what is workplace harassment? - the grocery outlet€¦ · in some cases, a targeted person may...

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What is Workplace Harassment? Workplace harassment is engaging in a course of vexatious comments or conduct against a worker in a workplace that is known or ought reasonably be known to be unwelcome. Some types of behaviours that may be workplace harassment include: bullying teasing intimidating or offensive jokes/remarks/innuendoes sexual advances towards employees displaying or circulating offensive pictures or materials offensive or intimidating phone calls Workers may face harassment in any workplace and from any person in the workplace. The harassing person may be someone the worker comes into contact with due to the nature of his or her work. This may include a client, customer, another employee or supplier. The harassing person may also be a part of the workforce, including a coworker, manager, supervisor or employer. Or the person may be someone with no formal connection to the workplace such as a stranger or domestic/intimate partner who brings harassment into the workplace. The definition of workplace harassment is broad enough to include harassment prohibited under Ontario’s Human Rights code, as well as what is often called “psychological harassment” or “personal harassment.” What isn’t Workplace Harassment? Reasonable action or conduct by an employer, manager or supervisor that is part of his or her normal work function would not normally be considered workplace harassment. This is the case even if there are sometimes unpleasant consequences for a worker. Examples could include changes in work assignments, scheduling, job assessment and evaluation, workplace inspections, implementation of dress code and disciplinary action. Differences in opinion or minor disagreements between coworkers would also not generally be considered workplace harassment. In addition, any behaviour that would meet the definition of workplace violence would not be considered to be workplace harassment. Continuum of Inappropriate Behaviour A continuum of inappropriate behaviours can occur at the workplace. This can range from offensive remarks to violence. Workplace harassment may escalate over time into threats, or acts of physical violence. In some cases, a targeted person may react violently to prolonged harassment in the workplace. Below is a copy of Almost Perfect/The Grocery Outlet’s Non Harassment Policy that is posted on the health and safety board of the workplace.

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Page 1: What is Workplace Harassment? - The Grocery Outlet€¦ · In some cases, a targeted person may react violently to prolonged harassment in the ... Employees will avoid harassment,

What is Workplace Harassment? Workplace harassment is engaging in a course of vexatious comments or conduct against a worker in aworkplace that is known or ought reasonably be known to be unwelcome. Some types of behavioursthat may be workplace harassment include:

• bullying

• teasing

• intimidating or offensive jokes/remarks/innuendoes

• sexual advances towards employees

• displaying or circulating offensive pictures or materials

• offensive or intimidating phone calls

Workers may face harassment in any workplace and from any person in the workplace. The harassingperson may be someone the worker comes into contact with due to the nature of his or her work. Thismay include a client, customer, another employee or supplier. The harassing person may also be a partof the workforce, including a coworker, manager, supervisor or employer. Or the person may besomeone with no formal connection to the workplace such as a stranger or domestic/intimate partnerwho brings harassment into the workplace. The definition of workplace harassment is broad enough toinclude harassment prohibited under Ontario’s Human Rights code, as well as what is often called“psychological harassment” or “personal harassment.”

What isn’t Workplace Harassment? Reasonable action or conduct by an employer, manager or supervisor that is part of his or her normalwork function would not normally be considered workplace harassment. This is the case even if thereare sometimes unpleasant consequences for a worker. Examples could include changes in workassignments, scheduling, job assessment and evaluation, workplace inspections, implementation ofdress code and disciplinary action. Differences in opinion or minor disagreements between coworkerswould also not generally be considered workplace harassment. In addition, any behaviour that wouldmeet the definition of workplace violence would not be considered to be workplace harassment.

Continuum of Inappropriate Behaviour A continuum of inappropriate behaviours can occur at the workplace. This can range from offensiveremarks to violence. Workplace harassment may escalate over time into threats, or acts of physicalviolence. In some cases, a targeted person may react violently to prolonged harassment in theworkplace.

Below is a copy of Almost Perfect/The Grocery Outlet’s Non Harassment Policy that is posted on thehealth and safety board of the workplace.

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Workplace Non Harassment Policy The management of Almost Perfect Inc./The Grocery Outlet is committed to providing a workenvironment in which al individuals are treated with respect and dignity.

Workplace harassment will not be tolerated from any person in the workplace including, head officestaff, team leaders, assistant team leaders, store employees, warehouse employees, maintenanceemployees, drivers, suppliers and any visitor on Almost Perfect/The Grocery Outlet property. Everyonein the workplace must be dedicated to preventing workplace harassment. Managers and workers areexpected to uphold this policy, and will be held accountable by the employer.

