How to use this template. This document is a starting framework that combines the two
documents the Occupational Health and Safety Act (OHSA) requires of most Ontario employers: a
workplace violence and harassment policy and the supporting program
(measures and procedures). Replace every [bracketed] field with your own
details, delete the guidance notes before publishing, and have the finished document reviewed against
current legislation by qualified HR or legal counsel before adoption. It is not legal advice. Statutory
references are to OHSA Part III.0.1 (sections 32.0.1–32.0.8) and related provisions as in force in Ontario.
Who must have this. Under OHSA s. 32.0.1, an employer must prepare a written workplace
violence policy and a written workplace harassment policy and review each at least annually. The requirement
to post the policy and to develop and maintain a program in writing applies to employers
who regularly employ more than five workers (OHSA ss. 32.0.1(2)–(3), 32.0.2(2),
32.0.6(3)). Confirm how the thresholds apply to your organization.
[Company Name] is committed to providing a work environment in which all
workers are treated with respect and dignity and are free from workplace violence and workplace harassment.
Workplace violence and workplace harassment will not be tolerated from any person in the workplace — including
workers, supervisors, managers, the employer, clients, customers, suppliers, contractors, and visitors.
Everyone in the workplace is expected to uphold this policy and to work together to prevent workplace
violence and harassment. This commitment is endorsed at the most senior level of the organization by
[Name and title of most senior officer / owner / board].
2. Scope
This policy and program apply to:
Who is covered: all workers, including full-time, part-time, temporary, casual, and
seasonal employees, students on placement, volunteers, and contractors, as defined under OHSA.
Who may be a respondent: any person a worker encounters in the course of work,
including co-workers, supervisors, managers, the employer, clients, customers, members of the public,
suppliers, contractors, and visitors.
Where it applies: the physical workplace, any other location where work is performed,
work-related travel, work-related social events, and all work-related communications, including email,
messaging, phone, and online platforms.
3. Definitions
The following definitions are taken from OHSA s. 1(1) and s. 32.0.1. Use the statutory language;
plain-language explanation and examples are added for clarity only.
Workplace violence
Workplace violence means:
the 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; and
a statement or behaviour that it 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.
Workplace harassment
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; or
workplace sexual harassment.
A reasonable action taken by an employer or supervisor relating to the management and direction of workers
or the workplace is not workplace harassment.
Workplace sexual harassment
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 it 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.
Add your own examples. List concrete examples relevant to your workplace of conduct that
may constitute harassment (e.g. offensive jokes, intimidation, isolating a worker, displaying offensive
material) and conduct that does not (e.g. legitimate performance management, assigning work,
appropriate discipline). Clarifying the line between firm management and harassment is the most common
practical need.
4. Roles and Responsibilities
The employer / senior leadership will
prepare, review, and maintain this policy and program in writing;
provide information, instruction, and training to workers;
ensure that incidents and complaints are appropriately investigated and dealt with; and
take every reasonable precaution in the circumstances for the protection of workers
(OHSA s. 25(2)(h)).
Supervisors and managers will
act when they become aware of, or ought reasonably to be aware of, workplace violence or harassment —
a formal complaint is not required to trigger this duty;
follow the reporting and investigation procedures set out below; and
model respectful conduct and support workers who raise concerns.
Workers will
refrain from workplace violence and harassment;
report incidents or concerns in accordance with this policy; and
cooperate with any investigation.
The designated contacts responsible for receiving reports and overseeing the program are:
[Name / title / contact details — e.g. HR Lead and an alternate outside the
reporting chain].
5. Workplace Violence Risk Assessment
As required by OHSA s. 32.0.3, [Company Name] will assess the risks of
workplace violence that may arise from the nature of the workplace, the type of work, and the conditions of
work. The assessment takes into account circumstances common to similar workplaces, circumstances specific
to this workplace, and any other prescribed elements.
The employer will:
conduct and document the risk assessment, and reassess as often as necessary to protect workers
(including when circumstances change);
report the results of the assessment to the joint health and safety committee or health and safety
representative, or directly to the workers where there is none; and
develop and maintain measures and procedures to control the identified risks.
Date of most recent risk assessment: [Date]. Summary of identified risks and
controls: [Brief summary or reference to the assessment record].
6. Reporting Procedures
A worker who experiences or witnesses workplace violence or harassment is encouraged to report it as soon
as possible. Reports may be made verbally or in writing, and the employer's obligation to
investigate applies regardless of the format of the report.
