Working at Punahou

Code of Conduct for Employees, Contractors, and Volunteers

2023 – 2024

PREAMBLE

The purpose of Working at Punahou – Code of Conduct for Employees, Contractors, and Volunteers (“Working at Punahou”) is to describe Punahou School’s overarching values, and how they translate into standards of professional and ethical conduct required for employees, those performing contracted services, and volunteers at Punahou School (“School”). All employees, contractors, and volunteers are expected to read this document and to adhere to the content therein.

Whereas Working at Punahou sets Punahou’s general expectations for employee, contractor, and volunteer conduct, the following documents provide additional information on School policies, guidelines, and procedures applicable to specific members of Punahou’s workforce:

» Employee Handbook – a summary of policies, guidelines, and procedures applicable to all paid faculty, staff, student workers, and coaches (collectively, “employees”). This document is accessible on myPunahou;

» Coaches’ Handbook – a summary of additional policies, guidelines, and procedures applicable to all paid and volunteer coaches (collectively, “coaches”). This document is accessible from the Athletics department; and

» Volunteer Handbook – a summary of policies, guidelines, and procedures applicable to all volunteers. This document is accessible from the respective volunteer coordinator and/or the Office of Human Resource Development. (collectively, “Handbook”).

Employees, coaches, and volunteers should refer to the appropriate companion Handbook whenever a specific question regarding work at Punahou School arises. Whenever a question or concern arises that neither Working at Punahou nor the Handbook can answer, and Working at Punahou does not provide sufficient guidance on the generally expected professional or ethical behavior, employees, contractors, and volunteers should contact their supervisor or the Office of Human Resource Development (“OHRD”) for assistance in a timely manner.

DISCLAIMERS

Working at Punahou is not a contract of employment. It does not promise or guarantee any particular benefit or specific action. Absent a valid employment agreement to the contrary, employment with the School is “at will,” based on mutual consent. As an at-will employee, you or the School may end the employment relationship at any time, with or without prior notice, and for any lawful reason. The School may terminate the employment of an employee if his/her/their performance or conduct is not satisfactory; negatively impacts the School’s legitimate interests in managing its organization, fulfilling its Mission, upholding its Values, or honoring its commitment to student safety; violates any of Punahou’s policies, guidelines or procedures; or any other lawful reason.

Punahou School may revise and update this document, including the Handbook, periodically. The School strives to keep employees apprised of all pertinent changes, additions or deletions to policies, guidelines and procedures either in writing or electronically, such as through postings to myPunahou or via email notification. Employees should visit myPunahou periodically to look for the latest versions.

INTRODUCTION Message from the President

As the school year begins, I want to offer a warm welcome back to all our faculty and staff and a special aloha to our newest employees, who are joining our Punahou community. As Children of Ka Punahou, the New Spring, we are all members of a remarkable educational community that, since 1841, has been a home for generations of students to dream and discover their purpose and kuleana to Hawai‘i and the world.

Punahou is truly a remarkable educational institution, founded on the mission of engaging in discovery and enabling all of us to lead lives of purpose and meaning. Central to that mission are a set of core values and a commitment to building a welcoming community of which we can all be proud. I encourage you to review our school’s Mission and Values, and to reflect on how they shape your own sense of purpose.

Each year, our Office of Human Resource Development shares our Code of Conduct, Working at Punahou, with all employees, contractors, and volunteers. Working at Punahou is a declaration of our values and culture as a place of learning and growth. It is a living document that defines our high expectations for professional and ethical conduct. These include our commitment to student safeguarding and our duty to report any evidence of abuse or misconduct to the authorities; and a work environment characterized by personal responsibility, mutual respect and professional care and support.

Please take the time to read this document carefully. All employees, contractors, and volunteers are required to attest to their understanding of and commitment to the principles and obligations set forth in this document. If you have any questions about the information contained in Working at Punahou, please contact yourhr@punahou.edu

As the year begins, I want to extend my deepest appreciation to each one of you, our valued employees, contractors, and volunteers. More than any other aspect of our School, it is our people that make Punahou so special and unique. Working together, we will continue to strengthen our School for our students, each other and our entire community.

With gratitude,

Michael E. Latham, Ph.D. ’86 President, Punahou School

Our Mission

We are children of Ka Punahou, the new spring. From under the hala tree, we weave a mat that seats many, our home to dream and discover our purpose and kuleana to Hawai‘i and the world.

Our Values

Children of the New Spring

We develop spiritual and ethical values that affirm the worth and dignity of everyone, inspired by our Hawaiian and Christian heritage.

Dream and Discover

We inspire a love for learning, innovation, and exploration from kindergarten through life, empowering all to discover their gifts and passions.

Purpose and Kuleana

We commit to personal responsibility and kuleana as central tenets of our larger public purpose to create a just, compassionate, and sustainable world.

A Mat That Seats Many

We welcome all to realize the full expression of themselves, knowing that our differences are our source of strength.

Hawai‘i and the World

We honor our many communities and unique kuana‘ike while embracing the entire world as our home.

Punahou School upholds the fundamental principle that every individual should be treated with dignity, respect and care.

We affirm that a school should be a place where students learn not only about the world around them, but about themselves – creating a strong social, emotional and ethical foundation that will shape their experiences here and throughout their lives.

This foundation is based on the core belief that every student should have the opportunity to learn in a safe and caring environment, free from harassment, bullying and unsafe or unethical behavior.

All members of our community – whether students, parents, guardians, faculty, staff, contractors or volunteers – play a vital role in the development of a healthy learning environment.

Our Commitment to a Caring Community

Punahou’s culture of care is deeply woven into every aspect of our School community. Our Mission and Values guide the actions of our students, parents, guardians, employees and volunteers every day.

We are committed to education in its broadest sense, which includes learning that builds character, sound judgment and ethical behavior. We actively seek to create an environment in which students and adults alike develop the capacity for moral decision-making based upon clear values that:

» Acknowledge the worth and dignity of all members of our school community;

» Uphold both real and perceived personal safety;

» Respect the property of others;

» Pursue learning with complete academic integrity; and

» Are free of alcohol and drugs and people under the influence.

We expect that our students and their families, as well as our employees, volunteers and contractors, actively and thoughtfully embrace these values. Likewise, we expect all members of our community to serve as respectful citizens by abiding by our Code of Conduct.

Diversity, Equity, Inclusion and Belonging at Punahou

Our Mission and Values call upon us to affirm the worth and dignity of everyone.

Each day, through our words and actions, we weave a mat that seats many – a welcoming community where individuals can realize the full expression of themselves. When all members of a school feel a true sense of belonging, the best teaching and learning takes place and the entire community flourishes.

