Sexual Harassment - Its Not Academic Title IX 2008

1. U.S.DEPARTMENT OF EDUCATION

2. SexualHarassment
It Not Acadenric
Seotember
2008
Office for Civil Rights
U.S.Department of Education

3. U. S. Department of Education
Margaret Spellings
Secretary
Office for Civil Rights
Stephanie Monroe
AssistantSecretary
RevisedSeptember
2008.
This publication is in the public domain.Authorization to reproduce
it in whole or in part is granted.The publication'scitation should
be: U.S. Department of Education,Office for Civil Rights, Sexual
Harasmen I t Not A cademi
s t: c,Washington, C., 2008.
D.
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You may fax your order to: 30I-470-7244 or sendan e-mail request
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ii

4. Contents
Introduction.... I
Part One: Defining SexualHarassment 3
a
What is sexual
harassment?. . .
. J
a
What aresomeexamples sexual
of conduct?. J
Is all physicalcontact sexualin nature? 4
What if the sexualconduct is criminal in nature? 4
Mustthesexualcond u c t b e u n we lc o me ? . . ........ 5
When doessenualconduct "deny or limit a student'sability to
particrpatein or benefit from a school'seducationprogram?".. . . . . 5
Can young school children engagein sexualharassment?. . . . . . . . 7
Ate gayand lesbianstudentsprotectedfrom sexralharassment?.. 8
.
PartTwo: RespondingtoSexualHarassment
.... 9
How shoulda schoolrespondwhen it receives
information about
allegedsexualharas s me n t ? . . . . ....9
What if the victim requestsconfidentiality or asksthat the
complaintnotbepurs u e d ? ........9
Does a schoolhaveto do anythingaboutsexralharassment a
if
particularincident is not reportedto the school? . . . 10
What actions,tf schoolstake while investigating
acomplaint?.... ^y,should
....LI
What doesa schoolhaveto do oncethe investigation complete? 11
is
What aresomeexamples the stepsa schoolshouldtaketo end
of
harassment
andpreventitfrom happeningagun? . . . . . . . . 73
What aresomeexamplesofhowa school canrcmedythe effectsof
sexualharassment? . . . . .....13
lu

5. PartThree: Reporting and Preventing SexualHarassment . . . . . 15
Who shouldreportincidentsofsexualharassment?.. . . . . . . . . . .15
.
To whom should a victim or other individual report
theharassment?. ....15
What if the harasser
threatensto retaliareagainstthe victim if
he orshereports theinc id e n t ? . . . . ........15
What proceduresmust a school havein placeto prevent sorual
harassmentandres o lv e c o mp la in t s ? ........16
W hataregrievancep ro c e d u re s ? . . . . .......16
W hatdoestheTitlelXc o o rd in a t o rd o ? . . ........16
Howdo I knowwho myschool's
TitleIX coordinator . . . . . . .,17
is?
What other stepscan a schooltake to prevent socualharassment? 17
What is OC& and how do I report incidents of sorualharassment
tothatoffice? .......17
Where can I get more information about a school'sresponsibilities
toaddressandpreventsexualharassment? .... ....18
lv

6. Introduction
Sexualharassment studentsis illegal' A federallaw, Title IX of the
of
EducationAmendments1972 (Titk 1,$, prohibitsdiscrimination
0f
on the basisof sex,including sexualharassment, education
in
programsand activities. public and private educationinstitutions
A1l
ihai receiveany federalfunds must comply with Title IX. Title IX
protectsstudents from harassment connected any of the academic,
to
educational, extracurricular, athletic,and other programsor activities
of schools,regardless the location. Title IX protectsboth male and
of
female studentsfrom sexualharassmentbyanyschoolempioyee,
another student,or a non-employeethird party.
Preventingand remedyingsexual harassment schoolsis essential
in
to ensurea nondiscriminatory, safeenvironmentin which students
can learn.Unfortunately,students, Parents,and schoolstaff may
not know what sexual harassment how to stoPit, and what
is,
can be done to preventit from happening. This pamphlet usesa
question-and-answer format to provide students,Parents,school
administrators,schoolemployees, otherswith fundamental
and
information on recognizingand, addressing sexualharassment
under Title IX asit is interpretedby the U.S.Department of
Educationt Office for Civil Rights (OCR). OCR is the federal
agencyresponsible enforcing Title lXin schools
for that receive
federalfunds from the U.S. Department of Education.

