001Yeah, whatever you want. Hello everybody, good morning. Thank you all for coming today um to the HR workplace conduct. Um this is really kind of a a a renewed phase of really kind of looking at how we continue and promote operational excellence. Doing that through trust, uh communication, commitment, and accountability. Um this is kind of really the first [snorts] kind of a new phase, I guess, of really looking at um developing this culture of trust and accountability. Like I said, I think we all know we've we've weathered I always say this, but we've kind of been weathering some storms and and we're coming out of that, hopefully. So, we're really engaged in getting everybody kind of connected back to the mission of the service to our students, whether that support is direct or indirect. So,
002this is really for all leaders, educators, and staff on kind of focusing in on really what it takes for each of us to kind of give our best and really kind of um bring our best selves every day for each other and for the students that we serve in the community. Um you know, in order to set that stage, and this is really what this training is doing, uh we really want to kind of focus in on this like I said, trust and accountability. But, really governs that beginning stage is our staff ethics policy, and that's board policy 3210. David Sapusek, our legal counsel, always wants me to bring it back to a policy or administrative guideline, right? So, I want to read to you what that board policy says in kind of pertinent part.
003It sets the stage for staff ethics. It begins with an an effective educational program and successful operation of the district requires the services of individuals with integrity, high ideals, and human understanding. To maintain and promote these essentials, the Board of Education expects expects all professional staff members to maintain high standards in their working relationships and the performance of their professional duties. Today, our goal is really to kind of begin with setting the setting that stage, but begin with kind of reviewing the board policies that deal with you know, anti-harassment, non-discrimination, sexual harassment, retaliation, whistleblower. These are policies that that govern our leadership, but also serve to protect staff. And we want to keep you guys informed of that, and we're going to talk about different ways of communicating in terms of when anything like this
004happens, but it's designed to promote accountability within our leadership, but also inform you and protect you as well. As we move forward over the next couple years, um you'll see more of this conversation continuing from HR. We'll be providing training and professional development around this. So, this is really the basis, the jump-off point for you. So, um we're going to begin today. We have Jackie Walsh Brickman from our from our law firm Pabalan & Wagner that we that we use here and there, and she's going to kind of start working through these policies. Uh I'm going to bring it over to our beloved superintendent to see if she has a few few words to get us started today. As she sits in the media corner. I'm taking notes. Good morning, everyone. Good morning. Can they
005hear me on the second floor? You cannot. Okay. Okay. Yeah. Yes, I do. Okay. Okay, so are we pushing pause? >> [laughter] >> This is an HR function. Okay, don't get me in trouble. Yeah. Oh, yes, I can talk. Yes. >> [clears throat] >> Yes, yes, yes. You need me to say anything else? Can they hear me? Yeah, where is Wayne at with his dad jokes? Well, Chase has Do you have him on a mic? >> [clears throat and cough] >> Okay, thanks. She's talking already. Yeah, where where's I got him on the phone. Okay, Mary, you want to Do you want Mary to tell you? Yeah, that's what I said. Are you ready? >> [laughter] >> We're still live. We're still live. Okay, we're ready to begin. So, they missed all of what Chase
006said earlier, all that foundational information. Wow. oh well. >> [laughter] >> So Wilma, exactly what did you hear today? >> [laughter] >> That this is the beginning of many. Many what? Many more meetings for HR to share workplace conduct. All right, very see, she was listening. I'm having an Oprah moment. Let me see, that was one for the front row. Let me see who else was Oh, okay, Stancy. Hi, this is Stancy Sachs. It all goes back to policy. Woah, she sounds like an attorney. >> [laughter] >> I wonder if politics running that family. Good job. Okay, we're going to turn it back over to you so you can get us started. Do you want me to redo it? I they didn't hear it up here. >> Okay. Well, I hope they can hear me
007and and again, I'll I'll put this more of a nutshell for you as opposed to long-winded. But really this is kind of today's workplace conduct training. Thank you all for coming. Um is really here to kind of set the stage for really kind of focusing on what we shall be seeing in more promoting operational excellence and that's through trust, commitment, accountability. This is for all leaders, educators, and staff. And our staff and what we'll be doing is kind of focusing on how we set the stage uh for more continued training as Wilma said in terms of workplace conduct next year, the year after that. Um this is really the foundational element where we'll review some of the policies that govern leadership and protect staff like anti-harassment, sexual harassment, non-discrimination, retaliation, and whistleblower. So these, like
008I said, all are all serve to to we want to keep you informed on how to communicate when any event arises, but also show you that leadership is is taking this seriously and focusing on on accountability throughout. And I'm going to I'm going to read it again for you cuz we always set the stage with board policy and board policy 3210 is our staff ethics policy. And for classified staff, I think it's 2210. It's the same basic idea of staff ethics. So board policy starts off with an effective educational program successful operation of the district requires the services of individuals with integrity, high ideals, and human understanding. To maintain and promote these essentials, the Board of Education expects all professional staff members and classified staff members to maintain high standards in their working relationship and
009in the performance of their duties. So our goal here is to is really educate you towards that end. And like I said, we'll be we'll be bringing about more of this conversation, continuing the conversation. Um so with that, I'm going to go ahead and introduce reintroduce Jackie Walsh Brickman from our law firm Pepple & Wagner that we work with every once in a while. And she's going to walk us through this and I believe we'll be taking questions. I'll kind of run around with the mic. Um if you guys have any questions during the presentation, is that okay with you, Jackie? >> Absolutely. >> Okay. So I'll just turn it over to Jackie then. Okay. All right, well good morning everybody. Uh yes, please if you have questions, I'm happy to answer questions. I want
010this to be a useful training for everybody. You have a lot of other things you could be doing this morning. I want this to be a worthwhile hour that we spend together. I'm going to be focusing on a few different things. One is talking about the various policies that the board has in place. And the reason why it's important is because those are the policies that govern. If you do have an issue, this is the procedure that should be followed. For administrators, it's so that you know what is it that you're supposed to be doing. And for other staff members, it's so that you know what to expect, right? I run into a problem, how is it that I should report it? What should I expect to see in terms of how it's handled? And
011it also covers a lot of things about hey, how should we be conducting ourselves in the workplace, right? What are the things that we should be doing, things that we shouldn't be doing. So talking about some of those things as well. And part of that is also the things that maybe don't fall underneath some of those policies. It doesn't mean that the behavior is okay, but maybe we have to deal with it in a different way. Cuz folks sometimes get frustrated if they feel like well, I reported something under such and such policy and then well, wait a minute, it didn't follow that procedure when really maybe that policy didn't apply. And that can be very confusing. One of the things that I do, I am a partner with Pepple & Wagner and one of
012the phone calls I get is from administrators who say, hey, we ran into this issue, how do we deal with it? And I'm looking at the policies and saying, okay, I think we should do this versus this and it can be confusing, which is understandable. So just so that you're aware and you know where to look, there is an outline that I believe Mr. Canfield made available to everybody that has materials that you can refer to. And then we'll also obviously be going through the slides, you'll see it up there as well as far as what are the policies that I am referring to that you can look at on, you know, the board's website as well. So to get Oh, go ahead. I didn't hear that yet, but I will be sending that out.