Workplace harassment means engaging in a course of vexatious comment or conduct against a workerin a workplace, a comment or conduct that is known or ought to be known to be unwelcome.

Harassment may also relate to a form of discrimination as set out in the Ontario Human Rights Code,but does not have to.

This policy is not intended to limit or constrain the reasonable exercise of management functions in theworkplace. Workers are encouraged to report any incidents of workplace harassment. Management willinvestigate and deal with all concerns, complaints, or incidents of workplace harassment in a a fair andtimely manner while respecting workers’ privacy as much as possible.

Nothing in this policy prevents or discourages a worker from filing an application with the HumanRights Tribunal of Ontario on a matter related to Ontario’s Human Rights code within one year of thelast alleged incident. A worker also retains the right to exercise any other legal avenues that may beavailable.

Signed: _________________________________ Owner Date: _______________________

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Acknowledgment of Non-Harassment Policy To be signed by all persons upon receipt of the Non-Harassment Policy

I hereby acknowledge and confirm that on the date stated below that I have been provided with a copyof the Almost Perfect/The Grocery Outlet’s Non-Harassment Policy and that I have reasonableopportunity to review the policy and ask questions regarding the policy and the complaint procedure.

Name (signature): ______________________________________________________

Date: ___________________________________________

To be filed in employee file upon signing form.

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Roles and Responsibilities of the Employer Almost Perfect Inc./The Grocery Outlet will make every effort to see that our actions, and those of ouragents and supervisory employees, are free from harassment of employees. Almost Perfect Inc./TheGrocery Outlet will also take appropriate corrective action in those instances where it, its agents orsupervisory employees, know or should have known of harassment of any employee. For AlmostPerfect Inc. to fulfill its obligations, all levels of Almost Perfect/The Grocery Outlet’s management andsupervisory employees will:

a) Assured employees that all forms of harassment are expressly prohibited, that management willconduct a prompt and thorough investigation in a manner as discreetly and confidentially as possible.

b) Reject any offer or promise of sexual or other favours by any employee

c) Avoid harassment, including the appearance of such harassment, by refraining from actions,language and jokes and by disposing of materials, such as posters or magazines, which may offend anemployee

d) Employers and supervisors may be held liable under Ontario’s human rights system if harassmentoccurs in the workplace or at work related functions. They may be also be liable for failing to takeproper steps to address and prevent the harassment

e) Procedures for informing or advising workers of any incident that occurs

f) Forms for reporting incidents involving harassment

g) Explanation of what will be done during the investigation and following the investigation

h) Follow up and conclusion to the incident reported in a timely fashion

Roles and Responsibilities of the Employee The roles and responsibilities of the employee include the following with workplace harassment:

a) Any employee who feels harassed or knows of or suspects the occurrence of harassment isresponsible for informing their Team Leader. If the the Team Leader is the alleged harasser then theemployee will contact the District Manager. If the District Manager is the alleged harasser, theemployee can contact anyone at the Head Office in Whitby.

b) Employees will avoid harassment, including the appearance of such harassment, by refraining fromactions, language and jokes, and by disposing of materials, such as posters or magazines, which mayoffend another employee

c) Will not retaliate against individuals who report incidents of harassment or who participates in aninvestigation of alleged harassment. Employees will report any incidents of retaliation to their TeamLeader. If the the Team Leader is the alleged harasser then the employee will contact the DistrictManager. If the District Manager is the alleged harasser, the employee can contact anyone at the HeadOffice in Whitby.

d) Fill out the proper forms immediately and report the incident to their Team Leader. If the the TeamLeader is the alleged harasser then the employee will contact the District Manager. If the DistrictManager is the alleged harasser, the employee can contact anyone at the Head Office in Whitby.

