Institute Faculty, Staff, Facilitator and Administration Code of Conduct
1. Definition of Terms
In this document, “EPI persons” means all full-time and part-time Faculty members, Staff and Administration members of the Institute, and any other person who teaches or works at or under the auspices of the Institute (including but not limited to Students, temporary Faculty and Facilitators).
In this document, the term “Student” refers to all individuals who are presently enrolled at the Institute in a credit course or who are monitoring a course as well as individuals under the academic supervision of Faculty within the Institute.
2. Safe and Respectful Working Environment for Students, Faculty, Staff
and Administration
a. Preamble
The Essential Psychotherapy Institute (EPI) envisions a climate in which Students, Faculty, Staff and adminsitration are provided with the best possible conditions for learning and working, including an environment that is dedicated to awareness, excellence, equity and mutual respect. The EPI strives to realize this vision by establishing employment and educational practices that respect the dignity of individuals and make it possible for everyone to work and study in a positive and supportive environment.
b. Statement of Principle
The ideal environment for working and learning is one in which awareness, respect, civility, diversity, opportunity and inclusion are valued. Everyone at the EPI is expected to conduct themselves in a manner that upholds these principles in all communications and interactions with fellow EPI community members and the public in all Institute-related settings.
c. The Safe and Respectful Institute Environment
§ In the context of an academic and therapeutic community, responsibility for maintaining a safe and respectful environment falls on all community members, including Students, Faculty, Staff, Administration and members of the public who participate in Institute-related activities.
§ Excellence in learning and work in the Institute community is fostered by promoting the freest possible exchange of information, ideas, beliefs and opinions in diverse forms, and it includes dissemination and discussion of controversial topics and unpopular points of view. Respect for the value of freedom of expression and promotion of free inquiry are central to the Institute’s mission.
§ However, these freedoms cannot exist without an equally dynamic commitment to the recognition of and the respect for the freedoms of others, and concern for the wellbeing of every member of the Institute community. Excellence in teaching and employment activities flows from active concern and respect for others, including their ability to participate meaningfully in the exchange of information, ideas, beliefs and opinions.
§ Therefore, freedom of expression and freedom of inquiry must be exercised responsibly, in ways that recognize and respect the dignity of others, having careful regard to the dynamics of different relationships within the Institute environment, such as between instructor and Student, Therapist and client, or supervisor and employee. A respectful environment is a climate in which the human dignity of each individual is valued and the diverse perspectives, ideas and experiences of all members of the community are able to flourish.
d. Activities Harmful to a Safe and Respectful Environment
Personal harassment, which is sometimes referred to as psychological harassment or bullying, is harmful to a respectful environment and therefore has no place at EPI. It is not only a direct attack on the dignity and worth of the individual or group at whom it is directed, it undermines the freedoms of the whole community.
Personal harassment is objectionable and unwanted behavior that is verbally or physically abusive, distressing or hostile, that is without reasonable justification, and that creates a hostile or intimidating environment for working or learning. Personal harassment may be intentional or unintentional. While personal harassment usually consists of repeated acts, a single serious incident that has a lasting harmful effect may constitute personal harassment.
Personal harassment behavior includes persistent demeaning or intimidating comments, gestures or conduct; threats to a person’s employment or educational status, person or property; persistent comments or conduct, including ostracism or exclusion of a person, that undermines an individual’s self-esteem so as to compromise their ability to achieve work or study goals; unwarranted and excessive criticism of an individual; abuse of power, authority or position; sabotage of a person’s work; spreading of malicious rumors or lies; or making malicious or distressing complaints about a person.
Personal harassment does not include the exercise of appropriate managerial or supervisory direction, including performance management and the imposition of discipline; constructive criticism; reasonable changes to assignments or duties; correction of inappropriate Student, Staff or Administration behavior; instructional techniques such as humor, conjecture, and refutation, or assigning readings or other instructional materials that advocate controversial positions; and single incidents of thoughtless, petty or foolish words or acts that cause fleeting harm.
A determination that personal harassment has occurred is based not only on what the alleged perpetrator and target of the harassment actually experienced, knew, or understood about each other and the situation, but on what a reasonable person in each of their circumstances would have experienced, known or understood, taking into account the full context of the situation.
e. Sexual Misconduct
EPI will not tolerate any form of Sexual Misconduct.
