if the charges fall into the “Discretionary Qualification” category (CORI – Table B).

When communicating to the administration and staff that an employee is not to have unmonitored supervision of children, it must be emphasized that this no way implies that an employee has any adverse Background Record Check information.

Process (current employees):
All current employees of HEC will undergo background record checks at a time period not to
exceed every three (3) years or at any time HEC determines appropriate due to information surfacing regarding an employee’s circumstance.

All employees will need to complete and sign the BRC Consent Form and provide a Government
Issued Photo ID each time a BRC is to be conducted.

If the employee’s CORI information reveals an outstanding warrant for any offense, or DCF information indicates that there is an open 51B investigation, then the employee may be suspended from HEC in accordance with the Arrest/Criminal Charges Policy.

In the event that adverse findings are received regarding the CORI or DCF component of the
BRC, then a Discretionary Review must take place (see below).

Periodic BRC’s will be conducted for the Licensee and Reviewers at the time of each license renewal.

Discretionary Review:
Adverse findings are defined as those findings (other than “no record” or “no findings”) that
appear on a CORI/DCF record check. HEC reserves the right to review those findings and make a determination of whether or not the agency feels that the employee/candidate poses a risk to students. This is known as a discretionary review.

Any DCF information that shows that a candidate has been named in a supported 51B report as the person responsible for the abuse or neglect of a child will result in a “Discretionary Disqualification” of the candidate. In these cases the employee will be contacted and HEC will request approval to proceed with requesting the detailed findings. In the event the employee fails to grant approval, the employee will be considered to have resigned from their position and the resignation will be accepted immediately.

Upon receipt of the DCF 51B report, HEC will review the findings and make a determination of continuing employment or terminating employment if there is a concern of risk to our students. HEC will document its decision outlining the rationale for either terminating the employee or granting a discretionary approval to maintain employment and place this documentation in the employees BRC file. H.E.C will notify DEEC of the decisions made regarding the Discretionary Review (as outlined on results page of the BRC received from DEEC).

Criminal Charges/Arrests:
• All staff are required to report any arrests or charges of criminal offense (need to
clarify) to the Program Director or designee and the Human Resources Department, prior to the start of the next scheduled shift.
• All documentation of the charges must be submitted to Human Resources. Depending on the charges filed the following may occur:
• Staff who are arrested/charged with an offense that would be a disqualifying offense under
CORI hiring guidelines will be placed on leave without pay for up to 15 days.
• Staff who are arrested/charged with an offense that would not be a disqualifying offense under CORI hiring guidelines may be placed on leave without pay for up to 15 days.

DCF Investigation:
All staff are required to report to the Program Director or designee and the Human Resources Department if they have been named in a 51A or 51B or if they are involved in any activity that may be considered an investigation by DCF.

Human Resources will meet with the employee to gather data regarding the nature of DCF investigation. Depending upon the nature of the DCF investigation, HEC will make a determination regarding the continuation or termination of employment. In some instances the employee may be suspended pending this investigation (see above Criminal Charges/Arrests).

Failure to report arrests, charges, or DCF investigations per this policy will be subject to disciplinary action up to and including termination.

Process:
If an employee is suspended, a suspension letter will be given to the employee indicating the
dates of suspension and impact on the employee’s benefits.

Once a complaint has been resolved, employee must bring official documentation to Human
Resources stating resolution and a decision will be made on reinstatement.

Factors considered will include the nature of the allegation and any conditions of continuance, the entire CORI record of the employee, length of employment, and employment history. Based upon the needs of the agency, a decision regarding filling the position will be made.

Eligible employees will be reinstated to the same position if possible, or to a similar position if original position has been filled.

Prior to returning to full unrestricted employment, a new BRC will be conducted.

Benefit and Paid Time Implications:
Employees who are suspended due to criminal charges, an arrest, or a DCF investigation may use vacation and/or personal time, within the guidelines of usage in Personnel Policies (example: maximum annual for personal time is 24 hours). If employees do not have enough benefit time to cover the time off, the time will be without pay. (Long Term Illness and sick time are not available to use during this time off.)

Record Retention:
As mentioned above, only the BRC Consent Form, Government Issued Photo ID, and the BRC
submittal form, will be stored in the employee’s personnel file. All other information including but not limited to adverse finding results, 51B’s, and discretionary review determinations will be stored in the separate locked BRC cabinet. This documentation will be retained for no more than
3 years or until a new BRC is conducted, whichever comes first. At the end of this period, all
prior documents, with the exception of the rationale for hire, will be destroyed.