e) Employees who are witnesses will make themselves available to participate in the investigation andbe required to fill in necessary paper work

f) Keep all information discussed confidential

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Disciplinary Procedure In the event a thorough investigation of a report or suspected occurrence of harassment reveals that anemployee has engaged in a form of harassment, Head Office, based upon the circumstances and itsoverall assessment of the seriousness of the violation, will take appropriate actions. This includes, butnot limited to:

a) Warning the employee that any additional or further acts of harassment will result in furtherdisciplinary action, including suspension or termination of employment

b) Where there is an extremely serious violation of this policy will result in immediate termination ofthe employee. Examples of extremely serious violations include:

a) Using the power of authority of a position to explicitly condition an employment decisionupon the response of an employee for employment to a request for sexual or other favours

b) Abusive physical actions to obtain sexual or other favours

c) Using extreme offensive language and actions towards employees

What do I do if an act of harassment has been committed to myself or other employee? If an act of harassment has been committed and it involves yourself or another employee it is yourresponsibility to report it to your team leader immediately. This is to ensure all paper work and reportscan be started immediately while the incident is still fresh in your mind. When you report the incidentto your Team Leader you will be required to fill out the workplace harassment incident report whichwill then be sent to head office for review and follow up. If the incident is of serious nature then theTeam Leader will be required to call Head Office immediately. Incidents of serious nature include anyinjury caused to an employee where medical attention is required, any incident that involves theauthorities to be contacted immediately, any incident that puts the complainant and other employees indanger. Please note that any information completed on the form is 100% confidential and will not bediscussed with other employees. The information on the report will be seen by Head Office ONLY. Ifyou are a witness to an incident it is very important that you do not expose any information to otherstaff that has been discussed in any meetings between yourself, team leader and victim.

How is the investigation done? When a complaint is brought to the Team Leader's attention regarding an incident(s) of harassmentand/or violence the complaint must be taken seriously and dealt with immediately. If the Team Leaderis unable to resolve the issue within the location through an investigation the Team Leader will contactthe District Manager for assistance. If the complaint is toward the Team Leader or District Manager,the complainant will contact Head Office first and someone at Head Office will begin the investigationprocess immediately.

The person doing the investigation must be neutral and a competent person. The person doing theinvestigation will first review the harassment report that was filled out. Following that, they willinterview any complainant, witnesses and alleged harasser with a list of questions and have the witnesssign a form stating all information is true. Detailed notes and all questions will be written and will beattached to the final report of conclusions. If the incident is of a serious nature where the police orMinistry of Labour had to be contacted a more formal investigation done by them will have to takeplace.

The following are all the examples of forms that will be used when a harassment incident occurs.

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Incident Report Almost Perfect/The Grocery Outlet’s Non-Harassment/ViolencePolicy

To be completed by all persons making complaints under the Non-Harassment Policy and retuned tothe designated company representative.

This form is designed to assist individuals making a complaint under the Non-Harassment Policy. Theindividual making the complaints should complete the form, return it to the designated companyrepresentative. Almost Perfect/The Grocery Outlet is committed to promptly and responsiblyinvestigate all claims of sexual harassment and all other forms of improper harassment under the Non-Harassment Policy. Your cooperation in truthfully completing this form and providing as much accurateinformation as possible will enable the company to investigate and respond to these matters morequickly and efficiently.

Your Name: _____________________________________ Date: ______________________

Your Position: ___________________________________ Location: ____________________

Describe what happened (provide dates, times, names and places). Please provide as much detail aspossible.____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

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Complainant Witness Acknowledgment Form I hereby acknowledge and confirm that on the date below I was interviewed in connection with theinvestigation of possible violations of Almost Perfect/The Grocery Outlet’s Non-Harassment/ViolencePolicy as a result of a complaint by _________________________________ (complainant’s name)

I further certify that all information provided below during the interview was true and correct to thebest of my knowledge.

Describe what occurred (provide dates, times, names and places). Please provide as much detail aspossible. (This is to be filled out by the investigator)

__________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

I understand that it is a violation of the Non-Harassment Policy to retaliate against individuals who filecomplaints, or who are otherwise involved in the investigation. I will inform management if I sufferany retaliation, or become aware of retaliatory acts in connection with this investigation.

Name (signature): ________________________________________________

Date: ___________________________________

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Employee Witness Acknowledgment Form

I hereby acknowledge and confirm that on the date below I was interviewed in connection with theinvestigation of possible violations of Almost Perfect/The Grocery Outlet’s Non-Harassment/ViolencePolicy as a result of a complaint by _________________________________ (complainant’s name)

I further certify that all information provided below during the interview was true and correct to thebest of my knowledge.

Describe what occurred (provide dates, times, names and places). Please provide as much detail aspossible. (This is to be filled out by the investigator)

__________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

I understand that it is a violation of the Non-Harassment Policy to retaliate against individuals who filecomplaints, or who are otherwise involved in the investigation. I will inform management if I sufferany retaliation, or become aware of retaliatory acts in connection with this investigation.