The term sexual misconduct encompasses the behaviors prohibited under this policy.
EPI recognizes that certain relationships between Students and other Members of the EPI Community are relationships of heightened trust and vulnerability. Sexual or intimate relationships between individuals in the following classes of Members of the EPI Community where there is a supervisory role or where an individual has influence over a Student’s current or future academic activities, working conditions, or career advancement are Prohibited Relationships:
a) Faculty and Students;
b) Staff and Students;
c) Administration and Students
d) Facilitators and Students
e) assistants and Students
An individual in a supervisory role or position of influence as previously described who engages in a Prohibited Relationship, breaches this Policy and will be subject to disciplinary action notwithstanding that the relationship is claimed to be consensual.
In circumstances where there is an existing consensual sexual or intimate relationship that pre- dates a Prohibited Relationship as described above, the relationship must be disclosed to the Director who will take appropriate steps pursuant to the Institute’s conflict of interest and conflict of commitment policy
“Sexual Misconduct” includes sexualized violence and refers to any sexual act or act targeting an individual’s sexuality, gender identity or gender expression, whether the act is physical or psychological in nature, that is committed, threatened, or attempted against an individual without that individual’s Consent. The following list sets out examples of Sexual Misconduct. The list is intended to help Members of the EPI Community understand the kinds of acts that will be considered Sexual Misconduct. The list is not exhaustive and other acts may constitute Sexual Misconduct under this Policy even if they do not appear in the list below. Sexual Misconduct includes, but is not limited to, the following:
a) sexual assault, which is any form of sexual touching or the threat, express or implied, of sexual touching without the individual’s Consent;
b) sexual harassment, which is unwelcome conduct, by comment or gesture, of a sexual nature that detrimentally affects the working, learning, or living environment, or leads to adverse consequences for the individual directly subjected to the harassment;
c) stalking and cyberstalking (stalking through the use of the internet or other electronic means), which is engaging in unwelcome conduct expressed or implied, that causes an individual to fear for their physical or psychological safety, and includes repeatedly following the individual, repeatedly communicating with the individual through any means, engaging in threatening conduct, or keeping watch over the place where the individual happens to be;
d) indecent exposure which is exposing one’s body to another individual either physically or electronically, or through any other means, for a sexual purpose without the individual’s consent, or coercing another individual to remove their clothing in order to expose their body;
e) voyeurism, which is non-consensual viewing, photographing, or otherwise recording another individual in a location where there is an expectation of privacy and where the viewing, photographing, or recording is done for a sexual purpose; and
f) the distribution of a sexually explicit photograph or recording of an individual to one or more individuals other than the individual in the photograph or recording without the consent of the individual in the photograph or recording.
f. Addressing Respectful Environment Concerns
Primary responsibility for addressing safe and respectful environment concerns, including concerns about personal harassment and sexual misconduct, lies with those members of the EPI community who exercise supervisory or leadership roles. These individuals are well-placed to set examples for others by their own conduct, to communicate to those under their direction EPI’s commitment to a safe and respectful Institute environment, and to take appropriate action to preserve or restore a safe and respectful environment if problems arise.
Specifically, Faculty or Staff who have concerns about personal harassment or sexual misconduct should contact the Ethical Committee or Director.
It is the responsibility of the Director to ensure that those in supervisory or leadership roles have access to the proper training necessary to understand rights and responsibilities in a respectful working and learning environment, including their own responsibility to investigate, respond to, and manage complaints of harassment and to educate those they supervise or lead regarding those rights and responsibilities.
Education, increased awareness and prompt action are vital to create and maintain respectful working and learning environments at EPI. The Institute must provide training, support and resources to raise awareness about the principles of a respectful working, learning and living environment and to address concerns in a positive and effective manner when they do occur.
g. Related Policies and Provisions
Where policies and mechanisms for addressing unacceptable conduct already exist, whether in work or education contexts, this Safe and Respectful Environment Statement is intended to supplement, not to displace them.
The Institute also expects all EPI persons to comply with the European Convention on Human Rights. The Convention prohibits discrimination or harassment based on race, color, ancestry, place of origin, political belief, religion, marital status, family status, physical or mental disability, sex, sexual orientation or age, and criminal conviction unrelated to the employment.
The Institute’s Ethical Committee takes initiative in promoting equity and inclusion across the Institute.
