1.01 The Canadian College of Naturopathic Medicine is committed to providing a safe and healthy working and learning environment for its employees, students, and visitors.

1.02 Acts of violence, harassment, or sexual harassment against or by any employee or student will not be condoned or tolerated by CCNM. It is important to remember that the perception of the receiver is critical in determining whether the potentially offensive message is acceptable or not, be it spoken, gestural, pictorial, or some other form of communication which may be deemed objectionable or unwelcome.

1.03 Weapons of any nature are strictly prohibited from the College’s premises and violators will be subject to disciplinary action, and the incident will be reported to the police.

2. Scope

2.01 This policy applies to all workers and students in the CCNM community.

3. Definitions

3.01 “Workplace violence” is an exercise of physical force by a person against a worker, in a workplace, that causes or could cause physical injury to the worker; an attempt to exercise physical force against a worker, in a workplace, that could cause physical injury to the worker; or a statement or behaviour that is reasonable for a worker to interpret as a threat to exercise physical force against the worker, in a workplace, that could cause physical injury to the worker.

3.02 “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.

3.03 “Workplace sexual harassment” means 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 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.

3.04 “Bullying” is a repeated pattern of behaviour intended to intimidate, offend, degrade, or humiliate a particular group or person. It is also the assertion of power through aggression, targeting the competence level of the person being bullied. Although it can include physical abuse or the threat of abuse, bullying usually causes psychological rather than physical harm. Bullying can occur in person or by using an electronic or online medium, such as social media websites, online chat rooms, e-mail, or text messages. This is referred to as online bullying or online harassment.

3.05 “Respondent” is a person whom another individual has accused of committing an act of violence or harassment.

3.06 “Complainant” is a person who has made a complaint about another individual who they believe committed an act of violence or harassment towards them.

4. Responsibilty

4.01 Each member of the CCNM community is responsible for providing a safe and healthy work environment, free from violence, threats of violence, discrimination, harassment, sexual harassment, intimidation, and such other forms of misconduct.

4.02 Managers are responsible for preventing and discouraging violence, harassment, and sexual harassment, and for intervening immediately when/if they observe these behaviours.

4.03 Human Resources is responsible for providing violence, harassment, and sexual harassment training to all employees, as well as communicating the College’s violence and harassment prevention practices and procedures.

4.04 The Joint Health & Safety Committee will assist in developing and maintaining a program to prevent, investigate, and correct all acts of violence, harassment, and sexual harassment in the College.

4.05 The Executive Committee will review and approve this policy and program annually.

5. Workplace Violence and Harassment Program

5.01 Immediate Assistance Procedures
If a violent or threatening situation is imminent or occurring, an immediate call to emergency services using “9-1-1” should be placed.

5.02 Reporting Incidents of Workplace Violence and Harassment.
Complaints of violence or harassment should be immediately reported to Human Resources, Legal Counsel, a Supervisor, or Security.

The complaint must include the following information:

• The date and time of the incident
• The name of any persons involved in the incident or who witnessed
  the incident; and
• The date and time of the incident

5.03 An employee or student who believes they have been subject to harassment may also choose to confront the harasser without filing a formal complaint. They can confront the harasser directly or through writing, detailing the unwelcome behaviour and requesting it to stop.

5.04 Investigation Procedures
Once a complaint has been received, CCNM will complete a thorough investigation. The College will ensure that, where practicable, the investigation is completed within 90 days of the complaint being filed.

5.05 The investigation will include:

• Interviewing the complainant, any persons involved in the incident,
  and any witnesses;
• Informing and interviewing the respondent of the complaint; and
• Obtaining statements from all parties involved.

5.06 All of the above information will be documented and used to determine whether an incident of violence or harassment occurred. If necessary, CCNM may employ outside assistance or request the use of legal counsel.

5.07 CCNM will take all measures to prevent any disclosure of the incident and the identities of the parties involved, unless the disclosure is necessary for the investigation, for taking corrective action or required by law.