8. Part One: Defining Sexual Harassment
What is sexualharassment?
Sexualharassmentis conduct that:
1) is sexual nature;
in
2) is unwelcome;
and
3) deniesor limits a student'sability to participatein or benefit
from a school'seducationprogram.
Sexualharassmentcan take different forms depending on the
harasser and the nature of the harassment. The conduct can be
carried out by school employees, other students,and non-employee
third parties,such as a visiting speaker.Both male and female
studentscan be victims of sexualharassment. and the harasserand
the victim can be of the samesex.
The conduct can occur in any schoolprogram or activity and can
take placein schoolfacilities,on a schoolbus,or at other off-
campuslocations,suchas a school-sponsored field trip or a training
program at anotherlocation.Tlie conductcan be verbal,nonverbal,
or physical.
The judgment and common sense teachersand school
of
administrators arevery important elementsin determining whether
sexualharassmenthas occurredand in determining an appropriate
response,especiallywhen dealing with young children.
What are someexamples sexualconduct?
of
Examplesof sexual
conductinclude:
' making sexual
propositionsor pressuring
students sexual
for favors;
' touching of a sexualnature;
' writing graffiti of a sexualnature;
' displaying or distributing sexuallyexplicit drawings,pictures,or
written materials:

9. performing sexual
gestures touching oneselfsexualiy front
or in
of others:
telling sexualor dirty jokes;
spreading sexualrumors or rating other studentsasto sexual
activitlr or performance;or
circulatingor showinge-mailsor Web sitesof a sexualnature.
Example; A school official sendsa student a text message
to arrangea time to meet for a sexualencounter.Sending
such a text messagewould constitute sexualconduct.
Is all pbysicalcontact
sexualin nature?
No. Legitimate nonsexual touching or conductgenerallywill not
be considered sexualharassment.
However,it may rise to that level
if it takeson sexual
connotations.
Example: A high school athletic coachhugs a srudent
who makesa goal.This by itself is not consideredsexual
conduct. However, a coach'shugging of a student could be
consideredsexualconduct if it is unwelcomeand occurs
under,inappropriatecircumstances.
LVhat thesexualconduct criminal in nature?
if is
Sexualharassment includesconductthat is criminal in nature,
such as rape,sexualassault,dating violence,and sexuallymotivated
stalking.Even if a schoolreportspossiblecriminal conduct to the
police,that doesnot relievethe schoolof its responsibilities
under
Title lX,which are discussed Part Two.
in

10. Must thesexualconduct unwelcorne?
be
Yes.Conduct is considered unwelcomeif the studentdid not
requestor invite it and considered conductto be undesirable
the
or offensive.
The ageof the student,the nature of the conduct,
and other relevantfactors affectwhether a student was capable
of welcoming the sexual conduct.A student's submission the
to
conduct or failure to complain doesnot alwaysmean that the
conductwaswelcome.
F-xample1: A middle school student makesoffensivesexual
jokes to another student,but the student doesnot object to the
jokes or speakout againstthem.The student'sfailure to object
doesnot mean that he or shehaswelcomedthe comments-
F-nample2:A femalehigh schoolstudentwillingly
kissesa male studenton one occasion. When the student
subsequently attemptsto kiss her again,sheobjects, he
but
kisses anyway.
her This subsequent is considered be
kiss to
unwelcomedespitethe welcomeness the first kiss.
of
Wbendoes sexualconduct "denyor limit a student ability to
participate in or beneftfrom a scbool'seducationprogram?"
Two generaltypesof sexual conductcan deny or limit a student's
ability to participatein or benefit from a schoolt program.As
discussed below,teachers and other schoolemployees engage
can
in either type of conduct,while studentsand third partiescan
engage only one type.
in
One form of sexual harassment occurswhen a teacheror other
schoolemployee conditionsan educational
decisionor benefit
on the student'ssubmission unwelcomesexual
to conduct.If this

11. occurs,it doesnot matter whether the student resistsand suffers
the threatenedharm or submits to and avoidsthe threatenedharm.
Sexualharassmentalso occurswhen a teacher,school employee,
other student,or third party qeatesa hostile environment
that is sufficiently seriousto deny or limit a student'sability to
participate in or benefit from the school'sprogram.Whether such
a hostile environment has been createddependson the particular
circumstances the incident(s).Relevantconsiderations
of include,
but are not limited to:
' how much of an adverseeffect the conduct had on the
studendseducationl
' the type, frequency,or duration ofthe conduct;
' the iddntiry age,andsex the harasser(s) the victim(s),
of and
and the relationship betweenthem;
' the number of individuals who engagedin the harassing
conduct and atwhom the harassment was directed;
' the sizeof the school,locationof the incidents,and contextin
which they occurred;and
' whether other incidents occurredat the school involving
different students.

