Anti-Discrimination and Discriminatory Harassment Policy and Procedures for Students

In this Policy, the following terms apply: 

• A Complainant refers to the person (or persons) who is alleged to have been subjected to prohibited conduct under this Policy;
• A Respondent refers to a Student Respondent or Recognized Student Group alleged to have engaged in Prohibited Conduct;     
• The Complainant(s) and Respondent(s) in any proceeding are referred to as the Parties; and
• A Reporter refers to a person who makes a Report of alleged conduct pursuant to this Policy. The Reporter need not be either the Complainant or a University affiliate. In cases where the Reporter is someone other than the Complainant, this Policy will apply to the extent applicable in the same manner as if the Complainant had made the initial Report.

This Policy governs alleged Prohibited Conduct, including Discrimination and Discriminatory Harassment, where the Respondent is a current University Student, including Students on a leave of absence, and regardless of a Student’s current registration status.^{5, 6}

This Policy also governs the conduct of Recognized Student Groups and their members and affiliates. Where a Report is made regarding a Recognized Student Group, the individuals who represent themselves as the leaders of the Group to the University will generally serve as the Group Representatives for purposes of any interactions with OIE, subject to the Office’s discretion to determine whether those individuals are the appropriate representatives. Communications from the Office will be sent to the Recognized Student Group’s email address and to the email addresses of its Group Representatives.⁷ A Recognized Student Group that has been suspended by the University will continue to qualify as a Respondent under this Policy for a period of two (2) years following the date of suspension.

     This Policy applies when the alleged conduct occurs:

1. On Columbia property, including Columbia servers, e-mail or computer systems; or
2. Off Columbia property, including conduct using social media, other non-Columbia online platforms, and/or other media related outlets if:
   1. The conduct directly involves a University program, a University-recognized program or activity, or another University-related activity such as attending a conference, a study abroad program, or conducting research in the field; and
   2. The conduct may have the effect of creating or contributing to a hostile or abusive work or learning environment for a member of the University community.

If alleged Prohibited Conduct arises out of the same facts or circumstances as alleged conduct that is prohibited under any other applicable University policy or policies, the Office may coordinate its proceedings with any other University office or entity responsible for enforcing the other applicable policies, or may, in agreement with another University office or entity, consolidate some or all of the allegations into a single proceeding to be administered by the Office, except for allegations concerning conduct that is prohibited under the Rules of University Conduct. Respondents who are alleged to have engaged in conduct that implicates both this Policy and any other University policy, including the Rules of University Conduct, may be subject to contemporaneous disciplinary action under both policies.

While this Policy may identify the University office or Employee who will typically perform certain roles or duties, the Office may exercise its discretion to designate other University offices or Employees to perform any roles or duties described in this Policy. The Office may also exercise its discretion to assign appropriate non-Employees to perform roles or duties described in this Policy.

Nothing in this Policy prevents a Complainant from seeking the assistance of relevant law enforcement authorities in addition to or instead of any University process. Nothing in this Policy may be construed to abridge academic freedom, principles of free speech, or the University’s educational mission.  

⁵ For the purposes of this Policy, the term “University” includes Columbia University only. It does not include Barnard College or Teachers College. If the Respondent is a Barnard College student, employee, or otherwise affiliated with Barnard College, please see Barnard College’s Office of Non-Discrimination and Title IX website. If the Respondent is a Teachers College student, employee, or otherwise affiliated with Teachers College, please see the Teachers College Policy and Procedures on Discrimination and Harassment. If the Respondent is a University Student, but the Complainant is a Barnard College affiliate or Teachers College affiliate, this Policy applies. For information about policies applicable to elementary and secondary school students enrolled in University programs, and other information regarding minors on Columbia’s campus, please visit Protection and Treatment of Minors at Columbia University.

⁶ Reports concerning allegations of Discrimination, Discriminatory Harassment, or other Prohibited Conduct where the Respondent is an Employee, Contractor, or Active Alum will be addressed under the University’s Anti-Discrimination and Discriminatory Harassment Policies & Procedures for Faculty & Staff. 

