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REGULATIONS – COEXISTENCE PROGRAM

The coexistence criteria of IBP – in line with the current regulatory framework of the BCNLIP Group – aim to foster respectful dialogue in a diverse and multicultural environment, define and structure relationships within the educational institution, and establish clear and necessary boundaries for its functioning. Rules that improve school community life are always a point of reference and clarification in the face of doubt, confusion, or conflict, which are inevitable in any heterogeneous human group, and from which an educational organization is not exempt.

Understanding the rules of coexistence, bringing them into the classroom, and sharing with students the importance of their application, respect, and enforcement is everyone’s responsibility and sustains our daily work.

1. Course Profile

1.a. Respect for cultural, sexual, gender, social, and economic diversity. The teaching-learning process and all school activities are framed by mutual respect among all IBP members. Our differences – an expression of diversity and multiculturalism – define the school’s identity. The principles and educational values are based on recognizing the dignity of others and promoting their integration.

1.b. Behaviors, verbal expressions, or gestures that undermine the dignity of any person – student, teacher, administrative staff, or any member of the institution – will not be allowed or accepted.

1.c. Physical violence within or outside the school premises, including the entrance and surrounding areas, will not be tolerated. Students involved in such acts – individually or in groups, whether spontaneous or premeditated – will be sanctioned and, depending on the severity, may be immediately expelled by decision of the management after evaluation.

2.a. Courses are in-person and attendance is mandatory. To be graded through continuous assessment, students must attend at least 80% of each module (UF).

2.b. Absences due to serious or important reasons must be justified with official documents to be evaluated and approved if necessary.

2.c. Students must enter the classroom at the scheduled time. In case of delays or exceptional circumstances, they must inform the relevant teacher in advance. Entry is not allowed more than 10 minutes after the start of the first class. After this time, any student not present at the beginning of the second class will be excluded until the next session. In both cases, they will be marked as absent.

2.d. Attendance may be reviewed by immigration authorities or police for administrative, criminal, or background-check purposes, unrelated to IBP (e.g., for residency permit renewals).

2.e. Work-family balance will be considered in allowing flexibility in attendance for students with newborns or minors in their care, subject to proper documentation (e.g., work contract).

2.f. Children are not allowed in the classroom during lessons, nor to remain on school premises. The school will not be responsible for unaccompanied minors.

2.g. Any attempt to impersonate another person in school-related acts, attending classes or exams, or falsifying or stealing academic documents or private data, including hacking, will lead to immediate expulsion and legal action.

3.a. Mobile phone use is prohibited in class unless authorized by the teacher for educational purposes.

3.b. Recording classmates or teachers inside or outside class without consent – especially for sharing – is strictly prohibited. WhatsApp groups (if used) must have a strictly pedagogical purpose. Use of such groups to extract information (phone numbers, profiles, personal data) or contact teachers outside working hours is forbidden. The classroom and school are private spaces. Violations will be immediately sanctioned according to Article 197 of the Spanish Penal Code and data protection laws.

4.a. Appropriate behavior and mutual respect among students and teachers are required. Failure to comply may result in expulsion from the class.

4.b. Any classroom or academic issues must be channeled through the class representative and tutor, not through reception or administrative staff.

4.c. Eating is not allowed in class. Students may drink water if needed. Coffee, tea, soft drinks, beer, and similar beverages are prohibited.

4.d. Classrooms must be kept clean and tidy for everyone’s benefit.

5.a. Academic freedom: IBP teachers exercise academic freedom in line with their ideas and the BCNLIP Group’s principles, according to Article 20.1 of the Spanish Constitution.

5.b. Teachers will inform students about their assessment methods, which may vary across instructors.

5.c. Late arrivals to exams are allowed only until a classmate submits their test. No extra time will be granted.

5.d. Extraordinary exams may be requested only in cases of justified serious absences.

5.e. Use of translators or tech tools to plagiarize or assist with writing will result in immediate annulment of the exam or activity.

5.f. Students must bring their own laptops. If unavailable, they must contact their tutor or the management in advance.

