GSL Group and any of its subsidiaries (collectively referred to as the “Company”) is committed to providing an environment free of discrimination, harassment, bullying, and violence in which all individuals are treated with respect and dignity and where the person’s health, safety and physical and psychological integrity are respected and protected.   

The Company respects all fundamental human rights and freedoms and complies with the governing laws and provisions. Nothing in this Policy affects the right of an employee to exercise their rights under applicable human rights or employment legislation. 

Any acts of harassment, bullying, discrimination, or violence will not be tolerated, condoned, or ignored. The Company will investigate incidents and complaints in an appropriate, fair, and timely manner.  If a claim of prohibited behavior is proven, disciplinary/ corrective measures will be applied against the offending employee(s), up to and including dismissal. Given the serious nature of this matter, abuse of the policy by falsely accusing other employees of discrimination, harassment, bullying, and violence, is also a serious offense and will be subject to disciplinary action up to and including termination. 



The right to freedom from discrimination and harassment extends to all employees, including full-time, part-time, casual, temporary, seasonal, and contract staff, as well as volunteers, co-op students, interns, and apprentices in relationships with each other. 

In addition, this policy applies to our staff members or independent contractors working on our behalf with external stakeholders such as clients, customers, suppliers, and service and goods providers. 

This policy applies to every level of our organization and to every aspect of the workplace environment, employment relationships, and external stakeholder interactions. Furthermore, this policy applies to events outside the physical workplace, such as business trips, off-site meetings, conferences, training, events, concerts, games, and company parties. Workplace repercussions extend to online interactions, encompassing interactions that occur over the internet, mobile devices, or social media platforms.  



Workplace Violence is defined as the exercise of physical force by a person against a worker that causes or could cause physical injury to the worker; an attempt to exercise physical force against a worker; or a statement or behavior that is reasonable for a worker to interpret as a threat to exercise physical force against the worker. 

Discrimination means any form of unequal treatment based on a protected ground, whether imposing extra burdens or denying benefits. It may be intentional or unintentional. It may involve direct actions that are discriminatory on their face, or it may involve rules, practices, or procedures that appear neutral but have the effect of disadvantaging certain groups of people.  

The list of characteristics or identities includes age, religion, sex, sexual orientation, gender identity, gender expression, family status, marital status, disability, race, ancestry, place of origin, ethnic origin, citizenship, color, language, political convictions, record of offenses for which a pardon has been received, and any other ground identified under provincial human rights legislation. 

Bullying and Harassment mean any single incident or repeated incidents of objectionable or unwelcome conduct, comment, bullying, or action by a person that the person knows or ought reasonably to know will or would cause offense, humiliation, or intimidation to another person, or adversely affects the person’s health and safety, and includes inappropriate conduct or comments relating to a person that is a protected ground under the Human Rights Code. It also includes unwelcome sexual solicitation or advances. Lack of intent does not mean the conduct is not bullying and harassment if the bully ought to have known the behavior would cause the victim to be humiliated or intimidated.  

Without limiting the generality of the foregoing, the following are examples of harassment:  

  • Verbal - intimidation, insulting or disagreeable comments, derogatory jokes or hints, or inappropriate remarks about a person’s physical appearance or clothing. Verbal harassment also includes unwanted comments of a sexual nature. 
  • Visual - obscene gestures or degrading or offensive images, displays, caricatures, graffiti, or pictures shown to a person or a group of persons or displayed in the workplace. This includes displaying materials that are sexually explicit, degrading, racist, ethnic, or religious in any degrading or derogatory manner. 
  • Physical - unwanted physical contact or touching or gestures of a sexual nature that are unwanted or an impediment to one’s work.  

Sexual Harassment means engaging in the 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, demonstrated content, or conduct is known or ought reasonably to be known to be unwelcome; and/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, and/or making implicit or expressed promises in the form of rewards for accepting sexual advances or threats of reprisal in case the advances are rejected. 



