Regulations on the Anti-Discrimination, Prevention of Sexual Harassment and Equality Support Policy
at National Aerospace University
«Kharkiv Aviation Institute»
Approved by:
The Academic Council of
National Aerospace University
«Kharkiv Aviation Institute»
Protocol No. 3 dated October 22, 2025
Enacted by Order No. 491 dated October 23, 2025
QMS KhAI-CQA-P/001:2025
Effective date: October 23, 2025
Revision No. 2
Preamble
National Aerospace University «Kharkiv Aviation Institute» (hereinafter referred to as the University) recognizes that sexual harassment and discrimination violate human rights, degrade human dignity, hinder the creation of an inclusive educational environment, and cause harm to the physical, psychological, and social well-being of affected individuals.
The University is an organization that fosters a welcoming attitude and open actions aimed at promoting respect for the individual, regardless of their gender, age, race, or physical condition. The University demonstrates its commitment to ensuring human rights, equal opportunities, and respect for diversity, fair and impartial treatment, and creating conditions within the University and in society as a whole under which the dignity of every individual is respected and valued, with an emphasis on vulnerable population groups. Equal opportunities and respect for diversity at the University are implemented across grounds of gender, age, health status and disability, racial, ethnic, and cultural background, religion, and belief.
The principles of gender equality at the University are prioritized in both the educational and working environments and are part of a number of core tasks of the University regarding the establishment of a European-level educational space. The implementation of gender equality principles at the University involves systematic monitoring, analysis, and dissemination of data on gender equality, cooperation with all-Ukrainian and international organizations, scholars, and experts, as well as combating gender discrimination, sexism, gender stereotypes, etc.
The University undertakes to ensure:
- respect for human dignity, private life, and the rights of every person;
- zero tolerance for any form of discrimination and violence, including sexual harassment;
- a survivor-centered and trauma-informed approach, preventing retraumatization;
- a presumption of trust in complaints submitted by affected individuals;
- confidentiality;
- institutional sustainability;
- impartial, timely, comprehensive, and effective response to complaints.
In order to create a safe, inclusive, and non-discriminatory educational environment at the University, based on the Methodological Recommendations on the Implementation of Anti-Discrimination, Sexual Harassment Prevention, and Equality Support Policies in Higher Education Institutions of Ukraine, approved by Order of the Ministry of Education and Science of Ukraine dated August 23, 2025, No. 1275, the University approves the Regulations on the Anti-Discrimination, Sexual Harassment Prevention, and Equality Support Policy (hereinafter referred to as the Regulations).
1. General Provisions
1.1. These Regulations have been developed on the basis of the University Code of Ethics to establish procedures for preventing and combating sexual harassment, violence, and discrimination, ensuring equal opportunities for participants in the educational process to exercise the rights and freedoms of all employees and learners, and maintaining an educational environment at the University free from discrimination, bullying, mobbing, and insults to personal honor and dignity.
1.2. These Regulations have been created taking into account the best practices of other higher education institutions of Ukraine as well as existing best practices at the University on this matter. They are aimed at ensuring ethical conduct and apply to all individuals who study or maintain employment or other contractual relations with the University, including, in particular, learners, University employees, individuals working under civil law contracts, etc. These Regulations approve the internal University policy on anti-discrimination, sexual harassment prevention, and equality support (hereinafter referred to as the Policy). These Regulations constitute an updated version of the Regulations on the Prevention and Counteracting of Discrimination and Resolution of Conflict Situations (QMS KhAI-ED-P/003:2023), which remains in effect after the enactment of these Regulations with regard to the application of formal / informal procedures for preventing discrimination, including bullying, mobbing, and other manifestations of unethical behavior, as well as the resolution of conflict situations.
1.3. The University recognizes the importance of adhering to universally recognized principles of respect for human dignity, human rights, and freedoms in accordance with the Constitution of Ukraine, the Universal Declaration of Human Rights, the UN Convention on the Elimination of All Forms of Discrimination against Women (CEDAW), the Council of Europe Convention on the Protection of Children against Sexual Exploitation and Sexual Abuse (Lanzarote Convention), the Council of Europe Convention on Preventing and Combating Violence against Women and Domestic Violence (Istanbul Convention), the UN 2030 Sustainable Development Goals, the Beijing Declaration and Platform for Action, the Labor Code of Ukraine, the Laws of Ukraine «On Education», «On Higher Education», «On Ensuring Equal Rights and Opportunities of Women and Men», «On the Principles of Preventing and Combating Discrimination in Ukraine», «On Preventing and Combating Domestic Violence», «On Personal Data Protection», «On Citizens' Appeals», Decree of the Cabinet of Ministers of Ukraine dated December 20, 2022, No. 1163-r «On Approval of the Strategy for the Implementation of Gender Equality in the Field of Education until 2030 and Approval of the Operational Action Plan for 2022-2024 for Its Implementation», Decree of the Cabinet of Ministers of Ukraine dated March 25, 2025, No. 260 «On Approval of the Operational Action Plan for 2025-2027 for the Implementation of the Strategy for the Implementation of Gender Equality in the Field of Education until 2030», the National Action Plan for the Implementation of UN Security Council Resolution 1325 dated October 28, 2020, No. 1544-r «Women, Peace, Security» for the period up to 2025, approved by Decree of the Cabinet of Ministers of Ukraine, Order of the Ministry of Social Policy dated February 07, 2020, No. 86 «On Approval of Instructions for the Integration of Gender Approaches in the Development of Regulatory Acts», Resolution of the Cabinet of Ministers of Ukraine dated June 04, 2025, No. 658 «On Approval of the Model Program for Preventing Violence and Ill-Treatment of Children», Resolution of the Cabinet of Ministers of Ukraine dated August 22, 2018, No. 658 «On Approval of the Procedure for Interaction among Subjects Carrying Out Measures in the Sphere of Preventing and Combating Domestic Violence and Gender-Based Violence», Recommendation CM/Rec (2019) 1 «Preventing and Combating Sexism», adopted by the Committee of Ministers of the Council of Europe on March 27, 2019, and Recommendation CM/Rec (2022) 16 of the Committee of Ministers of the Council of Europe to Member States on Combating Hate Speech.