We seek to create an environment in which the identities, experiences, and cultural backgrounds of our students, employees, families, and alumni are valued and respected. Throughout the Punahou journey, diverse voices and perspectives strengthen the learning experience for all. They also empower us to fulfill our kuleana and make meaningful contributions to the wider community of which we are a part.

Members of the Punahou community are expected to uphold the highest standards of fairness and inclusivity so that all may fully participate in the life of the School and contribute to its Mission.

CODE OF CONDUCT

This Code of Conduct (“Code of Conduct”) articulates Punahou’s expectations around professional and ethical conduct. However, the Code of Conduct cannot cover every eventuality. If specific situations are not expressly covered, the spirit of our Code of Conduct must be upheld by exercising common sense and good judgment pursuant to our Mission, Values, and Commitment to a Caring Community and always in compliance with applicable laws, regulations and cultural practices of the areas where we provide programs both domestic and abroad.

Employee, Contractor, and Volunteer Expectations

All employees, contractors, and volunteers must:

» Know and understand the requirements of Working at Punahou.

» Undertake relevant training as required of their position.

» Follow Working at Punahou, seeking clarity and advice from their supervisor or the OHRD whenever there is not a full understanding of Punahou’s expectations.

» Immediately report any observed or suspected actual or potential breaches of Working at Punahou, whether accidental or deliberate.

All employees, contractors, and volunteers must not:

» Ignore or fail to report situations where they believe or suspect there is or may be a breach of Working at Punahou

» Attempt to prevent a colleague from reporting a potential or actual breach or encourage them to ignore an issue.

» Retaliate against any colleague who reports a potential or actual breach or participates in an investigation.

» Discuss any potential or actual breach under investigation with other colleagues, unless expressly authorized by the investigation team.

Standards of Professional and Ethical Conduct Confidentiality

As an educational institution and an employer, the School handles confidential and sensitive information relating to the School and its current and former faculty and staff, students, family, alumni, donors, and applicants to the School. It is the School’s policy to protect its property and all such confidential and sensitive information. The information can only be shared within Punahou School on a “need-to-know” basis, i.e. only to the extent required. It is not to be released to or shared outside the School unless authorized by an appropriate administrator for that purpose or required by law. Confidential information includes, but is not limited to, the following:

» Current and former student, parent and alumni personal information of any and all types;

» Current and former student academic information, including enrollment information;

» Current and former student, employee, alumni and donor lists, including, but not limited to, contact information and other data;

» Employee information, including, but not limited to, all contents of personnel files;

» Any and all financial information about the School;

» All School reports that have been deemed confidential;

» School photocopies that have been deemed confidential; and

» Names and addresses (including email addresses) of employees, students, parents, alumni and donors to the School.

If you are in doubt as to whether particular internal information is confidential, you should consult with your supervisor before disclosing such information to third parties. Any person who improperly copies, removes (whether physically or electronically), uses, or discloses confidential information internally or outside of the School, may be subject to disciplinary action up to and including termination and/or legal action.

Nothing herein prohibits an employee from disclosing their own wages, terms of employment or otherwise engaging in protected concerted activity.

Conflicts of Interest

Employees, contractors, and volunteers, especially those that conduct business with others on behalf of the School, are prohibited from engaging in conduct that would create actual or perceived conflicts of interest and should avoid situations that involve potential conflicts of interest. A conflict of interest is created when an individual’s conduct or relationships impair(s) the individual’s judgment or objectivity as it relates to the performance of their duties to the School. You are expected to devote your best efforts in the performance of your duties at Punahou. Outside employment or activities should not prevent or interfere with your responsibilities for the School or negatively affect the School’s legitimate interests. In addition, outside employment, income or activities should not be with a school, company or organization that competes directly or indirectly with Punahou School or otherwise creates an actual or perceived conflict of interest.

You must disclose any outside employment, income or activity that creates any actual, perceived or potential conflicts of interest to your supervisor or to the OHRD before you begin that outside work or activity. You must fully disclose all pertinent information so that the School can assess any potential impact to its interests.

Outside coaching

There are additional guidelines for any individual offered or working in a coaching position at Punahou. If you are offered or working in a coaching position at Punahou, your primary commitment is to the Punahou athletic program. Faculty or staff who do not hold a coaching position at Punahou may request approval to coach teams in interscholastic programs at schools outside of the Interscholastic League of Honolulu (ILH). Such requests should be directed to the appropriate Athletic Director, and approval must be received from the Athletic Director, Dean of Students and Principal before you can engage in any such activity. The School shall consider such requests by reviewing any potential conflicts with the individual’s teaching commitment and/or other School responsibilities. Any approval is given on a year-to-year basis.

Other outside employment

The School is aware that faculty and staff members, including coaches, may be employed or otherwise associated with non-Punahou related clubs, teams, activities or programs. Punahou has no desire to interfere with your outside interests as long as they do not: interfere with your judgment and capability to perform your duties at the School; violate our Conflicts of Interest Policy; or violate any applicable state, league or sport association administrative rules, or otherwise create problems for the School. You must not promote any outside interest using Punahou School’s resources or leveraging your employment at or relationship with the School.

You must disclose your employment or association with any outside, non-Punahou related clubs, teams, activities or programs in the appropriate manner described in this policy.

IMPORTANT: You must avoid any real or perceived favoritism because of your association with outside clubs, teams, activities or programs. You are encouraged to contact the OHRD about the application of this policy to your outside interests.

Any outside employment, income or activity that is deemed by the School to violate this policy or our Conflicts of Interest policy may lead to immediate termination (please refer also to the Employee Handbook policies on Tutoring and Employment of Relatives).

Discrimination and Harassment

Punahou is committed to creating and maintaining a safe, respectful and healthy learning environment. Consistent with our policy of equal employment opportunity, Punahou School strictly prohibits the discrimination against or harassment of any employee, student, applicant for employment, vendor, contractor, volunteer, parent/guardian or visitor to the School based on an individual’s race; religion; national origin; color; sex, including sexual orientation and gender identity; pregnancy; age; ancestry; handicap status or disability; arrest and court record; marital status; reproductive health decision; genetic information; sexual orientation; domestic or sexual violence victim status; credit history; citizenship; military/veterans status or any other category protected by applicable federal and state laws, regulations and/or executive orders.

