Am I federally regulated or provincially regulated?

Federally regulated industries are defined in the Canada Labour Code and include: banks, interprovincial and international transportation (air, rail, trucking, shipping), telecommunications and broadcasting, ports, postal services, federal Crown corporations and most First Nations governance. All other private-sector employers in Canada (other than Quebec, which has its own regime) fall under the OHS legislation of the province in which the workplace is physically located.

How often must I update this Policy?

At least annually. The federal SOR/2020-130 requires the Policy to be reviewed and updated at intervals of no more than three years (s. 5(2)), but best practice is a calendar-year review with the workplace health-and-safety committee or representative. The Policy must also be updated whenever there is a material change in the workplace, the workforce, the work performed or the applicable legislation.

Do I need to provide harassment-and-violence training?

Yes. Federal SOR/2020-130 s. 12 requires training at onboarding and at intervals not exceeding three years. Ontario OHSA s. 32.0.7 requires the employer to provide a Worker with information and instruction that is appropriate for the Worker on the contents of the Policy and the Program. Equivalent training obligations apply in BC under WorkSafeBC and in Alberta under the OHS Act. In higher-risk industries, an annual training refresher is best practice.

Must I name a Designated Recipient?

For federally regulated employers, yes — section 14 of SOR/2020-130 requires the Policy to designate, by name, a person or work unit to receive complaints. The Designated Recipient may be an employee, an external HR or law firm, or a workplace ombudsperson. For provincially regulated employers, the requirement is functionally equivalent — Ontario OHSA s. 32.0.6 requires the Policy to specify how to make a complaint and to whom — and a named contact is best practice everywhere.

Can the Designated Recipient be an external third party?

Yes. Section 14 of SOR/2020-130 expressly contemplates that the Designated Recipient may be a person or work unit that is not an employee of the workplace — including an external HR firm, an employment-law firm, or a workplace ombudsperson. An external Designated Recipient is the gold standard for smaller employers without a dedicated HR function and for any employer where complaints might be made against members of the executive team.

What investigation timeline applies?

Section 24 of SOR/2020-130 imposes a statutory longstop of one year from the date the report is made for the federal investigation to be completed. Most employers target 90 calendar days as the working timeline. The Ontario OHSA does not prescribe a fixed timeline but the Ministry of Labour expects investigation to be completed within a "reasonable period" — typically interpreted as 90 days for routine matters and up to 180 days for complex investigations.

How long must I keep records of occurrences and investigations?

Federal SOR/2020-130 s. 30 requires records of harassment-and-violence occurrences, employer investigation reports, police reports, and the annual report to the Labour Program to be retained for at least ten (10) years. Ontario OHSA does not prescribe a fixed retention period, but seven years is best practice (aligning with the Limitations Act, 2002 in Ontario for related civil claims). Records must be kept securely and disclosed only as required by law.

What is the federal annual report?

Section 35 of SOR/2020-130 requires every federally regulated employer to file an annual report with the Head of Compliance and Enforcement (Employment and Social Development Canada) on or before 1 March each year, covering the prior calendar year. The report must include the number of occurrences received, broken down by type (harassment / violence / sexual harassment / sexual violence / domestic violence), the number that were resolved at each stage, and the time to resolution. Failure to file is a regulatory offence under Part II of the Canada Labour Code.

Can a single Policy cover multiple provinces?

Yes. A multi-jurisdictional employer should hold a single master Policy that lists every province of operation and references each province's applicable OHS statute. The Expert tier in this template enables exactly this approach — a single document that satisfies every applicable jurisdiction, eliminating the need for separate provincial policies and the risk of inconsistency between them.

BusinessCanada

Workplace Harassment & Violence Prevention Policy Template

A Workplace Harassment and Violence Prevention Policy is a written employer-issued statement that records the employer's mandatory occupational-health-and-safety obligations under the federal Canada Labour Code Part II (and SOR/2020-130) or the relevant provincial OHS legislation. Our free Canadian template tracks the federal Bill C-65 / SOR/2020-130 framework, Ontario's Bill 132 amendments to the OHSA, British Columbia's WorkSafeBC Bullying and Harassment regime, and Alberta's Occupational Health and Safety Act, S.A. 2017, c. O-2.1 — drafted to satisfy the most-cited inspection deficiencies (recorded risk assessment + named designated recipient + investigation timeline + corrective-action matrix).