013All right, never mind. That will be forthcoming. You haven't received it yet. So the policies are required because there are actual federal laws that prohibit certain types of conduct in the workplace, particularly because this is a public school district. So there are a lot of laws that apply to public school districts that don't apply to me at Pepple & Wagner, but do apply to all of you. So the first is Title VII. And this is a federal law that prohibits discrimination on a variety of, you know, any of those protected classes, whether that's race, color, national origin, and says, hey, we can't discriminate against people on the basis of that. The under Title VII specifically outlines the various unlawful uh employment practices. There are a lot of the things that I think that we would
014expect to be discrimination, right? You can't refuse to hire someone based on them being a member of a particular class. You can't treat them differently than others, whether it's during the application period of becoming an employee or once you actually are an employee. So Title VII is one of the laws that applies that prohibits discrimination that your board has adopted policies to make sure, hey, we're treating people fairly, we're treating people equally, we're not treating somebody different based on who they are. In addition to Title IX, there's also Title IX. This is where it gets so confusing, right? This is why I have a job. Title IX is specific to discrimination on the basis of sex. So while Title VII talks about things like race, color, national origin, Title IX talks about sex and specifically
015talks about sexual harassment. For whatever reason, don't ask me why, there is a different procedure for investigating and responding to sexual harassment than any other types of complaint that might be made. So that falls underneath underneath Title IX and that's a specific procedure and a policy that your board has. So in addition to those laws, your board has adopted policies because hey, the board says, you know, this obviously isn't something that we want to have happening in our school district. Both because it's legally required, but also because it's just wrong. That's not how we want to operate as a school district, that's not the type type of organization we want to be. We want everyone to be treated well and have a positive workplace. So your board has adopted, again, just the regular non-discrimination policy,
016which talks about what we just referred to under Title VII and Title IX, is that the board does not discriminate on the basis of race, color, national origin, sex, and that covers things like sexual orientation, transgender status, disability, age, religion, military status, ancestry, genetic information, basically all of the things. The board has made clear we're not going to treat people differently based on those particular aspects that they might have. They the policies also designate who is required to look into issues should they arise. And what you will see if that's outdated, Mr. Canfield obviously is the one who will be overseeing those. So it's his job to look into and to handle any issues that should arise, which hopefully there will be none, right? This will be a smooth sailing year and there will be
017no problems for anybody, but should there be problems, you send those over to HR as far as non-discrimination issues. He's also the complaint coordinator, which again is the same idea, right? It's just different words for for essentially the same job of okay, if I have a complaint, I'm responsible for coordinating it, for making sure that the investigation is being done, for making sure that we're looking into things properly. So Mr. Canfield is also the person that you go to if you have issues and it's hey, you know, I don't really think that this is being handled the way it's supposed to and it's it's something that falls underneath that umbrella of non-discrimination, that that's going to go to him as well. Go ahead. And and that is me. I I apologize for not introducing myself
018off the beginning. There's many of the faces I haven't met before, so I'm Chase Canfield. Thanks. So what does that look like, right? If we have an issue where we feel like somebody is treating us in a in a way that's not acceptable based on one of those protected classes, there's a few different options. One is an informal process and that is exactly what it sounds like. It's like, hey, I'm having an issue with this person and I want to in in just discuss that informally with Mr. Canfield. I want to make him aware that we're having this problem and see if there's a way that we can resolve it. I don't necessarily want to turn this into a big investigation, I just kind of want to resolve it and and have it be over
019and done with. And for a lot of people, that's what they're looking for. Maybe they tried to resolve it themselves, which ideally that's what we do first, right? As adults, as professionals in the workplace, we try and sort things out ourselves. Um but if that was ineffective, then it might be time to move up the chain and seek some assistance. And you have the option of saying, "Can you help me resolve this informally with somebody? Here's this problem that I'm having that I believe falls under this particular board policy." There also is the option of a more formal complaint. So, a formal complaint is exactly that. I'm filing a formal complaint, and then there's a procedure under the board policy that your district is supposed to follow. Um there's a timeline within which you do
020need to file these these things. So, complaint needs to be filed within 30 days under your board policy. All right? So, you want to try and "Hey, can I work it out with this person? If I can't, or if it's of such a significance where that doesn't really something that makes sense, there is a timing issue in terms of making sure that we're responding to things in in a prompt manner." And the idea behind that, and this is similar for a lot of boards, is people shouldn't be sitting on things for a year, right? And then saying, "And then a year ago, so-and-so did such-and-such." Right? If there's a real problem, we want to be resolving those things in real time, so that we're able to timely address things and make sure that the workplace
021is operating the way that it should. There's then going to be an investigation, and this is supposed to be something that happens in a timely manner. So, your policy does include various timelines as far as when your administrators are going to look into things and get back to you on uh you know, what they find and whether they determine that there is or is not an issue that occurred. And then ultimately, there is the option to appeal. So, if you're not happy with the outcome of that particular investigation, you have the ability to appeal to the superintendent. And again, there are time limits for that under your policy. It's 5 business days to say, "Hey, I disagree with this outcome, and I want somebody else to look at it." So, the idea is that there
022is a multi-level, you know, way to report these things and to look into them. But something to be aware of is that this applies specifically to those types of discrimination complaints. So, one of the things that I do see happen sometimes is people have something that happens in the workplace that they're not happy about, and they want to file this type of complaint. And that's not really the right way to handle it because it wasn't really discrimination. Maybe it was just a personality conflict. Maybe just two people aren't working well together. So, sometimes there are things that really are just for your supervisor to deal with, right? That that they don't come up to HR, that they're just "Hey, look, this isn't really working well. We need to work things out, or so-and-so is doing
023X, Y, or Z that is problematic, uh and I want to report it, and it should be handled at the superintendent level." Well, when we're talking about the HR level, we're really talking about those types of non-discrimination issues where we think we're being treated poorly or differently based on that protected class. The superintendent off ultimately then makes that final decision on those types of complaints. So, non-discrimination isn't the one that I get as often as harassment. Harassment is the more common types of complaints that I see from, you know, employees saying, "Hey, I feel like I'm being harassed in the workplace." And what's become interesting is harassment is one of those words that is being used now the way that I always talk to teachers about bullying being used. Like, people just use the word,