Any abusive, intimidating, hostile, offensive, or other unwelcome verbal, non-verbal, or physical conduct may constitute harassment. Conduct may be unwelcome and violate this policy if it is offensive, unwanted or undesirable to any person who observes, hears or experiences it, whether or not that person is the intended recipient. Because reasonable people may have differing views of what constitutes harassment and what behavior may be unwelcome, employees, contractors and volunteers should avoid any conduct that may be perceived by anyone as intimidating, hostile or offensive.

Examples of prohibited conduct include:

» Slurs or epithets;

» Offensive jokes, innuendos, mockery, insults, displaying offensive objects or pictures;

» Physical threats or unwanted touching;

» Unwelcome discussion about a protected category (e.g. religious evangelism in the workplace); and

» Directly or indirectly conditioning terms and conditions of employment upon an individual’s participation or acquiescence in conduct related to a protected category (e.g., requesting or suggesting that an employee attend church in exchange for job benefits).

Such conduct is prohibited in the workplace, even if the conduct is not sufficiently severe or pervasive to constitute unlawful discrimination or harassment. For example, even if a stray remark regarding an individual’s protected status might not constitute unlawful harassment, such a remark still violates this policy. When such conduct is so severe or pervasive that it creates an intimidating, hostile or offensive work environment or unreasonably interferes with an individual’s work performance, the conduct may also violate federal and/or state laws.

In addition, discrimination and harassment that occurs outside of working hours and/or outside of the workplace can still violate this policy. Your communications and interaction with co-workers, regardless of the time or place, must conform to our policy prohibiting discrimination and harassment.

Prohibited conduct can occur not only between fellow employees, but also between supervisors and subordinates. Prohibited conduct can also occur between employees and third-parties, such as vendors, suppliers and customers. As aforementioned, the victim of discrimination or harassment does not have to be the person the conduct is directed toward—even witnessing prohibited conduct directed towards others may itself create a hostile and offensive work environment.

Sexual Harassment

Punahou School strictly prohibits sexual harassment or gender-specific conduct in the workplace that is deemed to be offensive, hostile, intimidating, or unwelcome by anyone, including, but not limited to: employees, contractors, volunteers, vendors, parents/guardians or visitors. This victim may either be the intended recipient of the unwelcome conduct or an unintended bystander.

Sexual harassment is defined as an unwelcome sexual advance, a request for sexual favors and other verbal or physical conduct of a sexual nature when:

1. submission to such conduct is made an implicit or explicit condition of employment;

2. submission to or rejection of such conduct affects employment opportunities; or

3. the conduct interferes with an individual’s work or creates an intimidating, hostile or offensive work environment.

The purpose of this policy is not to regulate personal morality within the School but to ensure that, at the School, all individuals are free from sexual harassment. While not feasible to list every type of conduct that could constitute sexual harassment, examples include, but are not limited to:

» Obscene gestures, suggestive winking or lingering glances, or wolf whistles;

» Exposure of one’s privates;

» Displaying sexually graphic magazines, calendars or posters;

» Sending sexually explicit emails or text messages;

» Verbal or physical conduct of a sexual nature;

» Uninvited or unwelcome touching (e.g., back massages, hugging, kissing);

» Sexual joking or innuendos, vulgar or offensive;

» Conversation or jokes, commenting about another’s physical appearance;

» Unwelcome sexual flirtations, advances or propositions (e.g., requests for dates);

» Any use of sexually degrading or gender-specific profane words to describe an individual (e.g., b---h);

» Any display in the workplace of sexually suggestive objects, cartoons, pictures or calendars;

» Conversation about one’s own or someone else’s sex life;

» Teasing or other conduct directed toward a person because of their gender which is sufficiently severe or pervasive to create an unprofessional and hostile working environment;

» Directly or indirectly requesting or suggesting sexual favors in exchange for a job, promotion, raise or business opportunity;

» Disciplining or firing a subordinate because they ended a romantic relationship; and

» Changing job performance expectations after a subordinate refuses repeated requests for a date.

No employee, contractor, or volunteer shall threaten or insinuate, either explicitly or implicitly, that another individual’s refusal to submit to sexual advances will adversely affect that person’s employment, work status evaluation, wages, advancement, assigned duties, shifts or any other condition of employment or career development. Similarly, no employee, contractor, or volunteer shall promise, imply or grant any preferential treatment in connection with another individual engaging in sexual conduct or consenting to or covering up harassment. All of the aforementioned conduct is strictly prohibited and will result in disciplinary action, up to and including immediate termination.

Workplace Bullying

The School prohibits bullying of any member of the Punahou community for any reason, including, but not limited to, the protected categories of unlawful employment discrimination and harassment under federal and state laws. Workplace bullying refers to repeated, unwelcome behaviors by one or more individuals that are intended to intimidate, humiliate, degrade and/or offend an employee, contractor, or volunteer, or have the impact of creating a risk to the health and safety of an employee, contractor, or volunteer. Workplace bullying often involves an abuse or misuse of power. It can be committed by anyone, including supervisors, co-workers, parents and even students. Any instances of bullying will result in disciplinary action, up to and including termination.

Cyberbullying

“Cyberbullying” means electronically transmitted acts, i.e. internet, cell phone or wireless hand-held device that an individual(s) has exhibited toward another individual(s) which causes mental or physical harm and is sufficiently severe, persistent or pervasive that it creates an intimidating, threatening or abusive environment. Unlike face-to-face bullying, cyberbullying can be conducted 24/7, at school or at home, making it difficult for victims to find relief.

Examples of cyberbullying include:

» Posting comments or rumors about someone online that are mean, hurtful or embarrassing;

» Sharing a mean or hurtful picture or video online or by text;

» Pretending to be someone else online in order to solicit or post personal or false information about someone else;

» Creating a mean or hurtful webpage or social media profile about someone;

» Doxxing, a form of online harassment used to exact revenge and to threaten and destroy the privacy of individuals by making their personal information public, including addresses, social security, credit card and phone numbers, links to social media accounts and other private data; and

» Sexting, which is defined as the production, possession or dissemination of sexual materials, including suggestive text messages, sexually explicit or sexually suggestive images or video via mobile device or computer.

Hazing

Hazing refers to any activity expected of an individual joining a group (or to maintain full status in a group) that humiliates, degrades, risks emotional and/or physical harm to that person, regardless of the individual’s willingness to participate. Punahou does not tolerate any form of hazing in our community.

Hazing has been generally understood as subjecting victims to physically, psychologically or emotionally abusive, hazardous and/or sexually violative acts, but they can take other forms as well. Whenever anyone in the Punahou community is intentionally made to feel ostracized or “lower” than their peers, this could be considered hazing.

