23 June 2014 MR. STEPHEN DEKREY President Asian Institute of Management Paseo de Roxas Makati City

DYSFUNCTIONAL BEHAVIOUR COMPLAINT Against Dr. Hazel Paragua (Program Director) and Dean Juan Miguel Luz

Dear President Dekrey: Although the Student Handbook of 2014 does not expressly state that a complaint may be initiated at the Office of the President, it appears that considering the rank of the officials involved, the nature of the matters in this complaint more than warrant direct recourse to your office. Dr. Hazel Paragua and Associate Dean J. M. Luz are here being charged with dysfunctional behavior for failing to act on valid complaints involving serious violations of the Student Handbook of 2014 and favoritism, preferential treatment, coupled with bullying, discriminatory and dismissive attitudes against the complainant. The acts of plagiarism were committed by Mr. Armando Lee in the Presentation for the Concept Notes submitted for his MRR.

1. On 25 Feb. 2014, Complainant sent an email to Dr. Paragua and Dean Luz pointing out the existence of unmistakable plagiarism in the work of one Armando Lee, class president. The email states

From: Khristin Consunji Date: Tue, Feb 25, 2014 at 6:57 PM Subject: Fwd: Management Research Report (Concept Notes) To: Hazel Paragua , Juan Miguel Luz , Juan Miguel Luz Dear Dr. Hazel and Dean Luz, Please note the chronology -- Arman did not submit his report until after Rommel did. I also have earlier emails from Rommel when he gave his draft to our LT for comments, so I can personally attest to his original authorship. Best, Chin

2. As stated in the email, Complainant brought to the attention of Dr. Paragua and

Dean Luz the copying or plagiarism committed by Armand Lee, who stole intellectual work from Rommel Rubiales. As stated, it is a matter of record that Rommel Rubiales distributed his Concept Notes to all members of the Learning Team and submitted them ahead of Armando Lee.

3. During a meeting attended by President Dekrey on 18 June 2014, Dean Luz flatly claimed that they looked at it and there was nothing there, stating that he did not regard the copying or replication by Arman as a case of plagiarism.

4. Luz, apparently speaking for Dr. Paragua and allegedly, Ron Chua, went to some lengths to explain that similarities existed but these were just like templates, which, he further claimed, cannot be the subject of plagiarism. He used the example of a speaker introducing himself in this fashion

SPEAKER A: Hi, my name is Juan dela Cruz, I am from De La Salle. SPEAKER B: Hi, my name is Juan Miguel Luz, I am from AIM.

5. Dean Luz correctly concluded, on the basis of the above explanation and example, that there could be no plagiarism to speak of because these statements did not involve any original intellectual work.

6. Regrettably, these statements made in the context of the said meeting, can only be regarded as having the intention of deceiving Dr. Dekrey into believing that the material copied is superficial or incidental and that Complainant is delusional and given to exaggeration. Clearly, Dean Luz attempted to discredit Complainant before Dr. Dekrey painting her to be irrational or paranoid or of unstable emotional and intellectual wellbeing.

7. Dean Luz also assured Dr. Dekrey that he himself looked into the complaint for plagiarism and that he replied to Complainant and informed her of his negative findings.

8. Just to be clear, here are the slides that Complainant sought to bring to the attention of Dr. Paragua and Dean Luz

Slide No.

Rommels Slides Armans Slides Annex

3

A

4

B

6

C

7

D

8

E

9

F

10

G

9. The unmistakable identity and similarity of the content of the slides is not limited to the text alone, but goes to the very organization and progression of the intellectual framework behind the work. Surely, these slides demonstrate a degree of duplication that far exceeds the I am Juan Miguel Luz from AIM analogy presented by Dean Luz to President Dekrey.

10. More importantly, this direct comparison establishes that Dean Luz and Dr. Paragua completely ignored the complaint for plagiarism.

11. Undoubtedly, the outright copying evident here merits more than merely stating that there was nothing there.

12. Despite what appears undeniably as a facially serious offense, Dean Luz practically twitted Complainant during the meeting with President Dekrey, dismissing the entire matter as a non-event.

13. To even conclude that the copying involved here is not plagiarism, there must at least have been some effort to explain why the prohibitions in the Student Handbook of 2014 do not apply. (See Academic Dysfunctional Behaviour on pp. 17 to 19 of the Student Handbook of 2014) No such effort was made to enlighten complainant about violations of the rules of the school.

14. To be precise, this complaint for dysfunctional behavior also includes the dismissive response to the plagiarism complaint and the patent deception during the meeting

with President Dekrey, indicative of a bias against complainant or blatant favoritism or unwarranted protection of offender Armando Lee.

