(Applies to both Mentor and Rocky River Campuses)

1. POLICY FOR REPORTING OF CRIME / ADDRESSING TIMELY WARNINGS

FOR STUDENTS:

• Upon observing or involvement in any type of crime taking place on the property of the Brown Aveda Institute, whether it is in the building, the entranceways, parking lot or surrounding the building, student should notify a staff member immediately.  If you are a victim and do not want to file charges and keep this a confidential matter, we will abide by your wishes IF we feel it does not affect the safety of other students and staff.     
• Specific Sexual Harassment Procedures are found in detail in our Student Manual which is reviewed on the first day of class and received by each student.  
• Specific Drug, Alcohol and Weapons Policies are also found in detail in our Student Manual which is reviewed on the first day of class and received by each student.

FOR STAFF:

• Upon receiving notification or observing a crime on the property of Brown Aveda Institute, whether it is in the building, the entranceways, or parking lot surrounding the building, notify your supervisor immediately.  If your supervisor is not readily available, use professional judgment on taking the next steps as indicated below.
• Supervisor will make a decision on whether it warrants calling 911 or notifying the School Director.
• School Director will review each crime on a case by case basis with other management staff and, if needed, local or state law enforcement to discuss if and when it is necessary to issue a warning notice of the crime to students and staff for their safety.

• If it is decided that a timely warning is required, this warning will be issued by the School Director in person to the staff and students.  It will also be placed on our website, www.brownaveda.com, on the Enrollment / Student News tab.

• School Director or member of Management Staff must notify the Campus Security Survey Administrator so she can determine if this crime falls under the reporting requirements for the Campus Crime Report.  Specific Sexual Harassment Procedures are found in detail in our Employee Handbook, which is distributed by our HR Dept. to each new employee.

• Specific Drug, Alcohol and Weapons Policies are also found in detail in our Employee Handbook, which is distributed by our HR Dept. to each new employee.

The Institution will, upon written request, disclose to the alleged victim of a crime of violence or a non-forcible sex offense, the report on the results of any disciplinary proceeding conducted by such institution against a student who is the alleged perpetrator of such crime or offense.  If the alleged victim is deceased as a result of such crime or offense, the next of kin of such victim shall be treated as the alleged victim for purposes of this statement.

2. POLICY STATEMENT ADDRESSING COUNSELORS

All reports will be investigated.  The Institute does not have procedures for voluntary, confidential reporting of crime statistics.  Violations of the law will be referred to law enforcement agencies and when appropriate, to the School Administrator for review.  Staff will assist in notifying appropriate law enforcement authorities if student requests the assistance of personnel.  Crisis, Mental Health and Victim Resource Hotline numbers are posted at the Mentor and Rocky River Campuses as well as listed in the Student Manual should students need to contact these agencies.  When a potentially dangerous threat to either Campus arises, timely reports or warnings will be issued through e-mail announcements, the posting of flyers at the Campus, in-class announcements, or other appropriate means.  

3. COMPLETION and DISSEMINATION METHODS FOR

          THE ANNUAL SECURITY REPORT AND CRIME REPORTS

Each year prior to October 1, the Campus Security Survey Administrator prepares this report to comply with the Jeanne Clery Disclosure of Campus Security Policy and Crime Statistics Act.  The full text of this report can be located on our web site at www.brownaveda.com.  This report is prepared in cooperation with the local law enforcement agencies surrounding our main campus and alternate sites.  Each entity provides updated information on their educational efforts and programs to comply with the Act.  Campus crime, arrest and referral statistics include those reported to the designated campus officials and local law enforcement agencies.  Each year, notices indicating the web site to access the Annual Security Report and Crime Report are provided to all enrolled students.  During the course of the year, this information will also be made available to all new students on their first day of class in their student manuals.  Copies of the report may also be obtained at the Administrative Offices of the Mentor Campus (440)255-9494, ext. 246 and Rocky River Campus (440)255-9494, ext. 403. A Crime Statistics Report can be viewed on line at http://ope.ed.gov/security.    

The Admissions Dept. will also include the information on where to obtain this data in the inserts to the catalog that they distribute to prospective students.

Faculty and staff receive similar notification from our Human Resource Dept.  All prospective employees may obtain a copy from the Human Resource Office (440)255-9494, ext. 209.  The web site address will be provided with applications.   

