NON-DISCRIMINATION, HARASSMENT AND RETALIATION POLICY

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Purpose of the Policy: TORONTO CARES INITIATIVE is committed to providing a workplace that is safe, respectful and in compliance with the Canadian Human Rights Act (or provincial counterpart) that promotes equality and is free from all forms of discrimination, psychological and/or sexual harassment and reprisals. As part of this commitment, TORONTO CARES INITIATIVE (the "employer") has implemented this Non-discrimination, Harassment and Retaliation Policy (the "Policy").

Scope of the Policy: This Policy applies to all employees, including senior executives, officers and directors, advisory council and committee members, as well as temporary staff, volunteers or interns (all those listed here will be collectively referred to as "Employees").

Employees are prohibited from committing any acts of harassment, discrimination or retaliation against other employees, independent contractors, vendors, suppliers or any other person doing business with TORONTO CARES INITIATIVE. Any employee who violates the Policy will be subject to immediate and severe disciplinary action, up to and including termination of employment.

TORONTO CARES INITIATIVE also prohibits third parties that do business with the Company from committing any acts of harassment, discrimination or retaliation against its employees. Employees with concerns that they may have experienced discrimination, harassment or retaliation from a third party doing business with TORONTO CARES INITIATIVE, such as independent contractors, vendors, suppliers or others, should contact their immediate supervisor as soon as possible. Any complaint made in this regard will be dealt with promptly and confidentially.

The Policy prohibits conduct that may constitute discrimination, harassment or retaliation, including, but not limited to: race, national or ethnic origin, colour, religion, age, sex, sexual orientation, gender identity or expression, marital status, family status, disability, genetic characteristics and a conviction for which a pardon had been granted or a record suspended. There is no hierarchy among the above-mentioned grounds for discrimination and harassment. In other words, none of them is more important or more significant than the others.

TORONTO CARES INITIATIVE does not tolerate any acts of discrimination, harassment or retaliation by or towards any person. Harassment, discrimination or retaliation of any kind shall be considered a form of misconduct by an employee and sanctions will be imposed on those who engage in such acts as well as on management who knowingly permit such conduct to continue.

Definition:

• Psychological/emotional harassment: Psychological/emotional harassment includes any vexatious behaviour in the form of repeated and hostile or unwanted conduct, words, actions or gestures that affect an employee's dignity or psychological or physical integrity and that results in a harmful work environment for the employee. A single serious act of conduct may also constitute psychological harassment if it causes such harm and has a continuing harmful effect on the employee.
• Sexual harassment: Sexual harassment includes any form of unwanted attention or unwanted advances with sexual connotations, such as: insistent solicitation, glances, kisses or touching, sexist insults, rude comments. Sexual harassment also includes any comments, jokes or images with sexual connotations transmitted by any technological or other means.
• Discrimination: Discrimination is the act of treating a person differently because of their personal characteristics and preventing them from exercising their rights.
• Retaliation: Retaliation is prohibited by the Canadian Human Rights Act (or provincial counterpart). It is a discriminatory practice for a person against whom a complaint has been filed under Part III, or any person acting on their behalf, to retaliate or threaten retaliation against the individual who filed the complaint or the alleged victim. TORONTO CARES INITIATIVE prohibits retaliation against any employee who has reported a breach of the Policy, any employee who has participated in an investigation of a reported breach of the Policy, or the family member of such employee. Retaliation is prohibited in the following cases (as examples only):
• a) When a complaint has been filed with the company; When a complaint has been filed with the company;
• b) When a complaint has been filed with a competent authority or government agency;
• c) When a person has given testimony;
• d) When a person has cooperated or participated in an investigation.

Complaint and Reports Process: Employees who suspect that they have experienced harassment or discrimination are encouraged to document the behaviour and must immediately report the incident to their supervisor, or if the complaint involves their supervisor, to a higher manager. People acting on behalf of the employer who have received a report of such behaviour are advised to document it thoroughly. The complaint or report may be made verbally or in writing.

All employees may also report any incident within the company to the following person:
Sarah Robinson (Founder and Executive Director)
helping.toronto.2020@gmail.com
647-451-3663
OR
Toronto Cares Initiative (Board of Directors and Advisory Council)
toronto.cares.initiative.board@gmail.com

Employees may also file a complaint with the Canadian Human Rights Commission (or provincial counterpart).

Intervention and investigation procedures:
TORONTO CARES INITIATIVE will promptly and thoroughly investigate all complaints reported under this Policy.

The investigation will be completed in a timely manner. Investigation may involve interviews, review of physical evidence, and involvement of qualified personnel such as human resources or legal counsel. The investigation will remain confidential and will only be disclosed if the need arises. TORONTO CARES INITIATIVE will also keep a record of the investigation, including documentation of all interviews and evidence so that the complainant can monitor its progress.

Upon completion of the investigation, TORONTO CARES INITIATIVE will take any action deemed appropriate based on the evidence gathered, including termination of the offending employee or reporting to law enforcement authorities.

If TORONTO CARES INITIATIVE finds that the behaviour does not correspond to the definition of discrimination, harassment or retaliation, but the behaviour is not controlled, TORONTO CARES INITIATIVE will take appropriate action to remedy the situation.

If an employee reporting a complaint under the Policy feels that the response of TORONTO CARES INITIATIVE is not adequate, he/she may appeal to the competent authorities if he/she deems it necessary, in his/her sole and exclusive discretion.

Expectations: TORONTO CARES INITIATIVE expects staff to contribute to a workplace free from discrimination, harassment and retaliation, to respect individuals in the course of their work, to participate in the mechanisms established by the employer to prevent and stop discrimination, harassment and retaliation, and to report any situation relating to discrimination, harassment or retaliation as soon as possible to one of the responsible persons designated by TORONTO CARES INITIATIVE.

Additional Information: Managers or Team Leaders are responsible for educating employees on their individual responsibility to maintain a workplace free of discrimination, harassment and retaliation. With the cooperation of the staff of every work unit, managers or team leaders are also responsible for identifying risk factors, to decide or recommend actions to be taken to prevent risk situations, to follow up, to intervene informally or formally to resolve risk situations and finally to decide on or recommend actions to be taken as a result of an intervention, including disciplinary measures.

Communication: It is essential that all employees communicate with TORONTO CARES INITIATIVE regarding any incidents involving discrimination, harassment or retaliation. TORONTO CARES INITIATIVE is only able to assist employees when the issue is brought to its attention. It is the employee's responsibility to raise such concerns as soon as possible.

Legislation: The Canada Labour Standards Regulation, Canadian Human Rights Act and any provincial Human Rights Codes and Labour Standards Acts apply to any situation that constitutes discrimination, harassment or retaliation in the workplace.

Local Protections: Employees may also contact the county, city or town in which they live to find out if additional laws against discrimination, harassment or retaliation may be applicable.

If the employee has been the victim of unwanted physical contact, forced physical confinement or forced sexual acts, this conduct may constitute a crime. It is strongly recommended that police authorities be contacted.

Limitation: Nothing in the Policy is intended to replace or limit the rights that employees may have to seek remedies under applicable laws.