1.4. The legal framework for preventing and combating sexual harassment, violence, and discrimination, in particular, consists of:
- The Criminal Code of Ukraine (hereinafter — CC of Ukraine), the provisions of which establish criminal liability for such criminal offenses and crimes as: «Rape» (Article 152 of the CC of Ukraine); «Sexual Violence» (Article 153 of the CC of Ukraine), «Coercion into Sexual Intercourse» (Article 154 of the CC of Ukraine), «Corruption of Minors» (Article 156 of the CC of Ukraine), «Violation of Equality of Citizens Depending on Their Race, Nationality, Religious Beliefs, Disability, and Other Grounds» (Article 161 of the CC of Ukraine), «Abuse of Power or Official Position» (Article 364 of the CC of Ukraine);
- The Code of Ukraine on Administrative Offenses (hereinafter — CUAO), primarily: Article 1732 of the CUAO «Committing Domestic Violence, Gender-Based Violence, Failure to Comply with an Emergency Protection Order, or Failure to Notify of One's Temporary Residence Location», Article 1734 of the CUAO «Bullying (Harassment) of a Participant in the Educational Process», Article 1735 of the CUAO «Mobbing (Harassment) of an Employee», Article 1736 of the CUAO «Committing Gender-Based Violence», Article 1737 of the CUAO «Sexual Harassment», Article 1843 of the CUAO «Failure of Officials to Perform Duties Regarding the Prevention and Counteraction of Domestic Violence and Gender-Based Violence».
1.5. In these Regulations, terms are used in the following meanings:
Accessibility / Barrier-free environment — a principle of creating an environment in which every person has equal access to opportunities regardless of age, sex, health status, or other characteristics; it entails eliminating physical, informational, and social barriers.
Bullying (harassment) — actions by participants in the educational process consisting of psychological, physical, economic, or sexual violence, including through electronic communications, committed against a minor or by a minor against other participants in the educational process, resulting in potential or actual harm to the mental or physical health of the victim.
Victim-blaming — shifting the blame for what happened, in particular for a committed offense, from the perpetrator to the affected person.
Gender — socially established roles, behaviors, activities, and attributes that a given society considers appropriate for women/men.
Gender equality — a state of equal rights, responsibilities, and opportunities for women and men, which ensures that the interests, needs, and priorities of both women and men are taken into account.
Gender-based violence — violence directed against a person because of their sex, or violence that disproportionately affects women.
Gender-sensitive, non-discriminatory language — the implementation of gender equality in written and spoken language, achieved when women and men, as well as non-binary individuals, become visible in language as persons of equal value, dignity, integrity, and respect; in particular, this includes the use of feminitives — feminine words used to denote professions, positions, social status, and types of activity referring to women.
Gender-sensitive approach — taking into account specific social, cultural, economic, political, and other characteristics of living conditions and needs of women and men.
Discriminatory expressions — verbal or non-verbal expressions, including in electronic communications, that degrade the dignity of a person or a group of persons based on sex, race, age, sexual orientation, gender identity, or other characteristics, which may lead to biased treatment or create a hostile environment.
Discrimination — a situation in which a person and/or group of persons experiences restriction in the recognition, implementation, or enjoyment of rights and freedoms in any form based on their actual or perceived race, skin color, political, religious, or other beliefs, sex, age, disability, ethnic or social origin, citizenship, marital or property status, place of residence, linguistic or other characteristics (hereinafter — certain characteristics), except when such restriction pursues a legitimate, objectively justified goal, and the means of achieving it are appropriate and necessary.
Sex-based discrimination — a situation in which a person and/or group of persons experiences restriction in the recognition, implementation, or enjoyment of rights, freedoms, or privileges in any form established by the Law of Ukraine «On the Principles of Preventing and Combating Discrimination in Ukraine» based on their actual or perceived sex, except when such restrictions or privileges pursue a legitimate, objectively justified goal, and the means of achieving it are appropriate and necessary.
Electronic communications — the exchange of information (text messages, photo, video, audio files, etc.) carried out using electronic means of communication, such as email, messengers, social networks, mobile applications, online platforms, video communication, etc., including those used in the course of and for the purpose of educational and scientific activities.
Complainant — a person who has filed a complaint regarding a violation of equal rights and opportunities for women and men.
Cybermobbing (cyberbullying) — mobbing or bullying conducted through intentional insults, threats, and sharing compromising data about a person within a group using modern mobile communications, typically over an extended period, taking place in cyberspace via information and communication channels, including email, instant messaging apps, and social networks.
Confidentiality — non-disclosure of any information to any party without the informed consent of the person concerned; exceptions to confidentiality consist of mandatory reporting requirements established by regulations.
Conflict of interest — a situation in which a person has a personal interest in the sphere of their professional, academic, or representative activities that could affect their ability to act impartially, objectively, and in a manner consistent with the principles of equality, non-discrimination, and respect for the rights of others.
Perpetrator / Offender — a person who has committed a violation.
Mobbing (harassment) — systematic (repeated), prolonged, intentional actions or inaction by an employer, individual employees, or a group of employees aimed at humiliating the honor, dignity, or business reputation of an employee, including for the purpose of acquiring, altering, or terminating their labor rights and duties; manifested in psychological and/or economic pressure, including via electronic communications, creating a tense, hostile, or offensive atmosphere that may lead to the employee underestimating their professional competence.
Hate speech — expressions that incite, promote, spread, or justify violence, hatred, or discrimination against a person or a group of persons based on real or perceived/imagined personal characteristics (status) such as: race, skin color, language, religion, nationality, national or ethnic origin, age, disability, sex, gender identity, and sexual orientation.
Mandatory reporting — a statutory requirement to inform authorized bodies or individuals about alleged violations that pose threats to the safety of the affected person and others, forming an exception to confidentiality (in particular, those aimed at protecting minors or containing signs of an alleged criminal offense subject to public prosecution).
Person against whom a complaint is filed — a person whose actions or behavior are the subject of a complaint.
Stalking — repeated attempts to observe, follow, and/or harass a specific individual, causing the person to fear for their own safety or the safety of others or to suffer significant emotional distress.
Affirmative action (positive measures) — special temporary measures with a legitimate, objectively justified goal aimed at eliminating legal or factual inequality in opportunities between women and men regarding the implementation of rights and freedoms established by the Constitution and laws of Ukraine.
Affected person / Victim — a person who has suffered from discrimination, sexual harassment, or other violations.