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WORKPLACE HARASSMENT AND VIOLENCE PREVENTION POLICY

Northwind Logistics Inc. · Province Of Ontario, Canada

Effective: 2026-06-01

Jurisdiction: Ontario · Next review: 2027

EMPLOYER

EMPLOYER NAME	Northwind Logistics Inc.
ADDRESS	180 Lake Shore Boulevard East, Toronto, ON M5A 3X7
TYPE	corporation
APPROXIMATE WORKFORCE SIZE	65
INDUSTRY	Freight forwarding and warehousing

Northwind Logistics Inc. (the "Employer") is committed to providing a workplace free from harassment and violence. This Workplace Harassment and Violence Prevention Policy (the "Policy") records the Employer's mandatory obligations under the Occupational Health and Safety Act, R.S.O. 1990, c. O.1, as amended by the Sexual Violence and Harassment Action Plan Act, 2016, S.O. 2016, c. 2, Sched. 4 (sections 32.0.1 to 32.0.7 and 55.3), and the procedures by which any employee, contractor, intern, volunteer or other person performing work for the Employer (each, a "Worker") may report and obtain resolution of any occurrence of workplace harassment or violence.

PURPOSE AND SCOPE

The purpose of this Policy is to (a) prohibit workplace harassment and violence in all forms, (b) describe the procedures by which Workers may report any occurrence, (c) describe how reports will be investigated and resolved, and (d) record the Employer's commitment to protect Workers who report from any form of retaliation. This Policy applies to all Workers at every workplace under the Employer's control, including the Employer's premises, any field or off-site location where work is performed, employer-sponsored social events, and any virtual or remote work environment. It binds the Employer, every member of senior management, every supervisor, and every Worker.

DEFINITIONS — HARASSMENT, SEXUAL HARASSMENT, VIOLENCE

In this Policy:

"Workplace harassment" means engaging in a course of vexatious comment or conduct against a Worker in a workplace that is known or ought reasonably to be known to be unwelcome, and includes workplace sexual harassment.

"Workplace sexual harassment" means (a) engaging in a course of vexatious comment or conduct against a Worker in a workplace because of sex, sexual orientation, gender identity or gender expression, where the course of comment or conduct is known or ought reasonably to be known to be unwelcome, or (b) making a sexual solicitation or advance where the person making the solicitation or advance is in a position to confer, grant or deny a benefit or advancement to the Worker and the person knows or ought reasonably to know that the solicitation or advance is unwelcome.

"Workplace violence" means the exercise of physical force by a person against a Worker in a workplace that causes or could cause physical injury, an attempt to exercise such physical force, or a statement or behaviour that it is reasonable for a Worker to interpret as a threat to exercise such physical force.

These definitions are read consistently with the corresponding statutory definitions in the Occupational Health and Safety Act, R.S.O. 1990, c. O.1, as amended by the Sexual Violence and Harassment Action Plan Act, 2016, S.O. 2016, c. 2, Sched. 4 (sections 32.0.1 to 32.0.7 and 55.3).

PROHIBITED CONDUCT

Workplace harassment, workplace sexual harassment and workplace violence are absolutely prohibited. This prohibition extends without limitation to: verbal or written abuse, threats, intimidation, bullying and ridicule; unwelcome physical contact, unwelcome sexual advances, unwelcome jokes or comments of a sexual nature, and the display of sexual material in the workplace; discrimination, harassment or differential treatment based on any ground protected under the applicable provincial or federal human rights legislation (including race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, gender identity, gender expression, age, marital status, family status or disability); cyber-harassment via email, text, instant messaging, internal communication platforms, social media or any other digital channel; and any retaliation against any Worker who reports an occurrence, supports a complainant or participates in an investigation.

REPORTING AN OCCURRENCE

Any Worker who has experienced or witnessed an occurrence of workplace harassment or violence is encouraged to report the occurrence as soon as reasonably possible. Reports may be made orally or in writing.

Primary contact — Hannah Reilly, Director of People andamp; Culture.
Email: hannah.reilly@northwindlogistics.ca. Phone: +1 416 555 0144.