BRC documentation for those candidates not employed for reasons not related to a BRC check will be destroyed at the time of decision. BRC documentation related to a candidate that is not hired, or is terminated for reasons related to the BRC will be retained for the same duration as is typical with the maintenance of personnel records.

LETTER OF EMPLOYMENT

Each new employee at Hillcrest Educational Centers will receive a letter of employment.
This letter will contain the name of your immediate supervisor, your initial work schedule, your
starting pay, as well as other information important for you to know.

INTRODUCTORY PERIOD

The first 90 days of your employment or starting of a new position with Hillcrest Educational Centers is known as the introductory period. It is the period that gives new employees an opportunity to discover whether they enjoy working with HEC, on a specific campus, or student population, and want to continue. It also gives your supervisor an opportunity to evaluate your interest in your job and your ability to carry out its requirements. During this introductory period, employees will undergo evaluation by their supervisor and will have a number of opportunities to discuss their progress with supervisory personnel.

At the end of this period, their supervisor will recommend to their Program Director or
Department Head, one of three options:
• Classification as regular employee
• Extension of introductory period (not to exceed six months in total)
• Termination of employment

Upon review, the Program Director or Department Head will implement one of the above options. A new employee who is in their introductory period will not be allowed to utilize any accrued leave or benefit time until the employee has attained classification as regular employee. An employee whose introductory period has been extended may use benefit time if approved in accordance with our time off policy.

During the introductory period, employees are not permitted to apply for open positions within the agency. Any employee who accepts a new position in the agency will be subject to a new three-month introductory period.

Successful completion of the Introductory Period does not alter an employee’s status as an at-
will employee, nor is an employee guaranteed employment throughout an Introductory Period, as
all employment at HEC is considered employment-at-will.

INTERNAL JOB POSTING AND TRANSFER PROGRAM

In an effort to encourage personal and professional growth within the agency, HEC utilizes a job- posting program. Each week POST TIME, an updated list of all open positions throughout HEC, is distributed to all programs. Typically, existing employees have seven (7) days to apply for a newly posted position. After that time, the position will be “closed” but will remain on POST TIME until it has been filled. Employees who are currently in their Introductory Period (see Introductory Period) are ineligible to apply for an open position. Any employee with current or unresolved disciplinary action may be ineligible to apply for an open position.

Staff who are interested in being considered for an open position (either a promotion or lateral transfer) should complete the Internal Job Application Form, available at all HEC locations, on HECnet, or through the Human Resources Department. The completed application form should be returned to the Employment Manager in the Human Resources Department, where it will be reviewed and forwarded to the appropriate manager. While every attempt will be made to accommodate an internal move, this cannot be guaranteed.

While HEC employees are given consideration for any available position, it may also be necessary to advertise externally and to hire external candidates. This decision is made at the sole discretion of HEC, based upon the particulars of the available position and the needs of the agency. As with all aspects of employment, HEC is an equal opportunity employer with regard to hiring and

All of us at Hillcrest Educational Centers, Inc. (HEC) extend a sincere welcome to you and are very pleased to have you with us.

This manual has been prepared to serve as a general guide to help you understand important agency and personnel policies and practices in our daily operation. Included is an outline of your employment benefits. We ask that you become familiar with its contents since a basic understanding of these policies is essential to a successful work performance as well as the success of our combined efforts.

Our goal is to provide the highest standard of care for those entrusted to us. The efforts of the staff toward this goal are indispensable.

The person primarily responsible for your work, activities and progress is your immediate supervisor. Feel free to discuss with your supervisor any problem, which may be affecting your work. A good relationship is important to you and the facility, and all of us stand to gain from discussion in the spirit of cooperation.

We value your ideas, suggestions and comments on any matter pertaining to your employment. We hope that your association with Hillcrest Educational Centers, Inc. will be rewarding.

Gerard E. Burke
President/CEO

ABOUT THIS MANUAL

We feel it is important that all employees understand our philosophies, policies and procedures. This manual will familiarize you with the various aspects of working with us at HEC and provide a general overview of useful information. We encourage you to use it as a reference document. Nothing herein should be interpreted as interfering with the rights of employees under the National Labor Relations Act or any other applicable laws.

It is also important to understand that this manual and any of the policies, benefits, procedures and practices contained herein may be changed, amended, modified or terminated by Hillcrest Educational Centers at any time, with or with out notice. All employee benefits discussed herein are subject to the specific terms, provisions and requirements set forth in applicable plan documents, which are available for your review. Hillcrest Educational Centers also reserves the right to decide whether, and to what extent, a policy or practice applies to any particular situation, and to interpret the manual provisions. This personnel policy manual supersedes any and all past editions.