Survivor-centered approach — a comprehensive approach that involves the recognition, respect, and protection of the rights and dignity of persons who have experienced any form of discrimination, sexual harassment, or other violations inconsistent with the Regulations, by creating sensitive, safe, non-discriminatory response procedures, providing support, and preventing revictimization and traumatization, taking into account the needs and vulnerabilities of affected persons and understanding the gender-based nature of violence.
Retraumatization (repeated traumatization) — the process of re-experiencing a traumatic experience or similar emotional stress, which complicates recovery.
Equality — a principle that guarantees equal rights, opportunities, and treatment for all persons regardless of their characteristics.
Witness — a person who knows or may know about the commission of sexual harassment and/or discrimination against another person (persons), or who was an eyewitness to the situation.
Sexism — any act, gesture, visual expression, spoken or written words, practice, or behavior based on the idea that a person or group of persons is inferior because of their sex, occurring in the public or private sphere, online or offline, and aimed at (or resulting in): violating human dignity or rights of a person or group of persons; physical, sexual, psychological, or socio-economic harm or suffering to a person or group of persons; creating a threatening, hostile, degrading, or offensive environment; impeding the independence or full exercise of human rights by a person or group of persons; maintaining and reinforcing gender stereotypes.
Sexual harassment — any form of unwanted verbal, non-verbal, or physical conduct of a sexual nature, the purpose or effect of which is to violate the dignity of a person, in particular by creating an intimidating, hostile, humiliating, or offensive environment, expressed verbally (threats, intimidation, indecent/unwanted proposals and/or remarks, jokes, messages and letters, display of images, etc.) or physically (unwanted touching, patting, etc.).
Trauma-informed approach — a comprehensive approach that involves understanding and recognizing how trauma can affect a person's behavior, emotional state, learning, and social interactions, based on the principles of respect for human dignity of affected persons, creating a safe environment, and preventing retraumatization during assistance, communication, or decision-making.
Harassment / Oppression — conduct unwanted by a person and/or a group of persons, the purpose or effect of which is to humiliate their human dignity based on certain characteristics or to create a tense, hostile, offensive, or disrespectful atmosphere toward such a person or group of persons.
Other terms used in these Regulations are applied in the meaning defined by the legislation of Ukraine.
1.6. Within the meaning of these Regulations, discrimination (discriminatory actions) includes, in particular, bullying, mobbing, cyberbullying/cybermobbing, sexual harassment, stalking, harassment/oppression, and other types of violence. These types of unlawful actions are classified as instances of unethical behavior at the University. Instances of unethical behavior also include the intentional submission of a knowingly false complaint or the provision of knowingly false information, as confirmed in the established manner.
1.7. Within the meaning of these Regulations, lawful demands of University officials issued within their authority to higher education learners or University employees, aimed at ensuring the proper performance of their duties in accordance with the legislation of Ukraine, the Statute, the Internal Rules of the University, the terms of agreements with the University, job descriptions, etc., are not considered discrimination (discriminatory actions), including bullying or mobbing.
1.8. Violations of the requirements of these Regulations constitute grounds for conducting an internal review, investigation, and bringing the guilty persons to liability provided for by law. The application of procedures and measures provided for by these Regulations does not preclude the possibility of applying the norms of current Ukrainian legislation regarding the protection of a person's rights in another manner.
1.9. The scope of these Regulations extends to all employees, learners, other individuals involved in the activities of the University, as well as visitors to the University within the educational, scientific, labor, cultural, sports, administrative, and information environment of the university.
1.10. The scope of these Regulations covers conduct (any actions and/or inaction) that occurs:
- on the premises of the University and in any facilities owned and/or used by the University;
- during events organized by the University or with the participation of University representatives;
- on the Internet, including web pages and social media pages administered by the University or its representatives;
- during studies (including using electronic communications), training and competition processes, internships, research activities, etc., outside the University premises, provided the University is responsible for ensuring the safety of the educational process participants;
- during recruitment, employment relations, remuneration at the University, etc.
2. Rights and Obligations of Participants in the Process of Preventing and Combating Discrimination, Sexual Harassment, Bullying, and Mobbing
2.1. The University guarantees:
- the provision of legal relationships and respectful treatment of all participants in the educational process;
- promoting awareness among all participants in the educational process regarding stereotypes and prejudices underlying inequality, discrimination, and sexual harassment through education and outreach;
- accessibility of necessary information and resources for obtaining help, publications on the official website of the University, visual materials, manuals, and information campaigns (information must be presented in accessible formats consistent with barrier-free principles);
- transparent procedures for protection against discrimination and sexual harassment, adhering to fairness and a gender-sensitive approach;
- compliance with confidentiality and objectivity, impartiality, and fairness in the complaint review process;
- preventing any negative consequences for complainants, affected persons, or witnesses (in particular, the creation of a hostile atmosphere and harassment (mobbing, bullying), dismissal of employees, obstruction in taking exams or other assessment activities for higher education learners, stalking, retaliation, or intimidation by the person against whom a complaint is filed, etc.);
- the introduction, if necessary, of affirmative action as a means of achieving the goals of the Policy.
2.2. Every higher education learner and every employee of the University has the right to:
- safe learning and working conditions free from any discrimination;
- personal integrity;
- protection of honor, dignity, rights, freedoms, and legitimate interests in ways provided for by the legislation of Ukraine and these Regulations;
- protection against discrimination;
- have a representative or an attorney during the investigation of discrimination facts in accordance with the procedure provided for by these Regulations.
2.3. All higher education learners and employees of the University are obliged to:
- respect individual rights and dignity in relations between learners and academic staff (employees), among learners, among employees, and between learners/employees and other persons, observing norms of mutual respect, equal cooperation, tactfulness, correctness, politeness, and tolerance;
- refrain from manifestations of national, religious, racial, or gender intolerance, as well as any discriminatory actions;
- respect the private life of other persons and adhere to confidentiality principles;
- be aware of the content of the University's Anti-Discrimination, Sexual Harassment Prevention, and Equality Support Policy and comply with its provisions in their activities;
- refrain from behavior that could be perceived as discrimination and/or sexual harassment or violence, including gender-based violence;
- where possible, report instances of discriminatory behavior, violence (in particular gender-based violence), and sexual harassment they have witnessed, and, whenever possible, oppose them;
- when appointed to managerial or teaching positions, or participating in student self-government, serve as an example of compliance with ethical and legal norms and standards of conduct;
- proactively support measures aimed at promoting equality, non-discrimination, and combating sexual harassment;
- maintain an atmosphere of goodwill, friendship, mutual assistance, and mutual responsibility within academic groups, departments, and across the University as a whole.