Name (signature): ________________________________________________

Date: ___________________________________

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Management Witness Acknowledgment Form

I hereby acknowledge and confirm that on the date below I was interviewed in connection with theinvestigation of possible violations of Almost Perfect/The Grocery Outlet’s Non-Harassment/ViolencePolicy as a result of a complaint by _________________________________ (complainant’s name)

I further certify that all information provided below during the interview was true and correct to thebest of my knowledge.

Describe what occurred (provide dates, times, names and places). Please provide as much detail aspossible. (This is to be filled out by the investigator)

__________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

I understand that it is a violation of the Non-Harassment Policy to retaliate against individuals who filecomplaints, or who are otherwise involved in the investigation. I will inform management if I sufferany retaliation, or become aware of retaliatory acts in connection with this investigation.

Name (signature): ________________________________________________

Date: ___________________________________

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Investigation Report In response to Incident under the Almost Perfect’s Non-Harassment/Violence Policy

Report prepared by:_____________________________ Date: _________________________

Complainant: ________________________________________

Alleged Harassment:____________________________________________________________________________________________________________________________________________________________

Date of Complaint: ____________________ Date Investigation Initiated ________________

The complaint investigated (Attach incident form)

Summary of the investigation conducted (List persons interviewed, and summarize the results) Attachall witness statements.____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Conclusions of the investigation (state conclusion and explain how and why factual discrepancies wereresolved).____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

I hereby certify, subject to the penalties of perjury, that the information provided in this investigationreport accurately and fairly summarizes the investigation I conducted.

Signature: ________________________________________ Date: _____________________

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Before you begin the investigationIf a Team Member has made a complaint and brought it to the attention of their Team Leader, the TeamLeader will immediately start rectifying the situation by first having the complainant fill out the properpaper work and any additional paper work that could help their case. They could have witnesses andthe Team Leader should interview other Team Leaders as well. It is very important that the TeamLeader let the Head Office know of all complaints made and the status of the investigation until theinvestigation is complete. You must let Head Office know immediately of the situation.

What happens after the investigation is complete? After the complainant, witnesses and alleged harasser have been interviewed the person who completedthe investigation along with someone from Head Office will have a meeting with the complainant.They will discuss what their final report and they will provide a copy in writing to both the complainantand the accused. It will say how they came to that decision and what the final outcome of the incidentwill be. Whether it involves placing changes, terminating an employee or giving them a verbal warningwill be discussed in the meeting. If at the time of the meeting the complainant does not approve of thefinal outcome of the investigation they must bring it to the attention of the investigator at the time ofthe meeting. If at that time the attempt to resolve the case has failed, a competent person must becontacted to investigate the case further. If for whatever reason at the time the investigation iscomplete and either the complainant or accused is no longer employed at Almost Perfect/The Groceryoutlet and copy of the investigation in writing will be mailed to the address that was provided underyour welcome package when you started your employment.

What is meant by a “competent person” to investigate the matter? A competent person is someone who is:

a) Impartial and is seen by the parties to be impartial

b) Has knowledge, training and experience in issues relating to work place harassment

c) Has knowledge of relevant legislation

The relevant legislation about which the “competent person” must have knowledge includes Part II ofthe Canada Labour Code and the Canada Occupational Health and Safety Regulations. The purpose ofwhich is to protect the health and safety of workers. The term “relevant legislation” is not intended togo beyond the scheme of the code.

Page 12: What is Workplace Harassment? - The Grocery Outlet€¦ · In some cases, a targeted person may react violently to prolonged harassment in the ... Employees will avoid harassment,

Part 2-Workplace Violence What is work place violence? By “work place violence” it means any action, conduct, threat or gesture of a person towards anemployee in their workplace that can reasonably be expected to cause harm, injury or illness to thatemployee. The word “person” includes both individuals who work in the work place as well as otherswho may enter the work place, such as suppliers and truck drivers. Work place violence also includesthe following:

* The exercise of physical force by a person against a worker, in a workplace that causes or could causephysical injury to the worker

* An attempt to exercise physical force against a worker, in a workplace that could cause physicalinjury to the worker

* A statement or behaviour that it is reasonable for a worker to interpret as a threat to exercise physicalforce against a worker, in a workplace, that could cause physical injury to the worker

Does work place violence include physiological violence? Yes, it does include factors include bullying, teasing, and other aggressive behaviour, which arecomponents of physchological violence.

Almost Perfect/The Grocery Outlet offers a zero tolerance policy towards workplace violence againstor by any employee.