024and there is an actual meaning to it, right? So, sometimes people say it, and they feel like they're being harassed, but it's they're not getting along with somebody, or there's a personality conflict, or it's some of those things. That's not necessarily the the actual definition of harassment under your policy. So, I'm going to talk about what does arise under your policy and the types of things that we shouldn't be engaging in absolutely not in the workplace. And if it happens, this is the procedure for you to look into it, for you to report it, for you to make sure that, you know, the school district as a whole has people who are behaving in a professional manner and treating each other with respect and professionalism as required under the board policy that Mr. Canfield talked
025about at the beginning. So, anti-harassment is the board policy that applies. Uh I'm using 3362, but as you probably noted it from Mr. Canfield at the beginning, you guys have NEOLA, which means that there's like different chapters, right? There's one that deals with administrators, that there's one that deals with professional staff, there's one that deals with your classified staff. It's the same policy in each section. Just the number at the beginning changes. So, it might be 2362, 4362. So, I've just used one policy for, you know, ease of the presentation. But when you're actually looking at it, the number might be a little bit different for you, uh depending on your role in the district. So, the anti-harassment uh policy again says, "Hey, the board wants to make sure that we have an environment that
026is free of harassment, and we're going to investigate those allegations and make sure that none of those things are happening uh should we receive any complaints to that effect." There's going to be immediate disciplinary action if people are engaged in harassment. Like, that is something that the board takes seriously. You also can't retaliate against people who report harassment. So, that is sometimes a a concern that people raise to me is, "Well, I don't I'm afraid to come forward, or I'm afraid to participate in an investigation because I don't want to be retaliated against." The policy specifically prohibits that, which means that someone who does retaliate against someone can be disciplined for that. Now, uh we'll talk about the retaliation policy later. But something to know about that that I've run into in my personal life,
027I had a uh family member who filed a complaint about something and basically said, "No, I can't be fired. I'm protected for life." That's not true, right? If you actually engage in misconduct or do something bad, you can still be disciplined even if you have participated in one of these complaints. You can't be disciplined or, you know, there can't be negative action against you just because you filed a complaint, right? So, there's a little bit of a of a distinction there. But nonetheless, there is protection from the idea that "Hey, because you have participated in this, that whether it's an administrator or another employee, that they are going to be treating you badly as a result of that." There also is a prohibition against maliciously filing a or knowingly filing a false report. So, when
028you file a report, it needs to be filed in good faith, right? We have a good reason to believe that something happened. Not filing something because, you know, we're mad at somebody, or we had an issue with somebody, or we heard something through the rumor mill that we actually haven't really kind of had any first-hand knowledge about, right? So, the idea that filing reports is going to be because we have a good faith first-hand belief that something happened, and that it's not something that's that's ever going to be misused. And if it's misused, then the person who made that false report is the one who would potentially be in trouble for that. And then also, the the board policy prohibits disregarding or failing to investigate those allegations. So, there is an expectation that the allegations
029are going to be looked into uh if they are brought to light. So, there is a specific definition of sexual harassment under Title VII. Remember I talked at the beginning about Title VII versus Title IX. And just to make it as confusing as possible, uh there's two different definitions of sexual harassment depending on which policy you are under. So, sexual harassment under Title VII is broader in scope. It covers more than under Title IX. Um so, sexual harassment under Title VII is unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature. When there's when that submission to that conduct is what we call quid pro quo, where there's sort of this expectation of, "Hey, you, you know, need to engage in this to receive some sort of benefit
030of, you know, the school district, right? You'll get that promotion, you'll get that day off, you'll you know, there's going to be some positive for you for engaging in that." Um or the conduct otherwise is interfering with the person's ability to do their job. It's usually this last one. I don't get a lot of quid pro quo cases. It's usually if I get these types of cases, it's, "Hey, look, this is occurring, and it's creating this hostile environment, right? It's an intimidating environment for to be for me to be in. It's an offensive working environment, or it's otherwise interfering with my ability to do my job." Those sorts of things obviously are unacceptable. They're a violation of Title VII, and they are prohibition and they are prohibited under your board's policy. So, what what kinds
031of things am I talking about, right? When I'm talking about conduct that's prohibited by Title VII. It's the sort of thing you feel like you shouldn't have to tell people not to do, uh but nonetheless, we do get these issues, right? These things do happen. So, I'm going to tell people not to do it. That's one of the reasons why I'm here today is to make sure everybody knows, here are the some of the things that we're not allowed to do. So, sexual propositions, invitations, solicitations, flirtations. Things I've seen people get in trouble for in this, right? Real-life examples. Someone is interested in having a romantic relationship with someone. They make that invitation. They say, "Hey, you want to go out with me?" Whatever it might be. Person says, "No, thank you." They continue to
032persist. They don't accept no for an answer. That can land you in some hot water. Um things that are, I guess, not polite to say, inappropriate in nature, graphic, using um any sort of words that I'm not going to repeat out loud. Uh but, you know, very sort of specific invitations to engage in a particular activity. That's going to be a problem, right? So, those are things that again, I have had those cases. Please don't do it. Uh any obviously any type of physical assault where you're forcing somebody to engage in a particular activity. Um any kind of just unwelcome verbal expressions of a sexual nature is one of the things in your policy. So, things that I've seen there, there's a lot of things that happen in folks' personal life. Leave it at home,
033right? Nobody needs to know about our the details of our romantic relationships, and there's no reason to ask anybody about what's happening in your romantic relationship. So, those are some of the types of cases I've seen where people are, you know, being, I would say, oversharing, uh or seeking to get information from others that really is inappropriate relationship real inappropriate conversations to have at work. Or sometimes people maybe they're friends, they're engaging that type of conversations, making everybody around them really uncomfortable, right? Those are just not the types of conversations that should be occurring in the workplace. Any kind of um sexually explicit videos, photographs. Again, I've had cases where it might not be pornography, but someone's pulling up pictures or videos of people who are scantily clad. Um or I've had some where it
034was like the the WWE wrestlers, but it was the women, uh and, you know, com- conversations happening about that. So again, just you work in schools, it's the workplace. Let's just not do any of that and avoids a lot of trouble. And then any other kind of unwelcome touching pattern padding that type of thing. And where I've sometimes seen people land in hot water with that one is some folks are very just physical. Like that's part of you know, kind of who they are as a as a person, but it's not always well received by the other person, right? So you know, you want to make sure that you're aware of those professional boundaries and that we're not hugging people or touching people when maybe that's not something that they are comfortable with even if