2.4. The Rector (or Vice-Rectors and other University officials acting on their behalf):
- organizes the creation of an environment within the University free from any form of discrimination and insults to personal honor and dignity;
- exercises control over the prevention of privileges or restrictions (discrimination) based on sex, race, ethnic origin, age, language, sexual orientation, gender identity, disability, political, religious, or other beliefs, marital or property status, place of residence, or other specified characteristics;
- exercises control over the execution of the action plan aimed at preventing and combating discrimination, sexual harassment, bullying, and other discriminatory actions, including commissioning (at least once a year) a survey of educational process participants and employees regarding the anti-discrimination situation at the University;
- considers complaints regarding refusal to respond to instances of discrimination, sexual harassment, or bullying submitted by higher education learners, their parents, legal representatives, or other persons, and makes decisions based on the review results of such complaints; considers applications regarding instances of discrimination, sexual harassment, and bullying, issues decisions to conduct an investigation, and takes appropriate response measures based on its findings;
- considers applications and complaints regarding instances of discrimination, sexual harassment, and mobbing submitted by University employees, makes decisions based on the review results of such applications and complaints, issues decisions to conduct an investigation, and takes appropriate response measures based on its findings.
2.5. Heads of structural units, in particular Deans of faculties, Heads of departments together with other department/dean's office employees, as well as supervisors of clubs and sports sections must:
- ensure the creation of a safe and harmonious environment in subordinate structural units and serve as a model of the highest standards of conduct;
- ensure systematic awareness-raising activities aimed at preventing manifestations of discrimination and other forms of unethical behavior in subordinate structural units;
- foster legal consciousness, lawful behavior, personal responsibility, independence, and the pursuit of self-fulfillment in learners;
- protect learners during the educational process and extracurricular time from any forms of discrimination, including bullying and other manifestations of unethical behavior on any grounds that cause harm to health and psychological well-being;
- notify the University administration of facts of discrimination and other manifestations of unethical behavior toward higher education learners, teaching staff, and other persons involved in the educational process, which
they personally witnessed or about which they received reliable information from other persons;
- assist the commission in investigating facts of discrimination, including bullying, mobbing, and other manifestations of unethical behavior at the University, and execute its decisions and recommendations;
- respond immediately to instances of unethical behavior in accordance with the procedure provided for by these Regulations;
- adhere to the principles of objectivity, fairness, and permissible confidentiality when resolving conflict situations.
2.6. Officials of the University Campus (Student Town), the Department of Educational and Social Work (including the Psychological Service), as well as University officials assigned the duties of academic group tutors or vice-deans, together with representatives of student self-government bodies and the primary trade union organization of students, postgraduates, and doctoral students, must:
- ensure a safe living environment for learners in University dormitories for their daily life and leisure;
- organize systematic awareness-raising events among learners aimed at preventing discrimination and other manifestations of unethical behavior through thematic events: lectures, talks, and consultations with a practicing psychologist;
- ensure the implementation of measures to provide social, psychological, and pedagogical services to learners who have committed, witnessed, or suffered from bullying and other types of unethical behavior;
- maintain records of instances of bullying and other types of unethical behavior, along with the preparation of relevant documentation;
- build skills of tolerant and non-violent communication and interaction among educational process participants;
- respond immediately to instances of unethical behavior in accordance with the procedure provided for by these Regulations;
- adhere to the principles of objectivity, fairness, and permissible confidentiality when resolving conflict situations.
2.7. University learners must:
- comply with the legislation of Ukraine, the Statute, the Internal Rules, the Code of Ethics of the University, and these Regulations;
- respect the dignity, rights, freedoms, and legitimate interests of all persons working and studying at the University, and adhere to ethical standards of conduct;
- notify the academic group tutor, department administration, faculty leadership, or University administration of facts of discrimination, including bullying, mobbing, cyberbullying, and other manifestations of unethical behavior toward learners, teaching, academic, and research staff, or other persons involved in the educational process, which they personally witnessed or about which they received reliable information from other persons.
2.8. Parents (legal representatives) of learners have the right to:
- submit an application to the University administration (faculty, Campus) regarding instances of bullying toward their child or any other participant in the educational process;
- demand a full and impartial investigation into instances of bullying toward their child or any other participant in the educational process.
2.9. Parents of minor learners are obliged to:
- assist the University administration (faculty, Campus) in conducting investigations regarding instances of bullying;
- execute decisions and recommendations of the commission for considering instances of bullying at the University.
2.10. University employees must:
- comply with the legislation of Ukraine, the Statute, the Internal Rules, the Code of Ethics of the University, and these Regulations;
- respect the dignity, rights, freedoms, and legitimate interests of all persons working and studying at the University, and adhere to ethical standards of conduct;
- observe pedagogical ethics and protect learners during the educational process from any forms of physical and psychological violence, humiliation of honor and dignity, and discrimination on any grounds (applicable to teaching, academic, and research staff);
- promote respect for public morality and social values, including truth, justice, humanism, and tolerance, through guidance and personal example;
- always choose a non-confrontational way of resolving work issues, and avoid transferring personal troubles and problems onto relationships with colleagues;
- immediately notify the head of their unit, and, if necessary, the University leadership, about facts of discrimination, including bullying, mobbing, and other manifestations of unethical behavior toward higher education learners or other University employees, which they personally witnessed or about which they received reliable information from other persons.
3. Unacceptable Forms of Conduct
3.1. Unacceptable conduct may manifest in various forms — both open and covert. It can occur in both physical and online environments, encompassing verbal and non-verbal acts that may affect the dignity, physical or psychological state, and equality of opportunities for all participants in the educational process. The consequences of such actions are in any case harmful to the individual and/or the collective. The definition and identification of unacceptable conduct is the first step toward its prevention and eradication.
3.2. An indicative list of examples of conduct that may be considered manifestations of discrimination and sexual harassment, as well as other behavior that contradicts the principles and values defined as key in the University Policy:
3.2.1. Physical and verbal harassment:
- unwelcome physical attention or contact, including intrusive invasion of personal space or uninvited physical interference;
- proposals of an intimate nature or unwelcome remarks, comments, and innuendos of a sexual nature.
