If the Title VI Coordinator becomes aware of a single egregious offense, or receives repeated allegations of offenses against the same person but each of the persons making allegations is unwilling to file a written complaint and appear as complainant, and if circumstances are considered by the Title VI Coordinator to be such that a complaint should be lodged, the Title VI Coordinator, in his or her sole discretion, may inform the appropriate Vice-President or member of the Executive Council, or in the case of conflict of interest, the President.

The Title VI Coordinator shall communicate with persons drawn from the pertinent notes/records who might provide evidence of discrimination or harassment to determine their willingness to provide testimony if the Seminary were to proceed as a complainant against the alleged offender. The Title VI Coordinator shall not communicate the contents of the notes to such persons in either written or verbal form.

The Title VI Coordinator shall provide to the appropriate Vice-President(s) or corresponding member of the Executive Council the names of witnesses who agree to testify, the name of the alleged respondent, and copies of any written complaints and responses submitted to the Officer relating to alleged offense(s) by the respondent.

The appropriate Vice-President or member of the Executive Council shall communicate with witnesses and the alleged respondent, review all information and decide (as soon as possible but no later than four weeks from the date of receiving the information) whether to initiate formal procedures against the respondent. The Title VI Coordinator shall be informed in writing of the Vice-President’s or Executive Council’s decision. If the Vice-President or corresponding Executive Council member decides to initiate formal proceedings against the respondent, such proceedings normally should be initiated within one week of making the decision [See Section X, Step 6]