CLERY ACT CAMPUS SECURITY

CLERY ACT CAMPUS SECURITY 2015 ANNUAL SECURITY REPORT / CRIME STATISTICS Heritage College, Kansas City, Missouri 2012 2013 2014 CRIMINAL OFFENSES ON CAMPUS Burglary 0 0 0 Arrests for liquor law violations, drug law violations, and illegal weapons possession (include persons who were 0 0 0 referred for campus disciplinary action for any of the above) Domestic Violence n/a 0 0 Dating Violence n/a 0 0 Stalking n/a 0 0 CRIMINAL OFFENSES PUBLIC PROPERTY Burglary 0 0 0 Arrests for liquor law violations, drug law violations, and illegal weapons possession (include persons who were 0 0 0 referred for campus disciplinary action for any of the above) Domestic Violence n/a 0 0 Dating Violence n/a 0 0 Stalking n/a 0 0 CRIMINAL OFFENSES IN OR ON A NON-CAMPUS BUILDING OR PROPERTY Burglary 0 0 1 1

Heritage College, Kansas City, Missouri 2012 2013 2014 Arrests for liquor law violations, drug law violations, and illegal weapons possession (include persons who were 0 0 0 referred for campus disciplinary action for any of the above) Domestic Violence n/a 0 0 Dating Violence n/a 0 0 Stalking n/a 0 0 HATE CRIMES* ON CAMPUS Burglary 0 0 0 Simple Assault 0 0 0 Larceny-theft 0 0 0 Intimidation 0 0 0 Destruction/damage/vandalism of property 0 0 0 Other crimes involving injury to any person in which the victim is intentionally selected because of the actual or perceived race, gender, religion, national origin, sexual n/a 0 0 orientation, gender identity, ethnicity, or disability of the victim HATE CRIMES* PUBLIC PROPERTY Burglary 0 0 0 Simple Assault 0 0 0 Larceny-theft 0 0 0 Intimidation 0 0 0 Destruction/damage/vandalism of property 0 0 0 Other crimes involving injury to any person in which the victim is intentionally selected because of the actual or perceived race, gender, religion, national origin, sexual n/a 0 0 orientation, gender identity, ethnicity, or disability of the victim HATE CRIMES* IN OR ON A NON-CAMPUS BUILDING OR PROPERTY 2

Heritage College, Kansas City, Missouri 2012 2013 2014 Burglary 0 0 0 Simple Assault 0 0 0 Larceny-theft 0 0 0 Intimidation 0 0 0 Destruction/damage/vandalism of property 0 0 0 Other crimes involving injury to any person in which the victim is intentionally selected because of the actual or perceived race, gender, religion, national origin, sexual n/a 0 0 orientation, gender identity, ethnicity, or disability of the victim * In the event of Hate Crime occurrences, each event would be identified according to its category of bias (race, gender, religion, national Origin, sexual orientation, gender identity, ethnicity, or disability) Note: Heritage does not have residential facilities or student housing. TIMELY WARNING POLICY Policy for Making Timely Warning Reports to Members of the Campus Community Regarding the Occurrence of Crimes If there is an immediate threat to the health or safety of students or employees occurring on campus, the school will follow its Emergency Notification Procedures. The manner in which the warning will be issued will depend on the nature of the crime. Warnings may be in writing, electronically, or in person by the Executive Director or a designated employee. The Executive Director will warn members of the campus community regarding the occurrence of any Clery Act crime in a timely manner for the purpose of aiding in the prevention of similar crimes. ANNUAL DISCLOSURES POLICY Policy for Preparing the Annual Disclosure of Crime Statistics The Executive Director maintain a crime log and will collect the crime statistics for the preceding year to prepare the annual report of crime statistics. The Executive Director may appoint an employee to maintain crime log and crime statistic information. Heritage makes a reasonable, good faith effort to obtain the required statistics from the local and State policy agency, and may rely on information supplied by them for inclusion in the report. The Heritage corporate office will facilitate the annual disclosure of Crime Statistics. TITLES OF PERSONS TO REPORT CRIMES List of Titles of Each Person to whom Students and Employees Should Report Criminal Offenses for the Purpose of Making Timely Warning Reports and the Annual Statistical Disclosure Students and employees should report criminal offenses to the Executive Director. The Director of Education or senior education manager in the building can accept crime reports on behalf of the Executive Director. 3