Alternate contact — Marcus Brooks, email marcus.brooks@northwindlogistics.ca.

Reports may also be made by an anonymous third party. The Employer shall treat every report seriously, shall record it in confidence, and shall acknowledge receipt to the reporting Worker (where known) within seven (7) calendar days.

ANTI-RETALIATION COMMITMENT

No Worker shall be subjected to any form of reprisal, discipline, dismissal, demotion, transfer, withholding of benefit, exclusion from training or career opportunity, or any other detriment for having made a report under this Policy, for having supported a complainant, for having participated in an investigation, for having exercised any right under the applicable occupational-health-and-safety legislation, or for having refused to participate in any conduct that the Worker reasonably believes to be a breach of this Policy. Any allegation of reprisal will be investigated under this Policy and may, where substantiated, result in discipline up to and including dismissal for just cause.

WORKPLACE RISK ASSESSMENT

The Employer shall conduct, and shall record in writing, a proactive workplace risk assessment to identify any risk of workplace harassment or violence that may be present at any workplace under the Employer's control, considering risk factors including (a) the nature of the work performed, (b) the conditions under which the work is performed, (c) any history of incidents or near-misses, (d) the workforce demographic, (e) any risk associated with working alone, working remotely, working at client sites, working with the public or working with at-risk populations, and (f) any external risk arising from domestic violence carried into the workplace. The risk assessment shall be reviewed and updated at least every three (3) years and whenever there is a material change in the workplace or in the work performed.

Date of most recent risk assessment: 2026-04-15.

Identified risks at this workplace:
Warehouse floor operations with high turnover and night-shift scheduling — elevated risk of physical incidents and after-hours isolation.
Delivery drivers working alone at third-party client sites — risk of harassment by client personnel and exposure to domestic-violence carry-in.
Front-office reception with public-facing duties — risk of verbal abuse from members of the public.

Control measures in place:
CCTV coverage of warehouse floor, with retention period of 90 days.
Lone-worker check-in protocol for delivery drivers (every 4 hours via dispatch).
Reception panic button connected to building security desk.
Mandatory annual training for all supervisors on bystander intervention and disclosure response.

INVESTIGATION PROCEDURES AND DESIGNATED RECIPIENT

Designated Recipient: Marcus Brooks, Senior HR Business Partner (designated.recipient@northwindlogistics.ca).

On receipt of a report, the Employer shall: (a) acknowledge the report to the principal party (the complainant) within seven (7) calendar days; (b) determine whether the report describes an occurrence falling within this Policy; (c) attempt resolution through negotiated settlement or, if the principal party agrees, conciliation; (d) where resolution is not achieved, undertake or commission an investigation; (e) complete the investigation and provide the principal party with a written report and recommendations no later than 90 calendar days after the report is made (subject to the SOR/2020-130 s. 24 one-year longstop); (f) implement appropriate corrective and preventive measures; and (g) record the occurrence and its resolution in the Employer's confidential occurrence register, retained for at least ten (10) years (SOR/2020-130 s. 30). The investigator shall be impartial, free of any conflict of interest, and qualified by training or experience in occupational-health-and-safety investigations.

Third-party investigator threshold: The Employer shall engage an external third-party investigator where the complaint is against the CEO, against any member of the executive team, or where the Employer's in-house resources would create a conflict of interest or reasonable apprehension of bias.

COMPLAINT FORM AND CORRECTIVE ACTION MATRIX

Complaint Form Annex. The Employer maintains a standard Workplace Harassment and Violence Complaint Form (annexed to this Policy) which Workers may use to make a written report. Use of the Form is optional; an oral or informal report is equally valid and will be treated identically. The Form captures: (i) date, time and location of the alleged occurrence; (ii) parties involved; (iii) description of the conduct; (iv) witnesses, if any; (v) any documentary or electronic evidence; (vi) the complainant's preferred resolution; and (vii) acknowledgment that the report is made in good faith.

Corrective Action Matrix. Substantiated occurrences will be addressed by corrective and preventive measures proportionate to the seriousness and pattern of the conduct, drawing from the following non-exhaustive matrix: written warning, mandatory training or counselling, reassignment, suspension (paid or unpaid), demotion, last-chance agreement, termination for just cause, referral to police where the conduct constitutes a Criminal Code offence.