Hillcrest reserves the right to alter, change or modify this manual at any time.

EMPLOYMENT AT-WILL

Your employment with Hillcrest Educational Centers is a voluntary at-will relationship, and nothing in this manual constitutes an expressed or implied contract of any kind, including but not limited to a contract of employment, nor shall be construed as providing you with any expressed or implied promises to you whatsoever. You have the right to terminate your employment relationship at will for any reason you wish, at any time, with or without notice. Hillcrest Educational Centers has the same right to terminate your employment at any time and for any reason, with or without notice.

MISSION STATEMENT:

Our mission at Hillcrest Educational Centers is to facilitate the social, emotional, intellectual, and physical growth of our students through the development of new skills that will enable them to succeed in their home community.

OUR GUIDING PRINCIPALS:

• Every student has the potential to succeed in life.

• Every member of the Hillcrest community (students, families, and employees) is entitled to unconditional respect.

• Every student is entitled to individualized treatment and education.

• Students need our services because they have lacked the skills, resources, or support required to cope with their environments.

• Families are an integral part of our students’ success.

• We are committed to assuring that our students reach their full academic potential.

• We are committed to continuous improvement and learning.

• We are committed to fiscal responsibility.

• We are committed to teamwork.

• We are committed to excellence.

CODE OF ETHICS

HEC has established this statement of organizational ethics in recognition of the agency’s responsibilities to our students, staff and the community we serve. It is the responsibility of every member of the Hillcrest team – governing Board Members, Administration, Staff Members, Interns, and Volunteers — to act in a manner that is consistent with this organizational statement and its supporting policies. The following principals will guide our behavior:

• A dedication to the principle that all Students, Employees, Interns, and Volunteers deserve to be treated with dignity, respect and courtesy.

• We will fairly and accurately represent our capabilities and ourselves.

• We will provide high quality services to meet the identified needs of our students.

• We will adhere to a uniform standard of treatment throughout the agency.

• We will provide a safe environment for both staff and students.

• We will ensure the privacy rights of our students are respected and confidentiality is maintained.

• We will maintain staff and students’ records as confidential.

• We will constantly seek to understand and respect the students’ goals as reflected in their
Clinical Treatment Plans.

• We will adhere to mandated reporting laws.

• We will diligently avoid and/or report any conflict of interest.

• We will bill for services rendered based on tuition rates set by our Massachusetts regulatory agency (Massachusetts Department of Purchased Services).

• We will adhere to admission procedures based on our ability to provide safe and appropriate treatment to students within our population descriptors on an unbiased basis.

The students, or their families and agencies, will be involved in decisions regarding the treatment that we deliver to the extent that such is practical and possible.

In addition to serving the students, we remind staff that they have a commitment to each other to act in a manner that treats every co-worker in a professional manner, with dignity, respect and courtesy. This includes such actions as not engaging in gossip, harassment, or any other behavior that is inconsistent with our mission or ethics.

• We will never discuss personal business or activities in front of, or within earshot of, students.

• We will never discuss students, or students’ issues, in a non-therapeutic way.

• We will never discuss staff or agency issues or concerns in front of,, or within earshot of students.

• We will report abuse or neglect immediately.

• We will maintain professional boundaries with students at all times.

• We will maintain professionalism and act professionally at all times.

• We will not discuss personal life issues (e.g., relationships or what we do for recreation when we’re not working) in front of, or within earshot of, students.

• We will maintain confidentiality of students at all times.

• We will take care of and respect all Hillcrest equipment and property as if it were our own.

By word, deed and example, we will teach our students to take pride in and demonstrate respect for all equipment and property, regardless of the ownership of that property.

We all have a responsibility to follow these ethical guidelines and to report any infractions by other staff to the supervisor immediately. Our mission is achievable only if each and every one of us makes this commitment.

BRIEF HISTORY OF HILLCREST EDUCATIONAL CENTERS

In the spring of 1985, under the leadership of Judge John A. Barry, the Board of Trustees of the Hillcrest Foundation assumed responsibility for the Avalon School; a private residential school servicing a population of 100 developmentally disabled students in five locations in Berkshire County. The Hillcrest Foundation appointed a Board of Directors and William J. Goggins, Jr. as the first Executive Director of HEC

Through experienced leadership, Hillcrest Educational Centers responded to the needs of a changing mental health market, shifting its treatment focus from a population of students with Developmental Disabilities to students experiencing severe Behavior Disorders and significant adjustment problems. HEC has since implemented a comprehensive continuum of care including an Intensive Treatment/Diagnostic Unit, Residential Treatment Facilities, a program for adolescent male sexual abusers, a therapeutic Day Treatment Program, and Hillcrest Psychological Services.

