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VII. PROCESS FOR INFORMAL RESOLUTION AND FORMAL PROCESS FOR INVESTIGATING AND RESOLVING COMPLAINTS

This section describes how Olin will: 1) consider informal resolution options; 2) investigate complaints, and 3) determine what, if any, remedial measures and/or disciplinary sanctions are appropriate for individuals found responsible for violating Olin’s Sexual and Interpersonal Misconduct Policy.

As indicated below, some procedures apply to cases that involve either Title IX Sexual Harassment or Non- Title IX Misconduct, and some apply only to one category of alleged misconduct or the other.

The College’s procedures, as outlined below, are intended to resolve complaints of Prohibited Conduct promptly and equitably.

A.  Optional Informal Resolution Procedures

The following Informal Resolution Procedure will not be used in an effort to resolve allegations that an Olin College employee sexually harassed a student. Also, in accordance with the May 2020 Title IX regulations, in cases involving allegations that, if proved, would constitute Title IX Sexual Harassment rather than Non-Title IX Misconduct as defined above, it may only be used if a Formal Complaint is signed by the complainant or the Title IX Coordinator.

All Parties and the Title IX Coordinator must agree to informal resolution for this option to be used. The Title IX Coordinator will assess the request for an informal resolution against the severity of the alleged violation and the potential risks to Olin community members. If the Title IX Coordinator determines that an informal resolution is appropriate, the Title IX Coordinator will notify the Parties in writing that participation is strictly voluntary and is not offered as a condition of enrollment/continuing enrollment, employment/continuing employment, or a waiver of the right to a formal investigation. Moreover, the written notification will state that the parties have the right to withdraw from the informal resolution process at any time and resume the grievance process with respect to the complaint. The notice will also state that the parties have the right to be accompanied by an advisor of their choice, and will describe any consequences resulting from participating in the informal resolution process, including the records that will be maintained or could be shared.

If, after receiving written notification of the above rights, the parties both voluntarily consent in writing to pursue informal resolution, the Title IX Coordinator will assign a trained administrator or third-party external to the College to facilitate the informal resolution process.

The allegation will be deemed resolved when the parties expressly agree in writing to a resolution that is acceptable to them, and which is deemed acceptable and approved by the Title IX Coordinator in consultation with other appropriate College administrators. If, however, informal resolution efforts are unsuccessful, the investigation and/or grievance hearing process will continue.

A party may withdraw from the informal resolution process at any time before the parties agree to a resolution in writing. The Title IX Coordinator may also reinitiate an investigation at any time they deem appropriate.

 

B.  The Investigation Phase of the Formal Resolution Process

The procedures used during the investigation phase of the formal resolution process will be the same in cases that involve allegations of either Title IX Sexual Harassment or Non-Title IX Misconduct.

 

NOTICE OF AN INVESTIGATION. If an investigation is going to be initiated, the Title IX Coordinator will prepare a written notice to the complainant and respondent as described in the Notice of the Allegation(s) to the Parties section above, and that includes information about any supportive measures in place of which either party needs to made aware. This written notice does not constitute a finding or a determination of responsibility.

INVESTIGATION PHASE GUIDELINES. During the investigation and throughout the formal grievance process, the Title IX Coordinator will:

  1. Provide an equal opportunity for the parties to present witnesses, including fact and expert witnesses, and other inculpatory and exculpatory evidence;
  2. Not restrict the ability of either party to discuss the allegations under investigation or to gather and present relevant evidence;
  3. Provide the parties with the same opportunities to have others present during any grievance proceeding, including the opportunity to be accompanied to any related meeting or proceeding by an advisor of their choice, who may be, but is not required to be, an attorney, and not limit the choice or presence of advisor for either the complainant or respondent in any meeting or grievance proceeding (see the Information about Advisors in Connection with Allegations of Prohibited Conduct section below for more information); however, the College may establish restrictions regarding the extent to which an advisor may participate in the proceedings, as long as the restrictions apply equally to both parties;
  4. Provide, to a party whose participation is invited or expected, written notice of the date, time, location, participants, and purpose of all hearings, investigative interviews, or other meetings, with sufficient time for the party to prepare to participate;
  5. Provide both parties a timely and equal opportunity to inspect and review any evidence obtained as part of the investigation that is directly related to the allegations raised in the formal complaint, including the evidence upon which the College does not intend to rely in reaching a determination regarding responsibility and inculpatory or exculpatory evidence whether obtained from a party or other source, so that each party can meaningfully respond to the evidence prior to conclusion of the investigation.