Examples agreed by the Employer:
First-time low-severity (e.g., off-colour joke): documented coaching + mandatory respect-in-the-workplace training within 30 days.
First-time moderate-severity (e.g., persistent unwelcome comments): written warning + suspension up to 5 days + mandatory training + 6-month behavioural monitoring.
First-time high-severity (e.g., physical assault, sexual touching): immediate suspension pending investigation + termination for just cause + Criminal Code referral.
Retaliation against any reporting Worker: same scale, treated as aggravating factor at every tier.

STATUTORY COMPLIANCE, TRAINING, AND ANNUAL REVIEW

This Policy is drafted to satisfy the Occupational Health and Safety Act, R.S.O. 1990, c. O.1, as amended by the Sexual Violence and Harassment Action Plan Act, 2016, S.O. 2016, c. 2, Sched. 4 (sections 32.0.1 to 32.0.7 and 55.3).

Provinces of operation covered by this Policy:
Ontario — primary operations at 180 Lake Shore Boulevard East, Toronto.
British Columbia — Vancouver warehouse (12 employees) at 1450 Powell Street, Vancouver.
Alberta — Calgary distribution centre (8 employees) at 4400 32nd Street NE, Calgary.

Training. The Employer shall provide initial training on this Policy to every Worker as part of the Worker's onboarding, and shall provide refresher training to every Worker at intervals not exceeding 36 months. Training shall cover the contents of this Policy, the relevant statutory framework, the rights and responsibilities of Workers and supervisors, and the resources available to Workers.

Annual review. This Policy shall be reviewed and, if necessary, updated annually in the month of January, and at any time on a material change in the workforce, the workplace, the work performed, or the applicable legislation. The review shall be conducted jointly with the workplace health-and-safety committee (or, where no committee exists, with the health-and-safety representative).

10.

CONFIDENTIALITY

Information obtained about an occurrence, including identifying information about any individual involved, shall not be disclosed except as necessary for the purposes of investigating or resolving the occurrence, taking corrective action, or as required by law (including disclosure to the relevant occupational-health-and-safety regulator). Confidentiality protects the integrity of the investigation, the privacy of the parties and the safety of any Worker who reports.

11.

ACKNOWLEDGEMENT AND ENFORCEMENT

This Policy is binding on the Employer, every member of senior management, every supervisor, and every Worker. Failure by any Worker to comply with this Policy may result in discipline up to and including dismissal for just cause. The Employer commits to make this Policy easily accessible to all Workers, including by posting it in a conspicuous workplace location, making it available on the Employer's intranet or shared drive, and providing a copy on request.

EMPLOYER ATTESTATION. Northwind Logistics Inc. hereby adopts this Policy effective 2026-06-01, and authorises its publication to all Workers and posting in the workplace.

EMPLOYER

Diana Khaledi

Chief Executive Officer

Date: ____________________

Available as a print-ready PDF or an editable Microsoft Word (.docx) file.

What Is a Workplace Harassment and Violence Prevention Policy?

A Workplace Harassment and Violence Prevention Policy is a written, employer-issued statement that prohibits workplace harassment and violence in all forms, describes the procedures by which Workers may report any occurrence, describes how reports will be investigated and resolved, and records the employer's commitment to protect Workers from any form of retaliation. Every Canadian employer must hold a current, signed Policy — failure to do so is the single most common deficiency cited in Ministry of Labour / WorkSafeBC / Alberta OHS inspections.

For federally regulated employers (banks, telecoms, airlines, rail, federal Crown corps), the controlling framework is Part II of the Canada Labour Code, R.S.C. 1985, c. L-2, together with the Work Place Harassment and Violence Prevention Regulations, SOR/2020-130, in force since 1 January 2021. Section 10 of those Regulations sets out the mandatory contents of the policy; section 14 requires a named Designated Recipient; section 30 imposes a 10-year record-retention obligation; section 35 requires an annual report to the Head of Compliance and Enforcement.