Hillcrest Educational Centers continues to expand the breadth of its services to facilitate the growth and development of students.

EQUAL EMPLOYMENT OPPORTUNITY POLICY STATEMENT

It is the policy of HEC to provide equal opportunity to all employees and applicants for employment without unlawful discrimination as to race, creed, color, national origin, ethnicity, sex, age, disability, marital status, sexual orientation, religion, ancestry, genetic information, military status, status as a disabled or Vietnam Era veteran of the United States Armed Forces, being a member of the Reserves or National Guard or status in any other group protected by federal, state or local law. Equal opportunity applies to all employment-related decisions, including but not limited to recruitment, hiring/selection, job assignment, compensation, training and apprenticeship, promotion, upgrading, demotion, downgrading, recall, transfer, layoff, leaves of absence, supervision, compensation, discipline, termination, access to benefits and training
and all other terms and conditions of employment. No preference is given to the hiring of
relatives or friends but the referrals are welcome.

HARASSMENT

It is the policy of HEC to maintain a working environment free from all forms of harassment, discrimination and/or intimidation. HEC does not tolerate unlawful discrimination or harassment based on race, creed, color, national origin, ethnicity, sex, age, disability, marital status, sexual orientation, religion, ancestry, genetic information, military status, status as a disabled or
Vietnam Era veteran of the United States Armed Forces, being a member of the Reserves or National Guard or status in any other group protected by federal, state or local law. Harassment of our employees is prohibited, whether it is committed by a manager, coworker, subordinate or non-employee (such as a vendor or customer). Examples of prohibited harassment include, but are not limited to, unwelcome physical contact, comments, jokes, or epithets, threats, insults, name-calling, offensive gestures, negative stereotyping, possession or display of derogatory pictures or other graphic materials, and any other words or conduct that demean, stigmatize, intimidate or single-out a person because of his/her membership in a protected category. Hillcrest takes all complaints of harassment seriously, and each will be investigated promptly and thoroughly. Therefore, HEC has instituted the following policy preventing harassment.

Introduction
It is the goal of HEC to promote a workplace that is free of harassment. Harassment of employees occurring in the workplace or in other settings in which employees may find themselves in connection with their employment is unlawful and will not be tolerated by this organization. Further, any retaliation against individuals for cooperating with an investigation of a harassment complaint is similarly unlawful and will not be tolerated. To achieve our goal of providing a workplace free from harassment, the inappropriate conduct that is described in this policy will not be tolerated and we have provided a procedure by which inappropriate conduct will be dealt with, if encountered by employees.

Because HEC takes allegations of harassment seriously, we will respond promptly to complaints of sexual or other forms of harassment and where it is determined that such inappropriate conduct has occurred, we will act promptly to eliminate the conduct and impose such corrective action as is necessary, including disciplinary action where appropriate.

This policy applies equally to all individuals working at HEC, male and female. This policy applies to all employment relationships including, but not limited to, superior/subordinate relationships, peer employee relationships and relationships between employees and non- employees (such as delivery people and visitors).

All employees are responsible for ensuring that their behavior is free of any form of harassment. No individual working at HEC should engage in, encourage, or tolerate harassing behavior. Managers are responsible for being pro-active and ensuring the workplace is free of harassment and for reporting to Human Resources any claims of harassment reported to them. The Human Resources Department is responsible for investigating each claim and assisting in the resolution of claims of harassment.

Please note that while this policy sets forth our goals of promoting a workplace that is free of harassment, the policy is not designed or intended to limit our authority to discipline or take remedial action for workplace conduct which we deem unacceptable, regardless of whether that conduct satisfies the legal definition of harassment.

Definition of Sexual Harassment
In Massachusetts, the legal definition for sexual harassment is:
“Sexual Harassment” means sexual advances, requests for sexual favors, and verbal or physical conduct of a sexual nature when:

A. Submission to, or rejection of, such advances, requests or conduct is made either explicitly or implicitly a term or condition of employment or as a basis for employment decisions;
Or

B. Such advances, requests or conduct have the purpose or effect of unreasonably interfering with an individual’s work performance by creating an intimidating, hostile, humiliating or sexually offense work environment.

Under these definitions, direct or implied requests by a supervisor for sexual favors in exchange for actual or promised job benefits such as favorable reviews, salary increases, promotions, increased benefits, or continued employment may constitute sexual harassment.