 

INFORMATION ABOUT ADVISORS IN CONNECTION WITH ALLEGATIONS OF PROHIBITED CONDUCT. Each party may have a single advisor of their choice to guide and accompany them throughout the investigation, grievance hearing (where applicable in Title IX Sexual Harassment cases), and appeal processes. The advisor may be a friend, mentor, family member, advocate, confidential resource provider, attorney or any other supporter a party chooses to advise them.

During the investigation phase, advisors may not participate actively and may not speak or otherwise communicate on the part of the party that they represent. However, the advisor may ask to suspend any meeting or interview briefly to provide private consultation related to the investigation proceeding in progress.

An advisor is subject to the same confidentiality expectations applicable to others in attendance. Accommodations, including scheduling of interviews or reviews, generally will not be made for any advisor if they unduly delay the process. Without prior approval of the Title IX Coordinator, as determined in their sole discretion, the advisor is not permitted to attend a meeting or proceeding without the party. Olin reserves the right to take appropriate action regarding any advisor who disrupts the process, or who does not abide by the restrictions on their participation as determined in the sole discretion of the Title IX Coordinator. A union-represented employee who is the respondent may choose an advisor who is not a union representative, if the respondent does not desire to have the union representative participate in the proceeding.

DESIGNATION OF INVESTIGATOR. The Title IX Coordinator will designate at least one Investigator to conduct a prompt, fair, and impartial investigation of the reported conduct and prepare a report of investigative finding (the “Investigative Report”). At Olin’s discretion, the Investigator may be an external investigator, and more than one investigator may be assigned (though “Investigator” will be used in these procedures for ease of reference). All investigators will be selected from a group of qualified and trained individuals engaged by Olin for the purpose of conducting investigations under Olin’s Sexual and Interpersonal Misconduct Policy. Investigators will receive not less than annual training on issues relating to sexual misconduct, investigatory procedures and hearing procedures to protect the safety and rights of students and employees and promote accountability. The Title IX Coordinator will provide the parties with the name of the investigator(s) assigned to investigate the reported conduct. As soon as possible, but no later than three (3) calendar days after notification of the identity of the Investigator, the parties should inform the Title IX Coordinator (in writing) of any conflicts of interest with regard to the selected Investigator. The Title IX Coordinator will consider the nature of the reported conflict and determine if different investigator(s) should be assigned. The Title IX Coordinator’s decision regarding any conflicts is final. The Title IX Coordinator may consult with other Olin employees (e.g., the Dean of Student Affairs and/or Chief Human Resources Officer) to discuss any conflicts of interest.

NATURE OF THE INVESTIGATION. The investigation will include separate interviews with the complainant, the respondent, and any witnesses whom the Investigator believes will provide necessary and relevant information. The investigation may include review of documentation or other items relevant to the reported conduct. The Investigator will provide the parties with written notices of meetings in which their presence is required.

THE PARTIES’ IDENTIFICATION OF POTENTIAL WITNESS AND DOCUMENTATION. The parties have the opportunity to identify potential witnesses who have specific information about the reported conduct and with whom they would like the Investigator to speak. The parties also have the opportunity to provide the Investigator with any documentation or other items or questions they would like to be considered (and, in Non-Title IX Misconduct cases in which no hearing will be held, with a more formal opportunity to submit specific questions to the Investigator for consideration, as detailed below). All information described in this section must be presented to the Investigator in writing and include a brief description as to how the persons, documents, and/or items are relevant to the reported conduct. This information must be provided to the Investigator during the Investigation Phase and without delay upon becoming aware of it. The Investigator will exercise discretion in their determination of what information to consider and which potential witnesses identified by the parties can provide relevant information to the investigation.

INVESTIGATION PROHIBITIONS. Neither party will be permitted to question or cross-examine the other Party directly during the investigation or any applicable hearing proceedings. Moreover, the Investigator generally will not gather or consider information related to either party’s sexual history outside of the conduct in question unless offered to prove someone other than the respondent committed the alleged conduct, or if the questions and evidence concern specific incidents of the complainant’s prior sexual behavior with respect to the respondent and are offered to prove consent.