6.a. Students must properly use the facilities, bathrooms, furniture, and school materials. Damages or theft will be sanctioned, and the cost must be covered with an invoice.

6.b. Scooters, bicycles, or other vehicles are not allowed inside. They must be parked outside without blocking access.

6.c. Smoking is not allowed inside or near the school entrance.

6.d. Pets are generally not allowed. Exceptions require group and teacher consent. New students must be consulted each time to ensure the emotional well-being of the group.

6.e. Entry with dangerous objects or substances is strictly prohibited. Any suspicious situation or discovery must be reported immediately.

BCNLIP promotes environmental respect and responsible consumption. Goals include:

– Promoting energy efficiency.
– Encouraging responsible water use.
– Promoting responsible consumption in the school and nearby.
– Supporting waste reduction, reuse, and recycling.
– Identifying and reducing other environmental impacts.

OFFENSES AND SANCTIONS

Sanctions aim to educate and repair harm. They ensure respect for all students and promote resolution and understanding. Their main purpose is to help students learn from their mistakes.

Sanctions will be applied by IBP management, considering:

  • Age: Focus on correction rather than punishment.
  • Personal/family circumstances: Considered in determining the response.
  • Mitigating factors: Apologies, reparations, or acknowledgement may reduce severity.
  • Aggravating factors: Premeditation, repetition, indifference, or harm to others may increase severity. All forms of discrimination are considered serious.
MINOR OFFENSES
  • Repeated, unjustified lateness or absence.
  • Disruptive behavior in class.
  • Refusal to participate in activities.
  • Disrespect toward community members.
  • Accidental damage to property.

 

Sanctions:

  1. Written warning.
  2. Meeting with the tutor (who may inform the director).
  3. Tasks to repair damage or support school activities.
  • Repeated violations of school rules.
  • Intentional damage to facilities or property.
  • Misuse of electronics during class.
  • Failure to comply with previous sanctions.

 

Sanctions:

  1. Repair tasks or school improvement contributions.
  2. Suspension from class (1 to 5 days), decided by a disciplinary panel (director, tutor, and a class representative).
  3. Payment for damaged/stolen items.
  • Serious misconduct, insults, physical or emotional aggression.
  • Discrimination based on ethnicity, gender, disability, politics, or religion (Law 15/22 of July 12, 2022).
  • Identity theft or document falsification.
  • Recording and sharing abuse or humiliation.
  • Bringing harmful or dangerous substances or objects.

 

Sanctions:

  1. Suspension from class (20 to 30 days), effective immediately and communicated afterward.
  2. Repair tasks and written acknowledgment of wrongdoing.
  3. Expulsion without refund.

Protocol against sexual harassment and gender-based harassment

1- Introduction and justification of the issue of sexual harassment and gender-based harassment. Importance of applying the protocol

Sexual harassment and/or gender-based harassment in academic settings are forms of violence that violate fundamental rights and have a devastating effect on the physical, psychological, and moral integrity of individuals, especially women.

The prevention and management of sexual and/or gender-based harassment clearly and forcefully demonstrate BCNLIP Group’s commitment to combating these forms of violence, both to the educational community’s staff—across its different sectors and areas of activity—and to its students. It raises awareness among staff and students and highlights preventive protection against harassment while ensuring an internal, confidential, and swift process for investigating, clarifying the facts, protecting the victim, resolving the issue, sanctioning, and eliminating such behaviors.

BCNLIP Group maintains zero tolerance for any behavior that constitutes harassment or sexual harassment. In situations where inappropriate behavior may occur between members of the educational community, activating the protocol helps clarify the facts and evidence of the case to determine whether such elements are present and to apply the necessary corrective measures, which, if not taken, could lead to more serious situations.

The protocol is the ideal tool to ensure effective protection against harassment by enabling the prevention and reparation of the harm experienced by the victim. Informing and training the entire educational community helps prevent harassment-related behaviors, ensures their proper handling, and facilitates their eradication, guaranteeing compliance with current regulations.

