(A)   The township has established the following procedure for lodging a complaint of harassment, discrimination or retaliation.
   (B)   The township will treat all aspects of the procedure confidentially to the extent reasonably possible.
      (1)   Complaints should be submitted as soon as possible after an incident has occurred, preferably in writing.
      (2)   Upon receiving a complaint, or being advised by a supervisor or manager that violation of this policy may be occurring, the person receiving the complaint will notify senior administration and review the complaint with the township’s legal counsel.
      (3)   The appropriate officer will initiate an investigation to determine whether there is a reasonable basis for believing that the alleged violation of this policy occurred.
      (4)   If necessary, the complainant and the respondent will be separated during the course of the investigation, by whatever means are necessary.
      (5)   During the investigation, administration, together with legal counsel or other management employees, will interview the complainant, the respondent and any witnesses to determine whether the alleged conduct occurred.
      (6)   (a)   Upon conclusion of an investigation, investigator will submit a written report of his or her findings to the township. If it is determined that a violation of this policy has occurred, the investigator will recommend appropriate disciplinary action.
         (b)   The appropriate action will depend on the following factors:
            1.   The severity, frequency and pervasiveness of the conduct;
            2.   Prior complaints made by the complainant;
            3.   Prior complaints made against the respondent; and
            4.   The quality of the evidence (e.g., firsthand knowledge, credible corroboration).
         (c)   If the investigation is inconclusive or if it is determined that there has been no violation of policy but potentially problematic conduct may have occurred, appropriate preventive action may be recommended.
      (7)   Senior administration will review the investigative report and any statements submitted by the complainant or respondent, discuss results of the investigation with other management staff as appropriate, and decide what action, if any, will be taken.
      (8)   Once a final decision is made by administration, the appropriate administrator will meet with the complainant and the respondent separately and notify them of the findings of the investigation. If disciplinary action is to be taken, the respondent will be informed of the nature of the discipline and how it will be executed.
(Board and Administrative Policies Manual, § 9.8)