Some examples include, but are not limited to:

» Deprivation of privileges granted to other members;

» Socially isolating new members;

» Name calling; assigning status and titles; forced servitude;

» Physical abuse or endangerment;

» Verbal abuse, threats or implied threats;

» Asking new members to wear embarrassing or humiliating attire;

» Forced or coerced consumption of alcohol, drugs, or vile substances;

» Beating, paddling, branding, burning or other forms of assault;

» Public nudity; sexual simulations;

» Forcing members to engage in illegal activity; and

» Bondage/abductions/kidnapping.

If a Punahou employee, contractor, or volunteer becomes aware of any form of hazing involving anyone in the Punahou community, they must take immediate and proactive action to stop it and report this immediately to the OHRD, the individual’s supervisor and/or a school administrator. Any individual who participates in, encourages, or has knowledge of but fails to report hazing shall be subject to disciplinary action up to and including termination.

Gifts, Fundraising

Punahou School prohibits employees, contractors, volunteers and their immediate family from soliciting monetary gifts and their equivalents and gifts of any value, unless it is part of the individual’s job responsibilities at the School or for authorized fundraising activities. Although volunteering is appreciated, individuals should refrain from taking on fundraising responsibilities outside of recognized, school-wide sanctioned initiatives (e.g., Punahou Carnival).

Generally, the School discourages employees, contractors, volunteers and their immediate family from accepting gifts of any value from any student, parent, independent contractor, vendor, applicant or any outside concern. Accepting such gifts can have the undesired outcome of creating avoidable suspicion on an individual’s ability to be objective and not favor one student over another, whether real or not.

However, the School recognizes the value of nurturing the spirit of goodwill gifts to teachers, other employees and volunteers—as long as proper controls are implemented. Gifts may be offered if made or created by students or if purchased at a small cost as a token gift. The School allows group or class gifts (usually at the year’s end) with an aggregated value of up to $150 per school year to a teacher, coach or staff member as long as the individual givers and amounts are not disclosed to the recipient. Individual gifts with an aggregated value of up to $25 per school year to a teacher, coach or staff member are allowed as long as they are shared with other employees and not taken home (e.g., flowers and food).

Punahou School does not give or receive—whether directly or indirectly—bribes or other improper advantages for student admission, operational or financial gain. No employee, contractor, or volunteer may offer, give or receive any gift or payment which is, or may be construed as being, a bribe.

If you have any questions about whether a gift or fundraising activity is acceptable, please contact the OHRD.

Plagiarism and Cheating

Punahou School is a learning community with the highest standards of ethical educational practices and pursues learning with complete academic integrity.

Plagiarism involves, but is not limited to:

» Submitting or participating in the submission of work or any product that has been knowingly obtained or copied in whole or in part from another individual’s work without a clear identification of the source.

» Neglecting to identify the source of a quotation, a documented idea, or information acquired through a personal interview, or the use of a passage that is paraphrased in such a way that the reader is misled as to the source.

» The use of information technology or artificial intelligence in an unauthorized way, replacing the work that an individual was expected to complete.

Cheating involves, but is not limited to:

» Forging, falsifying or altering any information on application forms, transcripts, School records or communication.

» Engaging in dishonest conduct in any competitive event.

Plagiarism and cheating are prohibited, and Punahou believes it is essential that action be taken when cheating and/or plagiarism occur. Employees, contractors and volunteers who condone, allow, or fail to report plagiarism or cheating may be subject to disciplinary action, up to and including termination. Additional details regarding Punahou’s policies on plagiarism and cheating can be found in the Student and Parent Code of Conduct, accessible via Punahou’s homepage.

Political Activity and Lobbying

Punahou School is committed to the full, open and civil discussion of a broad range of ideas, perspectives and opinions and encourages members of the School community to be active and engaged citizens, to exercise their right to vote and to participate in the electoral process.

At the same time, as a tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code, Punahou School is prohibited from directly or indirectly participating or intervening in any political campaign on behalf of, or in opposition to, any candidate for elective public office. The prohibition applies to all campaigns, including campaigns at the federal, state and local level, and is absolute. Violations of our policy on political activity and lobbying could result in the School losing its tax-exempt status.

Prohibition on political campaign activity applies only to the School, not to the activities of individual members of the School community in their private capacities. The prohibition on political activity is not intended to restrict free expression on political matters by campus community members as individuals independent of their formal roles and responsibilities at the School, nor does it prohibit the School from having contact with individuals who are candidates for public office. However, the prohibition and other laws (including laws that regulate lobbying activity intended to influence proposed legislation), impose certain limitations on expressions of political opinion by the School or those acting in official capacities on the School’s behalf and the use of School resources to support or subsidize political activities.

Political activities of individual campus community members, including campaigning for political candidates, must be kept separate and clearly distinguishable from actions taken by such community members for or on behalf of Punahou School. Individuals who choose to engage in political campaign activities must do so on their own time and with their own resources.

The School is permitted to engage in a limited amount of lobbying up to certain limits without losing its tax-exempt status. Because of these limits and IRS reporting requirements for lobbying, the President, with appropriate consultation with the Vice President for Institutional Advancement and the Vice President of Finance and Operations, must approve all lobbying activities done on behalf of Punahou School. The Office of the President will inform the Business Office about approved lobbying so lobbying expenditures are tracked for required reporting.

Prohibited Conduct

Punahou maintains a reputation in our community as an educational institution with the highest standards of lawfulness, responsibility and accountability. As a member of our community and representative of the School, you are expected to uphold the School’s reputation by conducting yourself in an honest, trustworthy and ethical manner—both on and off the job—especially when you are representing the School in an official capacity.

In addition to the conduct guidelines that are published elsewhere in Working at Punahou, the following is a list of examples of prohibited conduct that may result in disciplinary action, up to and including termination. The list does not cover all circumstances for which an employee, contractor or volunteer may be disciplined. Additional examples may be added in the future or the list may be amended. The order in which they are listed does not reflect the importance or weight placed on any particular action.

1. A violation of any School policy, guideline or procedure.

2. Insubordination or refusal to complete an assigned instruction that is not illegal, unethical or a violation of School policy.

3. Interference with others in the performance of their jobs or disorderly conduct while on work time or on Punahou premises.

4. Deliberate or careless conduct endangering the safety of self or other employees, contractors, or volunteers, including the provocation or instigation of violence or aggressive or hostile behavior that causes another person to fear for their own safety or causes physical injury to another person.

5. Intentional or negligent conduct that results in loss, damage, waste or destruction of School property, or the property of other employees, contractors, volunteers, students, parents or visitors, or which creates unsafe or unsanitary conditions; failure to follow safety rules; or engaging in any unsafe conduct.