3.2.2. Direct sexual harassment:
- repeated demands or other forms of pressure regarding sexual or other personal rather than professional relationships (e.g., frequent invitations on dates);
- groundless, intrusive, or persistent questions about a person's marital status or their sexual interests, sexual history, or sexual orientation;
- indecent messages sent via text messaging tools, email, video chat, social networks, or left on an answering machine or voicemail;
- explicit or implicit threats (or promises) that acceptance of sexual advances will be a condition for a certain form of reward, promotion of professional status, career advancement, or obtaining career development opportunities;
- remarks containing assumptions about a person's sexual activity or history, or remarks about one's own sexual activity or history;
- display of materials of a sexual nature (including pornographic materials), in particular posters, photographs of attractive women/men, caricatures, graffiti, objects, or messages by placing them on notice boards, desks, or in common areas;
- a manner of behavior that may be subtle in nature, which carries sexual undertones and is intended to cause suffering and/or humiliation to another person, or directly causes such suffering and/or humiliation;
- the use of unwanted terms of endearment;
- innuendos or other offensive or humiliating comments or jokes about a person's gender identity or sexual orientation.
Rape, attempted rape, sexual assault, or any sexual act committed with the use of coercion or without consent are criminal offenses and are considered in accordance with the current legislation of Ukraine.
3.2.3. Examples of discrimination:
- instances where an employee is not recommended (not considered) for promotion or other advancement, or is treated differently for any other purpose (e.g., regarding career development opportunities, overtime work, leave, working hours, bonuses, exclusion from participation in events, etc.) on the grounds of race, sex, gender identity, religion, citizenship, ethnic origin, sexual orientation, disability, pregnancy, age, language, social origin, or other status of the person;
- the use of derogatory or offensive nicknames on the grounds of race, sex, gender identity, religion, citizenship, ethnic origin, sexual orientation, disability, pregnancy, age, language, social origin, or other status of the person.
This also includes criticizing people for items (religious items) they wear for religious or cultural reasons:
- denigration of specific cultural or religious holidays or mocking comments regarding a person's beliefs;
- social exclusion on the grounds of race, sex, gender identity, religion, citizenship, ethnic origin, sexual orientation, disability, pregnancy, age, language, social origin, or other status of the person;
- jokes or inappropriate comments and questions regarding a person's abilities;
- groundless, intrusive, or persistent questions about a person's ethnic or racial origin, including their culture or religion.
3.2.4. Discriminatory statements and attitudes:
- derogatory comments or attitudes toward a person because of their sex, sexual orientation, gender identity, race, nationality, religion, age, disability, physical appearance, political views, social origin, financial status, place of residence, or other characteristics.
3.2.5. Use of hate speech:
- public communication suggesting the incapacity of women or men for certain areas of activity based on stereotypical notions.
3.2.6. Discrimination in the educational and professional process:
- biased attitude toward participants in the educational process based on their sex and/or other protected characteristics;
- distribution of tasks or roles in group work based on stereotypical notions about women and men;
- disregard and contempt for proposals and opinions expressed by women due to the belief that they cannot be experts in the relevant topic (oppression);
- ignoring the career advancement of women compared to men;
- refusal to hire women due to the potential need for maternity leave, denial of such leave to them, or refusal to grant parental leave to men and women, or refusal to hire them due to the potential need for such leave.
3.2.7. Violence:
- physical violence or threats of physical violence;
- psychological violence, including humiliation, intimidation, and harassment.
3.2.8. Any of these specified forms of unacceptable conduct, but not limited to them, are prohibited at the University.
3.3. Oral or written statements, language phrasing, as well as visual materials (presentations, slides, infographics, videos, images, text examples from public spaces, advertising materials, etc.) that contain examples of discriminatory, derogatory, or humiliating formulations are not considered violations if they are used exclusively for educational, analytical, or research purposes, in particular, to illustrate unacceptable conduct, demonstrate its harmfulness, and foster critical thinking.
4. Prevention of Sexual Harassment and Discrimination
4.1. The University ensures regular awareness-raising activities to combat discrimination and sexual harassment and support equality, in particular:
- information campaigns on the inadmissibility of sexual harassment and discrimination;
- training for employees and learners on issues of preventing and combating sexual harassment and discrimination;
- inclusion of relevant topics in educational curricula and professional development activities for staff;
- development, publication, and distribution of methodological materials on preventing and combating sexual harassment and discrimination;
- establishing polyethnic and multicultural dialogue within the university community, conducting targeted events, and supporting volunteer initiatives aimed at promoting equal opportunities and respect for diversity, particularly those involving University staff and learners.
4.2. The University ensures mandatory briefings for all participants in the educational process regarding the prevention of sexual harassment and discrimination, in particular:
- for learners — during the admissions campaign and at the beginning of each academic year;
- for employees — upon hiring and annually thereafter.
4.3. The University ensures the dissemination of information about complaint mechanisms regarding sexual harassment and discrimination, in particular by:
- publishing information on the official website of the University;
- posting information materials on notice boards on the University premises;
- including relevant information in orientation materials for learners;
- displaying the contact details of the person responsible for preventing and combating sexual harassment and discrimination, as well as other bodies that can be contacted in cases of sexual harassment and discrimination.
4.4. The University conducts regular monitoring of the situation regarding sexual harassment and discrimination, in particular through:
- periodic anonymous surveys among University learners and employees;
- analysis of complaints and appeals on these matters;
- evaluation of the effectiveness of measures undertaken to prevent and combat sexual harassment and discrimination.
Based on the monitoring results, the University assesses the risks of sexual harassment and discrimination cases occurring and takes measures to minimize them.
4.5. The University ensures annual reporting to the Academic Council of the University on the status of implementation of these Regulations and the results of monitoring.
5. Bodies and Officials Responsible for Preventing and Combating Sexual Harassment and Discrimination
5.1. The bodies responsible for preventing and combating sexual harassment and discrimination at the University are:
5.1.1. The Office of Equality, Inclusion, and Safe Environment of the University (hereinafter — the Office) with the status of an advisory body of the University, established by Order No. 483 dated October 17, 2025. The powers and operating procedures of the Office are set forth in the Regulations on the Office.