SECURITY AND ACCESS POLICY CONCERNING SECURITY OF AND ACCESS TO CAMPUS FACILITIES Students will be allowed access to the school during normal class hours and during prearranged facility use times. A school employee will be responsible for opening and securing facilities daily. Heritage does not have campus residences. Security is evaluated annually and is a consideration in building updates. SECURITY CONSIDERATIONS USED IN THE MAINTENANCE OF CAMPUS FACILITIES Heritage does not have campus residences. LAW ENFORCEMENT POLICY CONCERNING CAMPUS LAW ENFORCEMENT Enforcement Authority: Heritage does not have security personnel assigned to the school. The Executive Director and senior school staff members will work with State and local police agencies to enforce the law. School staff members do not have the authority to arrest individuals. Crime Reporting: All students and employees are encouraged to accurately and promptly report all crimes to the appropriate police agencies and to the Executive Director or Title IX Coordinator, depending on the nature of the crime. Students may report crimes on a voluntary, confidential basis for inclusion in the annual security report. Pastoral Counseling and Professional Counseling The school does not provide pastoral or professional counseling, but will assist in obtaining resources. INFORMING STUDENTS AND EMPLOYEES Informing Students and Employees About Campus Security Procedures And Practices, And About The Prevention Of Crimes Students and employees are notified by email on or before October 1st of each year of the annual security report and how to access it. New employees receive this information in their new-hire paperwork. New students are informed in the school catalog of the security information that is available to them upon request. Students and employees are encouraged to be responsible for their own security and the security of others. TYPE AND FREQUENCY OF PROGRAMS REGARDING CAMPUS SECURITY PROCEDURES Students and employees are made aware of the Campus Security Procedures when their employment/training commences. The school conducts a test of these procedures at least annually to assess its effectiveness. The prevention of crimes begins with awareness. Educating students and employees regarding what constitutes a crime, the procedures to report crimes, and the sanctions associated with the commission of crimes, aide in the crime prevention efforts on campus. MONITORING AND RECORDING OF OFF-CAMPUS CRIMINAL ACTIVITY The monitoring and recording of criminal activity off campus will be accomplished through local police agencies. Heritage does not have student organizations or offcampus housing facilities. 4

DRUG AND ALCOHOL POLICIES AND PREVENTION PROGRAMS The Heritage Drug and Alcohol Abuse Prevention policy is available at the campus and can be accessed using the following link: http://www.heritagecollege.edu/securityreport/info_files/drugpolicy.pdf A STATEMENT OF POLICY REGARDING DOMESTIC VIOLENCE, DATING VIOLENCE, SEXUAL ASSAULT AND STALKING Sexual Crimes and Preventions Heritage is fully committed to comply with Section 485(f) of the Higher Education Act of 1965 (Clery Act), as amended by Violence Against Women Reauthorization Act (VAWA). Sexual offenses, including crimes of harassment, assault, dating violence, domestic violence and stalking is prohibited. The policy regarding sexual crime prevention programs and the procedures to be followed if such an offense occurs, is delivered annually to each enrolled student and employee, and can be provided upon request. Heritage has a zero-tolerance policy for crimes of dating violence, domestic violence, sexual assault, and stalking. Policies to Prevent Dating Violence, Domestic Violence, Sexual Assault and Stalking Policy Statements Promoting the awareness and prevention of sexual offenses, including crimes of harassment, assault, rape, domestic violence, dating violence, and stalking will be conducted in a variety of formats including, but not limited to, seminars, guest speakers, media presentations and written materials. New students and employees will be provided orientation materials, and these are also available at the school. Awareness of Sex Offenses Reported Students and employees are made aware of any incidents of sex offenses through the annual security report. This report is delivered annually to all enrolled students and employees and can be provided by request and in this. Violence Against Women Act (VAWA) Terms The definitions provided below are found in the Violence Against Women Act. Sexual Harassment: Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature that tends to create a hostile work or educational environment. Sexual Assault: Illegal sexual contact that usually involves force upon a person without consent or is inflicted upon a person who is incapable of giving consent (because of age, or physical or mental incapacity). Rape: Penetration, no matter how slight, of the vagina or anus with any body part or object, or oral penetration by a sex organ of another person, without the consent of the victim. Dating Violence: Violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the victim; and where the existence of such a relationship shall be determined based on a consideration of the following factors: the length of the relationship; the type of relationship; and the frequency of interaction between the persons involved in the relationship. 5