RESPONDENT VOLUNTARY AGREEMENT TO POLICY VIOLATION. At any point prior to the conclusion of the investigation or grievance hearing, a respondent may agree, in writing, to 1) the alleged violation(s) of Olin’s Sexual and Interpersonal Misconduct Policy and 2) a proposed sanction. In such a situation, the Title IX Coordinator or assigned Hearing Officer (if applicable) may propose sanction(s) for the respondent and, if the complainant and the respondent agree to such proposed sanction(s), then the complaint may be resolved without a hearing and without any further rights of appeal by any party. If either the complainant or the respondent objects to such proposed sanction(s), then the matter will be assigned to a Hearing Officer in accordance with the Grievance Hearing Phase, who will convene a hearing for the exclusive purpose of determining a sanction.

INSPECTION AND REVIEW OF EVIDENCE. Prior to completion of the investigative report, the Investigator will send to each party and the party’s advisor, if any, in an electronic format or a hard copy any evidence obtained as part of the investigation that is directly related to the allegations raised in a complaint (including the evidence upon which the College does not intend to rely in reaching a determination regarding responsibility and inculpatory or exculpatory evidence whether obtained from a party or other source) so that each party can meaningfully respond to the evidence prior to conclusion of the investigation.

 

SPECIAL PROCEDURE FOR POSING QUESTIONS TO OTHER PARTY AND WITNESSES IN NON-TITLE IX MISCONDUCT CASES 

In cases that involve allegations of only Non-Title IX Misconduct or violations of other implicated policies that are being addressed through this Policy and its procedures, but no allegations of Title IX Sexual Harassment (and in which no hearing will be held, as outlined in section VII.D. below), each party may, within 7 days of the evidence being made available for their review, inform the Investigator of any questions that they would like the Investigator to pose to the other party or any witnesses. The Investigator will decide in their discretion which, if any, such questions they will pose to the other party and any witnesses and how exactly they will be phrased. The Investigator will notify the parties when they have concluded their posing of any additional questions to the other party and witnesses, at which point the 10 day period for the parties to prepare their written responses following their inspection and review of evidence (explained immediately below) will begin.

 

WRITTEN  RESPONSE  FOLLOWING  PARTIES’  INSPECTION  OF  REVIEW  AND EVIDENCE

At least 10 days after the evidence is made available for inspection and review in Title IX Sexual Harassment cases, and at least 10 days after the Investigator notifies the parties that they have concluded their posing of any additional questions to the other party and witnesses in Non-Title IX Misconduct cases, he parties may submit a written response, which the Investigator will consider prior to completion of the Investigative Report. In Title IX Sexual Harassment cases, the Investigator will make all such evidence subject to the parties’ inspection and review available at any hearing to give each party equal opportunity to refer to such evidence during any hearing, including for purposes of cross-examination. In Non-Title IX Misconduct cases, the Investigator will make all such evidence available to the Decision-Maker for their review, as outlined in section VII.D. below.

INVESTIGATIVE REPORT. At the conclusion of the Investigation Phase, the Investigator will prepare an Investigative Report, which will include a summary of the factual information presented during the Investigation Phase, and a separate section where the Investigator point(s) out relevant consistencies or inconsistencies (if any) between different sources of information. The Investigative Report will not include a determination by the Investigator as to whether the respondent has violated Olin’s Sexual and Interpersonal Misconduct Policy or what sanctions may be appropriate. The report will be issued in an electronic format or a hard copy to each party and the party’s advisor at least 10 days prior to the formal grievance hearing (where applicable, in Title IX Sexual Harassment cases) for their review and written response. The parties’ written responses should be submitted to either the Hearing Officer (in cases involving allegations of Title IX Sexual Harassment) or to the designated decision-maker (in cases involving allegations of only Non-Title IX Misconduct) within 10 days after the report was issued to them.

 

C. Hearing Phase in Title IX Sexual Harassment Cases

The following hearing phase procedures are required by the May 2020 Title IX regulations and will be used by Olin only in cases covered by those regulations, that is, cases in which some or all of the alleged conduct, if proven, would constitute Title IX Sexual Harassment as defined above. These hearing phase procedures will not be used in Non-Title IX Misconduct cases; the procedures that will be used in Non- Title IX Misconduct cases are outlined in section VII.D. below.