6. Conviction of any crime that causes the School to determine that the person poses a risk to the health, safety or well-being of children; or violation of local, state or federal law which causes unfavorable publicity to Punahou, impairs the credibility of an employee, contractor, or volunteer to perform a job, or otherwise bears a rational relationship to the individual’s job duties and responsibilities at Punahou.

7. Threatening others, provoking a fight, fighting or engaging in any act of physical aggression.

8. Inattention to duty, which may include sleeping or appearing to be sleeping during working hours.

9. Falsification or dishonesty in any form, including falsification of any records, reports and specimens; clocking in or out for another employee; giving a false reason for sick leave, leave of absence or time off from work; supplying false or misleading information during employment, or as part of the application process (regardless of when discovered); knowingly making false charges of illegal conduct against other employees, contractors or volunteers in relation to their work. Any material omission or falsification will automatically result in termination, regardless of when discovered.

10. Unlawful or immoral conduct at any time or place that adversely affects your relationship with your job, fellow coworkers and/or supervisors, or soliciting persons for illegal purposes or the aiding and/or abetting.

11. Failure to report loss, damage, breakage or breakdown of School property; failing to immediately report any job-related injury, illness or accident; falsifying information or refusing to give testimony or to cooperate in the investigation of accidents, employee, contractor, or volunteer misconduct, or grievances conducted by or on behalf of the School.

12. Discourtesy in any form or disrespect to students, parents, co-workers, supervisors or administrators; use of vulgarity or failing to render the appropriate degree of service or courtesy.

13. Gambling or promoting gambling on School premises at any time.

14. Loitering or unauthorized presence while on the job or anywhere on School premises.

15. Use of abusive, profane, disparaging, offensive or obscene language directed at an employee, contractor, volunteer, student or parent.

16. Maliciously false or defamatory statements, conduct or actions that disparage the School or its reputation, its administration, its Board of Trustees, its employees and/or the quality of its educational service or products.

17. Unauthorized possession, custody or utilization of student, parent, employee, contractor, volunteer or School property, including any item (lost or otherwise) found or present on School premises. (All articles found on School premises must immediately be turned in to your supervisor.)

18. Tampering with fire or safety equipment.

19. Abusing, defacing or destroying School property or property of students, parents, employees, contractors, or volunteers.

20. Improperly altering of any School records, including student, work and time records.

21. Failure to maintain accurate and proper accountability and control of cash banks, excessive or continuous cash shortages or other irregularities that are considered irresponsible, unacceptable or negligent.

22. Interfering with or hindering work schedules for any personal non-work-related or unlawful reason. Failing to work on a shift as scheduled or arranging your own replacement on a shift without the permission of your supervisor.

23. Recording by video or audio or taking photographs in private places (e.g., restrooms, locker rooms, etc.). Voice recording or videotaping of any conversation or meeting should be limited to safety, classroom instruction or other School-sponsored communications, or when otherwise authorized by all parties in advance of the recording or by an administrator. See also the Employee Handbook’s policy titled Social Media Guidelines

24. Possession, use or promotion of controlled substances or alcohol during working time, or reporting for duty while exhibiting signs of or under the influence of controlled substances or alcohol. Refer to the Employee Handbook’s policy titled Alcohol/ Controlled Substance Use and Abuse.

25. Consumption of controlled substances, unauthorized or excessive consumption of alcohol at School-sponsored events or functions.

26. Promoting or allowing the use of controlled substances or alcohol by students or minors.

27. Bringing weapons of any kind on campus, including but not limited to: firearms, explosives, knives, ammunition, chemical sprays, TASERS/stun guns, martial arts devices, billy clubs and batons, and other weapons that might be considered dangerous or that could cause harm. Refer to the Employee Handbook’s policy titled Weapons and Firearms.

Violation of any of these guidelines may subject an employee, contractor or volunteer to disciplinary action, up to and including reprimand, suspension or discharge.

Social Media and Online Presence

Whether you are posting on Punahou’s private social media tools (Punahou-related team or club social media accounts) or your own personal accounts, a general rule is that if you wouldn’t say it to someone in person, you shouldn’t say it on social media. Use good judgment and always consider the perspectives of students, their families, and your and the School’s reputation.

When collaborating with peers on Punahou’s private social media tools (Punahou-related team or club social media accounts), ask yourself: “Does my post have an educational purpose?” “Why am I posting this, and is it appropriate to share?” It is helpful to pause and reflect before posting. If you have any doubts about posting or not posting, it usually means that there is something that could be edited about the post, and it might be best to consult with colleagues and/or administrators to gain additional perspective.

Faculty, staff, coaches, parents, volunteers, contractors and others affiliated with Punahou School also engage in social media activities using their own personal accounts. The guidelines below are primarily intended to assist employees, contractors, and volunteers who comment or otherwise participate on Punahou’s public social media sites and who use personal social media accounts (such as Facebook, Instagram, LinkedIn, Snapchat, Twitter, Reddit, TikTok, YouTube, wikis and forums).

Etiquette, Privacy and Online Safety

Employees, contractors, and volunteers are expected to maintain good citizenship and character in their online presence, abiding by the generally accepted rules of computing, network etiquette, privacy and online safety. These rules include (but are not limited to) the following:

» Do not use language in social media, messaging platforms, or any other service that constitutes bullying or harassment of another student, faculty member, staff or any other person.

» Do not reveal any private information, including identification numbers, addresses, and phone numbers belonging to yourself, a student, faculty member, staff or any other person.

» Only access information consistent with your job responsibilities.

» Do not make representations on behalf of the School or as a representative of the School without first obtaining approval from the Director of Communications.

» Use appropriate language. Do not swear, use vulgarities or any other inappropriate language.

» Do not use computers or networks in such a way that would be disruptive to others or the performance of their jobs.

See the Employee Handbook’s policy titled Responsible Use of Technology for additional information, including the School’s policies regarding inspection and monitoring of its equipment and internet usage.

Protecting Our Students

Ensuring the safety of Punahou students is our primary concern. When posting there are a number of things to consider:

» Social media accounts for specific School teams or clubs may be created, but they must be disclosed to the Academy or Junior School Principal and the Director of Communications and access to them by School administrators shall be granted on request. These outlets are considered “private,” and external participation is largely disabled.

» School employees, contractors, and volunteers should not “friend” or send comments to students from their own private, non-Punahou social media or email accounts.

» School athletic teams and clubs may post photos of public events on social media, including competitions or practices and official team or club photos, but photos of private gatherings shall not be posted. In all cases, family privacy requests should be respected.