⁷ An Unrecognized Student Group is any Student group that has never been recognized by the University. It is synonymous with an “unrecognized Student Organization,” as that term was used in the August 4, 2025 version of this Policy. A De-recognized Student Group is a Student Group that has lost University recognition, including as a result of violations of the Student Group Accountability Review Board Policy and/or this Policy. A De-recognized Student Group has the same status as an Unrecognized Student Group for purposes of this Policy and may not qualify as a Respondent. Active and/or involved membership by a Student in an Unrecognized Student Group or De-recognized Student Group that is alleged to have engaged in Prohibited Conduct does not generally form a sufficient basis for OIE to initiate a formal investigation and make a determination as to the Student. OIE typically requires additional facts and circumstances, such as, but not limited to, a nexus between the Student and the Prohibited Conduct alleged to have occurred. Although an Unrecognized Student Group or De-recognized Student Group may not be Respondents under this Policy, OIE may, in its discretion, issue letters, request meetings, and otherwise investigate the reported alleged conduct of an Unrecognized Student Group or De-Recognized Student Group and issue public statements or other communications addressing the alleged Prohibited Conduct. OIE may, in its discretion, investigate a Recognized Student Group that does not, or refuses to, disavow or disaffiliate from an Unrecognized Student Group that engages in misconduct under this Policy.

⁸ The fact that Prohibited Conduct includes speech in a public setting or speech that is also motivated by political or religious beliefs does not relieve the University of its obligations to respond if the Prohibited Conduct otherwise involves allegations of Discrimination or Discriminatory Harassment.

This section sets out definitions of Discrimination, Discriminatory Harassment, and other forms of Prohibited Conduct under this Policy.

Prohibited Conduct

It is a violation of this Policy for a Student or Recognized Student Group to commit the following acts:

Discrimination 

Discrimination is defined as treating individuals less favorably because of their actual or perceived membership in, or association with, a Protected Class, or having a neutral policy or practice that has a disproportionate and unjustified adverse impact on actual or perceived members or associates of one Protected Class more than others. Discrimination includes treating an individual differently on the basis of their actual or perceived membership in, or association with, a Protected Class in the context of an educational program or activity without a legitimate, nondiscriminatory reason so as to deny or limit the ability of the individual to participate in or benefit from Columbia’s services, activities, or privileges.

Each of the following characteristics constitutes a “Protected Class” for purposes of this Policy: age; alienage or citizenship status; arrest or conviction record; caregiver status; caste; color; credit history; creed; disability; familial status; genetic predisposition or carrier status; gender; gender expression; gender identity; lactation accommodation; marital status; national origin (including shared ancestry, ethnic characteristics, or citizenship or residency in a country with a dominant religion or distinct religious identity); pregnancy; race; religion; salary history; sex; sexual orientation; sexual or reproductive health decisions; status as a victim of domestic violence, stalking, or sex offenses; unemployment status; veteran or active military status; or any other protected characteristic as established by law.^{9, 10}

Discriminatory Harassment

Discriminatory Harassment is defined as subjecting an individual to unwelcome conduct, whether verbal or physical, that creates or contributes to a hostile working, learning, or campus living environment; that alters the conditions of employment or education; or that unreasonably interferes with an individual’s work, academic performance, or ability to participate in or benefit from some aspect of the University’s educational programs or activities on the basis of the individual’s actual or perceived membership in, or association with, a Protected Class. 

Examples of Discriminatory Harassment include, but are not limited to, the following acts that denigrate or show hostility or aversion toward one or more actual or perceived members or associates of a Protected Class: verbal abuse; epithets or slurs; negative stereotyping (including, but not limited to, stereotypes about how an individual looks, including skin color, physical features, or style of dress that reflects ethnic traditions; a foreign accent; a foreign name, including names commonly associated with a particular shared ancestry or ethnic characteristics; or speaking a foreign language); threatening, intimidating, or hostile acts; denigrating jokes; insulting or obscene comments or gestures; calls for genocide and/or violence; and the display or circulation of offensive written or graphic material in any form.     