15. Ms. Ismeera Qadeer, as a member of Learning Team 6 (of whom both Mr. Rubiales and Ms. Consunji were members), was also aware that Armando Lee had copied the MRR Concept notes presentation of Rommel Rubiales as Ms. Consunji had alerted her to the issue.

16. Mr. Coen Damen, current SA Chairman, was also made aware of the similarities between the presentations. In the following email:

On Tue, Feb 25, 2014 at 10:02 AM, Coen Damen wrote: Hi Chin, Lets have lunch one of these days. I'm quite stunned by the similarities between the two! (actually I uttered a few profanities...) I have to check what exactly the role of the SA is in these matters, as I seem to recall that there is a distinct difference between disciplinary issues about behavior on campus and academic issues. I'm quite hung over today, this really doesn't help.... I also hope Rommel is not affected by this. Cheers, C.

17. Ms. Consunji had blocked both Mister Armando Lee and Ms. Maybelle Santos from her facebook page yet on May 26, 2014, Dean Juan Miguel Luz had sent her the following text messages from his number 09178842112:

Chin, you wrote on fb that we approved your transfer to another LT? I made it clear that WE would make the announcement once another LT has agreed to accept you. Now you have a class that is questioning this. Youd better explain this to Dr. Hazel and myself. You really need to process the implications of what you say and write before you speak out. We dont need to be spending more time dealing with these issues than we should. Mike Luz Sent at 8:21 am Correction: The class officers (not the class) are raising issue. Sent at 8:25 am

18. Ms. Qadeer had been informed of Ms. Consunjis impending move to another Learning Team on May 25, 2014 when Ms. Consunji had sent her a message on facebook about her impending move to another Learning Team stating:

Ok Ismeera thanks, I have two (Learning Teams) lined up already. Ty! Sent at 12: 29 am

19. Thus, it can only be deduced that Ms. Qadeer had informed Mr. Armando Lee or Ms. Maybelle Santos about Ms. Consunjis announcement on her facebook page from the previous night. Dean Juan Miguel Luzs continued preferential treatment of

Ms. Ismeera Qadeer and the class officers resulted in bullying and harassing behaviours to the extent of intruding upon the facebook page of the complainant which is not within the mandate of the Institution.

20. During a meeting attended by President Dekrey on June 18 2014, Dean Juan Miguel

Luz had alluded to the pending dysfunctional behavior complaint against Ms. Ismeera Qadeer by not naming her, and he also stated that BRAC (Ms. Qadeers employer) is the largest NGO in the world which contributed to his continued inaction against Ms. Qadeeer in order to satisfy his commercial client to the detriment of Ms. Consunjis health and well-being, which eventually enabled her to continue harassing complainant.

21. Ms. Consunji had filed a complaint against Doctor Hazel Paragua to Rey Reyes on

March 12, 2014 for her preferential treatment of Armando Lee as well as failure to investigate the plagiarism complaint:

---------- Forwarded message ---------- From: Khristin Consunji Date: Wed, Mar 12, 2014 at 1:11 AM Subject: Complaint To: "Reyes, Rey D." This is a formal complaint I am filing against our program director, Hazel Paragua, for lack of impartial behaviour in investigating a plagiarism allegation. On February 24, 2014, I was made aware that our class president Armando Lee had lifted significant portions of his MRR Concept Notes presentation from my teammate, Rommel Rubiales. When Ms. Paragua was made aware of this anomaly and when I spoke to her about it on the morning of February 26, 2014, she alleged that she did not believe any plagiarism occurred because she believed that Armando and Rommel had followed a "pro forma strategic management template" and that the MRR presentation was technically not subject to plagiarism charges, even if it was submitted to our instructor Professor Ron Chua. Ms. Paragua then referred the case to Dean Luz who called me into his office at approximately 11 am and reprimanded me for a supposedly false plagiarism accusation, with a copy of the MRR concept notes instead of the plagiarized presentation which was forwarded to him via e-mail on February 24. As of today, there have been no significant repercussions for Armando Lee for his plagiarism and such permissiveness from both our program director and the dean of the management school does not speak well of the academic integrity of our institution. Furthermore, Ms. Paragua did not exercise sage judgment in recommending a reprimand for the person who reported the plagiarism instead of the perpetrator of the plagiarism -- this constitutes dysfunctional and immensely biased behaviour in any context and will not be tolerated in any form. I would recommend that Ms. Paragua be recused from any and all assessments I am involved with, as I am seriously questioning her judgment or lack thereof with respect to academic matters. From: Khristin Consunji Date: Wed, Mar 12, 2014 at 1:18 AM Subject: Re: Complaint To: "Reyes, Rey D."

