Our Commitment to Pay Equity
Policy on Anti-Discrimination and Equal Opportunity
The University of Denver and the Sturm College of Law are committed to encouraging and sustaining a community that is free from prohibited discrimination and harassment. Consistent with University policies and applicable federal, state, and local laws, the University and the College of Law prohibit discrimination on the basis of race, color, national origin, age, religion, disability, sex, sexual orientation, gender identity, gender expression, marital status, pregnancy, military enlistment, veteran status, or genetic information in the administration of educational policies, admissions policies, financial aid, employment, or any other University-related program or activity.
Members of the Sturm College of Law community are encouraged to report any incident believed to be discriminatory to the University’s Office of Equal Employment Opportunity & Title IX, which will appropriately investigate reports of alleged discriminatory conduct pursuant to the Office’s procedures.
The University of Denver, through its Office of Equal Opportunity & Title IX, takes prompt and equitable action in response to reports of (1) discrimination, including pay discrimination; (2) sexual and gender-based harassment, sexual violence, relationship violence, and stalking; (3) failure to provide reasonable accommodations for disability and religion; and (4) retaliation against any individual or group of individuals involved in any investigation and/or resolution of a report of discrimination or harassment.
Know Your Rights
Reporting a Concern to the University
Any employee who observes discrimination – or receives a report of it – is expected to report the concern to the Office of Equal Opportunity & Title IX.
Employees may call the Office at 303-871-7016, e-mail the Office at [email protected], contact the Interim Director of Equal Opportunity Monica Reynoso ([email protected]), contact the Title IX Coordinator Jeremy Enlow ([email protected]), or submit an online report through the following clickable link:
The Office of Equal Opportunity & Title IX will promptly reach out to reporting and/or impacted persons to explore options for resolution, including a thorough, prompt, and equitable investigation of the concerns in accordance with the University’s Equal Opportunity & Title IX Procedures.
The Equal Pay Act of 1963, as amended, prohibits sex discrimination in payment of wages to women and men performing substantially equal work, in jobs that require equal skill, effort, and responsibility under similar working conditions, in the same establishment. The University of Denver is committed to principles of pay equity, and expressly prohibits disparate pay on the basis of an employee’s race, color, national origin, age, religion, disability, sex, sexual orientation, gender identity, gender expression, marital status, genetic information, or military or veteran status.
The University will not discharge – or in any other manner discriminate against – employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant. With this noted, employees who have access to the compensation information of other employees or applicants as part of their essential job functions cannot disclose the pay of such employees or applicants to individuals who do not otherwise have access to compensation information, unless the disclosure is (a) in response to a formal complaint or charge; (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer; or (c) consistent with the contractor’s legal duty to furnish information. See 41 CFR 60-1.35(c).
An individual who believes that they have been subjected to unlawful discrimination, harassment, or retaliation has the right to file a complaint with an appropriate local, state, or federal agency, such as the Department of Education Office of Civil Rights, the Equal Employment Opportunity Commission (EEOC), or the Colorado Civil Rights Division, within the respective agency’s applicable time limits.
In addition, any person who is dissatisfied with the University’s internal procedures utilized for handling complaints, or with the result of the investigation or the sanctions imposed, may seek redress through these means to the extent allowed by law. Complainants should be aware that filing a complaint with the University’s Office of Equal Opportunity & Title IX or any other University office does not extend or postpone the deadline for filing with external agencies.
If you believe that you have been discriminated against, and to ensure that you meet strict procedural timelines to preserve the ability of the EEOC to investigate your complaint and protect your right to file a private lawsuit, you should immediately contact the EEOC at its main office (131 M Street NE, Washington, DC 20507), at its Denver field office (303 E. 17th Avenue, Suite 410, Denver, CO 80203), or through its toll-free number (1-800-669-4000). For individuals with hearing impairments, the EEOC’s toll-free TTY number is 1-800-669-6820.
Additional Internal Resources
Office of Internal Audit
Employees may also report any concern of misconduct to the University’s Office of Internal Audit. The Office of Internal Audit independently and objectively examines and evaluates activities at the University of Denver. You may reach the Office of Internal Audit directly by phone at 303.871.7928, by e-mail at [email protected], or via an anonymous hotline or an anonymous online report.
Safety & Support
The University also encourages all employees to familiarize themselves with on- and off-campus Resources for support.