035you feel like, well, you know, this is me being friendly or this is who I am as a person. It it has to be consensual, right? The other person has to be okay with it as well. All right, I think we talked about that. And then remarks about other people's sexual history, their sexual relationships, speculating about them. This is something again that I have seen things that you should feels like you shouldn't have to tell people, but you know, it's not something that should be happening at work. It's it's really none of our business, right? What anyone else's relationships might be. So not all behavior even on that list will necessarily rise to the level of sexual harassment. People say dumb things, right? Someone make might make a remark that they should not make. Usually
036those one-time things if it's you know, particularly if they're apologetic if there's a whoops, maybe I shouldn't have said that. It's not necessarily going to rise level of sexual harassment. When we're talking about sexual harassment, we're really talking about repeated ongoing conduct that's really starting to to affect the employment situation, right? So that doesn't mean that that one-time off-color thing or the occasional comment shouldn't be dealt with, but that's the type of thing where you go to your supervisor and say, "Hey look, this happened. It really made me uncomfortable. I don't think it's okay." So it can be dealt with at that level as opposed to, "Hey, this is going on for a long period of time and now you know, we need to do this whole long investigation I'm going to talk about to
037really deal with it." Ideally we're kind of dealing with those things through your supervisor when they come up. But if this is an ongoing issue with someone, it absolutely can rise to level of sexual harassment where someone is really engaging in the workplace with others in a in a way that's inappropriate. Any questions before I move on to race? All right. So similar prohibitions for race. Same thing, right? Any unwelcome physical, verbal, or non-verbal conduct based on a person's race or color, that's also going to be considered harassment under your policy. And that harassment it really occurs when we're talking about any comments about a person's race or color, racial slurs, nicknames, stereotypes, negative references related to that. And the place where I see people get into trouble is they claim they're joking, right? I
038was just kidding around. Well, it wasn't funny and it was offensive, right? So just because we say something we think that it's funny, doesn't mean that it's not going to end up being a violation and constitute harassment. And the other thing to keep in mind is sometimes people laugh at something because they're uncomfortable. You know, so someone might laugh at something and say, "Well, I thought that it was okay because they laughed." Well, they were in an uncomfortable social situation. Maybe there are other co-workers around and maybe they weren't comfortable confronting you at that point in time. So they may have smiled and laughed and gone around gone along with it when in fact it was still something that they found to be offensive. So again, just you know, professionals in the workplace not making
039those types of conduct comments about anybody based on their race, color, national origin. Same thing about religion, right? So I don't get as many of these. Really most of the complaints that I get are really along the sex sexual harassment or race type issues, but the same thing applies to religion as applies to the others. So if there's any comments about you know, someone who someone's religious traditions, special clothing that they might wear, or any negative comments about particular religions, those can constitute harassment as well. So you know, same thing in terms of joking, you know, being careful about that. I generally just say those are the you know, jokes about anybody based on protected classes a bad idea even if they appear to think that it is funny as well. Same thing about national
040origin very similar in terms of the types of things that can land you in hot water. Anything about customs, manner of speaking, clothing, ethnic slurs, making fun of people's names. That's you know, kind of a big one, right? You know, someone has a name that is you know, part of their national origin, this is part of their family traditions, part of their culture, but we're making fun of their names, we're we're not trying to learn how to say it properly. Those are things that can be a problem. So of course we're all human, right? But we we need to make an effort to make sure that we are treating people with respect even if there's something different, right? That we're not used to. And then disability harassment. So disability also is a protected class, which
041I don't know that we've really talked about that yet, but there can be harassment that's on the basis of disability as well. So when we're talking about disability harassment, some of the things that I sometimes see people kind of have some issues with are where you know, anytime you're mimicking someone who has a disability. Anytime you're kind of again, this is the joking is the common one. People teasing someone about something that is a disability related issue. Again, people might laugh, but in reality they're not comfortable with it. Any conduct where we're talking about their physical impairments, their their defects, their appearance in particular, those are things that we just want to stay away with, right? Be respectful, be professional in the workplace and and there won't be an issue. So again, any of those
042issues, hopefully none arise. Everyone's heard the list of things not to do and will be perfectly professional from here on out. But if there are issues, Mr. Canfield again is the place where you would go to initiate a complaint that hey, this is an ongoing issue that I'm having with this particular person. We need to deal with it in some way. Confidentiality is a common concern that comes up when people are wanting to report complaints. And I know I believe one of the things the district is looking into is is you know, how or to what extent they can actually have confidential complaints. So one of the things I'm going to tell you just just out of so that you understand what the difficulty is. So people want to be want to say, "Hey look,
043you know, for whatever reason I want this to be confidential. I don't want you to tell anybody." That there's a few issues with that. One is your public school districts. You are subject to a variety of laws that require transparency including public records laws, right? And then also laws under FERPA if it involves a kid where parents have the right to information. So generally speaking, we as a school district can't decide we're going to keep this confidential. It's dictated by law whether or not something can be confidential. And I will tell you right now there is no exception for reports as far as confidentiality. So that's the number one issue is, "Hey look, if we got a public records request, any information we've received is potentially a public record. So it's very difficult for us
044to promise confidentiality." The other difficulty is that some of these policies as part of their process require the other person to have certain information so they can respond and defend themselves against the allegations. The idea being, "How can I defend myself against something if I don't even know who I allegedly did this to?" So there can be some challenges to confidentiality. So I generally tell folks that we can't promise confidentiality. We can say we'll do our best, right? But that there might be sometimes where the other person is potentially going to know. And the other situation where people potentially will know is let's assume this is a really bad terrible situation, which I hope that doesn't happen. And we're looking at disciplining someone and there's a challenge to that discipline and we end up in
045some sort of a hearing, well guess what? Folks are going to have to be called as witnesses. So there are a variety of times where that's just not going to happen. But nonetheless, I know that the district is looking into it and trying to find ways that would make it more easy and more comfortable for people to come forward with issues that might arise while still probably complying with all of those issues that I've talked about. But I share that with you so you know that it's not an easy thing and that sometimes people have sort of an expectation of confidentiality that's the district isn't always able to fulfill. All right. So again, this policy similar to your other one has an informal complaint procedure versus versus a formal complaint procedure. So your informal process