For provincially regulated employers, the controlling framework is the OHS legislation of the province in which the workplace is located. In Ontario, the Occupational Health and Safety Act, R.S.O. 1990, c. O.1, was amended by Bill 132 (the Sexual Violence and Harassment Action Plan Act, S.O. 2016, c. 2, Sched. 4) in 2016, which expanded the definition of "workplace harassment" to include sexual harassment and added the section 32.0.3 proactive-risk-assessment requirement. In British Columbia, WorkSafeBC Policies D3-115-1 through D3-115-3 implement the equivalent regime. In Alberta, the OHS Act, S.A. 2017, c. O-2.1, in force 1 June 2018, brought parallel obligations. On 15 January 2026, the federal Labour Program issued a compliance reminder to all federally regulated employers — a strong signal of forthcoming enforcement.

What's Covered in This Template

Our Workplace Harassment and Violence Prevention Policy template covers every element required by the federal Regulations and the equivalent provincial OHS statutes.

Employer Identification

Legal name, registered address, employer type (corporation / partnership / non-profit / public sector), approximate workforce size and industry.

Regulatory Jurisdiction

Selection between federally regulated (Canada Labour Code Part II) and any of the ten common-law provinces — automatically generates the correct statutory references.

Statutory Definitions

Workplace harassment, workplace sexual harassment and workplace violence defined per OHSA s. 1 (Ontario) and Canada Labour Code s. 122(1) (federal).

Prohibited Conduct

Verbal/written abuse, threats, unwelcome physical contact, sexual advances, discrimination on protected grounds, cyber-harassment, retaliation.

Reporting Channels

Primary and alternate contacts (named individuals with email + phone), anonymous third-party reporting, 7-day acknowledgment commitment.

Workplace Risk Assessment (Expert)

Mandatory under OHSA s. 32.0.3 and the equivalents — records identified risks and control measures, the most-cited inspection deficiency.

Investigation Procedures + Designated Recipient (Expert)

Named Designated Recipient per SOR/2020-130 s. 14 (in-house or external third party), 90-day investigation timeline, third-party investigator threshold.

Complaint Form + Corrective Action Matrix (Expert)

Standardised complaint form annex + three-severity-tier corrective action matrix (low / moderate / high) with proportionate consequences.

Multi-Jurisdiction Coverage (Expert)

Single Policy that satisfies every province in which the employer has a workplace, eliminating the need for separate provincial policies.

Anti-Retaliation + Confidentiality + Annual Review

Express anti-retaliation commitment, confidentiality protection, annual review schedule, training cadence (default 36 months per SOR/2020-130 minimum).

How to Create Your Workplace Harassment and Violence Prevention Policy

Follow these steps to prepare a Policy that satisfies the federal Regulations and the provincial OHS legislation applicable to your workplace.

1
Confirm Your Regulatory Jurisdiction
Federally regulated industries (banks, telecoms, airlines, rail, federal Crown corps) fall under the Canada Labour Code Part II + SOR/2020-130. All other employers fall under the OHS Act of the province in which the workplace is located.
2
Conduct and Record a Workplace Risk Assessment
Section 32.0.3 of the Ontario OHSA (and the equivalents) requires a proactive, written risk assessment identifying the harassment-and-violence risks at every workplace under the employer's control. The Expert tier records the assessment date, the identified risks and the control measures in place.
3
Name a Designated Recipient
Federal SOR/2020-130 s. 14 requires the Policy to name the person or work unit to whom reports may be made. This may be a senior HR member, an external HR consultancy or a workplace ombudsperson. The Expert tier records the name, title and confidential email.
4
Set the Investigation Timeline
Default 90 calendar days from report to written investigation report. SOR/2020-130 s. 24 imposes a statutory longstop of 1 year. The Expert tier records the chosen timeline and the threshold for engaging an external third-party investigator (typically: complaint against CEO / executive team or actual conflict of interest).
5
Build the Corrective Action Matrix
Document three severity tiers (low / moderate / high) with concrete proportionate consequences. Inconsistent discipline across substantiated occurrences is the most common source of human-rights and wrongful-dismissal claims arising from a harassment investigation.
6
Set the Annual Review and Training Cadence
The Policy must be reviewed at least annually with the workplace health-and-safety committee (or representative). Training is required at onboarding and at intervals not exceeding 36 months (federal minimum); 12 months is best practice in higher-risk industries.
7
Authorise + Publish
A senior management member (typically the CEO or HR Director) signs the Policy. The Policy is then posted in a conspicuous workplace location, distributed to all Workers, made available on the intranet, and produced on request.