The Office of Equal Opportunity & Title IX is responsible for compliance with state and federal equal employment opportunity (EEO) laws and affirmative action regulations. The Office is also responsible for implementing the University’s affirmative action plan, including equal employment practices, monitoring, and internal reporting. In support of the University’s EEO principles, the University has developed written affirmative action plans for women, minorities, individuals with disabilities, and covered veterans.
If you believe you have not been treated in accordance with such policies, please contact the Office of Equal Opportunity & Title IX. All employees and applicants for employment are protected, by both University policy and EEO/affirmative action regulations and law, from coercion, intimidation, interference, or discrimination in association with filing a complaint or assisting in an investigation.
Letter from the Dean
Dear Members of the University of Denver Sturm College of Law Community:
As you are aware, the University of Denver entered into a consent decree with the U.S. Equal Employment Opportunity Commission (EEOC) in May 2018 in association with a lawsuit filed in the United States District Court for the District of Colorado (EEOC et al. v. University of Denver, Civil Action No. 16-cv-02471-WYD-MJW) alleging discriminatory pay practices based on sex, in violation of Title VII of the Civil Rights Act of 1964 and the Equal Pay Act of 1963. As required by the consent decree, and consistent with the commitments of the University of Denver and the Sturm College of Law to anti-discrimination and equitable compensation, I write to reaffirm our core commitments and to update you on our efforts in the realm of pay equity.
Equal pay for equal work is a foundational legal and moral principle. In furtherance of this principle, the consent decree requires the University of Denver and the Sturm College of Law to institute a number of measures designed to enhance pay transparency and pay equity. We enthusiastically embrace both the letter and spirit of these requirements:
- Posting signage in the Ricketson Law Building expressing our commitment to equitable compensation practices and encouraging employees to report any perceived incidents of discrimination;
- Adopting a new policy statement that articulates our core anti-discrimination principles, encourages individuals to report any conduct believed to be discriminatory, and emphasizes the University’s commitment to investigating such matters promptly and appropriately, and in an environment free from retaliation;
- Developing a new “know your rights” web page to educate faculty and staff members about equal opportunity and equal pay, including the reporting of suspected violations through a 24-hour hotline;
- Working with an Independent Consultant (Dean John White), an expert in higher education practices and anti-discrimination law, to enhance policies and procedures relating to evaluation and compensation;
- Retaining an external consulting firm (Edgeworth Economics) with extensive expertise in the field of labor economics to conduct an annual compensation equity study to determine whether any disparities in compensation are attributable to gender, or to gender combined with other protected characteristics;
- Disclosing the salaries and other compensation of tenure-stream faculty members and faculty members on long-term contracts with governance rights; and
- Instituting mandatory Equal Employment Opportunity (EEO) training for employees, including training regarding the Equal Pay Act of 1963, Title VII of the Civil Rights Act of 1964, and other federal anti-discrimination laws.
Additionally, we intend to undertake the following voluntary measures – among others – designed to advance our commitment to pay equity:
- Instituting an external strategic communications campaign designed to affirm our adherence to pay equity and to educate external stakeholders about the continuing nationwide challenges in achieving it;
- Conducting internal pay equity analyses, at periodic intervals, to assess our pay policies and structure, and to make appropriate adjustments when warranted;
- Working with external organizations and individuals – including law firms, accounting firms, corporations, bar associations, governmental institutions, alumni, and civic leaders – to increase the representation of women in legal and civic institutions, including boards, courts, and law faculties;
- Offering a set of salary negotiation workshops for faculty members, staff members, and students – building on an innovative initiative instituted by the Association of American University Women (AAUW) – designed to empower individuals with the skills to negotiate compensation and other terms of employment more effectively; and
- Establishing a committee designed to assess best practices in evaluation and compensation and to furnish recommendations on such matters.
I am confident that this comprehensive set of measures will foster transparency, reward colleagues fairly for their contributions, advance equity, build trust, and – over time – materially strengthen our institution. Although this process will not be easy, I am confident that it will move our institution forward and make it a better community.
Although the Equal Pay Act of 1963 was enacted more than a half-century ago, considerable work remains. The project that we now need to undertake together reminds us all that securing the beneficial effects of law requires hard work, continued assessment, and earnest collaboration. As Dean of the Sturm College of Law, I pledge to commit my full leadership, energies, and moral capital to instituting a system of evaluation and compensation at the Sturm College of Law that is more equitable, transparent, and trusted – and, in doing so, to advance our stature as a national leader in pay equity.
Bruce P. Smith
University of Denver Sturm College of Law