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Workplace Non-Violence Policy

The management of Almost Perfect Inc./The Grocery Outlet is committed to the prevention ofworkplace violence and is ultimately responsible for worker health and safety. We will take whateversteps are reasonable to protect our workers from workplace violence from all sources.

Violent behaviour in the workplace is unacceptable from anyone. This policy applies to head officestaff, team leaders, assistant team leaders, store employees, warehouse employees, maintenanceemployees, drivers, suppliers, and any visitors on Almost Perfect/The Grocery Outlet property.Everyone is expected to uphold this policy to work together to prevent workplace violence.

There is a workplace violence program that implements this policy. It includes measures andprocedures to protect workers from workplace violence, a means of summoning immediate assistanceand a process for workers to report incidents, or raise concerns.

Almost Perfect/The Grocery Outlet, as the employer, will ensure that this policy and the supportingprogram are implemented and maintained and that all workers and management have the appropriateinformation and instruction to protect them from violence in the workplace.

Management will adhere to this policy and the supporting program. Management is responsible forensuring that measures and procedures are followed by workers and that workers have the informationthat they need to protect themselves.

Every worker must work in compliance with this policy and the supporting program. All workers areencouraged to raise any concerns about workplace violence and to report any violent incidents orthreats.

Management pledges to investigate and deal with all incidents and complaints of workplace violence ina timely and fair manner, respecting the privacy of all concerned to the extent possible.

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Acknowledgment of Non-Violence PolicyTo be signed by all persons upon receipt of the non-violence policy

I hereby acknowledge and confirm that on the date stated below that I have been provided with a copyof the Almost Perfect/The Grocery Outlet’s Non-Violence Policy and that I have reasonableopportunity to review the policy and ask questions regarding the policy and the complaint procedure.

Name (signature): ______________________________________________________

Date: ___________________________________________

To be filed in employee file upon signing form.

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Roles and Responsibilities of the Employer

The roles and responsibilities of the employer include the following for work place violence:

a) Have safe work procedures (examples include: stripping the tills, leaving the store together as agroup after the store is closed)

b) Designated safe locations for emergency situations

c) Procedures for informing or advising workers of any incident that occurs

d) Forms for reporting incidents or threats

e) How and when investigations will be conducted

f) Follow up to all investigation which will include a written document and meeting with

the victim and witnesses (if required)

Roles and Responsibilities of the Employee The roles and responsibilities of the employee include the following for work place violence:

a) Report any incident immediately to your team leader

b) Fill out the work place violence form with your team leader following an incident

c) Be available to answer any questions regarding the incident

d) Be involved in the investigation (if required)

e) Keep all information discussed in report confidential

Disciplinary Procedure In the event a thorough investigation of a report or suspected occurrence of violence reveals that anemployee has engaged in a form of a violent act, Head Office, based upon the circumstances and itsoverall assessment of the seriousness of the violation, will take appropriate actions. This includes, butnot limited to:

a) Warning the employee that any additional or further acts of violence will result in furtherdisciplinary action, including suspension or termination of employment

b) Where there is an extremely serious violation of this policy will result in immediate termination ofthe employee. Examples of extremely serious violations include:

a) Physically causing harm to another employee where medical attention is required and whereauthorities need to be contacted.

b) Verbal threats towards another employee insinuating causing serious physical harm to themor others around them.

What do I do if an act of violence has been committed to myself or other employee? If an act of violence has been committed to yourself or another employee it is your responsibility toreport it to your Team Leader immediately. If the the Team Leader is the person committing theoffence then the employee will contact the District Manager. If the District Manager is the personcommitting the offence, the employee can contact anyone at the Head Office in Whitby. This is toensure all paper work and reports can be started immediately while the incident is still fresh in yourmind. When you report the incident to your team leader you will be required to fill out the workplaceviolence incident report which will then be sent to Head Office for review and follow up. If the incidentis of serious nature then the team leader will be required to call Head Office immediately. Incidents of

Page 16: What is Workplace Harassment? - The Grocery Outlet€¦ · In some cases, a targeted person may react violently to prolonged harassment in the ... Employees will avoid harassment,

serious nature include any injury caused to an employee where medical attention is required, anyincident that involves the authorities to be contacted immediately, any incidents that puts thecomplainant and other employees in danger. Please note that any information completed on the form is100% confidential and will not be discussed with other employees. The information on the report willbe seen by Head Office ONLY. If you are a witness to an incident it is very important that you do notexpose any information to other staff that has been discussed in any meetings between yourself, teamleader and victim.