 

Following the opportunity for review and comment of the Investigative Report, the Title IX Coordinator will forward the case to a specially trained impartial Title IX Hearing Officer either internal or external to the College for formal resolution via a grievance hearing. Hearing Officers will receive not less than annual training on issues relating to sexual misconduct, investigatory procedures and hearing procedures to protect the safety and rights of students and employees and promote accountability.

The Hearing Officer may not have a conflict of interest and cannot be the same person(s) as the Title IX Coordinator or the Investigator.

 

NOTICE OF GRIEVANCE HEARING

The Title IX Coordinator will send a written notice of the hearing to the parties within ten business days prior to the hearing date. The written notice will include the following information:

  1. The time, date, and location of the hearing and the contact information of the Hearing Officer assigned to hear the matter;
  2. Information about requesting reasonable accommodations for the hearing;
  3. A copy of or link to the College’s hearing rules and procedures;
  4. Notice of the requirement that only an advisor may conduct cross-examination directly, orally, and in real time at the hearing, and that if a party does not have an advisor, the College will provide one free of charge;
  5. Notice of the right to request that the parties be separated with the utility of technology to enable the parties to see and hear one another as needed from different rooms;
  6. Notice of the right to raise a conflict of interest with the Hearing Officer in writing to the Title IX Coordinator.

     

HEARING RULES

The grievance hearing will be conducted in a fair and equitable manner for the purpose of determining whether it is more likely than not that the respondent violated Olin’s Sexual and Interpersonal Misconduct Policy or other implicated policy (i.e. “the preponderance of the evidence” standard).

The following rules and regulations apply to all grievance hearings:

  1. Hearings will be private and closed to everyone except the involved persons;
  2. The live hearing may be conducted in person or virtually at the discretion of the Hearing Officer;
  3. At the request of either party, the parties will be separated, but technology will be utilized to enable the parties to see and hear one another as needed from different rooms.
  1. The use of such technology must enable the Hearing Officer and parties to see and hear the witnesses testify in real time;
  2. Training in the usage of such technology will occur before the hearing to ensure proper execution;

4. Both parties will be provided an equal opportunity to present witnesses and other inculpatory and exculpatory evidence;

5. The respondent is presumed not responsible unless and until determined to be responsible for the alleged violation(s) at the end of the grievance process based upon a preponderance of the evidence, or more likely than not, standard;

6. During the hearing, only the parties’ respective advisors will be allowed to conduct cross- examination directly, orally, and in real time:

  1. Cross-examination may not be conducted directly by a party;
  2. If a party does not have an advisor, the College will provide a trained advisor of its choice to the party free of charge;

7. During the hearing, the Hearing Officer will have the right to determine the relevancy of any questions asked on cross-examination and may exclude any irrelevant questioning.

  1. The Hearing Officer will provide an explanation to the parties for excluding a question on the basis of irrelevancy.
  2. Questions about the predisposition or prior sexual behavior of the complainant are deemed not relevant, unless such questions and evidence about the complainant’s prior sexual behavior are offered to prove that someone other than the respondent committed the alleged conduct, or if the questions and evidence concern specific incidents of the complainant’s prior sexual behavior with respect to the respondent and are offered to prove consent;
  3. The Hearing Officer may not draw any inference about the determination regarding responsibility based solely on a party’s or witness’s absence from the live hearing or refusal to answer cross-examination or other questions;
  4. The Hearing Officer will not require, allow, rely upon, or otherwise use questions or evidence that constitute, or seek disclosure of, information protected under a legally recognized privilege, unless the person holding such privilege has waived the privilege in writing;

8. An audio recording of the hearing will be created by the College, which shall remain the property of Olin but will be made available to the parties for review only;

9. Cell phones and recording devices may not be used in the hearing room(s) (unless approved by the Hearing Officer in advance) and must be turned off before the hearing convenes;

10. Formal rules of evidence (e.g., federal or state rules for court) shall not be applicable;

11. The Hearing Officer may call any relevant witness to participate in a proceeding. Admission of any person to the hearing will be at the discretion of the Hearing Officer;

12.  Pertinent records, video-surveillance images, relevant exhibits, and written statements may be accepted as information for consideration by the Hearing Officer.