» Children, other than an employee’s, contractor’s, or volunteer’s own, should not be posted on any personal social media accounts. This includes photos; mentions of their names, including “tagging” them in social media posts; and any background images that may identify students. Parents should use discretion when posting images or identifying their own children.

» Posting stories, blogs, images and updates to parents must be behind a password protected site approved by IT.

Protecting Our School

Keep in mind the following when considering your use of social media:

» Your social networking activities may be visible to current, past or prospective students, parents, colleagues and other members of the Punahou and public community. Faculty and staff members at Punahou are expected to be responsible with respect to their expressions of opinion on controversial issues and consider their impact carefully, particularly in terms of the experience of our students. In all cases, they should strive for accuracy, engage others with respect and indicate when they are speaking as individuals and not on behalf of the institution.

» Whether you post on the Internet at work or during your personal time, your posts must not violate any policies in Working at Punahou, including but not limited to:

• disclosure of confidential School information;

• discrimination and harassment;

• no solicitation; and

• conflicts of interest and ethical violations.

» Exercise discretion when using social networks to ensure that your conduct does not negatively reflect upon the School, our Punahou community, and your role at the School.

» Exercise care regarding the content you post and in which you are identified.

» Employ social networking privacy settings to limit access to profiles and searchability.

» Do not hold yourself out to be speaking on behalf of the School on any social media network unless that function is part of your job duties and responsibilities.

» Any conduct that is impermissible under the law if expressed in any other form or forum is impermissible if expressed through a blog, web page, social networking or similar site. For example, posted material that is discriminatory, obscene, defamatory, libelous or violent is forbidden.

» Keep in mind the speed and manner in which information posted on a blog, web page and/or social networking site is received and often misunderstood by readers.

» Posted content should never be used to harass, ostracize, bully or otherwise harm any person in the Punahou community. Any action that could be construed as cyberbullying is strictly prohibited.

Solicitation/Distribution

To ensure a safe campus environment and avoid distractions, employees, contractors, and volunteers cannot solicit or be solicited for contributions or donations for reasons other than sanctioned School activities or listservs (e.g. “Want Ads”) during their working time. This applies to any form of solicitation, whether in person, telephone, mail, email, texting or messaging. Also, employees cannot distribute printed or written materials, including chain letters or emails, during working time or in work areas. Non-employees cannot engage in any kind of solicitation or distribution on School property at any time.

Theft, Misappropriation and Misuse

Punahou expects all members of the Punahou community to act with honesty, integrity and accountability while on or off the job. Pilferage, theft or misappropriation, unauthorized possession or custody of School property or the private property of others; any attempt to damage school or private property; any attempt to pilfer, steal or misappropriate any such property; and any unauthorized use or taking of School equipment and/or supplies (including but not limited to computer use) is strictly prohibited. The policy of the School is to report to law enforcement any faculty, staff, coach, volunteer or contractor who misappropriates, misuses, steals, or damages property of the School.

Every member of the Punahou community is required to report any observed or suspected dishonest acts to their supervisor or a member of the Senior Leadership Group (SLG) immediately. Individuals are also required to fully cooperate in the School’s investigations, whether or not they are directly involved in the alleged acts. Dishonesty or failure to fully cooperate in a School investigation is not tolerated and may result in disciplinary action, up to and including immediate termination.

Unacceptable Uses of Technology

The following actions are strictly prohibited under the Employee Handbook’s Responsible Use of Technology policy:

» Transmission of any material in violation of any U.S. or state regulation is prohibited. This includes, but is not limited to: threatening or obscene material or material protected by copyrights or trade secrets.

» Printing, downloading, streaming or distribution of copyrighted materials such as music, motion pictures, magazines, newspapers and other publications is prohibited unless authorized by the copyright owner or his/her/their licensee or allowed under the Fair Use Doctrine (see also the Employee Handbook’s Copyright Intellectual Property Policy).

» School computers and/or the Punahou School network and accounts may not be used to bully, threaten or intimidate others; to misrepresent yourself or others or to cause harm to the network or others.

» Use of the Punahou systems and network resources for commercial or business activities other than those of Punahou is prohibited.

» Use of the network for solicitations unrelated to Punahou, product advertisements or promotions, and political lobbying or campaigns (other than for School and alumni association offices) is prohibited.

» Vandalism, or any other effort to harm or destroy hardware, software, or data of the school or of another user, the internet or any other network that is connected to the internet, is prohibited.

» Distribution or sale of any Punahou email addresses to merchandisers or other mass marketing operations that may generate unsolicited email messages (“spam”) is prohibited. For similar reasons, giving Punahou email addresses to retailers and making online purchases through the network, except in connection with Punahou business, is strongly discouraged.

» The attempt to use any system or create a program to interfere with, change, or interact with programs, security settings, systems, networks, or devices that are the property of Punahou and are used for school related purposes by students, their parents and staff is prohibited.

» Using Punahou systems or networks to access pornographic or other online content unrelated to your work at Punahou.

» The attempt to get around security settings and content filters using tools such as proxies or VPN (Virtual Private Network) clients to access websites blocked by Punahou is prohibited.

Complaint Procedures

Whistleblowing

Punahou School adheres to all applicable federal, state and county laws. Employees, contractors, and volunteers who have observed potentially unlawful conduct or have reason to suspect its occurrence must make a full report to their supervisor or the OHRD so the matter can be investigated and, if necessary, corrective action can be taken. Any employee, contractor or volunteer who feels that they have been subjected to conduct that violates Working at Punahou or other School policies should immediately report the matter to their supervisor or the OHRD.

It is Punahou School’s policy to abide by laws protecting employees who engage in whistleblowing. Consistent with the Hawaii Whistleblowers’ Protection Act (“HWPA”), Punahou School prohibits retaliation against any employee who (1) reports or is about to report to Punahou School, or a public body, verbally or in writing, a violation or suspected violation of a law, rule, ordinance, or regulation, adopted pursuant to law of this State, a political subdivision of this State, or the United States; (2) reports or is about to report to Punahou School or a public body, verbally or in writing, a violation or suspected violation of a contract executed by this State, a political subdivision of this State, or the United States; and/or (3) is requested by a public body to participate in an investigation, hearing, or inquiry held by that public body, or a court action. However, an employee is not entitled to protection as a whistleblower if he/she/they know that the report he/she/they made or is about to make is false.

Punahou School encourages complaints made in good faith. If an investigation reveals that an individual maliciously or knowingly made a false accusation, the School may seek appropriate remedies as permitted by law, including disciplinary or legal actions.