5.1.2. The Commission for Considering Complaints Regarding Discrimination, Sexual Harassment, and Support for Equality (hereinafter — the Commission) with the status of an advisory body of the University. The powers and operating procedures of the Commission are set forth in these Regulations.
5.1.3. The Person Responsible for Preventing and Combating Sexual Harassment and Discrimination (hereinafter — the Responsible Person).
The Responsible Person is appointed by order of the Rector of the University from among employees with appropriate qualifications and experience.
The Responsible Person:
- receives and registers complaints regarding sexual harassment and discrimination;
- provides consultations regarding the procedure for filing and considering complaints;
- carries out an initial analysis of complaints and prepares materials for consideration by the Commission, in particular, requesting the necessary documents for this purpose;
- seeks advice and/or information from University employees who have no personal interest in the outcome of the complaint review;
- coordinates work on preventing and combating sexual harassment and discrimination;
- maintains records of sexual harassment and discrimination cases;
- ensures the implementation of educational activities and information campaigns;
- interacts with other institutions and organizations on issues of preventing and combating sexual harassment and discrimination.
5.1.4. The Psychological Service of the University.
The Psychological Service of the University provides psychological support and counselling to affected persons and interacts with the Commission and the Responsible Person. The Psychological Service of the University operates in accordance with these Regulations and the Regulations on the Psychological Service of the Department of Educational and Social Work of the University.
5.1.5. The Rector, Vice-Rectors, Deans of faculties, Heads of departments, officials of the University Campus, teachers, club leaders, and other officials of the University are responsible for preventing and combating sexual harassment and discrimination at the University in accordance with the procedure established by these Regulations, in particular, within their competence:
- perform gender impact assessments on equality when adopting regulations, decisions, and procedures, i.e., determine the direct or indirect impact (positive, negative, or neutral), as well as short-term and long-term consequences of such University regulations, decisions, and procedures on the status of women and men, girls and boys, in order to timely identify and eliminate disparities and prevent and combat gender inequality;
- support and encourage measures to implement the Policy and eliminate barriers to their realization, including: insufficient awareness among employees, a culture of silence or tolerance of violations, lack of effective response procedures, conflicts of interest when considering complaints, stereotypes and prejudices within the team, lack of training and development of relevant competencies, fear of retaliation or stigmatization, limited resources, or failure to designate responsible persons, etc.;
- are required to respond in a timely manner to violations of equal rights and opportunities for women and men and to take the necessary measures to prevent, counteract, and avoid their recurrence in the future; in cases where resolution cannot be achieved independently, they must immediately refer the matter to senior officials or relevant University units.
5.2. In order to ensure independence, objectivity, and transparency of all procedures, the University may involve representatives of civil society organizations, experts, or other specialists to participate in policy development, educational events, and consultations on the prevention and counteraction of sexual harassment, violence, and discrimination.
6. Composition, Powers, and Operating Procedures of the Commission
6.1. The total number of Commission members is at least 12 persons. The total number of Commission members is not limited, provided that the Commission maintains a balance between the representation of higher education learners, teaching staff, and the University administration.
The Commission shall include individuals from among:
- the University Student Council;
- academic and research staff of the University, at least one of whom represents the primary trade union organization of University employees;
- other employees, at least one of whom represents the primary trade union organization of University employees;
- the Responsible Person;
- University representatives who are gender experts or conduct research in this field;
- representatives of the University Educational and Methodological Department or other representatives from the University administration;
- representatives of the primary trade union organization of students, postgraduate students, and doctoral students of the University;
- representatives of the University Legal Service;
- psychologists employed by the University.
Each category of representatives listed above must be represented on the Commission by at least one person.
The Commission may include external independent experts, representatives of the public and non-governmental sectors working in gender equality and counteracting discrimination, violence (including gender-based violence), and sexual harassment, as well as the Educational Ombudsman upon consent if an appeal is received. Such external independent experts may join the Commission on a permanent basis or be involved as needed upon the initiative and decision of the Commission.
The composition of the Commission must be gender-balanced.
The composition of the Commission shall be approved by an order of the Rector, taking into account proposals from the University Student Council, the primary trade union organization of University employees, and the primary trade union organization of students, postgraduate students, and doctoral students of the University.
The approved composition of the Commission is empowered for a term of 3 years with the possibility of renewal.
The University undertakes to consider the active participation of staff and learners in the work of the Commission when determining the individual (work) workload of staff, setting evaluation criteria within the internal educational quality assurance system, and calculating student ratings, particularly for academic scholarship awards.
6.2. The Commission is considered quorate to conduct meetings and make decisions if 2/3 of its membership is present at the corresponding meeting. Decisions are adopted by open vote (or, by a separate decision of the Commission, by secret ballot) by a majority of votes of those present at the meeting. All Commission members have equal voting rights.
If a conflict of interest arises for any member of the Commission regarding a filed complaint, such member shall be recused from its consideration by decision of the Commission. If such recusal affects the quorum of the Commission, the Commission may elect a temporary member from among the group represented by the recused member.
If a conflict of interest arises for a University official or other person authorized to make a decision based on the results of a complaint review, including cases where the filed complaint concerns this person, such person shall be recused from decision-making in accordance with the conflict of interest resolution procedure provided for by Ukrainian legislation and internal University regulations, and the decision on the results of the complaint review shall be adopted by the deputy of such official or another person authorized to make such a decision.
6.3. From among its representatives, the members of the Commission shall elect the Chair of the Commission and the Deputy Chair of the Commission. The Responsible Person shall be appointed as Secretary of the Commission. The Chair of the Commission represents the Commission in interactions with other University departments and bodies, signs documents adopted by the Commission, and serves as the Commission's contact person. The vote of the Chair of the Commission is decisive in the event of a tie.
6.4. The Commission conducts its work in the form of meetings (in person and/or remotely). Each meeting of the Commission shall be recorded in Minutes signed by the Chair and the Secretary of the Commission. The Secretary is responsible for taking minutes of meetings and maintaining records of Commission documentation.
6.5. To consider a specific complaint, the Chair of the Commission shall designate a rapporteur for the complaint. During the Commission meeting, the rapporteur shall present the results of the preliminary check and the draft decision, as well as answer questions from other Commission members.