13.  The Hearing Officer will objectively review all relevant evidence—including both inculpatory and exculpatory evidence;

14.  The Hearing Officer may temporarily delay the grievance hearing or extend time frames for good cause with written notice to the complainant and the respondent of the delay or extension and the reasons for the action. Good cause may include considerations such as:

  1. The absence of a party, a party’s advisor, or a witness;
  2. Concurrent law enforcement activity; or
  3. The need for language assistance or accommodation of disabilities. The College asks all parties and witnesses to inform the Title IX office as soon as possible if they believe they may need disability-related accommodations, as such accommodations may require additional documentation if an individual does not already have a file with the College's disability services office.

 

WRITTEN DETERMINATION AND NOTIFICATION

Following the hearing, the Hearing Officer will review all information presented through the investigation and live hearing processes and then issue a written determination regarding responsibility, which includes:

  1. The allegations of Prohibited Conduct;
  2. A description of the procedural steps taken;
  3. Findings of fact;
  4. Conclusions regarding applying the policy to the facts;
  5. A statement with rationale detailing the result of each allegation;
  6. A listing of any imposed sanctions and any remedies provided; and
  7. An explanation of the College’s appeal process.

The written determination will be delivered simultaneously to both parties within 7 business days after a final determination of a complaint, not including any time for appeal, unless good cause for additional time is shown.

Standard of Proof. All findings and determinations of responsibility under Olin’s Sexual and Interpersonal Misconduct Policy will be made using a preponderance of the evidence standard. This standard requires the determination of whether it is more likely than not that a fact exists or that a violation of Olin’s Sexual and Interpersonal Misconduct Policy and/or other implicated policy occurred.

Please note that the preponderance of the evidence standard is not the standard used for criminal culpability in most jurisdictions, and a determination of responsibility under Olin’s Sexual and Interpersonal Misconduct Policy does not equate with a finding of a violation of criminal laws. Conversely, lack of a prosecution or conviction in a criminal proceeding does not necessarily imply that Olin’s Sexual and Interpersonal Misconduct Policy was not violated. The two procedures are significantly different and utilize different standards for determining violations.

 

DETERMINATION OF SANCTIONS

The Hearing Officer will determine the appropriate sanction(s) in the event that the respondent is found responsible for violating the College’s policy prohibiting Title IX Sexual Harassment or another implicated policy. The determination will be in writing and will be shared simultaneously with the parties as detailed in the Written Determination and Notification section above.

More detail about the types of sanctions and additional remedies that may be applied in Title IX Sexual Harassment cases is provided in section VII.E. below.

Appeals: Within three (3) business days of the delivery of the notice of the decision of responsibility and/or sanction, either Party may appeal the decision by submitting to the Title IX Coordinator a letter stating why the party requesting the appeal believes the determination of responsibility and/or sanctions were inappropriate. A party appealing under this section may only appeal on the following grounds:

  1. Procedural error by the Investigator or Hearing Officer that materially prejudiced the party requesting review and/or affected the outcome of the case; and/or
  2. Previously unavailable and/or newly discovered material or relevant evidence that could have significantly impacted or affected the outcome of the case that was not known to the party requesting review and not available to the Investigator and Hearing Officer; and/or
  3. The Title IX Coordinator, Investigator, or Hearing Officer had a conflict of interest or bias that affected the outcome; and/or where the sanction is disproportionate to the findings, the reporting party and the responding party shall be provided with an equal opportunity to appeal decisions regarding responsibility or sanctions; and/or
  4. The sanction was disproportionate to the findings.

The party submitting the appeal must set forth, in detail, the grounds for review and must attach all materials that they wish to have considered in the appeal process. If both the complainant and respondent appeal, the appeals will be considered concurrently. The Title IX Coordinator may dismiss the appeal for failing to state one of the grounds for appeal listed above. Failure to submit a written appeal within three (3) business days forfeits the right to appeal under this policy, regardless of the outcome of the other party’s appeal (if submitted). If either the complainant or respondent submits an appeal, the Title IX Coordinator will notify the other that an appeal has been filed and the grounds of the appeal. The non-appealing student may submit a written response within five (5) days after notice of an appeal.

The Appellate Officer(s): The Appellate Officer(s) will decide the merits of any appeal and, in doing so, may consult with the Investigator, the Title IX Coordinator, the Hearing Officer and any other individual the Appellate Officer(s) deem appropriate. Appeals are decided based on the objective evaluation of the record of the original proceeding and any relevant evidence submitted by the parties.