046is exactly what it sounds like. You know, there are a variety of things that can happen as part of the informal process. Sometimes it can be as simple as, "Hey, let's just remind everybody of our expectations as a school district." It sounds like maybe you know, after we have this training everybody will be very professional, I'm sure. There will be no problems, but sometimes over time things can slip and people might slide towards some bad habits that they may have had before. So sometimes it's as much saying, "Hey, you know what? I think we need to kind of have another reminder." Or if it's a more serious situation, for example, the example I gave you of the person who kept asking the person out. I did have a situation where the woman was starting to
047feel kind of very uncomfortable. The guy was kind of isolating her, you know, she was kind of a you know, in the parking lot kind of later at the end of the day, no one was there. He was following her out to her car. It was it was escalating to a point where she was feeling uncomfortable and she said, "I don't really care if you I don't want him to get him in trouble. I just want it to stop." And kind of a sit-down with an administrator saying, "Hey, you need to cut it out." was enough to end the conduct, which was all that that particular employee wanted. So the informal process can take a variety of forms. It's really about what is the complainant looking for? What makes sense here? And is there a
048way that we can resolve the situation quickly and to everybody's satisfaction or does it really need to go through a more formal process? You know, if I could just add to that Absolutely. Jackie. So you know, when we look at that kind of situations at the local level, you know, in a particular business unit with that supervisor, you know, that that can build trust as well by allowing that supervisor to handle a situation that you may not uh feel comfortable with and gives that opportunity to HR is always here, but we really want to see that development of the supervisor to be able to handle those types of complaints and really kind of get with you to see, you know, what that is and then if it needs to rise up, then, you know, we'll
049obviously always hear it. Um but I think that also builds trust within the employees that are doing everything right. Um if a if a supervisor is not addressing employees that are doing things wrong, it deteriorates the trust of others. So, we really want to empower and develop all of our supervisors, directors, managers to be able to handle these types of situations. Mhm. Yeah, that's a really good point, right? The The goal obviously of all of this is for this to be a positive place to work, for it to be a place that functions well, and everything going up to HR all the time is usually an indication that things aren't always functioning well, right? Ideally, things should should be functioning well at a lower level, and it's the more serious things that end up rising
050up to the HR level. So, if you do choose an informal process for your expectation for supervisor's expectation, the policy does expect that that that that's going to be attempted to be resolved within 2 weeks, right? So, there is an idea that, "Hey, you bring something to supervisor's attention, that they're going to respond promptly and then they're going to look into it and try and figure out if is this something that we can work out?" The other thing to be aware of is nothing prevents you from moving from the informal process to a formal process under any of these policies. So, you can always try to resolve it informally, and if that doesn't work out, say, "Okay, now it's time to kind of move it up the ladder." You don't have to, you can always
051start with a formal complaint. I don't want to make it sound like you have to do the informal one, but I want you to be aware that there's multiple ways to kind of deal with issues. The formal process, again, will go, that's where we're get we're heading up to HR, and under your complaint, the individual who's alleged to engage in the uh the harassment is going to receive notice that of the complaint. Um and then they're going to have the ability to respond to it. So, when we go anytime there's going to be a formal complaint, there is going to be that back and forth cuz the idea is that we're investigating, we're looking into it, and the person who's alleged to have engaged in the wrongdoing, they have the right to respond and tell
052their side of the story. So, in this particular process, it looks like that person having a certain number of days to submit any response to allegations. The complaint coordinator is then going to initiate a formal investigation. That can look like a lot of things. Uh it may be interviews with witnesses, it may be, you know, reviewing documents. It really is going to depend on the situation as far as what that investigation is going to look like, and it may or may not be the complaint coordinator who's actually doing that investigation. They can designate somebody else to carry out that role. They're going to attempt to complete that uh investigation within 14 calendar days. That often will depend on the nature of the situation, right? If it's a real quick, there's just a couple people to
053talk to, that can easily be done. If it's a more complicated situation, it might take them a little longer. So, to be aware that, "Hey, sometimes these timelines are not necessarily set in stone like you can never go past them." There are in in all the policies, there's usually built in the idea of, "Well, you know, if we have to talk to 30 people, right? That's going to take more than 14 days." As opposed to if we only have to talk to two. When when we're determining whether or not there is a violation, there are a variety things under the policy that is supposed to be considered, right? So, again, not everything is sort of off with someone's head, not everything is immediately going to rise to the to the level of harassment. There is
054the idea that this is something that is more ongoing in nature. That's part of harassment. So, for bullying, for example, I often kick out bullying complaints because in the law itself, it says there's supposed to be multiple instances. Harassment is a similar type of thing. Now, if it's one really severe incident, like an assault, for example, that's immediately going to be harassment. But if it's smaller things, it's it's often going to be an expectation that there's more than one occurrence. So, you'll see there the nature of the behavior, right? How significant is it that we're talking about? How often the conduct occurred? Whether there are past incidents? Is this someone who we've addressed this with before and now they're continuing to engage in this conduct or is this someone it's the first time that they've
055kind of stepped a toe out of line? Um the relationship between the parties, right? You know, what is there a friendship? Was there a belief that this was joking and kidding around versus, "Hey, there's no expectation for you to believe that I would have been receptive to whatever it was that you just said to me." Um certainly, you know, is the person part of that protected class? Cuz I went through, "Hey, here's the definition of harassment, here's the protected classes." Again, not everything that happens in the workplace is going to fall underneath this policy. Sometimes disagreements happen, and it it's not harassment at all. It's just a disagreement in the workplace, and that's something that should be handled by the supervisor, right? So, if it's not something that rises that falls underneath one of those
056definitions, that's just a general workplace issue that the supervisor is going to be responsible for dealing with. We're also looking at things like the number of people involved, right? So, I have had situations where, "Hey, someone is an equal opportunity offender for a variety of people." We're going to handle that differently than kind of the one-off with one person that maybe only happened once or twice. The age of the folks involved, it doesn't apply here so much, but certainly anything involving students is something that we're going to handle with a a higher level of severity than adults because adults we should be able to kind of handle ourselves to a certain extent and tell someone to cut it out if we don't like something, um and and hopefully deal with some of those things just
057ourselves as people who work with people in the workplace. And then whether there have been similar instance, right? Is this an indication that maybe we have a cultural issue where this is this type of behavior is happening with multiple people? Well, okay, then that's something we need to look at. And then we have to think about how we're going to handle that as a school district, right? But then that's a, "Okay, perhaps this particular I've had this where this particular group within a school district is kind of behaving in a way that isn't acceptable." Well, now we need to deal with that particular group that's engaged in that conduct. And then how does do these issues actually impact the person who made the report? Is there an impact in their ability to do their job?