I am enclosing the presentations, both the original from Mr. Rubiales (my teammate) and Armando Lee. To this date, Armando is given access to the work of other students (marked and unmarked) due to his position, which creates more opportunities for dysfunctional academic behaviour in the future. All correspondences where Mr. Rubiales sent out his original report to the entire class and Mr. Lee expressed his admiration for said report can be found on the server. E-mails alerting Hazel Paragua and Dean Luz to the similarities between these submissions can also be found on the server. ---------- Forwarded message ---------- From: Khristin Consunji Date: Thu, Mar 13, 2014 at 12:22 AM Subject: Re: Complaint To: "Reyes, Rey D." Dear Mr. Reyes, I have not forwarded a copy of this complaint to Dean Lim yet. To be perfectly honest, my experience in reporting the situation to Hazel Paragua and Dean Luz's response have made me reticent to forward this to Dean Lim until I could gather my thoughts. I spent the past two weeks debating the pros and cons, and after consulting extensively with my parents and my extended family, I was told to withdraw from the program if this type of behaviour was condoned in AIM. However, seeing as I have already committed to the program (both in terms of time and money), the other option was to see to it that these things never have the opportunity to repeat themselves. I would like to note that I had made Dean Luz aware of lack of impartiality on the part of Ms. Paragua before, particularly with respect to our RAA assignments. These correspondences can be found on the server. Ms. Paragua had advised our team that we were not to use prior contacts or work in sectors/industries we have had prior experience with for our RAA. (I can copy furnish all correspondences to that effect.) I had made her aware that this was to our detriment because our learning team contains members of government, two members of nonprofits, a member of the private sector such as myself and a member of the church -- in effect, this was to our detriment and it seemed like an arbitrarily excessive application of the RAA rules. Upon questioning two previous MDM students Ms. Paragua invited to our class this afternoon, it was noted that Ms. Lim's team violated the restrictions Ms. Paragua had enforced by working with a sector a teammate had prior experience with. Thus, I am questioning the inconsistencies and selective application of policies on her part with respect to RAA assignments, as her biases could severely affect the assessment we are meant to carry out. You are free to forward my correspondences to Dean Lim if the official submission of the complaint necessitates it. Best, Khristine

22. Subsequent failure to act on said complaint contributed to Dr. Paraguas and Dean Juan Miguel Luzs continued bullying behaviour, which eventually resulted in refusal to grant an extension for our Rapid Area Assessment report despite the fact that

there were only four members in Ms. Consunjis team as opposed to six in other teams. Complainant asked if she could extend the deadline for our Rapid Area Assessment report due to the absence of Ms. Dong Nguyen Thi Thu and Father Richard Ripon Rozario from the RAA. Ms. Dong Nguyen Thi Thus mother suffered from a stroke while the father of Father Ripon had passed away, leaving only four teammates to carry out an immensely difficult task:

On Tue, Apr 29, 2014 at 11:39 PM, wrote: Dear Chin, This is a rapid appraisal, not an MRR. The assumption is that you will not have complete data given the short period of time. But given data collected (and you seem to have a lot), you should be able to draw a profile of the community and its existing challenges. Do what you can and submit what you have. The deadline cannot be moved given the presentation schedule on May 1 and 2. Mike Luz

Sent from my BlackBerry wireless handheld

From: Khristin Consunji Date: Tue, 29 Apr 2014 23:05:47 +0800 To: Paragua, Hazel L.; Juan Miguel Luz; Juan Miguel Luz; Hazel Paragua Subject: Request for Extension of RAA Submission Dear Doctor Hazel and Dean Luz, I would like to request if we could extend the deadline for submission of the RAA report. Seeing as our team is understaffed at the moment (Dong and Father Ripon have family issues to attend to) and given the amount of fieldwork we had to undertake, it is simply not possible or feasible to have a report of 25-35 pages due by 1pm tomorrow. Today, Ismeera and I sat down for 15 hours straight with no breaks just to finish up our data analysis and write the preliminary draft. We are not sure what the other teammates are doing as we have asked Rommel and Leka to join us to write the report but we have not received submissions or feedback from them at this date. There was a considerable amount of fatigue involved given all the data we had to gather in such a short amount of time, as well as the stress of interviewing IDPs for the duration of our stay. The stresses also caused considerable conflicts in the team as we had a very complex topic to cover and we needed to give it the consideration it merited. I understand if this is not feasible or possible, but I hope you understand that we were all working immensely hard in the field and we barely had time to write after coming back to the resort every day. We also decided to stay in Estancia on April 27, 2014 to get the technical reports from DENR-EMB, Doctor Rex Sadaba and the rest of the interagency task force. The informal interviews we conducted with them were key, as they allowed us to finally understand why the contractor was hired and all the attendant issues. Since fishing is the main driver of the economy in Estancia and it is the LGUs role to enforce fishing bans 3k from the shore, unfortunately there is a very high chance that everything from that port is contaminated. We also discovered that residents were allowed to move back to the shoreline on December 20, 2014 but the benzene ppm on January 2, 2014 and January 4, 2014 was far above the permissible level. Other issues such as skin diseases and health issues we saw in the evacuation centers, as well as the considerable amount of bunker oil left on the shoreline where people are actively fishing are immense causes of concern and it still eludes us how to articulate the nature of what we observed. Best, Chin