The objectives are:

• To promote a preventive culture against sexual harassment and/or gender-based harassment.
• To express BCNLIP Group’s zero tolerance for any situation that may arise.
• To facilitate the identification of behaviors that constitute harassment.
• To implement a simple, quick, and accessible procedure for confidential complaints or reports.
• To swiftly, confidentially, and internally investigate complaints.
• To, if necessary, sanction the perpetrator of sexual and/or gender-based harassment.
• To support the person who has experienced harassment, preventing further victimization or re-victimization, and, if necessary, provide access to the psychological and social support they may require.

The protocol will be governed by the following principles:

a. Prevention and awareness of sexual and/or gender-based harassment. Information and accessibility to procedures and measures.
b. Confidentiality and respect for the privacy and dignity of the affected individuals.
c. Respect for the presumption of innocence.
d. Prohibition of retaliation against the alleged victim or those who support the complaint.
e. Diligence, speed, security, coordination, and collaboration in the process.
f. Guarantee of labor rights and social protection for victims.
g. Thorough investigation of the facts, based on the principles of confidentiality, contradiction, and oral proceedings.
h. Guarantee of action by adopting the necessary measures.
i. A gender and human rights-based approach throughout the process.

In accordance with Article 7.1 of Organic Law 3/2007, of March 22, for the effective equality of women and men, and without prejudice to what is established in the Criminal Code, for the purposes of a protocol, sexual harassment constitutes any behavior, verbal or physical, of a sexual nature that has the purpose or produces the effect of violating the dignity of a person, particularly when it creates an intimidating, degrading, or offensive environment.

Behaviors constituting sexual harassment

Verbal Conduct: Examples of verbal conduct that constitute sexual harassment include, among others, sexual innuendos, propositions or pressure for sexual activity; offensive flirting; suggestive, indirect, or obscene comments; unwanted or private phone calls or social media contacts; jokes or remarks about sexual appearance.

Non-verbal Conduct: Displaying sexually suggestive or pornographic photos, objects, or writings; lewd stares, gestures; offensive letters or emails or social media messages with clear sexual content.

Physical Behaviors: Deliberate and non-consensual physical contact, unwanted hugs or kisses, excessive and unnecessary physical proximity, non-consensual touching.

“Quid pro quo” Sexual Harassment or Sexual Coercion Among behaviors that constitute sexual harassment is “quid pro quo” sexual harassment or sexual coercion, which involves forcing the victim to choose between submitting to sexual demands or losing or seeing certain benefits or working conditions negatively affected. This may impact access to vocational training, continued employment, promotion, compensation, or any other decision related to this matter. As it constitutes an abuse of authority, the perpetrator will be someone who has the power, directly or indirectly, to provide or withdraw a benefit or work condition.

Hostile Work Environment Sexual Harassment In this type of sexual harassment, the harasser creates an intimidating, hostile, degrading, humiliating, or offensive environment for the victim, as a result of unwanted sexual attitudes and behaviors. It can be carried out by any member of the company, regardless of their position or status, or by third parties who are somehow connected to the workplace environment.

According to Article 7.2 of the Organic Law, dated March 22, gender-based harassment is any behavior carried out based on a person’s gender with the purpose or effect of violating their dignity and creating an intimidating, degrading, or offensive environment.

All gender-based harassment is considered discriminatory. A set of constitutive elements of a common denominator is required, among which the following stand out: • Harassment, understood as any intimidating, degrading, humiliating, or offensive behavior that originates externally and is perceived as such by the person suffering from it. • An objective attack on the victim’s dignity, which is subjectively perceived by them as such. • Multi-offensive result. Gender-based harassment does not preclude damage to other fundamental rights of the victim. • The behavior is not an isolated incident. • The motivation for these behaviors must relate to the fact of being a woman or to reproductive and caregiving roles, which, due to social discrimination, are presumed inherent to them. In this sense, gender-based harassment may also be experienced by men when they perform tasks or activities associated with roles traditionally attributed to women.