Before you begin the investigationIf a Team Member has made a complaint and brought it to the attention of their Team Leader, the TeamLeader will immediately start rectifying the situation by first having the complainant fill out the properpaper work and any additional paper work that could help their case. They could have witness and theTeam Leader should interview other Team Leaders as well. It is very important that the Team Leaderlet the Head Office know of all complaints made and the status of the investigation until theinvestigation is complete. You must let Head Office know immediately of the situation.

How is the investigation done? The person doing the investigation must be neutral and a competent person. The person doing theinvestigation will first review the workplace violence report that was filled out. Following that, theywill interview any complainant, witnesses and alleged violent offender with a list of questions and havethe witness sign a form stating all information is true. Detailed notes and all questions will be writtenand will be attached to the final report of conclusions. If the incident is of a serious nature where thepolice or Ministry of Labour had to be contacted a more formal investigation done by them will have totake place.

The following are all the examples of forms that will be used when a harassment incident occurs.

*All forms/reports are the same as the Harassment forms* The only difference is WorkplaceHarassment is replaced by Workplace Violence*

What happens after the investigation is complete? After the complainant, witnesses and alleged harasser have been interviewed the person who completedthe investigation along with someone from Head Office will have a meeting with the complainant.They will discuss what their final report and they will provide a copy in writing to both the complainantand the accused. It will say how they came to that decision and what the final outcome of the incidentwill be. Whether it involves placing changes, terminating an employee or giving them a verbal warningwill be discussed in the meeting. If at the time of the meeting the complainant does not approve of thefinal outcome of the investigation they must bring it to the attention of the investigator at the time ofthe meeting. If at that time the attempt to resolve the case has failed, a competent person must becontacted to investigate the case further. If for whatever reason at the time the investigation iscomplete and either the complainant or accused is no longer employed at Almost Perfect/The GroceryOutlet a copy of the investigation in writing will be mailed to the address that was provided under yourwelcome package when you started your employment.

What is meant by a “competent person” to investigate the matter? A competent person is someone who is:

a) Impartial and is seen by the parties to be impartial

b) Has knowledge, training and experience in issues relating to work place harassment

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c) Has knowledge of relevant legislation

The relevant legislation about which the “competent person” must have knowledge includes Part II ofthe Canada Labour Code and the Canada Occupational Health and Safety Regulations. The purpose ofwhich is to protect the health and safety of workers. The term “relevant legislation” is not intended togo beyond the scheme of the code.

Violence Risk Assessments (done at each location)Workplace assessments specific to workplace violence is completed at all locations and reviewed on ayearly basis. The risk assessment lays out all possible risk factors and how the risk is controlled.

Potential Risk Factors that are specific to all locations include:

• Dealing with cash at the till, closing the till at the end of the night and bringing the depositto the bank. All stores are equipped with cameras and an alarm system. All locations havebeen instructed never to leave a large amount of money in their tills. They are to ask theirTeam Leader or LOD to strip their till on a continuing basis especially when the stores arebusier. This is for their protection.

• When Team Members leave the store at the end of the night we never have anyone leavingalone. We have a 2 person policy when closing.

• When Team Members leave the store and take the deposit to the bank they are instructed toonly drop the deposit if they feel safe. If there are people around, they should wait untilthey feel comfortable depositing the money in the bank slot/machine.

• Dealing with the public. If at anytime a customer begins to cause a scene in the store andthe Team Members feel threatened at all they are to ask the customer to leave the store andare instructed to call 911 if they feel like they are in danger. If we have retuning customersthat come into the store and cause a scene we will ask them not to come back and servethem with a non trespassing form. We also have security cameras that record throughout theday where we are able to retrieve footage if necessary.

• Interacting with other team members and/or delivery truck drivers. If any team member isfaced with violence in the workplace involving another team member or anyone that iscontracted through the company (truck drivers/maintenance staff/pest control company etc)they are to report any incidents immediately to their Team Leader. If the incident involvestheir Team Leader they are to contact their District Manager. If the District Manager isinvolved then they are to contact someone at Head Office. Once a complaint has been filed,an investigation begins immediately. If the incident is of a serious nature, authorities will becontacted immediately.

Emergency Contact NumbersAll locations have posted on their memo board a list of all numbers that can be called in the event ofany emergency. All Team Members need to know where this information is posted,