Speech or conduct expressing views regarding a particular country’s policies or practices generally does not constitute Discriminatory Harassment based on national origin. However, if harassing speech or conduct that otherwise appears to be based on views about a country’s policies or practices is directed at or infused with discriminatory comments about persons from, or associated with, that country or another country, then it may constitute Discriminatory Harassment. The use of code words may implicate the Policy. In responding to Reports concerning speech or conduct regarding a country’s policies or practices, the Office will consider whether such speech or conduct is an exercise of academic freedom and inquiry.

Each reported incident of alleged speech or conduct will be assessed on a case-by-case basis. The Office will determine whether alleged speech or conduct constitutes Discrimination or Discriminatory Harassment, including by creating or contributing to a Hostile Environment, by considering the totality of the circumstances surrounding an alleged incident or course of conduct. The Office will consider all relevant objective and subjective factors in making its determination. The presence or absence of no single factor will be dispositive in the Office’s determination. Objective factors are those that indicate whether a reasonable person would find the alleged speech or conduct to meet the definition of Discrimination or Discriminatory Harassment. Subjective factors relate to how the Complainant actually perceived the alleged speech or conduct and whether the Complainant perceived the alleged speech or conduct to be discriminatory or harassing. The offensiveness of a particular expression as perceived by a Complainant, standing alone, is not a sufficient basis to create a Hostile Environment. 

The factors the Office will consider when assessing whether speech or conduct constitutes Discrimination or Discriminatory Harassment may include, but are not limited to, the following:

• The nature and severity of the alleged speech or conduct. The Office will be more likely to find that alleged speech or conduct constitutes Discrimination or Discriminatory Harassment if it involves words or symbols that are generally understood to express hatred of, or calls for violence against, one or more Protected Classes (e.g., racially charged epithets, language suggesting that Protected Class members or associates should be harmed or killed, etc.)
• Whether the alleged speech or conduct was intended and/or likely to incite violence, Discrimination, or Discriminatory Harassment, or to create or contribute to a Hostile Environment.
• The frequency, duration, and location of the alleged speech or conduct, and the identity, number, and relationships of the persons involved. For instance, words that might not constitute Discriminatory Harassment if used by a Student as part of a classroom discussion could constitute Discriminatory Harassment if shouted repeatedly by a Student or group of Students at one of their peers.
• Whether the alleged speech or conduct was directed at an identifiable individual or group of individuals. In the case of allegations of discriminatory and/or harassing speech or conduct on social media, the Office will consider whether alleged speech or conduct is directed at one or more University Affiliates.
• Whether the Complainant had any alternative to being subjected to the alleged speech or conduct. For instance, the Office will consider whether the alleged speech or conduct took place in a location the Complainant had to enter or pass by in order to access any of the University’s programs and activities and whether the Complainant could have chosen to avoid the alleged speech or conduct without detriment to the Complainant’s ability to access any University programs or activities.
• Whether there is any difference in status/authority between the Respondent and the Complainant.
• Whether the alleged speech or conduct otherwise impeded or limited the Complainant’s participation in or ability to benefit from any University program or activity.
• Whether the alleged speech or conduct, even if offensive, constitutes an expression of opinion on political, social, or similar topics. The Office will not determine that alleged speech or conduct constitutes Discrimination or Discriminatory Harassment solely because it may be considered offensive.
• Whether the alleged speech or conduct, even if offensive, constitutes an exercise of academic freedom on the part of a Respondent.

Retaliation

Retaliation is any adverse action or threatened action, taken or made, personally or through a third party, against a Complainant, a Respondent, or any other individual (such as a Witness, Reporter, or Advisor) because the individual has engaged with the Office and/or the Resolution process. All individuals, not just a Respondent or Complainant, are prohibited from engaging in Retaliation.