12. The conductdoesnot necessarily haveto be repetitive. If
sufficientlysevere,
singleor isolatedincidentsCancreatea
hostile environment.
Example 1: Throughout the school year,Student A
repeatedlypasses sexuallyexplicit photographsto Student
B during class.Thephotographs are offensiveto Student
B, and, consequently, Student B is unable to concentrate
during classor focus on the subject.Student A has created
a hostile environment that limits Student B's ability to
participate in the class.
Ellample 2: A high school student sexuallyassaulted
another high school student on one occasionwhen the
two were alone in a classroom. a result, the victim is
As
afnid of attending any classes coming into contact with
or
the harasser. Although this was an isolated incident, it is
sufficiently severe create,a
to hostile environment.
Canyoung school
cbildrenengage sexualltarassment?
in
Schoolpersonnelshouldconsiderthe ageand maturity of
studentsin respondingto allegations
ofsexual harassment.
When determiningwhether a young child hascommitted sexual
harassment, is important for teachers
it and schooladministrators
to usegoodjudgment and common sense.
Example 1: On one occasion,a first-grade student kisses
gr"tb"lfirst-grade student on the cheekin the playground.
This behavior doesnot constitute sexualharassmentl

13. Example 2zOn numerousoccasions over a period of
severalmonths, a fifth-grade student inappropriately
touchesanother fifth-grade student and makesoverdy
sexualcomments and gesturesto that student.The conduct
is unwelcome and resultsin the victim's gradesfalling
because or she is unable to concentrateon studying.This
he
behavior constitutessexualharassment.
Are gay and lesbianstudents
protectedfromsexualharassment?
Title IX prohibits harassingconduct that is of a sexualnature if it
is unwelcomeand deniesor limits a student'sability to participate
in or benefit from a school's
program,regardless whether the
of
harassment aimed gayor lesbianstudentsor is perpetrated
is by
^t
individualsof the sameor oppositesex.Title.IX doesnot address
discriminationor other issues relatedto sexual orientation.
Example 1: Throughout football season, male member
a
of the high school football team makesunwelcomesexual
advances toward another member of the football team.
who is a homosexualmale.As a result,the victim quits the
football team.This conduct is sexualin nature,unwelcome,
and has denied the victim the ability to participate on the
school,football team.This is sexualharassmentcoveredbv
Title IX.
Example 2: Studentsheckle another student with
comments that are basedon the studentb sexualorientation
but are not sexualin nature (r.g.,"g y studentsare not
welcome at this table in the lunch roorrt'').Even if these
comments are unwelcomeand deny the student'sability
to benefit from br participate in the school'seducation
program,the conduct is not sexual,and this is not sexual
harassmentcoveredby Title IX.
8

14. PartTwo: Responding to SexualFlarassment
Hora shoulda school respondwhen it receiwes
information about
aIIege sexuaI lt aras ment ?
d s
If a student,his or her parent,or a responsibleemployee reports
the harassment, a schoolemployee
or observes harassment,
the
the schoolshouldinform the harassed student(and the student's
parent dependingon the student'sage)of the options for formal
and informal action and of the school's responsibilities,
which are
discussed below.Resardless whether the victim files a formal
of
complaint or r.q.r.ri, action,the schoolmust conducta prompt,
impartial, and thorough investigationto determinewhat happened
and must take appropriatestepsto resolve situation.
the
If other sources,suchas a witnessto the incident,an anonymous
letter or phone call,or the media,report the harassment,
the
schoolshould respondin the samemannerdescribed aboveif it
is reasonable the schoolto conductan investigationand the
for
schoolcan confirm the allegations. Considerations relevantto this
determinationmay include,but are not limited to, the:
' sourceand natureof the information:
' seriousness the allegedincident;
of
' specificityof the information;
' objectivityand credibility of the sourcethat madethe report;
' ability to identify the allegedvictims; and
' cooperationfrom the allegedvictims in pursuingthe matter.
What if the victim requests
confdentiality or asksthat the complaint
not bepursued?
The schoolshould take all reasonable stepsto investigateand
respondto the complaint in a manner consistent with a requestfor
confidentialityfrom a student.If a studentinsiststhat his or her