Certain hostile actions that may occur occasionally at work may not, in themselves, constitute gender-based harassment if they occur in isolation and without repetition. However, if such hostile actions are detected, the school must act decisively to address them and prevent their potential recurrence. When the motive for the harassment behaviors is related to the gender roles traditionally assigned to women due to the historical social discrimination they have suffered, it will also be considered gender-based harassment, regardless of whether the harassed person is a man or a woman.

Below is a list of behaviors constituting gender-based harassment that, meeting the requirements highlighted in the previous point, serve as examples, without intending to be exclusive or limiting.

Actions aimed at isolating the victim:
• Ignoring the person’s presence.
• Refusing to speak to them.
• Restricting coworkers from talking to that person.
• Not allowing that person to express themselves.

Activities that affect the victim’s physical or mental health:
• Physical threats and assaults.
• Verbal or written threats.
• Shouting and/or insults.
• Frightening phone calls.
• Provoking the person, forcing them to react emotionally.
• Damaging their belongings.
• Belittling their work.

Attacks on private life and personal or professional reputation:
• Manipulating the person’s reputation through rumors, denigration, and ridicule.
• Suggesting the person has psychological problems.
• Mocking their gestures, voice, physical appearance, and disabilities. Giving them nicknames, etc.
• Criticizing their nationality, political and/or religious beliefs, private life, etc.

In the study of sexual and/or gender-based harassment, international, European, and national regulations must be taken into account.

International Scope

  • ILO Convention 111 on Discrimination in Employment (1958) (addresses sexual harassment in the workplace as a form of discrimination against female workers).
  • Article 1 of the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW, 1979) (defines “discrimination against women”).
  • Articles 1 and 2 of the Declaration on the Elimination of Violence against Women (1993) (defines “violence against women” and provides a specific concept of harassment and sexual intimidation in the workplace and educational institutions as forms of violence against women).

Within the European Union

  • Commission Recommendation 92/131/EEC, of November 27, concerning the protection of the dignity of women and men at work (includes a Code of Conduct on measures to combat sexual harassment).
  • Article 21 of the Charter of Fundamental Rights of the European Union (Nice, 2000), with binding effect since the Treaty of Lisbon in 2009 (prohibits all forms of discrimination, particularly those based on sex and sexual orientation).
  • Directive 2006/54/EC, regarding the implementation of the principle of equal treatment between men and women in matters of employment and occupation (includes definitions of sexual harassment, gender-based harassment, and other issues applicable to any discriminatory conduct or act. Section 6 of its preamble states that gender-based and sexual harassment are contrary to the principle of equal treatment between men and women and constitute discrimination based on sex).
  • Commission Communication on the European agreement on harassment and violence at work (COM (2007) 686 final), signed by European social partners (details various types of harassment based on their projection and effects, their externalization, the subjects involved, and their materialization).

National Scope

  • Constitution of Spain (CE), articles 1.1, 14, and 9.2, proclaims equality as a supreme value of the legal order, a fundamental right, and a mandate to public authorities.
  • CE, article 10.1, proclaims human dignity as a supreme value of the legal order and, in an interpretative framework, alongside the recognition of the free development of personality in relation to the rest of the articles on fundamental rights.
  • CE, article 15, proclaims the right to life, physical and moral integrity, and protection from degrading treatment.
  • CE, article 18.1, proclaims the right to honor, personal and family privacy, and one’s own image.
  • CE, article 27, proclaims the right to education.
  • CE, article 35 in conjunction with article 43, proclaims the right to work and to occupational health.
  • Law 31/1995, of November 8, on the Prevention of Occupational Risks. Its preamble refers to the constitutional mandate derived from article 40 CE to develop a policy for the protection of workers’ health through the prevention of work-related risks, including psychosocial risks.
  • Organic Law 10/1995, of November 23, of the Penal Code, especially article 184.
  • Organic Law 1/2004, of December 28, on Comprehensive Protection Measures against Gender Violence, especially articles 33, 34, 35, 36, 37, 38, 39, 40, and 41. Defines gender violence as a violation of human rights and as a form of discrimination.
  • Organic Law 3/2007, of March 22, on the effective equality of women and men, especially articles 7, 8, 9, 48, 51, and 62.
  • Technical Criteria of the Labor Inspectorate No. 69/2009, on the actions of the Labor and Social Security Inspectorate regarding harassment and violence at work. It considers the lack of evaluation and preventive measures against gender violence in the workplace to be an infringement in matters of prevention.