Examples of the type of behavior prohibited by this policy include but are not limited to: 

  • Exhibiting any form of sexual harassment, including touching, petting, pinching, kissing, unwelcome sexual flirtations, advances, requests, or invitations, leering or other suggestive gestures; 
  • Displaying  offensive pictures, graffiti, videos, or any material including sexual content, whether in print form or via e-mail or other electronic means, that ought to be unwelcome; 
  • Bullying; 
  • Isolating, shunning or excluding;  
  • Assaulting verbally or physically, threatening; 
  • Throwing an object, hitting, or attempting to hit an employee; 
  • Mimicking or mocking an employee who has a disability; 
  • Expressing offensive nicknames, remarks, jokes, innuendoes, or taunting about a person's body, age, marital status, gender, ethnic/racial origin, religion, accent, disabilities, or other protected grounds; 
  • Stating demeaning, intimidating, and belittling comments; 
  • Ridiculing an individual because of characteristics that are related to a protected ground;  
  • Creating a poisoned work environment through comments or conduct. The comments or conduct may not be directed at a specific individual and may be from any individual, regardless of position or status. A single comment or action, if sufficiently serious may create a poisoned environment. 



 Employees are responsible for:  

  • Reading, understanding, and upholding to the principles and procedures of this Policy; 
  • Participating in any education or training programs flowing from this Policy; 
  • Creating and maintaining a work environment where discrimination, harassment, bullying, and violence are not allowed, condoned, or ignored; 
  • Preventing the development, escalation, or recurrence of discrimination, harassment, and violence by speaking to persons involved (wherever possible or appropriate/safe to do so); 
  • Promptly reporting if they observe or experience instances of prohibited behavior; 
  • Participating fully in any investigation commenced under this Policy, and maintaining confidentiality of the complaint and the investigation process in which they are involved; 
  • Contacting emergency services in response to an immediate threat of workplace violence. 

In addition to the above, Managers are responsible for: 

  • Providing its employees with a work environment that is free of discrimination, harassment, and violence; 
  • Ensuring that staff review the Policy and understand the processes and concepts it contains; 
  • Ensuring that staff receive any training or education that flows from this Policy; 
  • Supporting employees who have experienced discrimination, harassment, or violence; 
  • Identifying/alerting employees to known violent persons (as appropriate) or hazardous situations;  
  • Complying with the appropriate occupational health and safety  and human rights legislative requirements where workplace violence may result in serious/critical injury or death; 
  • Ensuring that appropriate medical care is provided for anyone involved or affected by a workplace violence incident; 
  • Creating a written record for all complaints or incidents that come to their knowledge;  Promptly referring complaints or incidents to Human Resources for investigation as soon as they become aware of them and/or they are brought to their attention; this applies regardless of whether a formal complaint is filed or not; 
  • Implementing necessary interim safety measures of the parties in case of an investigation; 
  • Maintaining confidentiality of the complaint and the investigation process to the extent possible unless disclosure is necessary for investigating; 
  • Implementing and enforcing appropriate disciplinary measures or other corrective actions as a result of investigation, when a complaint of discrimination, harassment, or violence is found to have been substantiated. 

  Human Resources/Investigators are responsible for:  

  • Ensuring that employees are aware of this Policy and that copies of it are available to them; 
  • Advising employees on how to interpret the Policy and answering questions; 
  • Ensuring that complaints of prohibited behavior are addressed promptly and processed efficiently and in good faith; 
  • Examining whether the complaint reported falls within the scope of this policy, violates any other company policies, or contravenes legislation; 
  • Conducting investigations following the established procedures, or coordinating the process when appointing an external investigator; 
  • Conducting investigations that are objective, fair, thorough, timely, and appropriate given the seriousness and complexity of the allegations raised  
  • Maintaining confidentiality of the complaint and the investigation process to the extent possible unless disclosure is necessary for the purposes of investigating; 
  • Advising the complainant, respondent, and any witnesses of the confidentiality requirements with respect to the complaint and the investigation process;  
  • Providing the complainant and respondent with a written report/ statement of the investigation outcome and any corrective actions; 
  • Collaborating with a manager on implementing and enforcing appropriate disciplinary measures or other corrective actions as a result of investigation, when a complaint of discrimination, harassment, or violence is found to have been substantiated. 



If an emergency exists and the situation is one of immediate danger, then it should be immediately reported to the police by dialing “9-1-1” as soon as it is safe to do so. A person in a situation of immediate danger must at the same time take whatever steps are necessary to ensure their safety and to protect themselves against harm or injury. Once an employee is safe, then he or she can then report the matter to management. 

If an employee has experienced, or been witness to, an incident of discrimination, harassment, or violence in the workplace, they have two options available depending on the circumstances: making an ‘Informal Complaint’ or a ‘Formal Complaint’, both of which are described below.  