23. Complainant requested another extension as she had not slept due to the difficulties of the data-gathering required for the RAA, which Doctor Hazel Paragua oversees.

From:

Date: Tue, Apr 29, 2014 at 11:21 PM Subject: Re: Request for Extension of RAA Submission To: "Consunji, Khristin" , "Paragua, Hazel L." , Juan Miguel Luz , "Luz, Juan Miguel"

Dear Chin, We do understand your predicament but the deadline set for the written report (April 30, 1pm) only allows minimal time for the faculty to review your work before your oral report presentation. Since your group will be the first to report at 8:30am on May 1, it will be to your disadvantage if the faculty will not be able to even glance at your paper and base your evaluation almost entirely on the oral presentation. Before Dung and Fr Ripon left the country, they promised to participate in your report writing thru email. Since you were concerned about your group and individual grades and participation prior to leaving for Estancia, I suggest you get contribution from ALL team members so that not one or two will be overloaded. Remember that RAA grading is mostly about teamwork and cooperation. This must be reflected in your output as well. We can only move your deadline to 5pm tomorrow. We still have to provide all faculty members with hard copies of your written reports before they all leave AIM. Late papers will be graded down. Good luck. Dr Hazel ---------- Forwarded message ---------- From: Khristin Consunji Date: Tue, Apr 29, 2014 at 11:34 PM Subject: Re: Request for Extension of RAA Submission To: Hazel Paragua Cc: "Paragua, Hazel L." , Juan Miguel Luz , "Luz, Juan Miguel"

Dear Doctor Hazel, Thank you for your response. Would it be possible to submit our preliminary draft tomorrow and then the final one at a later date? I understand the need for teamwork but given the severity of the personal/family issues for Dong and Father Ripon, it has been difficult to contact them for participation in this report. On the evening of the 27th, there was also an incident where a teammate simply stated that he did not want to work anymore, as he had been overtaxed. Unfortunately, these are issues that happen and they are understandable when everybody is under duress, but this what we have to work with. Ismeera and I tried calling the other teammates to come in but they have refused, so we have to factor in the possibility that she and I will have to write this report solely. As of now, there are roughly 2,000 words and realistically, perhaps another 2,000 can be produced tomorrow but it is unsure what the quality of the output would be. I would like to stress that everybody has contributed and everybody has worked very hard -- it is a

collective effort. The team has performed and we performed well. But there's really nothing left in the tank and we cannot be assured that everything will come together in less than 24 hours time. If there is a late penalty, perhaps it would be best if we are aware of it so we can plan for that possibility. This is a good report and we were able to identify the key gaps -- but as I had joked, I believe we are also in need of some humanitarian assistance because exposure to these issues while working was very taxing for us all, psychologically. Best, Chin

24. Failure to grant the extension by both Dean Luz and Doctor Paragua resulted in Ms. Consunjis hospitalization on May 6, 2014 for high fever and exhaustion. Supporting documentation was submitted to Program Associate Lyndon Constantino.

25. It is believed that the manner in which Dean Luz condoned the bullying behavior on the part of Doctor Paragua stems from the personal relationship between Doctor Paragua and the donor to the AIM Center for Development Management, Stephen Zuellig.

26. Thus, Dean Luz knowingly and maliciously condoned injurious behavior against Ms. Consunji by Doctor Paragua as he valued commercial interests and fiscal concerns over the safely and well-being of his students.

27. Complainant respectfully prays for the application of the imposable sanctions against all liable parties under the rules of the Institute.

In the City of Makati, 24 June 2014. Khristine Consunji