Other regulatory references on sexual harassment and gender-based harassment include:

  1. General Health Law 14/1986, of April 25 (article 18.9).
  2. Royal Legislative Decree 1/1995, of March 24, approving the Revised Text of the Workers’ Statute Law (articles 4.2.e, 54.2, and 95.14).
  3. Royal Legislative Decree 2/1995, of April 7, approving the Revised Text of the Labor Procedure Law (articles 175-182).
  4. Law 29/1998, of July 13, regulating the contentious-administrative jurisdiction (article 19.1.i).
  5. Law 1/2000, of January 7, on Civil Procedure (article 11 bis) regarding standing.
  6. Royal Legislative Decree 5/2000, of August 4, approving the Revised Text of the Law on Infractions and Sanctions in the Social Order (article 8).

The stages and maximum time frames for carrying out the procedure are as follows:
• Submission of complaint or report: the complaint or report is filed, and the corresponding administrative file is opened.
• Activation of the harassment protocol (maximum time frame: 2 to 3 business days).
• Informative file (maximum time frame: 10 business days).
• Resolution of the harassment file (maximum time frame: 3 to 4 business days).
• Follow-up (maximum time frame: 30 calendar days).

A- Submission of the complaint, activation of the protocol, and processing of the administrative file. The complaint or report made by any member of the educational community of the entire BCNLIP Group (staff and/or students) will be forwarded to the academic director of the BCNLIP Language School, the director of IBP (International Business Programs), or the director of the BCNLIP Educational Foundation, the three organizations that make up the BCNLIP Group.

If they are absent from their workplace for any reason, all relevant information will be sent to individuals designated by them for this purpose. The complexity of the organization, its different locations, and activities mean that, in day-to-day operations, if a complaint arises, it may be received by various members of the administrative and/or teaching staff.

To ensure better organization and in accordance with confidentiality and professional secrecy principles, the management will assign different members of the group to handle this task. The entire educational community will be informed of their names and the channels for oral and written communication established for this purpose (email, available phone number, etc.).

The complaint cannot be anonymous and must be filed by the person who feels harassed or by someone who is aware of the situation.

Confidentiality, professional secrecy, and data protection will be upheld at all stages of the protocol and by all participants in the case.

B- Activation of the protocol Upon receiving the complaint or report of sexual harassment or gender-based harassment, the instructing committee will be convened, which must open a file, notify the initiation of an investigation, conduct relevant interviews with the parties, and follow up and analyze the case. The instructing committee will consist of members of the educational community.

If any member is absent due to illness, vacation, or any other legal reason, alternates will be appointed. The procedure for processing the complaint will be activated within a maximum of 2 to 3 business days. Any complaint, report, or claim submitted will be presumed to be truthful.

C- Informative file The person designated by the instructing committee will conduct a quick and confidential investigation within 10 business days, during which they will hear from the affected parties, witnesses, and request any necessary documentation, while respecting data protection and confidentiality. The designated individuals are required to cooperate as promptly as possible.

During the file processing, the victim will first be heard, followed by the accused. The hearing can be conducted in person or online, as agreed by the parties. The process should be as efficient and swift as possible while protecting the privacy, confidentiality, and dignity of the affected parties, as well as respecting the accused’s right to respond.

Throughout the procedure, strict confidentiality will be maintained, and all internal investigations will be conducted with tact and respect for both the complainant—who shall not receive unfavorable treatment for filing the report—and the accused, whose guilt shall not be presumed.