15. name not be disclosedto the harasser, school'sability to respond
the
maybg limited.The schoolalsomust consider responsibility
its to
provide a safeand nondiscriminatory environment for all students.
Thus,the schoolmust weigh the confidentialityrequestagainstthe
following factors:
' seriousness the alleged
of harassment;
'age ofthe harassed
student;
and
' other complaintsthat the sameindividual hasharassed
others.
Elrample A female elementaryschool student describes an
incident to her teacherthat involved another teacherforcing
her to engagein sexualactivity.The student begsthe teacher
to not tell anybodywhathappened.This a situationin
is
which the school'sduty to provide all studentswith a safe
environment might outweigh the student'srequest.
Additionally stateor local lawsmay requireschools report incidents
to
to the police.
Doesa school bawe doanytbing aboutsexual
to ltarassment aparticular
if
incidentis not reported theschool?
to
If the harasser a teacheror anotherschoolemployee
is and if the
harassment occurswhile the schoolemployeeis acting,or reasonably
apperys be acting,in rhe contextof his or her responsibilities
to to
provideaid,benefits, and services students, schoolis directly
to the
responsible and must remedythe harassment
for regardless ofwhether
the schoolknew or shouldhaveknown that the incident occurred.
If the harasser anotherstudent,a third party,ora schoolemployee
is
who is n9t acjrfg within the contextof hii or her responsibiJity
to provideaid,benefits, services students,
or to then the schooiis
responsible investigatilg the conduct and taking appropriatesteps
for
to resolvethe situation onlywhen it knows or should hive known that
the harassment occurred.
l0

16. Example: It is well-known to studentsand staffthat
graffiti of a sexualnature appears the sidesof
on
buildings throughout a school'scampusin plain sight.
The pervasiveness this harassmentmay be enough to
of
conclude that the school should have known that the
harassment occurred.If so,then the schoolis responsible
for investigating and respondingto the harassment
regardless whether it receiveda specificcomplaint about
of
the graffiti
What actions,if any, shouldschools while inaestigatinga
take
complaint?
It maybe necessary schoolsto take interim measures
for during
the investigation of a complaint. For instance,if a student alleges
harassment anotherstudent,the schoolmay keepthosestudents
by
separated until the investigation complete. a teacheris the
is If
allegedharasser, may be appropriatefor the str-rdent transfer to
it to
anotherclass.
It is a good practice for schoolsto keep the student who alleged
the harassment informed of the statusof the investigation.
What does school
a haoeto do once inaestigationis complete?
the
The schoolmust notify the victim (and his or her parents
depending on the ageof the victim) of the outcome of its
investigationand of anypunishments imposedthat directly relate
to the victim, suchas an order for the harasser stay awayftom
to
the victim.
If the schooldetermines that a studentwas sexually harassed, the
school must take reasonable, prompt, age-appropriate,and effective
action to end the harassmentand prevent it from happening
againto the victim or to others.If the schoolfails to do so,it must
remedy the effectsof the harassment the victim that could have
on
beenavoided ifthe schoolhad responded prompdyand effectively.
11