If any Faculty, Staff or Administration member has a complaint, please refer to the EPI Complaints Procedure.
3. EPI Policies and Expectations for EPI Faculty, Staff and Administration
a. Statement of purpose and application of this document
The Essential Psychotherapy Institute (EPI or the Institute) is committed to the core values of academic freedom, advancing and sharing knowledge, excellence, integrity, mutual respect, equity, and the public interest. The EPI Code of Conduct for Faculty, Staff and Administration further underlines that all EPI persons are expected to adhere to the highest ethical standards when engaging in EPI related activities. The Institute expects all EPI persons to adhere to its core values in their professional and personal conduct.
This document summarizes the standards of behavior expected of all EPI persons. It highlights the key principles and rules which EPI persons are expected to follow. It is the responsibility of every EPI person to comply with the underlying policies and procedures.
b. Teaching and Students
As teachers, the instructors encourage the free pursuit of learning of their Students. Instructors demonstrate respect for Students as individuals and adhere to their proper roles as guides and counselors. Instructors make every reasonable effort to foster honest academic conduct and to assure that their evaluations of Students reflect each Student’s true merit. They respect the confidential nature of the relationship between instructor and Student. They avoid any exploitation, harassment, or discriminatory treatment of Students.
The integrity of the Faculty-Student relationship vests considerable trust in the Faculty member, who, in turn, bears authority and accountability as mentor, educator, and evaluator. The unequal institutional power inherent in this relationship heightens the vulnerability of the Student and the potential for coercion. The pedagogical relationship between Faculty member and Student must be protected from influences or activities that can interfere with learning consistent with the goals and ideals of the Institute.
As the Institute is a Therapist training program, much of the time Faculty are also in the Therapist position and Students are in the participant or client position. This adds a deeper, more challenging dynamic to the Instructor – Student relationship. This means that within the context of the training, the Instructor – Student relationship is additionally governed by the principles of the Therapist – Client relationship. For this reason, in addition to the principles outlined in this document, all EPI persons assuming the Therapist position must adhere to the EPI Therapist Code of Ethics with regard to the Therapist – Client relationship.
When a Faculty member is responsible for education and training programs, he/she seeks to ensure that the programs are competently structured and provide appropriate experiences and training to fulfill the stated objectives. The Faculty member recognizes the power he/she holds over Students and supervisees and therefore conducts him/herself with respect toward Students and supervisees.
The Faculty member attempts to ensure that any education and training programs for which he/she is responsible have accurate descriptions of the program content, training goals, objectives, and requirements that must be met for satisfactory admission to and completion of the program. This information is made readily available to all interested parties.
When engaged in teaching or training, Faculty present pertinent information accurately and objectively with respectful critiques when appropriate.
The Faculty member establishes appropriate processes for providing feedback to Students and supervisees. He/she evaluates Students and supervisees on the basis of their actual performance on relevant and established program requirements.
Faculty maintain a level of confidentiality appropriate for the teaching environment. Faculty, Staff and Facilitators discuss trainees and supervisees only in accord with publicly stated policy or mutual agreement, for the purpose of enriching the educational opportunities of the individual or for the perceived benefit of their therapeutic process.
c. Types of Unacceptable Conduct:
Failure to meet the responsibilities of instruction, including:
a) arbitrary denial of access to instruction;
b) significant intrusion of material unrelated to the course;
c) significant failure to adhere, without legitimate reason, to the rules of the Faculty in the conduct of courses, to meet class or to hold examinations as scheduled;
d) evaluation of Student work by criteria not directly reflective of course performance;
Discrimination, including harassment, against a Student on political grounds, or for reasons of race, color, religion, sex, sexual orientation, gender identity, ethnic origin, national origin, ancestry, marital status, pregnancy, physical or mental disability, medical condition, because of age or citizenship or for other arbitrary or personal reasons.
Use of the position or powers of a Faculty member to coerce the judgment or conscience of a Student or to cause harm to a Student for arbitrary or personal reasons.
Participating in or deliberately aiding disruption, interference, or intimidation in the classroom.
Entering into a romantic or sexual relationship with any Student.
4. Conflict of Interest
a. General Statement
EPI persons are encouraged to engage in activities outside the Institute, so long as such activities do not interfere with their obligations to the Institute. While recognizing these activities may benefit the participants, the Institute, and the public at large, the Institute is committed to ensuring that they are conducted in a manner consistent with its interests and mission and which maintains the wider community’s trust and confidence.