Domestic Violence: A felony or misdemeanor crime of violence committed by a current or former spouse or intimate partner of the victim, a person with whom the victim shares a child in common, a person who is cohabitating with or has cohabitated with the victim as a spouse or intimate partner, a person similarly situated to a spouse of the victim under the domestic or family violence laws of the jurisdiction receiving grant monies [under VAWA], or, any other person against an adult or youth victim who is protected from that person s acts under the domestic or family violence laws of the jurisdiction. Stalking: Engaging in a course of conduct directed at a specific person that would cause a reasonable person to fear for his or her safety or the safety of others; or, suffer substantial emotional distress. Retaliation: An adverse action made against an individual for filing a charge of discrimination or harassment, participating in discrimination or harassment proceeding, or otherwise opposing discrimination or harassment. Hazing: Any action or situation that recklessly or intentionally endangers the mental or physical health or safety of a student for purposes including, but not limited to, initiation or admission into or affiliation with any student group or organization operating under the sanction of Heritage. Hazing occurs if an individual or group: Causes or attempts to cause physical injury or other harm to a student including but not limited to emotional distress, or engages in any conduct which presents a threat to the student s health or safety, which shall include but not be limited to any brutality if a physical nature, such as whipping beating, branding, exposure to the elements, forced consumption of any food, alcohol, drug or other substance, or other forced physical activity that could adversely affect the physical and/or mental health or safety of the student, and any activity that would subject the student to extreme mental stress, such as sleep deprivation, forced sexual conduct, and forced exclusion from social contact. Engages in an action or activity which has a tendency to or which is intended to demean, disgrace, humiliate, or degrade a student, which shall include but not be limited to, forced conduct that could result in extreme embarrassment, or other forced activity that could adversely affect the mental health or dignity of the student. Conduct that by design, intent or recklessness causes a student to be unable reasonably to pursue, or interferes with or attempts to interfere with a student s academic schedule or performance; or Causes, induces, pressures, coerces, or requires a student to violate the law. In response to allegations of hazing it is not a defense that: The victim gave consent to the conduct. The conduct was not part of an official organizational event or sanctioned or approved organization. The conduct was not done as a condition of membership in an organization. 6

Procedures to Follow if a Crime of Sexual Assault, Domestic Violence, Dating Violence, or Stalking has Occurred Get to a safe place Your immediate safety is your first priority. If you are in danger, you should call 911. Stay on the phone as long as you can until help arrives. Remember that the police will help you whether or not you choose to prosecute the assailant. Call a trusted friend or family member for support and/or the victim-assistance services offered by community or law enforcement agencies. Preserving Evidence Anyone who has experienced sexual violence or any sex offense should remember that it is important to preserve all evidence for use in prosecuting the perpetrator. Bathing or douching might be the first thing you want to do, but you may be washing away evidence needed to prosecute the assailant. Wait until you have a medical examination. Also, do not change or alter the crime scene. Changing your clothes is alright, but save the clothing you were wearing at the time of the assault. Place each item of clothing in a separate paper bag and give them to the police. Your clothing could be used as evidence for prosecution. Obtaining Medical Attention A medical examination is to check for physical injury, the presence of sexually transmitted diseases, or pregnancy as a result of the assault. A medical examination will also aid in the police investigation and legal proceedings. A person who has experienced sexual violence or any sex offence contact the Title IX Coordinator for information on obtaining immediate medical attention, if necessary. Reporting Cases of Sexual Violence Any person, who has experienced or witnessed sexual violence, or other sex offense, should immediately contact: The Title IX Coordinator or Designee The school s Title IX Coordinator or Designee is responsible for the school s overall compliance with Title IX of the Education Amendments of the 1972 ( Title IX ), 20 U.S.C. 1681 et seq., and Section 485(f) of the Higher Education Act of 1965 (Clery Act), as amended by VAWA, including response to reports of sexual offenses affecting the campus community. Students or employees who wish to make a report of sexual misconduct should follow the school grievance procedures. Assisting in Notifying Appropriate Law Enforcement Authorities Heritage encourages anyone who has experienced, witnessed, or become aware of sexual violence or any sex offense, to notify the Title IX Coordinator or Designee. Upon request, the school will assist that person with notifying appropriate law enforcement authorities. Confidentiality Heritage wishes to foster an environment in which individuals feel free to discuss concerns and make complaints. The school understands that complainants, witnesses, and others involved in the investigation process may be concerned about the confidentiality of information they are sharing. In some cases, the school may be obligated to take action when it becomes aware of information related to a complaint. Confidentiality will be maintained to the extent possible and consistent with the school s obligation in investigating complaints. Once an individual discloses identifying information to the school through the processes described above, he/she will be considered to have filed a complaint with Heritage. While the confidentiality of information received, the privacy of individuals involved, and compliance with the wishes of the complainant or witnesses cannot be guaranteed, they will be respected to the extent possible and appropriate. 7