The legal definition of sexual harassment is broad and in addition to the above examples, other sexually oriented conduct, whether it is intended or not, that is unwelcome and has the effect of creating a workplace environment that is hostile, offensive, intimidating, or humiliating to male or female workers may also constitute sexual harassment.

While it is not possible to list all those additional circumstances that may constitute sexual harassment, the following are some examples of conduct, which, if unwelcome, may constitute sexual harassment depending upon the totality of the circumstances, including the severity of the conduct and its pervasiveness:

• Unwelcome sexual advances – whether they involve physical touching or not;

• Sexual epithets, jokes, written or oral references to sexual conduct, gossip regarding one’s sex life; comment on an individual’s body, comment about an individual’s sexual activity, deficiencies or prowess;
• Displaying sexually suggestive objects, webpages, emails, text messages, pictures, and cartoons
• Unwelcome leering, whistling, brushing against the body, sexual gestures, suggestive or insulting comments
• Inquiries into one’s sexual experiences

• Discussion of one’s sexual activities

All employees should take special note that, as stated above, retaliation against an individual who has complained about sexual or other forms of harassment, and retaliation against individuals for cooperating with an investigation of a harassment complaint is unlawful and will not be tolerated by this organization.

Complaints of Harassment
If one of our employees believes that he or she has been subjected to harassment, the employee
has the right to file a complaint with our organization. This may be done in writing or verbally.
If you would like to file a complaint you may do so by contacting your supervisor or the Director
of Human Resources at HEC, 788 South St., Pittsfield, MA 01201; phone 499-7924 extension
126. The staff in Human Resources is also available to discuss any concerns you may have and
to provide information to you about our policy on harassment and our complaint process.

Harassment Investigation
When we receive the complaint we will promptly investigate the allegation in a fair and
expeditious manner. The investigation will be conducted in such a way as to maintain confidentiality to the extent practicable under the circumstances. Our investigation will ordinarily include a private interview with the person filing the complaint and with witnesses. We will also interview the person alleged to have committed harassment. When we have completed our investigation we will, to the extent appropriate, inform the person filing the complaint and the person alleged to have committed the conduct, of the results of that investigation.

If it is determined that inappropriate conduct has occurred, we will act promptly to eliminate the offending conduct and, where it is appropriate, we will also impose disciplinary action.

Disciplinary Action
If it is determined that inappropriate conduct has been committed by one of our employees, we will take such action as is appropriate under the circumstances. Such action may range from counseling to termination from employment, and may include such other forms of disciplinary action, as we deem appropriate under the circumstances.

State and Federal Remedies
In addition to the above, if you believe you have been subjected to harassment, you may file a formal complaint with either or both of the government agencies set forth below. Using our complaint process does not prohibit you from also filing a complaint with these agencies. Each of the agencies has a short time period for filing a claim (EEOC – 300 days; MCAD – 300 days).

The United States Equal Employment Opportunity Commission (EEOC) John F. Kennedy Building
475 Government Center
Boston, MA 02203 (800) 669-4000

The Massachusetts Commission Against Discrimination (MCAD)
Boston Office: Springfield Office:
One Ashburton Place, Rm. 601 436 Dwight Street, Rm. 220
Boston, MA 02108 Springfield, MA 01103
(617) 994-6000 (413) 739-2145

Filing with these agencies is not a substitute for bringing a complaint to our attention. Be assured, HEC wants to hear your complaints.

COMPLAINTS

HEC encourages all employees to promptly report any incidents of harassment, discrimination, intimidating behaviors or other concerns. While we encourage staff to use the chain of command to report these kinds of incidents, we also understand that reporting such information to your direct supervisor is sometimes inappropriate or uncomfortable, and may discourage employees from promptly reporting such information. It is our hope that this additional reporting
mechanism will provide staff with an option when these situations occur.

Staff who hear or see harassing, discriminating or intimidating behavior are encouraged to verbally report this immediately to a supervisor, member of the Campus Administration or another HEC Administrator so the event can be investigated immediately.

The Program Director/Manager may designate a member of the Campus Administration or ask another HEC Administrator to conduct the investigation, but upon completion of the investigation, the staff who made the complaint will meet with the Program Director/Manager to discuss the investigation and resolution of the complaint.

Every attempt will be made to protect the privacy and confidentiality of the staff who registered the complaint, as well as the privacy and confidentiality of the staff who is the subject of the complaint to the degree reasonably practical under the circumstances. However, we cannot guarantee absolute confidentiality, as it may be necessary to disclose names and statements of staff where the safety of the students and/or staff is potentially compromised, or where such disclosures are necessary to otherwise effectively complete an investigation depending upon the facts of a particular case.