17. In addition, if the harasser a schoolemployee
is and if the harassment
occurswhile the employee acting,or reasonably
is appears be acting,
to
in the contextof carryingout his or her responsibiJities provide
to
aid,benefits,and services, schoolmust remedythe effectsof the
the
harassment the victim.
on
Erample 1: A teachersexuallyharasses eighth-gradestudent
an
in the schoolhallway.Thestudentis not in any of the teacher's
classes the teacheris not a hall monitor. However,in light of
and
the 4geand educational levelofthe studentand the statusand
degreeofinfluence ofteachersin secondary the
schools, student
could reasonablvbelieve the teacherhad at leastinformal
that
disciplinaryu.rtjrority orr.r him or her.Therefore, conduct
this
is considered haveoccurredin the contextofthe teac-her's
to
responsibilityto provide aid,benefits,and services students,
to
and thus the schoolmust remedythe effectsof the harassment
in addition to stoppingit and prlventing it from recurting.
E><ample A faculty memberof a university's
2: history
departmentrepeatedly, overseveralweeks, touclresand makes
sexually suggestive remarksto a femalegraduateengineering
studentwhile waiting for the universityshutdebus,riding on
the bus,and exiting the bus.As a result,the studentstopsusing
the bu$and walftsthe long distances betweenher classes.This
conductoccurredoutsideof the contextof the faculty member's
dutiesto provide aid,benefits,or services the student,and
to
thus the schoolis not requiredto remedythe effectsof the
harassment. However,ifthe schoolfails to take reasonable
and efFective action to end the harassment after it hasreceived
notice of the harassment, schoolmust remedythe efibctsof
the
the harassment that could havebeenavoidedifthe schoolhad
responded promptly and effectively.
t2

18. What are someexamples
oftbe stEs a scbool
shouldtake to end
barassment prevent itfrom ltappening
and again?
The appropriatestepsshould be tailored to the specificsituation.For
example, schoolmay needto developand publicize new policies
the
or conduct training. Depending on the natureand severityof the
harassment, counseling, discipline,or further separation the victim
of
and harasser y be necessary.
m
Responsive measuresshould be designedto minimize the burden on
the victim asmuch aspossible. the schoolkinitial response
If does
not stop the harassmentand preventit from happeningagain,the
school may needto take additional,strongermeasures.
What are someexamples hozoa school remedy efectsof
of can the
sexualharassment?
If the school is required to remedy the effectsof the harassment
on the victim, the rypesof action requiredwill vary dependingon
the circumstances.
Example 1: A collegeprofessorsexually harassed student
a
in his or her classin the context of the professor's
duty to
provide services the student.Consequendy, student
to the
was unable to concentrateduring classand did not learn the
coursematerial.To remedythe effectsof the harassment, the
schoolmay be requiredto take suchactionsas:
. arrangingfor an independentassessment theof
student'swork
. xrungjng for the student to take the courseagain with
a different instructor;
' providing tutoring;
. making tuition adjustments; or
. offering reimbursements professional
for counseling.
t3

19. Example 2: A high.schoolstudent
informs
the school
another srudent .tu* l,r, l..o r;*"11il;;il;""' that
; i:l
avoid ,h"i;;;;"
hirn,
*: ti j!::.r,:
rare.lrsa result,
shehasmissed
coming class
ro
some pop quizies.If
the schooldelays response this complaint
its to
victim suffers andthe
additionaieffects orirr. i."russment,
missingadditional suchas
p"p qurn;;;;; shehasto continue
.gTing to classlate,the schoot *urtL*.ayrt.
of the harassment couldnil;;;;
that "d;;;,'*"
pr;.";J;f;;;
responded
::1"":ll1apqropriate promptly *nb.tir,.ly. this
re.medy
una In
:":",,.": mayinclud. ..r.h actionsas
calculating student's
the gradewithout a""rirg i; rh"-"
student's failureto taketfr. quirrrE,rJ"* the
student
opportuniryrake qi;,rr,;. ;;;d;;fo,
to in.-
n^1^.:
mdependentassessment the srudent,s u'
of work.
t4

20. PartThree: Reporting and preventing sexual Harassment
Whoshouldre?ort incidentsof sexualharassment?
AlFo-dl who sees sexualharassment occur shouldreport it; the
individual neednot be the victim of the harassmenr. Schools
should ensurethat employees clearlyunderstand extentof their
the
responsibilities reporting sexual
for harassment.
Tb ushomshoulda wictim or otherindiaidual reporttbe harassment?
The harassment shouldbe reportedto a responsible school
employee, suchas a teacher, principal,faculiy member,
administrator, security officer,uffir-utirr. u.iion oficer,
or
professional staffmemberin the office of studentaffaiis.
Additionally, as every school must have a Titre-rxcoordinator,
the
harassment be reportedto this individual aswell.
can
A.t*9."j,pjr1nt, or other individual alsomay file a complaint
y]t!_the u.s. Department of Education's ofice for civil'Rights
(OCR), asexplained below.
what if the harasserthreatens retaliateagainstthe nictim if be or
to
shereportsthe incident?
Title IX alsoprotects studentsfrom retaliation.The school
must
take stepsto prevent the allegedharasser anybody
or elseat the
school from retaliating againit the victim. s,r.fr ,,.p,
i".r"a.
informing students that lXprotects them from retaliation,
making-surethat victimslitte how to report any future problems,
know
follow-up inquiries to seeif ihere t,irr. U."rr'urryrr.*
.an{ Sakin_g
incidents.It alsomay be appropriate counser
to the harasse, to
ensurethat he or she,.rnderstands retaliationis prohibited.If
that
retaliationoccurs, schoolshouldtake strong responsive
the actions.
15