Confidentiality

The identity of individuals who report a perceived violation and any information obtained during the School’s investigation will be kept confidential, to the extent possible, consistent with a thorough and impartial investigation within relevant legal requirements. While confidentiality cannot be guaranteed, the School information regarding the complaint will be provided on a need-to-know basis only.

Duty to Cooperate

Complaints of policy violations will be investigated by qualified personnel, who shall conduct a fair, timely and thorough investigation. Employees, contractors, and volunteers are required to cooperate in any School investigations. This includes, but is not limited to, providing relevant information about the complaint, avoiding action that may compromise the complaint or investigation, and following rules related to prohibited campus access and/or contact with specific individuals. Individuals who fail to cooperate in an investigation shall be subject to disciplinary action, up to and including termination.

Corrective Measures/Discipline

It is the policy of Punahou School to take the necessary action to stop and to prevent future occurrences of prohibited conduct. If an employee, regardless of position or title, is found to have engaged in prohibited conduct, they shall be subject to disciplinary action up to and including immediate termination of employment. For complaints related to contractors and volunteers, the School may cease its relationship. For complaints related to visitors, the School may bar or no-trespass the individual. The School also reserves the right to take further legal action necessary to protect its workplace. Additional information can be found in the Employee Handbook’s policy titled Disciplinary/Corrective Action.

Retaliation

Punahou School expressly prohibits retaliation against an employee who has reported an actual or suspected violation made in good faith to the School or a government entity, complained of sexual or other forms or harassment, cooperated with the investigation of a complaint or acted as a witness during the investigation of a complaint.

Retaliation is defined as any form of materially adverse action such as intimidation, reprisal or harassment directed against an individual who makes a report or who provides information during an investigation. Retaliation can consist of threats, reprimands, negative evaluations, harassment in or out of the workplace, hazing and other types of adverse treatments, such as surveillance and exclusion from business-related activities that are reasonably likely to deter protected activity by that individual or other employees.

Any employee who engages in retaliation shall be subject to disciplinary action, up to and including immediate termination.

If an employee feels that they are the target of retaliation, the employee should immediately report the concern to their supervisor, the OHRD, the Vice President or the President.

OUR COMMITMENT TO STUDENT SAFEGUARDING

Punahou’s commitment to creating an environment for safe and healthy learning extends to adults who come into contact with our students. Punahou expects these adults to recognize and understand their kuleana, or responsibility, to keep our students safe from harassment, bullying, abuse, exploitation, and inappropriate situations at all times in accordance with this policy and the Student Safety and Well-Being plan located at https://www.punahou.edu/contact/campus-safety.

Sexual Misconduct Involving Students

Under Punahou’s policy, employees, contractors, and volunteers are prohibited from having any sexual or romantic relationship with a student. Punahou will not recognize a student’s “consent” to any such relationship. No sexual and/or romantic relationship between a student and employee, contractor, or volunteer at Punahou is EVER appropriate. ANY physical or verbal conduct towards a student that is sexual in nature is ALWAYS unwelcome because students cannot consent to such conduct.

Sexual harassment

Sexual harassment includes, but is not limited to:

» Molestation and sexual abuse, which requires sexual contact or relations (e.g., sexual assault) between an adult and a minor student;

» Making advances, unnecessary touching, hugging, kissing, pinching, hand-holding, flirting, lingering glances, or wolf whistles, sexual contact or conduct;

» Exposing one’s privates;

» Encouraging a student to engage in sexual conduct;

» Observing a student engaging in sexual conduct;

» Sexual comments, innuendos and jokes;

» Demeaning labels and abuse based on gender or sexual orientation, regardless of means of communications;

» Promises or demands for preferential or negative treatment in connection with sexual conduct;

» Displaying or sharing sexually suggestive, explicit or pornographic content, pictures, social media posts, objects, cartoons, posters, calendars, written material, graffiti or obscene gestures;

» Sexual advances, flirtations, requests or pressures for any type of sexual activity, whether verbal, visual or physical;

» Sexual or intimate contact, including but not limited to, patting or touching breasts, buttocks or other sexual body parts, holding hands, pinching, kissing, extended or frequent hugging, blocking of normal movement; and

» Discussion or communications about one’s romantic feelings for the other (adult to student, student to adult).

Sexual exploitation

Sexual exploitation is the actual or attempted abuse of someone’s position of vulnerability, differential power, or trust, to obtain sexual favors, including but not only, by offering money or other social, economic or political advantages. (source: World Health Organization). Examples of sexual exploitation include but are not limited to:

» Grooming: The preparatory process in which a perpetrator gradually gains a person’s trust with the intent to be sexually abusive;

» Giving gifts to an individual student; and

» Quid pro quo: Exchange of money, employment, goods, assistance or services for sex, including sexual favors or other forms of humiliating, degrading or exploitative behavior.

Punahou does not tolerate any sexual misconduct, harassment, grooming, exploitation, or abuse. All incidents will be investigated and may result in immediate termination and possible criminal prosecution.

Appropriate and inappropriate behaviors

Consistent with the Mission and Values of Punahou School, employees are encouraged to build positive relationships with each of their students to help students develop the moral and spiritual values that will enable them to reach their full potential. These relationships require our employees to remain fair and consistent with all of their students or athletes and remain within the boundaries of an acceptable adult-child relationship.

Our faculty and coaches are encouraged to engage in the following appropriate behaviors in order to build positive relationships with their students or athletes:

» Effective, professional and responsive interventions to address a student’s needs (e.g., recommend speaking to a parent/guardian and/or School counselor);

» Praise for a student’s personal achievements, skills, academic milestones or athletic accomplishments, including brief pats on the shoulder or upper back, high fives;

» Correction of inappropriate, high-risk behavior in an age-appropriate manner;

» Sending group communications by text, email or message to team or multiple students with another employee or adult copied on the communications;

» Using discretion and being aware of surroundings when discussing sensitive issues with another employee or student that may be overheard by another employee or student;

» Establishing a healthy, trusting and honest relationship with a student about sensitive issues while maintaining professional standards (e.g., documentation, referrals and parental/guardian involvement); and

» Brief one-on-one interactions that are observable and within an interruptible distance of another faculty member, coach or administrator.

Behaviors that can constitute boundary violations between adults and students include but are not limited to:

» Overly personal or sexually explicit conversations or communications, including personal discussion about social, dating, marital or sexual life;

» Sexually provocative, tasteless or degrading comments concerning one’s body, physical appearance, manner of dress or specific physical attributes;

» One-to-one meetings, activities or communications with a student beyond normal school requirements;

» Giving gifts to an individual student;

» Adding a student as a friend on social networking/social media sites or sending private messages;

» Sleepovers, parties, meetings, tutoring sessions, etc. at student’s or adult’s residence without the presence of a parent or guardian; and

» Any other association with a student in a manner which gives the appearance of impropriety, including, but not limited to, any situation or activity involving substances such as alcohol, tobacco, or drugs.