Informal Complaint Process

Employees with non-violent, minor concerns, or who feel comfortable resolving their concerns on their own, are encouraged to work through this process first, before seeking formal resolution.   

Step 1: Requesting Resolution Directly from Harasser(s)  

Employees who experience discrimination and/or harassment should first attempt to make it known to the individual(s) responsible, that the behavior is unwelcome and request that it stop. The harasser(s) may not realize that the behavior is unwelcome and in many instances, this will stop the undesired behavior. 

The Company recognizes that in some situations dealing directly with the harasser(s) may be difficult or inappropriate, or that the individual may have attempted to tell the harasser(s) to stop without success. In this case, the employee can escalate the concern to Step 2 as outlined below. 

Step 2: Requesting Assistance from Management  

Employees who experience discrimination or harassment and have unsuccessfully tried to deal with the harasser(s) directly, or who feel that a direct approach (i.e. Step 1) may not be appropriate, may choose to have the matter dealt with on an informal basis with the assistance of their direct Manager (or another member of the Management team) before proceeding with a formal complaint.  

The purpose of this step is to provide a means of obtaining information, voicing the concern, and seeking an informal resolution of the issue through management assistance. Managers need to create detailed records. 

Step 3: Notify Human Resources 

If the unwanted behavior reoccurs or continues, or if the Employee feels uncomfortable dealing directly with the harasser going forward, they should report the incident/concerns to their Manager and Human Resources and advise them of the steps taken so far.   

After discussing with the employee, the nature and extent of the situation facing them, Human Resources will, if necessary, explore possible solutions with the employee; such solutions may include an agreement between the parties concerned, an intervention in the workplace, or other support. 

 Formal Complaint Process  

If the Employee is not comfortable addressing the concern on their own, they feel unsafe, or they have been unsuccessful in resolving the issue through the Informal Complaint process, they should use the Formal Complaint Process and report the incident to their Manager & Human Resources. Wherever possible, employees are encouraged to submit their complaints in writing. The Workplace Complaint Form can be requested from the Manager or by contacting the Human Resources Representative. 

Step 1: Filing a formal complaint  

A formal complaint should include the details about the alleged incident(s), frequency, date(s), time(s) and location(s), what happened, who was involved, the names of any witnesses, steps taken to resolve the matter, and desired resolution. 

A manager in receipt of any report or complaint by an employee of workplace discrimination or harassment, or who otherwise becomes aware of any allegation of workplace discrimination or harassment, shall immediately notify the Human Resources Representative. 

After the complaint is filed, Human Resources will examine the complaint and decide whether the situation reported falls within the scope of this Policy. If it does not, Human Resources will inform the employee accordingly and, if applicable, direct them to the appropriate resources.   

If, on the other hand, the complaint falls within the scope of this Policy, Human Resources will initiate the investigation. The Investigator can be internal and a member of the Human Resources team, and in some cases, they can also be an external/third party (appointed by HR). In either situation, the investigator(s) will be objective and trained to conduct workplace investigations.   

Step 2: Workplace Investigation 

The Human Resources Representative or Investigator, upon receipt of a complaint or allegation of workplace discrimination or harassment, shall conduct a prompt, thorough, and confidential investigation into the allegation or complaint. 

The Company will ensure that all investigations conducted under this Policy are thorough and objective and shall not be based on presumptions about the guilt or innocence of either party. The objective is to solve such problems fairly, with a view to achieving and maintaining sound, mature working relationships among its employees at all levels. The Company reserves the right to conduct an investigation at any time if it has reason to believe that this Policy has been infringed. 

It may be necessary to implement interim measures to preserve the health and safety of the parties during the investigation. These measures may include adjusting work schedules, relocating any of the relevant parties to a different department or worksite, placing the party(s) on leave, implementing safety planning measures, or providing an alternative reporting relationship.   

The investigation procedure is as follows: 

  • Interview with the complainant: The investigator will interview the complainant concerning the facts underlying their allegation(s). 
  • Interview with the respondent: The investigator will interview the employee implicated in prohibited behaviors. The employee will be asked for their response to the allegation(s) being made and for their side of the story. 
  • Interviews with witnesses and other individuals: The investigator will then interview any other employees or individuals who may have witnessed the incidents of alleged workplace discrimination, violence, bullying, or harassment, or who may otherwise be able to provide information relevant to the investigation. 
  • Additional steps: if necessary the investigator may repeat any of the above steps, as well as collect and review physical evidence or visit the scene.  
  • Records: The investigation will be documented, and the record will consist of, among other things, detailed notes of all interviews with employees and witnesses and all other information relevant to the investigation. 
  • Report: The investigator will prepare a written report based on findings and a summary of evidence and will assess the validity of the complaint. The report will include a conclusion about whether discrimination, harassment, bullying or violence in contravention of this Policy was found or not, as well as the recommendation and course of action.  