21. What procedures must a schoolhatte in place to prewent sexual
harassment and resolvecomplaints ?
Every school must:
' issue a policy against sex discrimination;
a
adopt and publicize grievance
procedures;
and
have a Title IX coordinator.
What aregrieaance
procedures?
Grievanceprocedures internal schoolprocedures
are that address
violationsof a schooi's
policy againstdiscrimination,including
sexualharassment. Grievanceprocedures must providefor prompt
and equitableresolutionof complaintsof sexdiscrimination.
The schoolshould make surethat its policy againstsex
discriminationand grievance procedures widely distributed and
are
easilyunderstoodby students, parentsof elementaryand secondary
schoolstudents, and employees. a minimum, studentsmust
At
know that the grievanceprocedure exists,
know how it works, and
know how to file a complaint.When a studentor parent reports
sexualharassment, schoolshould explainhow its grievance
the
procedures work and offer the studentor parent the opportunity to
usethem.
If a studentor parentchooses not usethe school's
to grievance
procedures, doesnot relievethe schoolof its responsibilities
that to
investigateand take appropriateaction,asexplainedabovein PartTwo.
WhatdoestbeTidelX coordinator
do?
The Title IX coordinatoris responsible coordinatinga school's
for
efforts to complywith and carry out its Title IXresponsibilities.
Every schoolmust havea Title -IXcoordinator.Title lXcoordinators
must haveadequate training in sexualharassment and must be able
to explain the operationof the school'sgrievance procedure.
t6

22. Housdo I knouswho my school's is?
Title IX coordinator
Every schoolmust notify all studentsand employees the name,
of
office address, telephonenumber of its Title lXcoordinator(s).
and
taketopreaent sexualharassment?
What othersteps a school
can
OCR's experience showsthat the best way for a school to deal
with sexualharassment to prevent it from occurring in the first
is
place.In addition to the requirements explained above(well-
publicized nondiscrimination policy,grievance procedures, and
Title IX coordinator),a school may take a number of other steps
to preventharassment.
For example, schoolmay conductperiodic sexual
a harassment
awareness training for all schoolstafl including administrators,
teachers, guidancecounselors, age-appropriate
and and sexual
harassment The training can include
training for students.
information on the rypesof conductthat will be considered sexual
harassment and the rangeof possibleconsequences, damage
the
that resultsfrom harassment, where studentscan find help,waysto
opposeharassment, what to do about it.
and
to
What is OCR, and hozudoI report incidentsof sexualharassment
that ofice?
OCR is the federalagencyresponsible ensuringthat schools
for
comply with Title IX and other federal civil rights laws. One of
OCR's responsibilities to resolve
is complaintsof discrimination,
including sexual harassment complaints. OCR has L2
enforcementofices locatedthroughout the country that carry out
this responsibility.
An individual who wishesto file a complaintwith OCR should do
so by contactingthe enforcement office responsible the statein
for
which that schoolis located. find out which office is responsible
To
for your stateand how to contactthem, cali 1-800-42L-3487or
t7

23. check OCR'' Web site.at http://www.ed.govlocr.
complaint must be fiJedwithin Generally,the
rso a."^ of the date of the incident.
and parentsarenor required
*9:1" to usea school,s grievance
proceduresbeforefiling a compliantwith
OCR
where canr get rnoreinlformation
about a schoo,s
responsib,itiesto
address preoent sexualbarassrnent?
and
Pleaseread ocR's Rerisedsexual
HarassrnentGuidance: Harassment
of Studentsby Scbool Emptoyrrr,,Oiirl{ndents, or
availableotr-thr Deoartment's Third parties,
web site at http://www.ed,.gov/ocr/
publications.html fr"-
"i OCn."f"*ement office.
""y
18

24. t9

25. 20