EPI persons must act with integrity and adhere to the highest ethical standards at all times.
Occasionally, and often as a result of normal and productive engagements inside and outside the Institute, EPI persons may find themselves in an actual, potential or perceived conflict of interest. Those conflicts of interest that go unnoticed or are improperly managed can affect the reputation and integrity of the persons involved and, potentially, the Institute as a whole. EPI persons are therefore expected to guard against, or appropriately disclose, conflicts of interest – actual, potential or perceived – including conflicts of commitment.
b. Conflict of Interest Principles
“Conflict of interest” means a situation in which an EPI person, or persons related to him/her, have a personal interest that conflicts, or could conflict with, the EPI person’s obligations to the Institute.
A “perceived conflict of interest” is a situation where an actual or potential conflict of interest may or may not exist, but where there may be, nonetheless, from the perspective of a reasonably well-informed, impartial observer, a perception of a conflict of interest.
A “conflict of commitment” occurs where an EPI person engages in non-Institute activities that are substantial or demanding of the EPI person’s time and attention and adversely affect the discharge of the EPI person’s responsibilities to the Institute.
Conflicts of interest and perceived conflicts of interest fall into one of two categories: those that are permissible if appropriately managed; and those that are prohibited because they cannot be appropriately managed.
Conflicts of interest and perceived conflicts of interest can arise naturally from a EPI person’s engagement inside and outside the Institute, and the mere existence of a conflict of interest or the perception of a conflict of interest does not necessarily imply wrongdoing on anyone’s part.
Nonetheless, conflicts of interest and situations that give rise to perceptions of a conflict of interest must be recognized, disclosed, and assessed.
c. Conflict of Interest Disclosure
Prior to undertaking any activity that may give rise to a conflict of interest or a perceived conflict of interest, whether or not that activity is within the scope of the EPI person’s work at the Institute, an EPI person must disclose that activity. Where prior disclosure is impossible, disclosure must be made as soon as possible after commencement of the activity.
Where an EPI person seeks approval for a conflict of commitment, the Director may, in his or her discretion and may impose conditions, taking into consideration the following:
whether the activity interferes with the EPI person’s obligations to the Institute; and
if so, whether the activity nonetheless contributes to or benefits the Institute in such a way that warrants the interference.
d. Specific Situations of Conflict of Interest and Commitment
EPI persons are expected to vigilantly guard against conflicts of commitment, actual and potential conflicts of interest, and perceived conflicts of interest.
The Institute has not attempted to develop an exhaustive list of conflicts of interest since each situation depends upon its specific facts. However, the following are examples of situations where a conflict of interest exists:
Where an EPI person’s responsibility to instruct and evaluate Students in a fair, unbiased and effective manner is or could be impeded or compromised. The inherent power imbalance that exists between an EPI person and a Student must not be used for personal benefit.
Where an EPI person or a related party has a financial interest in their teaching activities at the Institute, other than their salary from the Institute.
Where an EPI person is in a position to influence human resource decisions (such as recruitment, offer of employment, evaluation of performance, promotion, or termination of employment) or admission decisions with respect to a person with whom the EPI person has a relationship that might reasonably be perceived as creating a Conflict of Interest.
Where an EPI person uses his or her position with the Institute to solicit Students, other EPI persons, government agencies, private companies, or members of the public for Non- Institute Activities, including employing or soliciting employment from Students and other EPI persons for services in a personal or commercial matter.
Where an EPI person uses information that is acquired as a result of his or her relationship with the Institute and not in the public domain for Non-Institute Activities unless the EPI person has proprietary rights to that information.
Where an EPI person’s obligations to any outside organization interfere with or compromise the EPI person’s obligations to the Institute.
Where personal considerations compromise a Faculty, Staff or Administration member’s professional judgment in teaching, or carrying out administrative activities.
Where an EPI Student, Staff, Faculty or Administration member is promoting one’s own services or products for financial gain or services or products from outside of the EPI on Institute premises, within Institute activities or through any EPI email, contact list or social media platform.
All conflicts of interest, actual, potential or perceived, must be avoided or disclosed to the Director, who will make an assessment of whether they can be appropriately managed or must be prohibited.
Conflicts of commitment are a subset of conflicts of interest and include the following situations:
Where an EPI person engages in Non-Institute Activities during his or her normal work hours at the Institute.