These policy and behavior guidelines are intended to assist our faculty and staff in establishing a trusting rapport or mentorship with a student while maintaining their professional or ethical standards. Employees, colleagues, students and parents/guardians are encouraged to raise issues and concerns about possible boundary violations before conduct becomes sexual exploitation.

One-on-one interactions (communications, meetings) between faculty and staff and students should be limited. Generally, communications between a teacher or coach and a student can be accomplished in the presence of other students and adults. However, in the rare cases where more privacy is required, the teacher or coach must ensure that the interaction is observable and within an interruptible distance of another faculty member, coach or administrator. If an adult cannot locate a nearby faculty member, coach or administrator, the adult must postpone the meeting until they are able to find one. One-on-one meetings with students by deans and counselors should take place in an open setting that is frequented by other adults, unless a more private meeting is expressly approved by the Principal or Academic Dean to address circumstances unique to that student and only after additional safeguards have been established.

Mandatory Reporting by Punahou Employees, Officers, and Contractors

Punahou School takes the health and safety of our students seriously and is committed to doing our part to protect the physical and psychological health of minors in our community. As a private school, Punahou and our employees and officers have certain obligations under Hawai’i law to report instances of suspected child abuse or neglect. To ensure we meet both our obligations under state law and our commitment to protecting minors from harm, this policy sets out Punahou’s expectations for all our employees, officers, and contractors serving as representatives of the School with respect to reporting actual, alleged, or suspected child abuse or neglect.

All Punahou Employees, Officers, and Contractors Are Required to Report Child Abuse or Neglect.

Any Punahou employee, officer, or contractor who, in their professional or official capacity, has reason to believe that child abuse or neglect has occurred or that there is a substantial risk that child abuse or neglect may occur in the reasonably near future, shall immediately report the matter to: (1) the department of Chi ld Welfare Services (CWS) or (2) the police department (HPD).

In addition, Punahou employees, officers and contractors must also report all instances of potential child abuse or neglect to the School so that the School can facilitate jointly with the reporting employee, official, or contractor a call or communication with CWS or HPD.

Punahou School broadly interprets its compliance obligations under Hawai‘i law to ensure the health and safety of minors. Every employee, officer, and contractor at Punahou is a mandatory reporter under this Policy. Further, depending on the circumstances and regardless of where it occurs, we will report child abuse or neglect committed by parents, guardians, and any School employee, contractor, or volunteer. This means that, should Punahou become aware of any child abuse, we will report it even if the minor is not currently a student at Punahou.

Child Abuse or Neglect

“Child abuse or neglect” is defined under Hawai‘i law and means the acts or omissions of any person who is responsible for a child’s care that have either resulted in harm to the physical or psychological health or welfare of the child or that subject the child to any foreseeable, substantial risk of being harmed.

The circumstances, acts or omissions, that can constitute child abuse are also enumerated in Hawaii Revised Statutes section 350-1 and include, without limitation, sexual assault, molestation, sexual fondling, incest or prostitution, obscene or pornographic filming, photography or depiction or other similar forms of sexual exploitation, skin bruising or substantial bleeding, malnutrition, soft tissue swelling, extreme pain, extreme mental distress, bone fractures or even death. These circumstances and indicators are not exclusive and, in the exercise of sound judgment, Punahou employees, officers, and contractors must report any suspected child abuse or neglect.

Please direct any questions or concerns about the School’s reporting obligations and any complaint or suspicion of sexual misconduct involving students immediately to any dean in the Academy, any administrative dean in the Junior School, a principal, the OHRD or any member of the School’s Community Care Response Team.

Community Care Response Team

The Community Care Response Team (CCRT) is responsible for the management of cases related to allegations of sexual abuse and harassment involving members of the Punahou School community. The CCRT is composed of deans, faculty members, counselors and other School administrators, including a Community Care Liaison (CCL).

During the process of addressing a report of sexual abuse, the CCRT seeks to ensure that the victim's safety is paramount and will provide or make referrals for other types of support as necessary. The team also involves the student’s family as the first line of response in dealing with sensitive matters.

The CCRT focuses on:

» Student Safety: The CCRT will determine if any immediate emergency, medical or legal assistance is required or requested by the student. The CCRT will determine if measures are needed to separate the student and alleged offender and, if so, implement those measures.

» Student Support and Accommodations: The CCL will establish contact with the student and their family to offer support services that may be appropriate to their situation, and keep the student and family apprised of the status of the School’s response to the report.

» External Reporting: The CCRT will ensure all mandated reports have been made to the appropriate public agencies.

» Confidentiality: The CCRT will make every effort to maintain the confidentiality of the report and subsequent investigations – notwithstanding mandatory reporting laws and civil requirements for disclosure – and limit disclosure to those persons with a “need-to-know.”

» Monitoring and Follow-up: The CCRT continues to track the status of cases with law enforcement and monitor the emotional and psychological well-being of the student. Cases are reevaluated on a quarterly basis.

Employees, contractors, and volunteers are responsible for:

» Cooperation: Employees, contractors, and volunteers are required to cooperate in all investigations conducted pursuant to this policy.

» Compliance: Employees, contractors, and volunteers will abide by all restrictions, limitations or other requirements regarding campus access and communication with alleged victim(s), students, employees, contractors, volunteers, families or other individuals as deemed appropriate or necessary in the course of the investigation or for the ongoing safety of Punahou School students.

Behavioral Intervention and Threat Assessment Management team (BITAM)

The BITAM’s primary function is to help keep the community safe through connecting individuals whose behaviors are concerning, disruptive, or threatening towards others to the appropriate support services. BITAM utilizes an approach that incorporates both prevention and response to specific situations. In doing this, BITAM:

» Gathers and manages reported information.

» Assesses the level of threat an individual's behavior poses.

» Intervenes with individuals and connects them with support services and intervention resources.

» Coordinates with Deans, Principals, and the Office of Human Resource Development.

» Cooperates and consults with external law enforcement agencies as well as Threat Team Hawaii.

Education and Training

Each employee, contractor, and volunteer will be required to participate in regular mandatory training related to our commitment to student safeguarding. In addition to completing the training, employees, contractors, and volunteers will be asked to sign an acknowledgement confirming their understanding and agreement to comply with the School’s policies.