058Um was this something that uh kind of harmed them in any way? And then we also have to think about things like free speech, right? So, everyone has First Amendment rights. Doesn't mean you get to violate laws with it. So, I've just mentioned that these are federal laws, but there are things that people might say that we might not like, that we might disagree with, but that they do get to say, right? It's a First Amendment right. Um so, I do sometimes run into that where someone reports something to me and they're they're kind of outraged. I'm like, "Well, you know, sometimes we get to be critical. Sometimes we get to express our view on something." But the thing you have to be mindful of is how you express your view, right? Are you Are
059you being respectful? Because if we express our views in a way that violates any of these policies, well, then that's not going to be uh protected by the First Amendment. Questions about any of that? No? All right. Yeah, go ahead. So, Sorry, I was It is like Oprah. Sorry. So, you said that um the timelines can be changed. >> Mhm. Is there anything in there that in the policy that says um we have to communicate with with the parties to let them know this is on um saying we're still working on this, we're still working on this, and not just crickets? Um well, I'm going to give you the lawyer answer everyone hates, which it depends. Uh so, some of the policies do have that type of language in there. For example, the Title IX
060policy permits you to temporarily delay an investigation to work with law enforcement, but you're supposed to notify the parties that you're doing that, right? Versus the other policies, if it's 14 days, but it takes you 16 days, you don't necessarily need to notify someone that it's going to take you a few days longer. I do think it's a good practice though. If it's going to take you a lot longer, right? Like if it's 14 days and it's going to take you 30, I think as a courtesy, it's a good idea to tell everybody, but the policies don't necessarily require it. It's not necessarily a violation to do that. >> It It is our goal to effectively communicate if those delays do come into play. I thought I saw another question. No? Okay. All right. So,
061at the conclusion of the investigation under these particular policies, there is a report that is given to the superintendent, and then the superintendent is the one who ultimately ends up issuing the decision under the on these under these particular harassment policies. So, you'll see there are some variations under the policies depending on what it's going to look like and what you're going to receive as an employee. Um and then a copy of that final decision goes to both the complainant and the respondent. So, the respondent is the one who's alleged to have engaged in that bad conduct. That person gets to know and so does the complainant, you get the same information. So, this is a situation where there is a written outcome, right? When I talked about the public records laws, there is a
062written outcome that is going to be a public record as a result of this, which is why you can see that sometimes in that confidentiality, you know, that promise, I always I always tell people, "Oh, don't just say that this definitely going to be confidential because here's an example of a time where we were were required to have a written report that's going to go to everybody, that is going to be a public record at the end of the day as far as what the school district found." There is also under this policy as well an appeal option, and um that appeal needs to be filed within 10 business days. That goes to the board, and the board will ultimately reject or affirm the decision of the superintendent, and that's the final decision on the
063harassment type complaints. All right. We're kind of switching gears again. I told you there's a lot of different ones. So, here we're talking about Title IX. So, I told you just to be confusing, there's two different definitions of sexual harassment because why would we make it easy and straightforward for people to understand how things are supposed to work. Talk to Congress, they did this in their infinite wisdom. So, sexual harassment under Title IX is similar to Title VII, but there are a few variations. So, it also includes the quid pro quo, which I talked about earlier, the idea of conditioning some sort of unwelcome conduct on, you know, you get some benefit or privilege of a school district as a result of participating in something, some sort of favoritism because you engage in this conduct.
064The one that I get more often is the second bullet point there, which is unwelcome conduct determined by a reasonable person to be so severe, uh pervasive, and objectively offensive that effectively denies equal participation in the school district's program or activity. That's similar. >> you talk a little bit more about the the focus on the education programs and activities, how it differentiates between 7 and 9? Yes. So, education program or activity, we're talking about the school district, right? How is it that you can do your job, right, in the school district? So, title 7, you know, we're talking about your ability to do your job at work, and then title 9, it's the same thing, but it also applies to students. So, we're talking about their ability to come to school. Title 9 applies to
065both students and employees the same way. Um so, in in both situations, we are looking at, hey, is there some impact on you at work, uh as opposed to, hey, you know, this wasn't awesome, but I'm I really didn't really bother me that much, and I just continued to do my job. That's fine. It doesn't mean that it was okay, whatever happened. It just means it probably wasn't sexual harassment, and we're going to be looking at dealing with it in some other way and not going through this complaint process. Still going to address it with the employee if it was inappropriate and shouldn't have happened, but we're going to do it just with your supervisor a little bit more informally, potentially, than in the full, you know, lengthy complaint process that we're talking about. So,
066the title 9 definition is similar again to title 7 in terms of the idea of, hey, it's unwelcome conduct, but it's a little bit of a higher bar in that it needs to be conduct that is severe, pervasive, and objectively offensive. It needs to meet all three of those things. And pervasive again is that idea of it's repeated, and then there also does need to be that impairing your ability to access your job, to do your job, that there's some impact on your ability to function and in the school district in some way. Then the last definition there deals with certain types of federal offenses. So, if there's a federal crime that happens, which I certainly hope is something that we're never going to see, right, uh in the school district, but things like sexual
067assaults, um dating violence, domestic violence, and stalking are all criminal conduct that would also rise to the level of being sexual harassment that's prohibited under title 9. Dr. Wanda Lash is the title 9 coordinator. So, Mr. Canfield does not handle this particular issue. This is uh Dr. Lash instead. And the uh the process under title 9 is much more complex, and it takes much more time than the other harassment policies. Because of the number of procedures, I usually do a 2-hour training when I'm training administrators on how to actually investigate under title 9. This is not that training, obviously. I think we've got, you know, 13 minutes left, so we're not going to cover all the details, but we'll give you kind of some broad strokes so you have a general understanding. Um so, it
068really does take a long time because there's a lot of procedure built into it. The first is that there's the idea of supportive measures. So, your title 9 coordinator will be meeting with someone saying, "Hey, how is it that we can enable you to kind of come to work and do your job while we are going through this process of actually investigating what happened?" Um there also is an informal resolution, very similar to the others, that the parties can kind of try and work together to to figure out, is there a way that we can resolve this without going through that formal process? But again, don't have to do that. Can absolutely just go forward with that formal complaint. As part of the investigation, both parties get the ability to present witnesses, so there is