Retaliation can refer to actions or threatened actions by any individual. Retaliation includes threatening, intimidating, coercing, discriminatory, harassing, or any other conduct that would discourage a reasonable person from seeking services; receiving Supportive Measures; reporting Discrimination, Discriminatory Harassment, and other Prohibited Conduct; or participating in the resolution process as a Complainant, Respondent, Witness, Reporter, or Advisor. It also includes maliciously or purposefully interfering with, threatening, or damaging the academic or professional career of another individual because the individual has engaged with the Office and/or the resolution process pursuant to this Policy. Reports that are intentionally false or found to have been made in bad faith may also constitute Retaliation. For example, Retaliation could include falsely reporting, or a threat of falsely reporting, a Complainant or Witness in order to deter them

from participating in an imminent or pending resolution process.¹¹ Retaliation may also include violations of a no-contact directive and/or other Supportive Measures and/or Interim Measures during the course of a proceeding pursuant to this Policy.

If the alleged Retaliation occurs between a Complainant, a Respondent, or a Non-Party, such as a Witness, while a matter is pending pursuant to this Policy, the alleged Retaliation may be addressed separately and/or, in the discretion of the Office, folded into the pending proceeding, based on the circumstances. 

Intentional Interference¹²

Intentionally taking action to impede the Office’s conduct pursuant to this Policy is prohibited. Intentional Interference may include, but is not limited to, the following:

• Any attempt to alter, prevent, or interfere with a Party’s or Witness’s participation in any proceeding under this Policy;
• Obstruction of any investigative interview, including Witness tampering which attempts to alter, prevent, or interfere with a Witness’s statement or testimony as part of any proceeding pursuant to this Policy;
• Intentionally disclosing any information, documents, or materials protected by this Policy’s provisions concerning the privacy of the Parties and/or the process (see Section IV.A);
• Intentionally withholding relevant information (other than privileged materials) for purposes of obstructing, interfering, or delaying any proceeding pursuant to this Policy;
• Knowingly making false statements or knowingly submitting false information during any proceedings pursuant to this Policy; and
• Intentionally failing to comply in any way with this Policy.

If a Party is determined to have engaged in Intentional Interference, that determination may result in disciplinary action, the drawing of an adverse inference (e.g., an inference that communications intentionally deleted by a Party contained material adverse to that Party), and/or Sanctions, as appropriate.

⁹ As part of a totality of the circumstances analysis for national origin, shared ancestry, and ethnicity claims of antisemitism, OIE considers the International Holocaust Remembrance Alliance (“IHRA”) definition of antisemitism, among other resources, including the framework provided for by the Columbia Antisemitism Task Force. 

The Columbia Antisemitism Task Force explains, “antisemitism can manifest in a range of ways, including as ethnic slurs, epithets, and caricatures; stereotypes; antisemitic tropes and symbols; Holocaust denial; targeting Jews or Israelis for violence or celebrating violence against them; exclusion or Discrimination based on Jewish identity or ancestry or real or perceived ties to Israel; and certain double standards applied to Israel.” 

¹⁰ Reports that meet the definition of Prohibited Conduct under the Title IX and Related Misconduct Policy and Procedures for Students will be addressed under that Policy and Procedures.

¹¹ Reports of Discrimination and Discriminatory Harassment made in good faith, even if the Respondent is ultimately determined not to be responsible for engaging in any Prohibited Conduct, are not considered Retaliation.

¹² Alleged Intentional Interference that occurs in connection with a pending matter, or between a Party and another individual, may be handled as part of a pending investigation under this Policy or be investigated separately through the Center for Student Success and Intervention’s Standards and Discipline Policy. The determination of whether alleged Retaliation will be handled under this or any other University policy is within the discretion of the Office in conjunction with the appropriate partner office(s).

The complete policy, including the procedures and resources, can be found on the Office of Institutional Equity (OIE) website.