OPERATING PRACTICES, STANDARDS, AND POLICIES General Conduct err on the side of caution and to report any concerns regarding abuse BB&N requires that all of its business be conducted with the highest or neglect. No adverse action or retaliation will be taken against any legal and ethical standards. All employees are considered agents individual who in good faith reports suspected abuse or neglect. Any of the school, and should refrain from actions (both personal and employee who is aware of abuse or neglect of a child and does not professional) that damage the integrity and reputation of the school. It comply with their legal responsibility to report under Massachusetts is imperative that all actions and behaviors promote a favorable image law will be subject to disciplinary action, up to and including of the School. termination. Non-compliance with this requirement has serious repercussions and may result in the employee’s loss of coverage under Adult/Student Relationships the school’s liability insurance policy. BB&N encourages the formation of healthy relationships between Whistleblower Policy adults and students. To foster these healthy relationships, it is important to cultivate an environment of mutual respect between adults and BB&N is committed to the highest possible standards of ethical, moral, students. Adults should be aware of the imbalance of power that exists and legal business conduct. In line with this commitment and the between adults, students and recent graduates of BB&N, and should school’s commitment to open communication, the Whistleblower establish boundaries in order to create respectful relationships with Policy applies to all BB&N employees, including part-time, temporary students and recent graduates. BB&N explicitly prohibits romantic, and contract employees, and aims to provide an avenue for employees dating or sexual relationships between its employees and students. to raise concerns and reassurance that they will be protected from BB&N employees should not engage in any physical or other conduct reprisals or victimization for whistleblowing in good faith. The with students and recent graduates that could be perceived as Whistleblower Policy is intended to cover serious concerns that could inappropriate. Employees must also follow the school’s Social Media have an impact on the School, such as actions that: Policy regarding online activity and students. • May lead to incorrect 昀椀nancial reporting; Employees who engage in inappropriate behavior with students are • Are unlawful; subject to immediate termination. In addition, BB&N may be obligated • Are not in line with School policy, including the community to report such conduct to the appropriate authorities, including standards; the Massachusetts Department of Children and Families and law • Otherwise amount to serious improper conduct. enforcement. BB&N will not tolerate harassment or victimization of the complainant Mandatory Reporting Policy (51A) and will make every e昀昀ort to protect the complainant’s identity. BB&N employees are required, as mandated reporters under state law, However, it is important to note that malicious allegations may result M.G.L. c. 51A, to immediately report to the Department of Children in disciplinary action. BB&N also encourages employees to put their and Families (“DCF”) when, in their professional capacity, they have names to allegations to allow the school to properly follow-up and reasonable cause to believe that a child under the age of eighteen complete an investigation into the complaint. Concerns expressed years’ is su昀昀ering from abuse or neglect. All employees at BB&N are anonymously will be investigated, taking into account the seriousness required to report any physical or emotional injury resulting from of the issue raised, the credibility of the concern, and the likelihood of abuse, including sexual abuse; or any indication of a neglect, including con昀椀rming the allegation from attributable sources. malnutrition. BB&N encourages employees to report ethical concerns or allegations Any person at BB&N who believes that a BB&N student is su昀昀ering internally. The school has also implemented a program through from abuse or neglect must contact the appropriate Director and the EthicsPoint to provide an anonymous and con昀椀dential method of Director of Student Support Services who will in turn notify the Head reporting misconduct. To submit a report, contact EthicsPoint by calling of school and DCF, as the law requires. BB&N employees are urged to 844-516-3777 or going online at Ethics Point reporting. - 22 -