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Legal Considerations

Workplace harassment and violence policies are governed by an overlay of federal and provincial OHS statutes plus human-rights legislation.

This template is for informational purposes only and does not constitute legal advice. Workplace harassment and violence carry significant criminal, regulatory, civil and human-rights consequences. Consult a qualified Canadian employment lawyer or OHS consultant for advice specific to your workplace, particularly where the workplace operates in multiple provinces or where there is an active complaint or investigation.

Reviewed for Canadian federal and provincial OHS requirements

Federal Canada Labour Code Part II

Section 122.1 of the Canada Labour Code provides that the purpose of Part II is to prevent accidents, occurrences of harassment and violence, and physical or psychological injuries and illnesses arising out of, linked with or occurring in the course of employment. Section 125(1)(z.16) imposes the general employer obligation to take prescribed steps to prevent and protect against harassment and violence. The detailed obligations are set out in the Work Place Harassment and Violence Prevention Regulations, SOR/2020-130, in force since 1 January 2021. Section 10 of those Regulations sets out the mandatory contents of the policy: definitions, statement of commitment, description of complaint resolution process, designation of recipient, training, retention rules.

Bill C-65 and the 2026 Compliance Reminder

Bill C-65, An Act to amend the Canada Labour Code (harassment and violence), S.C. 2018, c. 22, was assented to on 25 October 2018 and brought the unified federal harassment-and-violence framework into force. On 15 January 2026, the Labour Program issued an email reminder to all federally regulated employers about their compliance obligations — a strong signal of imminent enforcement. Federally regulated employers should treat their Policy as a live compliance document subject to annual update.

Ontario OHSA and Bill 132

The Sexual Violence and Harassment Action Plan Act (Supporting Survivors and Challenging Sexual Violence and Harassment), 2016, S.O. 2016, c. 2, Sched. 4 ("Bill 132"), in force 8 September 2016, expanded Ontario's OHSA definition of "workplace harassment" to include sexual harassment, and added new sections 32.0.1 to 32.0.7 setting out the mandatory contents of a Workplace Harassment Policy, the requirement for a proactive risk assessment, the requirement to provide information and instruction (training), and the requirement to investigate complaints. Section 55.3 empowers Ministry of Labour inspectors to order an employer to engage a third-party investigator at the employer's expense.

British Columbia WorkSafeBC Regime

WorkSafeBC Policies D3-115-1 (Employer Duties), D3-115-2 (Worker Duties) and D3-115-3 (Supervisor Duties), issued under the Workers Compensation Act, R.S.B.C. 2019, c. 1, and operationalised through Part 4 of the Occupational Health and Safety Regulation, B.C. Reg. 296/97, impose a parallel set of obligations on BC employers: written policy, risk assessment, prevention training, investigation procedures.

Alberta OHS Act 2017

The Occupational Health and Safety Act, S.A. 2017, c. O-2.1, in force 1 June 2018, defines harassment and violence in section 1 and imposes section 18 general employer obligations to protect workers from harassment and violence. The Alberta OHS Code requires a written harassment-and-violence prevention plan and an investigation procedure.

Interaction with Human Rights Legislation

A complaint of workplace harassment frequently engages the provincial Human Rights Code (or the federal Canadian Human Rights Act for federally regulated employers) where the harassment is based on a protected ground (sex, race, disability, sexual orientation, gender identity, etc.). The investigation may also engage criminal law where the conduct includes assault, sexual assault, criminal harassment or threats. The Policy must therefore co-exist with the employer's separate Human Rights Policy and Code-of-Conduct, and the employer must be prepared to refer the matter to the police where the conduct constitutes a Criminal Code offence.

Quebec — Excluded From This Template

Quebec is governed by a separate civil-law CNESST framework — the Loi sur les normes du travail (sections 81.18 to 81.20) and the Loi sur la santé et la sécurité du travail. A Quebec-specific template will follow in a future sprint.

Frequently Asked Questions

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