6.6. Members of the Commission shall undergo special periodic training or professional development on counteracting violence (including gender-based violence), sexual harassment, and discrimination, as well as ensuring equality and a safe, non-discriminatory educational environment.
6.7. Members of the Commission shall participate in organizing periodic training or professional development for University staff on counteracting violence (including gender-based violence), sexual harassment, and discrimination in the educational process.
6.8. The Commission has the exclusive right to receive and consider complaints regarding instances of discrimination, violence (including gender-based violence), and sexual harassment, and, based on the review of complaints, to forward relevant findings to the Rector, law enforcement agencies, and other individuals or bodies authorized to make decisions on the complaint.
6.9. In order to effectively implement the Policy, the Commission, together with the Office, shall perform the following functions:
- disseminate information on the developed Policy regarding the counteraction of discrimination and sexual harassment and the support of equality;
- conduct training for participants in the educational process on preventing discrimination, violence (including gender-based violence), and sexual harassment, and ensuring equality;
- provide information and advisory support to participants in the educational process on preventing discrimination, violence (including gender-based violence), and sexual harassment;
- adopt and approve an annual action plan aimed at raising awareness regarding the counteraction of discrimination and violence (including gender-based violence), and monitor its implementation;
- conduct university-wide surveys on the state of compliance with equal rights and opportunities for women and men, the effectiveness of protection mechanisms against violations, etc.;
- request information from heads of faculties, other structural units, and persons authorized to carry out educational and awareness-raising activities regarding the implementation status of planned measures, identified obstacles, and proposals for improving work;
- highlight and disseminate information on measures to combat discrimination and sexual harassment and to support equality at the University on the official website of the University and on social media.
7. Complaint Filing Procedure and Protection of Confidentiality
7.1. If a person believes they have suffered from or witnessed discrimination, violence (including gender-based violence), sexual harassment, or other conduct that violates the principle of ensuring equal rights and opportunities for women and men, they have the right to appeal to the Commission.
7.2. An appeal to the Commission can be made by submitting a complaint in written or electronic form to the Commission's email address, or through specially designated channels, such as a "Trust Box" or an "electronic trust box."
7.3. A complaint must contain:
- the last name and first name of the complainant;
- the date and time the complaint was drawn up;
- a statement of the circumstances of the situation constituting the violation;
- information about the person against whom the complaint is filed;
- materials confirming the alleged violation (if available);
- information about witnesses (if available).
A written complaint must be signed by the complainant. Complaints to the Commission are not submitted anonymously; however, the Commission guarantees confidentiality and consideration of the interests of the complainant and the victim during the review of the complaint.
A person may contact a member of the Commission to consult regarding the filing of a complaint or to receive assistance in submitting a complaint.
The filing of a complaint is not subject to a statute of limitations.
7.4. In the event an anonymous complaint is submitted, the Commission does not initiate a formal review procedure; however, it logs the receipt of the complaint in the relevant register of appeals and may take this information into account when formulating preventative work plans involving the relevant individuals and/or University bodies concerned by the complaint.
The subject of an appeal to the Commission may also include materials used within the educational process that allegedly contain discriminatory elements. A complaint to the Commission may serve as grounds for resolving the issue of their further use, adaptation, and/or editing in accordance with the key principles and values provided by the University Policy.
7.5. The complainant has the following rights during the complaint review procedure:
- to submit a complaint regarding acts of discrimination, including on the grounds of sex/gender, sexual harassment, or other conduct contrary to ensuring equal rights and opportunities for women and men, in a convenient manner;
- to submit any available materials confirming the alleged violation;
- to involve witnesses who can confirm the commission of the violation;
- to receive explanations from the Commission regarding the complaint review procedure and the consequences of decisions adopted by the Commission;
- to participate in Commission meetings in person or remotely (remote participation allows avoiding unwanted contact with the perpetrator or re-traumatization), if there is a need to clarify additional information about the complaint or in other processes related to the review of the complaint, subject to mandatory compliance with procedural confidentiality;
- to have confidentiality maintained regarding relevant information during the entire case review process, as well as after its conclusion;
- to receive information regarding the stage at which the complaint review currently stands;
- to provide additional information upon request of the Commission during the complaint review process;
- to choose the procedure for resolving the violation (the form of response to the complaint).
7.6. The person against whom a complaint has been filed has the following rights:
- to submit their explanations regarding the situation described in the complaint without disclosure of details concerning the complainant;
- to submit any available materials relevant to the alleged violation alongside explanations refuting the commission of the violation;
- to involve witnesses who can refute the commission of the violation;
- to receive explanations from the Commission regarding the complaint review procedure and the consequences of decisions adopted by the Commission;
- to participate in Commission meetings if there is a need to clarify additional information about the complaint, or in other processes related to the complaint review, and to know the stage at which the complaint review stands.
7.7. In case of disagreement with the decision of the Commission, the complainant and/or the person against whom the complaint was filed may submit a rebuttal to the head of the higher education institution within 10 days of its adoption. The filing of a complaint with the Commission, the decision rendered by the Commission, or the order of the University Rector regarding a violation of ensuring equal rights and opportunities for women and men does not deprive the complainant or the person against whom the complaint was filed of the right to appeal to other authorized bodies to protect their rights.
7.8. In the event a complaint is received regarding materials used within the educational process that the complainant considers an alleged violation of ensuring equal rights and opportunities for women and men, and which does not concern the conduct of another person, the Commission shall review such complaint taking into account the scope of the complainant's rights specified above.
8. Review of Complaints
8.1. The complainant, the person against whom the complaint was filed, and other participants in the complaint review process must strictly adhere to the norms of Ukrainian legislation during the review process and decision-making, refrain from obstructing the work of the Commission, provide only truthful materials and testimony confirming or refuting the alleged violation, and maintain procedural confidentiality.
8.2. Upon receiving a complaint, members of the Commission and other participants in the complaint review process must adhere to the presumption of credibility toward the complaint, remain impartial and objective, and refrain from engaging in behavior or using language that may constitute victim-blaming or lead to re-traumatization of the victim.
8.3. The procedure for conducting Commission meetings, including the designation of the chairing officer, quorum, participation procedures for other individuals, is detailed in these Regulations and the internal documents of the Commission concerning meeting regulations, documentation procedures, etc.