069always going to be a formal investigation part of this, where there's going to be witnesses, there's going to be evidence received that both of the parties are expected to actively participate in. And then at the end, each party has the opportunity to review the evidence that the complaint coordinator received. So again, getting back to the idea of confidentiality, this is one of those types of complaints where both parties have the right to review, what did everybody say, what information did you get? And the reason why is because each party then gets to file a response and say, "Here's why I think you should decide this in my favor based on the information that was collected during that investigation." After that, there's an investigative report. But because this process is so long, that's not the end
070of it yet. Uh there's then a question and answer period where each party gets to submit questions of each other in writing and see answers to those questions. Uh they have to be relevant questions. I have kicked questions out before when people are just asking stuff that I don't know why they want to know that, but it has nothing to do with the complaint. Uh so, this is not necessarily free for all, but it's the idea of, hey, you get to have some follow-up information based on that investigative report. And then there's ultimately going to be a formal determination. Um af- after that formal determination is reached, there then is the opportunity to appeal. So, that was a lot, but I I the point is that there's a multi-tiered step in with title 9 complaints,
071where it does take a while to investigate them. It just does because of the amount of process that is in place. Um but it is a a process that the idea is that the parties get access to information and that they get to actively participate in it, so that they should they get to know what is the information that was collected by the school district to help support whatever that school district's decision might be. Okay, I think okay. Ultimately, there also is the ability to appeal, just like with the other ones, and then there is a time limit for that appeal decision to be made here as well. All right. So, I wanted just briefly mention threatening behavior because it's something this policy was something that certainly is a workplace conduct issue. It doesn't quite
072fit into the other ones that there isn't necessarily a formal complaint procedure that goes along with it. So, this I think is an example of, and the staff conduct will be the same, how there's a lot of things that someone might do in the workplace that's not acceptable, that's a violation of the policy. Threatening behavior is one of them. Um but there's not going to be a process for HR to go through that's really going to be something that should go to your supervisor. So, your policy does have a uh your board does have a policy that specifically prohibits any type of threatening behavior, any type of intimidation of staff member. And those are the sorts of things I could go to a supervisor to say, "Hey, look, someone is behaving in this way towards
073me, making me feel threatened in some way, intimidating me in some way, um and, you know, we need to deal with that." Whistleblower. So, I want to talk about whistleblower because I think it gets the idea of retaliation, and people get concerned about retaliation, and, you know, what kind of protections do I have if I come forward? You've just told me that it may or may not be confidential depending on, you know, how things uh happen with that investigation. So, how is it that I'm going to be protected if I do make a complaint or if I'm a witness in an investigation and I have to talk about what it was that I may have seen. There is whistleblower protection uh under the board's policy. This also is something that exists in the law, so
074it's not something the school district made up. And that whistleblower could protection applies to anyone who is aware of a possible violation of board policy or administrative guidelines. That's built into your whistleblower protection policy. And um that the board has the authority to correct. So, you know, that is something that potentially will apply. There are certain procedures that have to be followed in order for somebody to have whistleblower protection. I did have a case years ago with someone who um went straight to DEW about something. He made a false report to DEW about some other employees that had been involved in a disciplinary action against him and tried to claim whistleblower protection saying, "Well, I was just reporting wrongdoing to DEW." I said, "It doesn't apply. Number one, whistleblower protection doesn't apply to false reports,
075right? You don't get to make a a false report and then say, you know, I'm protected. But you also have to go through the correct channels in order to have that protection." So, the policy really lays these out, but basically the idea is that you start with your immediate supervisor, right? So, if you have an issue, you go with your immediate supervisor. If that person isn't responsive, then you can move up to the superintendent, and if that official isn't responsive, then you can move up to people like the board president, the district's legal counsel, or the appropriate outside agency, which is what that person did. They kind of went straight to the top instead of working through the channels. Um so, if you really are concerned about something like whistleblower protection, you want to make
076sure that, hey, do it the right way. Talk to the supervisor first, and then if it doesn't get resolved, then you can kind of move up that process under the district's policy as far as how to resolve it. The district has no obligation to correct violations under the whistleblower policy. So, the idea is that, hey, if we report something and we find that there is a violation, that the district is going to do something about it. So, that's the other part to know, that, you know, part of being a whistleblower is the idea is we're trying to correct something in the district, and that's the reason why we're bringing the information forward. If an employee becomes aware of uh a possible violation, and the employee reasonably believes that it's a criminal offense that is likely
077to cause an imminent uh risk of harm to the persons, um the employee is required to notify their their immediate supervisor, right? So, if it's a bad enough offense, we as a school district, as school district employees, are supposed to be immediately notifying their supervisor of those things. Again, that's a very similar process for those types of situations where, hey, look, if your supervisor isn't immediately responsive, then you can move up the chain. But the idea being even those serious things, we want to go immediately to that supervisor. Now, if the supervisor is the person involved, then in my opinion, it would be okay to kind of move up the chain immediately, perhaps go to HR or somebody else, right? That's okay. But absent that, we're supposed to be starting with the supervisor. And I
078do sometimes have situations where people don't do that because, you know, maybe they don't like their supervisor, maybe they don't trust their supervisor. You have to give that person a chance, right? You have to give the person that opportunity to be responsive. Same thing in terms of the district being required to address those violations. That's the idea. Um there are there is a requirement to an expectation that we're going to actually try to determine the accuracy of things before we try and report them under this policy. So again, getting to my example where I had someone who reported something that turned out could not possibly have been true, right? We looked into it, and what what they claimed was happening, it was alleged testing violation. It was not possible because of the technology being used
079for what he alleged to have happened to have possibly happened. And if he had made any sort of effort to look into what he claimed was happening, he would have discovered that. So, there is an obligation on the employee to make a good faith effort to make sure, hey, what I'm reporting is is accurate, right? That, you know, I'm actually reporting something in good faith that has a reasonable basis. And if people fail to do that and make a false report, well, just like you know, I gave you that example, that person was disciplined. There is, you know, the ability to discipline still for false reports. Um, so these policies are meant to be in good faith, not just sort of making reports cuz we're frustrated or angry with someone or we believe something might