To ensure a worker is never required to report only to the person involved, multiple channels are available.
A worker may report to:
their direct supervisor or manager;
the designated HR contact: [Name / contact];
a senior leader outside the worker's reporting chain:
[Name / contact]; and
an alternative or external reporting channel:
[e.g. confidential email, hotline, or third-party intake service].
If there is an immediate threat to safety, call emergency services at 9-1-1 first.
7. Investigation Procedure
When an incident or complaint of workplace violence or harassment comes to the employer's attention, an
investigation appropriate in the circumstances will be conducted, as required by OHSA s. 32.0.7. The
general process is:
Intake and triage. The designated contact records the report and assesses any immediate
safety concerns.
Interim measures. Where appropriate, reasonable interim measures are put in place to
protect the parties while the investigation proceeds (for example, adjusting reporting lines or work
arrangements). Interim measures are not a finding of wrongdoing.
Assigning an investigator. The matter is assigned to an impartial investigator with no
personal involvement in or conflict of interest with the matter — internal
([name / title]) or an external investigator where impartiality, complexity,
or seniority of the parties requires it.
Interviews and evidence. The investigator interviews the complainant, the respondent,
and relevant witnesses, and gathers relevant documents. The respondent is informed of the substance of
the allegations and given an opportunity to respond.
Findings. The investigator assesses the evidence on a balance of probabilities and
prepares findings.
Corrective action. Where the allegations are substantiated, the employer takes
appropriate corrective action, which may range from training and counselling to progressive discipline
up to and including termination.
Target timelines: an investigation will normally be initiated within
[X] business days of a report and completed within
[Y] weeks, subject to the complexity of the matter and the availability of the
parties and witnesses.
8. Communicating Results
As required by OHSA s. 32.0.7(1)(b), the complainant and the respondent (if a worker) will be informed
in writing of the results of the investigation and of any corrective action that has been or will be taken
as a result. This information is limited to what is necessary to communicate the outcome and any corrective
action; it is not a copy of the full investigation report unless the employer decides otherwise.
9. Domestic Violence
As required by OHSA s. 32.0.4, if the employer becomes aware, or ought reasonably to be aware, that
domestic violence may occur in the workplace and would likely expose a worker to physical injury, the
employer will take every precaution reasonable in the circumstances to protect the worker. Workers are
encouraged to confidentially advise [designated contact] of any situation that
could create a risk in the workplace so that protective measures can be considered.
10. Protection from Reprisal
No worker will be subject to reprisal for reporting workplace violence or harassment in good faith,
participating in an investigation, or exercising any right under OHSA (which prohibits reprisal under
s. 50). Reprisal includes dismissal, discipline, demotion, reduced hours, reassignment to less
desirable work, exclusion from opportunities, threats, or any other adverse change to working conditions
taken because a worker exercised those rights. Anyone found to have engaged in reprisal will be subject to
corrective action up to and including termination.
11. Confidentiality
Information obtained about an incident or complaint, including identifying information, will not be disclosed
unless disclosure is necessary to investigate or take corrective action, or is otherwise required by law
(OHSA s. 32.0.8). Absolute confidentiality cannot be guaranteed: the respondent must know the substance
of the allegations, witnesses may need to be interviewed, and results must be communicated. The employer
will limit disclosure to those who need to know and will protect the privacy of all parties to the extent
reasonably possible.
12. Information, Instruction and Training
As required by OHSA s. 32.0.5 (violence) and s. 32.0.7(1)(c) (harassment),
[Company Name] will provide workers with information and instruction on the
contents of this policy and program. Training will be provided
[at onboarding and at least annually / on the following schedule] and records of
training will be kept.
13. External Complaint Options
This policy does not limit a worker's right to seek assistance or to file a complaint with an external body.
Depending on the circumstances, options may include:
the Ontario Ministry of Labour, Immigration, Training and Skills Development (Health and
Safety Contact Centre) regarding OHSA obligations;
the Human Rights Tribunal of Ontario, where the conduct relates to a protected ground
under the Human Rights Code; and
the police, where conduct may be criminal.
14. Annual Review
This policy and program will be reviewed at least once a year, as required by OHSA ss. 32.0.1(2) and
32.0.6(2), and updated as needed. Each review will be documented, including the date, who participated, what
changes (if any) were made, and the date the updated policy was communicated to workers.