8.4. Every complaint received by the Commission must be logged in a register and stored in an appropriate location, along with all other documents and materials related to the complaint. Registration and storage of complaint information are carried out with strict confidentiality. Access to this information is restricted solely to members of the Commission. If members of the Commission or any other person with access to complaint information violate its confidentiality, such person must be immediately recused from the review process for that complaint, and their ongoing participation in the Commission or in reviewing other complaints must be reassessed.
8.5. Within 10 working days after receiving a complaint, the Commission begins the process of its review. The Commission reviews the complaint, verifies its content, takes other actions to determine whether a violation occurred, and adopts a decision within 30 days from the commencement of the complaint review. If it is impossible to resolve the issues raised in the complaint within a one-month period and there is a substantiated need to extend the review period, the Commission establishes the necessary term for its review, of which the person who submitted the complaint is notified. In this case, the total period for reviewing the complaint may not exceed 45 days. A substantiated need implies, in particular, the necessity to clarify additional circumstances that could not be accomplished within the previously established timeframe, or the presence of unforeseen circumstances affecting the ability to review the complaint within the defined timeframe.
8.6. Depending on the circumstances of the case and the wishes of the complainant, the University's response to complaints concerning another person/persons regarding discrimination, violence (including gender-based violence), sexual harassment, or other violations may be carried out through:
- adaptive response, which involves an internal review and resolution of the situation under a simplified procedure, focusing on safety, support, and modifying conditions for the victim;
- internal investigation, which is a formalized verification of facts with the aim of making decisions regarding liability, including disciplinary action, and/or informing competent authorized bodies.
Both forms must be based on the principles of trauma-informed and victim-centered approaches, maintaining confidentiality and respecting the rights of the victim and other participants in the relevant procedures.
8.7. If the complainant chooses the institutional procedure of adaptive response, the Commission records this decision of the complainant, conducts a meeting at which the complainant and the person against whom the complaint was filed are present, and records the results of such a meeting in the minutes.
Based on the results of this procedure:
- the person against whom the complaint was filed may offer an apology for the actions committed;
- the Commission may refer the person against whom the complaint was filed to undergo relevant training to prevent the occurrence of such situations in the future.
If the complainant and the person against whom the complaint was filed do not achieve the outcomes described above, the Commission records this in the minutes and must initiate an internal investigation procedure.
8.8. An internal investigation must be conducted in accordance with the norms of Ukrainian labor legislation and other normative legal acts, including internal regulations of the University governing this matter.
During an internal investigation, the Commission:
- receives and reviews materials confirming the alleged violation from the complainant and the person against whom the complaint was filed;
- hears explanations from the complainant and the person against whom the complaint was filed;
- hears testimony from witnesses of the situation described in the complaint;
- if necessary, engages legal specialists, social workers, and gender experts to achieve the objectives of the internal investigation;
- adopts a decision establishing the presence or absence of a violation and recommending disciplinary measures;
- if necessary, in the case of an alleged administrative or criminal offense, informs the Rector of the University or an authorized person of the need to notify law enforcement authorities, with mandatory prior notification to the complainant and victim of such a necessity;
- may issue a recommendation to suspend the person against whom the complaint was filed from performing job duties or studies during the internal investigation to ensure a fair decision, or otherwise restrict contact between the complainant/victim and the person against whom the complaint was filed.
8.9. Based on the results of the internal investigation, if a violation is established, the Commission:
- records the adopted decision in the minutes;
- taking into account the interests of the complainant and victim, recommends to the Rector of the University the application of an appropriate disciplinary penalty proportionate to the offense committed;
- conducts educational work with the person against whom the complaint was filed to prevent such situations in the future;
- recommends referring the person against whom the complaint was filed for professional development or relevant training to avoid such situations in the future.
If the Commission does not establish a violation, such a decision is recorded in the minutes of the internal investigation, registered according to established procedures, and brought to the attention of the participants in the process.
If the complainant wishes to withdraw the complaint at any stage of its review, the Commission must record this wish of the complainant, clarify the reasons for such a decision, and inform the complainant of the consequences of the decision made.
8.10. In the event of reviewing a complaint regarding materials used within the educational process that the complainant considers an alleged violation and which do not concern the conduct of another person, the Commission:
- receives and examines materials regarding the alleged violation from the complainant;
- if necessary, engages relevant specialists to determine the presence or absence of a violation;
- adopts a decision establishing the presence or absence of a violation;
- in the event a violation is established, recommends that the University address the issue of restricting their further use, adaptation, and/or response.
8.11. If the complainant or the person against whom the complaint was filed is a minor, legal representatives participate in the complaint review and resolution procedures on their behalf.
If the complaint concerns potential instances of violence or cruel treatment involving a minor, the Commission immediately forwards such a complaint to the Rector of the University.
The Rector of the University, having reviewed complaints regarding instances of violence or cruel treatment of a minor, within 24 hours from the receipt of such a complaint and upon identifying signs of violence or cruel treatment, immediately notifies the parents or other legal representatives of the minor, and sends a written notification to the authorized unit of the National Police of Ukraine and the Children's Services.
If the complaint concerns other types of violence, particularly gender-based violence, the Commission, considering the best interests of the child, immediately informs the Rector of the University, who, in turn, informs their legal representatives about the receipt of the complaint, the commencement of relevant procedures, and their rights and obligations.
8.12. The Commission may recommend appealing to institutions, enterprises, or organizations that provide medical, psychological, legal, or other assistance if the person submitting the complaint requires such assistance.
The Commission must maintain an up-to-date database of contacts for entities capable of providing relevant assistance.
Upon the request of the complainant or the person against whom the complaint was filed, the Commission may involve the University's psychological service in the process.
If the victim does not wish to file a complaint in accordance with the established procedures but requires medical, psychological, legal, or other assistance, members of the Commission are obligated to refer the victim to the appropriate support entity.
If a person submits a complaint regarding a violation that falls outside the scope of the University Policy, the Commission must forward this complaint to the authorized person or body responsible for reviewing complaints regarding such violations.
9. Final Provisions
9.1. The Regulations are adopted by the Academic Council of the University and put into effect by an order of the Rector of the University.
9.2. Amendments and/or additions to these Regulations shall be made in accordance with the procedure established for their adoption.
9.3. The Regulations shall be communicated to all employees and higher education learners of the University by publishing them on the official website of the University and must be taken into account in their work.