The Appeals Officer shall not substitute the officer’s judgment for the decision of the original Hearing Officer or attempt to rehear the case. Credibility determinations will not be based on a person’s status as a complainant, respondent, or witness.

Sanctions of all types (including, but not limited to, any form of suspension, dismissal, or separation from the College) can be imposed, in full or in part, while an appeal is pending at the sole discretion of the Title IX Coordinator.

The Appellate Officer(s) may:

1. Deny the appeal and affirm all or part of the determination of responsibility or the determination of sanction; or

2. Refer the matter back to the Investigator and Title IX Coordinator for further consideration, with specific instruction. In the event of a referral for further consideration, the Title IX Coordinator will be consulted, and further proceedings may commence, as appropriate under the circumstances, consistent with Olin’s Sexual and Interpersonal Misconduct Policy.

Note: Cases should only be recommended for remand for a new hearing if the specified procedural errors or conflict of interest was so substantial, they effectively denied the respondent or complainant a fair hearing, or new evidence merits a new hearing.

The decision of the Appellate Officer(s) regarding the appeal will be in writing, describing the result of the appeal and the rationale for the result, and is final. The Title IX Coordinator will inform the Parties simultaneously and in writing of the outcome of the appeal.

Once the appeals process is completed, it shall be the responsibility of the Title IX Coordinator to oversee the implementation of any imposed sanctions, as applicable.

D. Formal Resolution Process in Non-Title IX Misconduct Cases

In cases that involve allegations of only Non-Title IX Misconduct or violations of other implicated policies that are being addressed through this Policy and its procedures, but no allegations of Title IX Sexual Harassment, the determination regarding responsibility will be made by a decision-maker selected by the Title IX Coordinator from a pool of trained decision-makers (“Decision-Maker”). Decision-Makers will receive not less than annual training on issues relating to sexual misconduct, investigatory procedures and hearing procedures to protect the safety and rights of students and employees and promote accountability. The Decision-Maker will base their decision on the Investigative Report and any documents referenced therein, the parties’ written responses to the Investigative Report, and any additional file documents referenced by the parties in their written submissions.

 

DETERMINATION OF SANCTIONS

The Decision-Maker will determine the appropriate sanction(s) in the event that a respondent is found responsible for violating the College’s policy prohibiting Non-Title IX Misconduct or another implicated policy. The determination will be in writing and will be shared simultaneously with the parties as detailed in the Written Determination and Notification section above.

 

More detail about the types of sanctions and additional remedies that may be applied in Non-Title IX Misconduct cases is provided in section VII.E. below.

E. Sanctions

The following sanction-related information applies in cases involving either alleged Title IX Sexual Harassment, Non-Title IX Misconduct, or both.

 

TYPES OF SANCTIONS

  1. Employees. Sanctions imposed with respect to respondents who are employees may include, but are not limited to, one or more of the following: dismissal from employment, non-renewal of an employment contract, suspension, probation, reprimand, warning, issuance of a no-contact order, training and/or counseling.
  2. Students. Sanctions may include, but are not limited to, one or more of the following: expulsion, suspension, probation, reprimand, warning, restitution, education/counseling, issuance of a no-contact order, restriction from extracurricular programs or activities, loss of leadership opportunity or positions in activities, housing restriction/relocation, and/or loss or restriction from College employment.

3. Considerations. In determining an appropriate sanction, the Hearing Officer may take into account the following:

  1. The nature and circumstances of the harassment.
  2. The impact of the harassment on the complainant.
  3. The impact of the harassment on the College community.
  4. The disciplinary history of the respondent.
  5. Any other mitigating or aggravating circumstances.

 

Additional Remedies. The Title IX Coordinator may also identify additional remedies to address the effects of the conduct on the impacted party. Remedies may include extending or making permanent any supportive measures. If a complainant declined or did not take advantage of a specific supportive measure or resource previously offered, Olin may re-offer the supportive measure, as applicable or necessary. The Title IX Coordinator may also consider broader remedial action for the campus community, such as increased supervision or monitoring, targeted or increased education and prevention efforts, and review of policies and procedures. In addition, if any matter raised, but not addressed hereunder, potentially violates any other Olin policy, rule, or procedure, the Title IX Coordinator may refer the matter raised to the appropriate officials, irrespective of the finding under this Policy.