4.  NOTIFICATION OF EMERGENCY SITUATIONS OR CLOSURES

• Upon a decision by the School Director and Director of Education to close either of our campuses for any reason, the Corporate Compliance Administrator will post this information on our website at www.brownaveda.com.  Please choose option; Enrollment / Student News for details.  
• The Corporate Director of Education will start a phone chain to notify the staff of this closure.
• School Campus Closures will also be posted by the Corporate Director of Education on the local news channels.  This information is given to the students on their first day of class.

5. CAMPUS LAW ENFORCEMENT POLICIES

Brown Aveda Institute does not employ security personnel or campus police.  We will follow procedures of contacting the local police department should the need arise.

6. EMERGENCY RESPONSE AND EVACUATION PROCEDURES

    In the case of a significant emergency or dangerous situation involving an immediate threat to the health or safety of students, employees, or clients occurring on either campus where it is deemed necessary to close by the School Director and Corporate Director of Education, the following evacuation procedure would be implemented:

• The Institution will, without delay, and taking into account the safety of the community, determine the content of the notification and initiate the notification system, unless the notification will, in the professional judgment of responsible authorities, compromise efforts to assist victims or to contain, respond to, or otherwise mitigate the emergency.

• The process used to confirm that there is a significant emergency, determine who to notify, determine the content of the notification and initiate the notification system is as follows:

• Situation will be assessed by the School Director, or in his absence, the Director of Educator at either location or responsible Administrative personnel who will then advise Director.  Should this be determined as a significant emergency, a call will be made to 911, the local police and/or fire department.  Determination will be made relative to characteristics of emergency as to whether students, staff, and clients will be evacuated or directed to protected areas of the building.

• The names and titles or the persons and organizations responsible for carrying out this process are:

• Edward T. Brown, Owner/School Director

• Barbara A. Bader, Corporate Director of Education

• Victoria J. Gibson, Corp. Compliance Administrator

• Rachel Carr, Managing Educator – Rocky River Campus

• Laura Beier, Student Aid Services & Marketing

• The procedure for disseminating emergency information to the larger community is by advising the local police and or fire department once the responsible parties have made this determination.

• Testing of the preceding emergency response and evacuation procedures will be performed on at least an annual basis and include the publicizing of the procedures taken.  Documentation of this exercise including date and time performed and whether announced or unannounced will be completed immediately following testing.

7. ACCESS POLICY

During business hours, each Campus will be open.  Students and staff utilize a key fob for a locked entrance.  During non-business hours access to each Campus is by key fob only or by admittance via a designated staff member.  Security cameras are posted in main areas and doorways for monitoring purposes.

8. SECURITY AWARENESS / CRIME PREVENTION PROGRAMS

During orientations students are informed of the various programs offered.  Power Point presentations and the Student Manual are reviewed.  These outline ways to maintain personal safety and sexual harassment/violence, theft, vandalism.  Students are provided with information regarding access to the Annual Security Report.  Similar information is presented to new employees.  Bullying seminars are scheduled to ensure full participation of all students and staff.  Should time be of the essence, information may be released to the Campus community through security alerts posted prominently or verbal advising.

9. POLICY ON ALCOHOLIC BEVERAGES / ILLEGAL DRUGS

The possession, sale or the furnishing of alcohol and/or illegal drugs on the Campus is governed by our policies and Ohio state law.  The enforcement of alcohol/illegal drugs laws on-campus is the primary responsibility of the local police department.  The Institute has been designated “Drug free”.  The possession, sale, manufacture or distribution of any controlled substance is illegal under both state and federal laws.  Such laws are strictly enforced by the local police department.  Violators are subject to Institute disciplinary action, criminal prosecution, fine and imprisonment.  It is unlawful to sell, furnish or provide alcohol to a person under the age of 21.  The possession of alcohol by anyone under 21 years of age in a public place or a place open to the public is illegal.  It is also a violation of “Institute” policy.  

10. POLICY ON ALCOHOL AND SUBSTANCE ABUSE EDUCATION

An Addiction Awareness Seminar is held periodically in conjunction with the Bullying Prevention Seminar through Crossroads to ensure full student/staff participation.  Counseling Services and numbers for abuse of drugs and/or alcohol are provided at this time as well as on an as-needed basis.

BROWN AVEDA INSTITUTE – Crime Report Statistics: