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Relevant Excerpt

Sexual Harassment – As defined by Title IX, it is any of three types of misconduct on the basis of sex which jeopardize equal access to education: ...  Any unwelcome sex-based conduct that a reasonable person would find so severe, persistent/pervasive, and objectively offensive that it denies a person equal educational access.

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Non-Title IX sexual harassment is defined as unwelcome sexual advances, requests for sexual
favors, or other conduct of a sexual nature including: verbal (e.g., specific demands for sexual
favors, sexual innuendoes, sexually suggestive comments, jokes of a sexual nature, sexual
propositions, or sexual threats); non-verbal (e.g., sexually suggestive emails, other writings,
articles or documents, objects or pictures, graphic commentaries, suggestive or insulting sounds
or gestures, leering, whistling, or obscene gestures); or physical (e.g., touching, pinching,
brushing the body, any unwelcome or coerced sexual activity, including sexual assault). This
conduct is sexual harassment when it constitutes a term or condition of employment and/or
hostile environment as described above. 

The types of non-Title IX sexual harassment prohibited by this policy are ... Hostile Environment, which occurs when verbal, non-verbal and/or physical conduct is sexual and/or based on sex, gender, gender identity or sexual orientation (actual or perceived), and is sufficiently severe, persistent or pervasive and objectively offensive that it interferes with, limits, or denies the ability of an individual to participate in or benefit from the educational programs, services, opportunities, or activities or the individual's employment access, benefits or opportunities. Mere subjective offensiveness is not enough to create a hostile environment.