Where an EPI person uses Institute resources for Non-Institute Activities.
Conflicts of commitment must be avoided or disclosed to, and authorized by, the Director.
5. Use of EPI Property
a. General Principles
All EPI property is to be used for legitimate Institute purposes and not for the personal benefit or gain of an EPI person or any other party, except in very limited circumstances as authorized by the relevant policies listed below. EPI is committed to maintaining sound management of public resources with integrity and honesty.
b. Physical assets
The principles of transparency and accountability underpin the use and management of Institute physical assets. All equipment, goods and supplies purchased by EPI for any purpose from Institute funds, remains the property of the Institute.
c. Human Resources
EPI values and respects all members of its communities. The utilization of EPI’s human resources must be in accordance with EPI’s values, its policies and procedures and applicable legislation. EPI human resources are not to be utilized for the personal benefit or gain of individuals. EPI strives to provide a safe, healthy and secure environment for all EPI persons in which to carry out EPI related activities.
All EPI persons that are in a position to influence human resource decisions or admission decisions with respect to a person with whom the EPI person has a relationship, must be mindful of potential actual or perceived conflicts of interest.
6. Intellectual property
The intellectual property of the Institute includes all material, written, audio, visual, created for use by the Institute. The use of the Institute’s intellectual property can only be granted by written permission by the Director.
a. General Principles
Intellectual property is a valuable Institute asset. The Institute’s policies around ownership and use of intellectual property reflect its identity as a community of scholars and its commitment to the pursuit and dissemination of true knowledge through teaching.
Earning revenue from the commercialization of knowledge is not a significant factor for the Institute. At the same time, the Institute seeks to recover a fair share in any gains realized through the distribution of teaching materials created with Institute resources.
b. Work Product of Administrative Staff
The Institute treats the intellectual product typically produced by non-academic Staff as a requirement of their employment, as Work Product. Work Product can include copyrights, trademarks and websites and is owned by the Institute. Work Product may not be publicly disclosed without the Institute’s prior written approval.
c. Teaching Materials
An EPI Faculty, Staff or administrative member may not place restrictions on, or publish commercially, teaching materials that have been developed with special EPI investment. Any member of the Institute must obtain written permission to share or distribute teaching materials outside of the scope of EPI activities.
d. Use of Institute Trademarks
The Institute has exclusive authority to regulate the use of Institute trademarks. All third parties wishing to use one or more of these must secure a written license to do so from the Institute. Use of Institute trademarks by Faculty and administrative units for Institute-related activities do not require a license agreement. Faculty, Staff and Administration should understand that their personal endorsement of any product does not constitute Institute endorsement and should not be given in a manner that might lead a member of the public to believe it does.
7. Protection of Privacy
All EPI Faculty members, Staff, volunteers and service providers must adhere to the requirements of the General Data Protection Regulation (GDPR).
a. Personal Information
EPI must collect, use and disclose personal information in a lawful and appropriate manner. “Personal information” is defined as “recorded information about an identifiable individual.” Collection of personal information must only occur with proper authority, using a privacy notification. Personal information must only be used for the purpose it was collected, or for a use consistent with that purpose. EPI persons must only share personal information within EPI on a need-to-know basis and must not share personal information outside EPI without approval.
EPI must make “reasonable security arrangements” to safeguard personal information in EPI’s custody or under its control. Where personal information is stored in electronic format it should be stored on secure servers wherever possible. If it is essential to store personal information on portable devices, it must be encrypted. EPI service providers with access to personal information must sign contracts requiring them to protect the information.
Personal information must be retained for at least one year after it is used to make a decision that directly affects the individual. If the information has not been used to make a decision, this retention requirement does not apply.
EPI treats the unauthorized collection, use, disclosure or disposal of personal information as serious matters. Any such privacy breaches must be reported immediately to the Director.
b. Protection of General EPI Information
The protection of general information must take place particularly within the context of the EPI values of academic freedom and advancement and sharing of knowledge. Notwithstanding this, EPI persons must not use data or information to which they have access for their own personal benefit or in a way that could be of detriment to EPI. EPI persons must maintain the confidentiality of general information including human resources records and must not disclose information to an internal or external person unless necessary in the discharge of their Institute obligations. This applies to both the period of employment with EPI as well as any time after the end of employment with EPI.