Findings and Notification Upon completion of the investigation, the Title IX Coordinator will report the findings of the investigation, based on a preponderance of the evidence, of any proposed resolution to the School Director. The school will then notify both parties in writing of these results, including sanction information. It is the school s goal to conduct an appropriate investigation and report back to the complainant in a timely manner, usually within 45 calendar days of the receipt of the complaint. The circumstances in particular cases may make a shorter or longer investigation necessary or appropriate. Obtaining Counseling, Mental Health Services, and Other Service A person who has experienced sexual violence or other sex offense, and is in need of these services, can obtain resource materials from the Title IX Coordinator. Changes in Academic, Transportation, Living or Work Situations Heritage will make every effort to accommodate, or provide resources for, changes in the student or employee s academic, transportation, living, or work situation if such a change is requested and is reasonably available. Accommodations or protective measures are available if the victim requests them and if they are reasonably available, regardless of whether the victim chooses to report the crime to local law enforcement. Rights and Options Following a report of dating violence, domestic violence, sexual assault, or stalking, whether the offense occurred on or off campus, Heritage will provide the student or employee a written explanation of the student s or employee s rights and options. Bystander Intervention Bystanders are often the largest group of people involved in incidents of sexual assault and gender-based violence and misconduct; they outnumber both the perpetrators and the victims. There are different circumstances in which we can be considered bystanders. A bystander might have knowledge that an incident of sexual violence will occur or is occurring, or a bystander may witness sexual assault or misconduct firsthand. A bystander could have knowledge about an assault that has already occurred. Regardless of the circumstances, we all have a choice whether we will be passive bystanders, standing by and taking insufficient or no action, or whether we will be active bystanders who are engaged and take the necessary action to prevent sexual violence. An active bystander has the power to prevent sexual violence from occurring and to assist survivors of assault in getting the help they need. An active bystander is someone who commits to making a choice to become involved. The first and foremost thing to remember as an active bystander is that you don t do anything that puts your safety at risk! Many, if not most of the actions you will take as an active bystander will be calling on others or the police, for help. Always remember that if you or someone else is in immediate danger, call 911. Registered Sex Offender Policy Students, employees, and the community may search for registered sex offenders on the National Sex Offender Public Website: https://www.nsopw.gov/ Disciplinary Procedures Some examples of sanctions imposed on students could be: conduct advisement, suspension, or withdrawal. Sanctions imposed on employees will be coordinated between the School Director and the Human Resources department. 8

TITLE IX COMPLIANCE Nondiscrimination Policy The Heritage Nondiscrimination policy is available at the campus and can be accessed here: http://www.heritagecollege.edu/securityreport/info_files/nondiscriminationpolicy.pdf Grievance Procedures The Heritage Grievance Procedures are available at the campus and can be accessed here: http://www.heritagecollege.edu/securityreport/info_files/titleixgrievance.pdf EMERGENCY RESPONSE AND EVACUATION Heritage will, without delay, and accounting for the safety of the community, determine the content of the notification and initiate the notification system, unless a notification will, in the professional judgment of responsible authorities, compromise efforts to assist a victim or to contain, respond to, or otherwise mitigate the emergency. If there is a report of an emergency or dangerous situation, the Executive Director shall be immediately contacted. Students or employees should not delay contacting an instructor or member of the management team if the Executive Director is inaccessible. Upon confirmation of a significant emergency or dangerous situation involving an immediate threat to the health or safety of students or employees occurring on the campus, the school will refer to its Emergency Preparedness Plan to determine the level/type of emergency and react accordingly. Determination of Appropriate Segments of Community to Receive Notification and Content of Notification In case of emergency, 911 shall be contacted immediately The employee who first learns of the emergency shall contact the Executive Director Upon confirmation of a significant emergency or dangerous situation involving immediate threat to the health and safety of students or employees, the campus community will be immediately notified Initiation and content of the notification is the responsibility of the Executive Director or designee Notification will occur by means of audible alert, email, intercom, text messages, telephone calls, face to face, or any other form of effective communication determined to best address the situation If indicated, the evacuation plan will be implemented The building will be secured and students and employees will be directed to a safe location If indicated, a campus lockdown procedure will be implemented The Executive Director will serve as the media contact and be responsible for dissemination of emergency information to the larger community Responsible Parties and Organizations Responsible parties will include, but are not limited to: The Executive Director, Local, County and State police forces, Local Fire Department personnel, Poison Control, Suicide Hotline, or appropriate utility personnel. Timely Warning A timely warning will be issued for any reported Clery Act crimes. The school will follow its emergency notification procedures. The method and content of the warning will be determined by the Executive Director and will include at a minimum, all information that would promote safety and aid in the prevention of similar crimes. 9

Testing Emergency Response At least once a year, each school will conduct either an announced or unannounced drill or exercise, along with a notification to all students/instructors/staff of the Heritage Emergency response and evacuation procedures. With each test, the school will document a description of the exercise, the date and time of the test, and if it was announced or unannounced. These tests are designed for assessment and evaluation of emergency plans and capabilities. This document was updated on September 22, 2015. 10