5.08 Results of Investigation
Upon completion of an investigation, CCNM will provide both the complainant and respondent a written summary of the findings of the investigation and any corrective action that has been or will be taken as a result of the investigation. This written notification will be provided within 30 days of the investigation being completed, and will not include the investigation report unless required by law.

5.10 Disciplinary Measures
Any disciplinary action will be determined by Human Resources and will be proportional to the seriousness of the behaviour or action involved in the incident and may involve counselling, a formal warning, or dismissal / expulsion.

5.11 Domestic Violence
If CCNM becomes aware that domestic violence is likely to expose an employee or student to physical injury in the College, CCNM will take every precaution reasonable in the circumstances for the protection of the employee or student.

5.12 Recommendations to Victims
CCNM will provide appropriate assistance to any employee or student who is a victim of violence or harassment through the Employee and Family Assistance Program or StudentCare. CCNM also recommends that an employee or student who has been harmed as a result of an incident of violence at the College consult their health care provider for treatment or referral for post-incident counselling, if appropriate.

6. Violence Risk Assessment

6.01 CCNM will conduct an annual risk assessment of the work environment to identify potential risks that could affect the health and safety of employees and students, and will institute measures to eliminate or control any identified risks.

6.02 The following factors will be considered during the assessment:

6.03 The risk assessment may include reviews of records, security reports, employee incident reports, staff perception surveys, health and safety inspection reports, first aid records, or other related records.

6.04 Areas that will be considered and may contribute to risk of violence include but are not limited to contact with the public, places with an exchange of money, receiving doors, and working alone or at night.

6.05 CCNM will provide the Joint Health & Safety Committee with a written copy of the assessment and advise of the results.

6.06 CCNM will disclose information to employees or students who are likely to encounter a known person with a history of violence in the performance of their job duties or studies, or if there is a potential risk of violence as a result of interactions with the person. However, CCNM will only disclose personal information that is deemed reasonably necessary to protect the employee from physical harm.

7. The Right to Refuse Unsafe Work

7.01 Employees have the right to refuse work if they have a reason to believe that workplace violence is likely to endanger them.

7.02 Upon refusing to work, the employee must report the circumstance of the refusal to their manager.

7.03 An investigation will follow in the presence of Human Resources and a member of the Joint Health and Safety Com0mittee.

8. Protection from Reprisals

8.01 This policy prohibits reprisals against individuals acting in good faith who report incidents of workplace violence or harassment or act as witnesses. Management will take all reasonable and practical measures to prevent reprisals, threats of reprisal, or further violence. Reprisal is defined as any act of retaliation, either direct or indirect.

8.02 Reasonable day-to-day actions by a manager or member of faculty that help manage, guide, teach, or direct employees or students does not constitute harassment.

9. Fraudulent or Malicious Complaints

9.01 It is a violation of this policy for anyone to knowingly make a false complaint, or to provide false information about a complaint. Unfounded or frivolous allegations may cause both the respondent and CCNM significant damage.

9.02 Any employee or student who knowingly makes a false allegation related to violence or harassment will be subject to immediate disciplinary action, up to and including termination of employment or expulsion from the College.

10. Recordkeeping

10.01 CCNM will ensure that appropriate records of complaints and investigations relating to incidents of violence and workplace harassment are kept in a secure location within the HR department, including:

11. Confidentiality

11.01 CCNM will not disclose the name of a complainant or a respondent or the circumstances related to the complaint to any person except where disclosure is necessary to investigate the complaint or take corrective action with respect to the complaint, or required by law.

11.02 CCNM will only disclose the minimum amount of personal information or details necessary for these purposes.

11.03 All records of harassment, and subsequent investigations, are considered confidential.

11.04 CCNM will do everything reasonably possible to protect the privacy of any individuals involved and to ensure that complainants and respondents are treated fairly and respectfully.

12. Policy Review

12.01 In accordance with the Occupational Health and Safety Act, this policy will be posted in a conspicuous place in the workplace and reviewed annually.