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National Network for Oral Health Access (NNOHA) is committed to the principles of diversity, inclusion, integrity, civility, and respect in all our activities. All forms of discrimination, harassment, bias, and bullying are prohibited in any NNOHA activity. This policy applies to all participants in all settings and locations in which NNOHA’s work and activities are conducted, including board, committee, and council meetings, conferences, webinars, and other work and social functions where staff, volunteers, sponsors, vendors, or guests are present.

DEFINITIONS

• Discrimination is prejudicial treatment of individuals or groups of people based on their race, ethnicity, color, national origin, sex, sexual orientation, gender identity, age, religion, disability, veteran status, or any other characteristic protected by applicable laws.

• Sexual harassment is unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature that creates an intimidating, hostile, or offensive environment.

• Other types of harassment include any verbal or physical conduct directed at individuals or groups of people because of their race, ethnicity, color, national origin, sex, sexual orientation, gender identity, age, religion, disability, veteran status, or any other characteristic protected by applicable laws, that creates an intimidating, hostile, or offensive environment.

• Bullying is unwelcome, aggressive behavior involving the use of influence, threat, intimidation, or coercion to dominate others in the professional environment.

• Bias is a preference either for or against an individual or group that negatively affects fair judgment.

• Implicit Bias: Attitudes or stereotypes that affect an individual's understanding, actions, and decisions in an unconscious manner.

REPORTING AND RESOLUTION

Any violation of this policy should be reported. If you experience or witness discrimination, harassment, bias, or bullying, you are encouraged to make your experience known to the individual at the time the incident occurs if you are comfortable doing so. If the incident cannot be resolved by the individuals involved, please submit a report by completing this form. Complaints should be filed within 14 business days after an incident, unless there are extenuating circumstances that justify a longer period and should include as much detail about the incident as possible. If the complainant is seeking follow-up from NNOHA, they must include their own name and contact information and the name (and contact information if known) of the accused. Anonymous reports will not be acted on due to the need for investigation. If the complainant is not seeking follow-up but wants to make a report so that NNOHA is aware of the incident, they can make an anonymous report. All complaints received will be logged in and indicate the resolution of the complaint, including those that are received anonymously.

Complaint submissions will be received by the Executive Director (ED). Should the ED be involved in a complaint - as the complainant, the accused, or a witness - the reporting individual should submit a report by email to the NNOHA Board President. Within 30 calendar days of the report submission, the ED and at least one member of the Ad-Hoc Conduct Committee (described below) will determine if the concern falls within the scope of this policy by meeting one of the definitions above. If so, the ED will refer the complaint to the Ad-Hoc Conduct Committee for further action. If not, the ED will follow up with the complainant to inform them that the submission falls outside the scope of this policy and no further action by the Ad-Hoc Conduct Committee will be taken. If a complaint is filed on behalf of another individual, the ED or President will reach out to the victim to see if they want to proceed with the complaint resolution process.

Upon receiving a complaint that is determined to fall within the scope of this policy, an investigation will be conducted by an Ad-Hoc Conduct Committee that will be appointed by the President. If the President is involved in a complaint or has a conflict of interest with the complainant or the accused, the President-Elect will appoint the Ad-Hoc Committee. If the President-Elect also has a conflict, then the Secretary will appoint the Ad-Hoc Committee. If the Secretary also has a conflict, then the Treasurer will appoint the Ad-Hoc Committee. If the Treasurer also has a conflict, then the Immediate Past President will appoint the Ad-Hoc Committee. If all members of the Executive Committee have conflicts, then the Executive Director will notify the Board of the complaint along with the protocol for calling a special meeting of the Board to appoint an Ad-Hoc Committee to investigate the complaint.

The Committee will review the complaint and will meet individually with both the complainant and the accused. Additionally, they may meet with any witnesses as needed. The Committee will then decide, within 60 calendar days of the referral from the ED, which actions, if any, will be taken. The Committee will have the authority to retain outside legal or other relevant expertise as necessary. The Committee will make decisions using a simple majority rule regarding actions to be taken. If the Committee determines that there is insufficient evidence to support a finding that a violation occurred, the decision of no further action will be provided in writing to the complainant and accused. If the committee finds sufficient evidence, potential actions include, but are not limited to, the following:

• If both parties agree, mediation will be facilitated by the ED

• Letter of reprimand, including learning resources to help avoid similar behavior in the future

• Suspension or termination from service on NNOHA committees, faculty appointments, or the board

• Ineligibility for scholarships and/or grants offered by the organization, either for a limited time or indefinitely

• Suspension or termination of NNOHA membership

• Revocation or prohibition of registration for upcoming NNOHA-sponsored event(s) including the NNOHA Annual Conference, Learning Collaborative events, NNOHA Oral Health Leadership Institute, etc.

• Immediate expulsion from an NNOHA-sponsored event including the NNOHA Annual Conference, Learning Collaborative events, NNOHA Oral Health Leadership Institute, etc.

• Any incidents involving criminal actions, such as assault or a hate crime, will be referred to law enforcement as appropriate.

There is no appeal process once the Committee comes to a decision regarding actions to be taken. At the conclusion of the investigation, the Committee will prepare a report summarizing its findings and any recommended disciplinary action. The complainant, accused, and the NNOHA Board of Directors will receive a copy of the report, which will be redacted as necessary to preserve confidentiality.

CONFIDENTIALITY

While complete confidentiality cannot be guaranteed, NNOHA will maintain strict confidentiality of all information related to the investigation and its findings to the fullest extent permitted by law, sharing information only on a need-to-know basis. NNOHA will not retaliate or tolerate retaliation against anyone who makes a good-faith report of discrimination, harassment, bias, or bullying. However, persons who submit repeated unsubstantiated complaints or complaints that abuse the intent of this policy may be subject to disciplinary action. The final decision will be shared at the following NNOHA Board meeting and entered into the minutes with no identifying information about the individuals involved. All investigation records will be maintained in a secure location for a period of seven years, after which they will be securely destroyed in accordance with applicable laws. In the Board’s sole discretion, the outcome of the complaint may also be shared with the complainant.

RESPONSIBLE PARTY

The Executive Director and NNOHA Board of Directors are responsible for oversight of and substantive changes to the policy.