During the file processing, the management will adopt necessary precautionary measures to immediately stop the harassment without causing permanent or definitive harm to the working conditions of the involved parties. Among other precautionary measures, the management will separate the alleged harasser from the victim.

D- Resolution of the harassment file Upon completing the investigation, the instructing committee will prepare a report detailing the facts, interviews, testimonies, and evidence gathered, concluding whether there are signs of sexual or gender-based harassment.

If the conclusion is that no imbalance, inequality, abuse, harassment, or discrimination has occurred, the protocol may be closed. For this, there must be an agreement signed by all parties involved in the assessment report. However, if the committee identifies inappropriate behavior or conflict that, if continued, could lead to harassment, they will notify the management, suggesting appropriate measures to prevent further incidents.

If the evidence suggests signs of harassment, the committee’s report will urge the BCNLIP Group management to take appropriate disciplinary measures. In severe cases, the committee may even recommend disciplinary dismissal or expulsion of the aggressor (whether a staff member or student).

E- Follow-up: The instructing committee will monitor the case for 30 days, depending on the severity and circumstances. If necessary, new precautionary measures will be taken, or the procedure will continue. If disciplinary dismissal is not the sanction applied, the committee is required to continue monitoring the accused’s behavior within the educational community. Simply applying the sanction is not enough; the person’s performance and behavior will need to be supervised.

According to international, community, and national legal frameworks, abuse, harassment, or discrimination are punishable by law, and depending on the severity of the case, the matter could be reported to Social Services, the Education Inspection Services (for Vocational Training cases), the Juvenile Prosecutor’s Office, the Civil Guard, and/or the Police.

In addition to any intervention by law enforcement or educational authorities, the BCNLIP Group will encourage the victim of harassment, abuse, or discrimination to receive guidance on self-protection, assertiveness, and support.

BCNLIP Group is committed to implementing:
• Preventive measures, including a statement of principles, definition of sexual harassment and gender-based harassment, and identification of behaviors that may constitute these types of harassment.
• Proactive or procedural measures to address harassment, providing a channel for complaints or reports that may arise, as well as applicable precautionary and/or corrective measures.
• Identification of reactive measures against harassment and, if applicable, the enforcement of disciplinary actions.

With this protocol, BCNLIP Group expresses its zero tolerance for any behavior constituting sexual harassment or gender-based harassment within its organization. By adopting this protocol, it emphasizes its commitment to preventing and addressing harassment in all its forms, informing all personnel who provide services within the organization—whether internal staff or those from other companies, including individuals without a formal employment relationship, such as trainees, non-working interns, or volunteers—of its implementation.

The protocol will apply to situations of sexual harassment or gender-based harassment that occur during work, in connection with work, or as a result of work, and it includes: a. Personnel of the educational community and the Foundation: management, teaching staff, administrative staff, commercial and/or external service providers, transport staff, and maintenance and cleaning staff. b. Students, families, and/or host guardians. c. All facilities of BCNLIP Group locations, including break rooms, dining areas, and restrooms. d. Public and private spaces when they constitute an extension of the workplace and/or leisure areas, including areas surrounding the locations. e. Travel, trips, events, or social, cultural, and/or educational activities related to work and educational activities. f. Communications related to work, including those conducted through information and communication technologies (virtual harassment or cyberbullying). g. Housing arrangements, student apartments, and/or family homes owned and/or managed by BCNLIP Group. h. Travel between home and the workplace.

BCNLIP Group will adopt a proactive stance in both preventing harassment—by raising awareness and providing information on behaviors not tolerated by the company—and in promoting best practices, implementing necessary measures to manage complaints and reports related to this matter, and resolving them as appropriate in each case. This protocol complies with the requirements of Articles 46.2 and 48 of Organic Law 3/2007, of March 22, for effective equality between women and men, Royal Decree 901/2020 of October 13, which regulates equality plans and their registration, and amends Royal Decree 713/2010 of May 28, regarding the registration and deposit of collective agreements and labor agreements, and Article 14 of Law 31/1995, of November 8, on the prevention of occupational risks.