080be the case, but factually it turns out that there's really no reason to believe that. The last item that we're going to talk about in just these last couple of minutes here is retaliation, which I've alluded to a few times already. And retaliation is covered in a variety of the policies that we already talked about. I've sort of pulled it out into one to show you that under multiple policies there is that prohibition against retaliation. So, this is the first um policy that we talked about prohibiting discrimination anyway, and that specifically says that federal law strictly prohibits retaliation against a complainant, respondent, or witness for participating, right? So, it includes witnesses cuz I sometimes do get folks who, you know, they're called in as a witness and they don't really necessarily want to participate, they're
081uncomfortable. That protection applies to witnesses as well as the people who are actually involved in the process as complainants or as respondents. Similarly, the whistleblower has a specific prohibition against retaliation. It says that no one is going to be retaliated against for reporting a possible violation, right? So, as long as we've done that duty to look into something, we believe we have accurate information, and we are we're reporting something in good faith, then we're protected under that retaliation and and we can't be, you know, disciplined or there can't be adverse action against us because we made this report. Again, as I mentioned with my example of of a family member who I had to set straight about she basically said, "Hey, I made this report. That means I can never be fired. I'm good for
082life." Like, "Well, no, right? If you steal something, then you can still be disciplined for that. The fact that you made some separate report at some earlier time doesn't mean that you're scot-free forever and ever. We still have to behave as good employees, but you can't you can't be disciplined because you engaged in that. And you can't be, you know, not promoted or have an adverse action because you had participated in that prior activity." Um, so the whistleblower policy does even lay out kind of what are we talking about when we're talking about retaliation because I also do sometimes have people who feel like they're retaliated against and it's not really retaliation. Retaliation is things like terminating your employment, um, withholding, you know, salary increases that you're supposed to have, transferring or reassigning someone. You
083know, just because you filed a complaint and maybe somebody is not your best friend anymore, that's not necessarily retaliation. That's someone who, you know, what, they just you're not their favorite person anymore. Uh, so we also have to be mindful that not everything that happens is going to constitute retaliation following an issue. That kind of brings us to the end. I want to leave a few minutes for questions if anyone has any questions that we haven't addressed yet. Any questions that come up for anybody? Okay, that's a lot of policy work right there, isn't it? Right. So, um, again, you know, we're looking at this from a standpoint of this is I mean, you all have access to this is all in the board policies online and the administrative guidelines. Um, but you know, we
084want to start off this kind of new phase in terms of being transparent and making sure you're educated towards these policies. So, thank you, Jackie, for coming in. My pleasure. Thanks for having me. Superintendent, thank you. There you go, Jackie. We kind of missed out on your little intro speech, so I fear a follow-up would be great. Um, but seriously, um, I'm grateful to have Chase Chase um coming to HR as our new executive director. And one of the things we had in common was when we met, I said, "Chase, have you ever seen those surveys where it says best companies to work for?" And he was like, "Yeah, yeah, you know." And we both agreed that APS should be one of those companies. And we want you to believe that, but we know that
085there's things happening. We're not blind. But we may not always be aware, okay? So, this is step one of making APS the best we can be. Because we want you to feel like you have an environment that you can work in, that you can thrive in, that you do not feel retaliated in, that's not hard like you you shouldn't come to work feel like it's a burden, you know, because of somebody at work bothering you or because you feel threatened or because you have knowledge of something going on and you want to be a whistleblower, but you're not sure. So, we're trying to equip you to do your job and to provide you with an environment that's conducive to doing your job. So, we really want you to embrace these trainings. Never feel bad to
086ask a question. Maybe you don't have the kind of personality, the spirit that raise your hand and ask publicly, but please feel comfortable enough to follow up with Chase so that he can address any questions, any concerns because truly we never want to have an employee even by accident walk themselves into one of these situations. We want to prevent it and knowledge is power, right? That's what we tell our kids. So, if we want you to stay out of trouble, we need to equip you with the knowledge and give you the opportunity to ask questions. Okay? So, do you feel okay about part one? This is the first of of different trainings that'll be coming your way. Even if you have an idea, you've seen something and you think we should train on it, let
087Chase know. You can send him an email, you can call. Okay? Just don't hug him. No. Just uh you know, without permission. But seriously, we really want this to be a place that you thrive in. Are there any questions before we close down part one? Yes, please. Sorry, I was upstairs, so I wanted to catch you. Um, at the beginning of the training you said under I think policy 3122 that a formal complaint needs to be filed within 30 days. But then you also discussed the possibility of working to rectify that informal complaint with the person. So, when does that timeline start? Is it from when you try to rectify it with the person or from the date that the issue started? Oh, that's a good question. So, it it generally is from the date
088that the issue started, right? But what you but when you come forward and you say, "Hey, I've got this issue." You're making the district aware, right? "Hey, look, this happened. I'm I'm willing to do the informal first, but in my opinion it doesn't mean, 'Oh, sorry, you missed your 30 days and you can't file the formal complaint because you went through the informal first, right?'" So, it does you'd want to start with the process within those 30 days and then you could try the informal and if that doesn't work, you could go to the formal and you haven't kind of missed the boat because you tried to do the informal first. All right, thank you. Yeah, the goal there really is resolution, right? We don't want anybody to go through anything like this, so that
089that's really our focus. Um, so if there's a later report, that's okay, too. We'll still look at it. Okay. Anybody else have any questions? Thank you for coming coming down. That that's great. And for those of you on floor two that can hear me, um, same thing. If you have any questions that that you didn't get answered today, please feel free to email me um, or Judy or Kathy are downstairs as well and they could probably answer your questions as well. Um, please remember to sign in if you have not. If you have not signed in and you sat through this, you will not be getting credit for attending this training and our goal is to have 100% participation across the district. So, this is kind of the first phase and we'll move into the
090next one and make sure everybody has access to this training. It is recorded, um, so, you know, we can keep this on Vector training. Jackie warned me, "Do not do this five years from now because the laws may change." Um, which I do not intend to. Um, so, maybe through the course of the year we use this training to get everybody on board, um, new onboarding for our new employees that come on so they understand our expectations as well. Well, thank you all for coming. Appreciate your time today. I know we're busy people. So, have a great day.