 Step Three: Action 

The results of an investigation (written statements) must be communicated within ten (10) calendar days of the investigation being concluded to the complainant and the respondent. If the complaint was substantiated, the investigator will provide the parties with written statements of the investigation outcome and disciplinary or any corrective actions where applicable. If the investigation does not corroborate the complaint(s), then the complainant(s) and the respondent(s) will be advised in writing and the matter will be closed. It is important to note that the results of the investigation are not the same as the investigation report. The results of the investigation are a summary of the findings of the investigation. 

If the investigation corroborates the complaint(s), then the Business will, among other things, take appropriate disciplinary/corrective action against the offending employee(s) and any other measures it deems necessary to properly address the incident and prevent future incidents of workplace discrimination and harassment. The nature and extent of any disciplinary or remedial action will be determined by the Business based on the seriousness and frequency of the offense and other relevant details. Any breach of this Policy may give rise to disciplinary action, including dismissal. The Business also may require that a worker participate in an anger management program or other form of counseling available through the EFAP and Benefit Programs, either voluntarily or as a condition of continued employment. 

Where the results of the investigation do not support the allegations, such allegations of discrimination, harassment or violence will be discussed, and if necessary, investigated.  Where, as a result of such an investigation, it is determined that the complaint was malicious, that is to say with specific and direct intent to harm someone – or made in bad faith with reasonable knowledge of an intent to harm, disciplinary actions may be taken against the complainant up to and including termination.   



If it is necessary for the purposes of completing, carrying out, or protecting the integrity of an investigation, or if it is necessary to maintain a work environment that is safe and free of harassment and discrimination, the Business may require an employee to remain out of the workplace while an investigation is being conducted. 

The participation and cooperation of all employees is critical to the development and implementation of this policy. The refusal or failure of any employee to cooperate with the Business is a serious form of misconduct for which an employee may be disciplined up to and including dismissal. 

The Business recognizes the difficulty of coming forward with a complaint of workplace discrimination or harassment and a complainant’s interest in keeping the matter confidential. To protect the interests of the complainant, the respondent, persons who may report incidents of workplace harassment, and the integrity of the process, confidentiality will be maintained throughout the process, and information relating to the complaint will be disclosed only to the extent necessary for the purposes of investigating or taking corrective action with respect to the incident or complaint or is otherwise required by law. 

All individuals involved in a workplace investigation are expected to keep the substance of the investigation strictly confidential. Unless otherwise set out in this policy, all records of complaints, including records of meetings, interviews, results of investigations, statements, and other relevant material, will be maintained in a confidential file and will be disclosed only to the extent necessary to carry out these procedures and where disclosure is required by law. 

No employee will be penalized (i.e., punished) or subject to negative treatment for bringing an incident of discrimination, harassment, or violence to the Company’s attention, or by participating in an investigation or resolution.  Any form of reprisal or retaliation for the above will result in disciplinary action up to and including dismissal.  


GSL Group will review this policy and procedures on an annual basis, or as required, and will make necessary adjustments to ensure that it meets the needs of all employees. Addition reviews and necessary training  may be provided post-incident if there are any issues with the policy, or if a safety representative requests a review. 

Inquires about this policy and related procedures can be made to the Human Resources department by emailing [email protected]. 



I acknowledge that I have received, read, and understood the Workplace Discrimination, Harassment, Bullying, and Violence Policy of GSL Group and its affiliates. I understand that failure to comply with the policy may result in disciplinary action up to and including dismissal.  

I understand that if I have any questions, at any time, regarding the GSL Group policy, I will consult with my Manager, and/or the Human Resources Department.  

All forms of harassment and retaliation are prohibited behaviors and against GSL Group policy. GSL Group and its affiliates are committed to providing a work environment free of inappropriate and disrespectful behavior, intimidation, and other conduct directed at an individual because of their protected characteristics.