Independent Workplace Investigations. Impartial. Rigorous. Documented.
Independent, external workplace investigations — impartial, methodical, and documented. When internal HR cannot credibly investigate a matter, we run it end to end, from conflict check and written scope to the final report.
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Independent fact-findingAWI-trained investigator of recordContemporaneous notes, chain of custodyWritten report in every matter
A named investigator. A documented process.
A reliable workplace investigation combines a trained, named investigator, strict independence, and a record documented so an independent reviewer can follow the evidence to the findings.
AWI (Association of Workplace Investigators) training, held by the named investigator of record, Ghaleb El Masri. A methodology aligned to the framework that applies to the workplace — Ontario’s OHSA for provincially regulated employers, the Canada Labour Code (Bill C-65 framework) for federally regulated ones.
Before accepting an investigation, 1205 assesses whether the firm, the proposed investigator, or any current client relationship creates an actual or perceived conflict. If independence could reasonably be questioned, we recommend a separate investigator or firm.
Chain of custody. Contemporaneous notes. Reasons that reference both evidence and the governing framework — documented so an independent reviewer can follow the evidence to the findings.
Four matter types. One documented standard.
Ontario employers are most commonly investigated for harassment and discrimination, workplace violence, sexual misconduct, and reprisal or bullying — each governed by OHSA, the Human Rights Code, or both.
Most Ontario workplace investigations fall into one of these patterns. The methodology is the same — the difference is the governing law and what an outside reviewer (an OHSA inspector, the HRTO, an arbitrator) will scrutinize when the report is tested.
Harassment & discrimination
Code-protected ground complaints (sex, race, disability, gender identity, religion), psychological harassment under Bill 132, and patterns across multiple complainants.
Workplace violence & threats
Bill 168 obligations: threats, physical altercations, intimate-partner violence spillover, and credible-threat assessments. Often parallel to a workplace safety hold.
Sexual harassment & misconduct
Including senior-leader matters, party-cultures, and historical complaints surfaced after a #MeToo moment. Discreet handling, anonymized reporting where the law permits.
Reprisal, bullying & systemic conduct
Allegations of retaliation against complainants, bullying claims that fall outside Code grounds, and pattern-of-conduct investigations across departments or sites.
The law that frames what the report must answer.
Ontario workplace investigations are governed primarily by the Occupational Health and Safety Act (OHSA, including Bill 168 and Bill 132), the Ontario Human Rights Code, and — for federally regulated employers — the Canada Labour Code (Bill C-65).
Ontario Occupational Health and Safety Act obligations to investigate workplace harassment and violence, including the statutory duty to conduct an investigation "appropriate in the circumstances." Applies to provincially regulated Ontario employers.
Code-protected grounds (sex, race, disability, religion, gender identity, family status, and others). The same grounds are examined when a matter reaches the Human Rights Tribunal of Ontario, so findings address them allegation by allegation.
Ontario provincially regulated workplaces investigate under the Occupational Health and Safety Act (OHSA); federally regulated workplaces follow the Canada Labour Code framework introduced by Bill C-65. The written scope identifies which framework applies to the matter. Federally regulated employers include banks, telecoms, airlines, and interprovincial transport.
Not every complaint needs us. These four do.
An external investigator is the right call when a senior leader is named, when HR has a conflict, when the matter is headed to tribunal, or when the parties demand it — the FAQ below covers each scenario in detail.
Most workplace complaints can — and should — be handled by a competent in-house HR team. The cases where an independent investigator earns the spend are the ones where independence itself is the deliverable.
When the respondent is a partner, VP, MD, or board member, internal HR cannot credibly investigate someone they functionally report to — the doctrine of reasonable apprehension of bias applies.
If the complainant reports directly to HR, or if HR was a witness to the underlying events, the investigation starts compromised before the first interview.
Once a complaint signals it may move to the HRTO, Ministry of Labour, or court, the investigation itself becomes part of the record. The independence of the investigator is among the first things an external reviewer examines.
Complainants and respondents are increasingly counsel-represented and demand external investigation as a condition of participation. Refusing can create its own risk.
Same statute. Different evidence map.
We investigate most frequently in healthcare, manufacturing, professional services, education, and technology — and provide specialized support for private members' clubs.
Workplace investigations vary more by industry than most employers realise. The legal framework — Ontario’s Occupational Health and Safety Act, the Human Rights Code, the Employment Standards Act — applies universally. But what gets investigated, and where the evidentiary risks sit, looks very different on a hospital floor than in a financial services office.
Including specialized investigation support for private members' clubs and member-staff complaints.
Patient-facing harassment, allegations against unionized staff with seniority rights, and the intersection of Bill 132 with the Public Hospitals Act. Often the most document-heavy matter type — clinical records, scheduling, and shift logs all become relevant evidence.
Bullying, racial harassment, and discrimination in male-dominated environments. Often involves union grievance procedures running in parallel with the investigation, requiring careful coordination so findings are not compromised by grievance disclosure.
Senior-leader matters where the respondent is a partner, MD, or board member. Independence is the entire game here — internal HR cannot credibly investigate someone they functionally report to.
Faculty-student power-imbalance complaints, allegations involving tenured staff, and matters with media risk. Often run under specific institutional policies (university Senate procedures) on top of statutory obligations.
Founder-to-employee complaints, equity-holder conflicts, and harassment in remote/hybrid workplaces. Evidence-gathering shifts heavily to Slack, email, and platform records — chain of custody on digital evidence is critical and often mishandled by internal teams.
Member-staff complaints, seasonal-worker issues, board-sensitive matters, and harassment or misconduct allegations in golf, yacht, racquet, city, country, and recreation-club environments. Dedicated industry page available.
Quoted after intake. In writing, before work begins.
Most matters are quoted on a fixed-fee basis of $9,500–$15,000. Executive, board, multi-party, or litigation-adjacent matters are individually quoted above $15,000. The scope reflects the number of parties, evidence volume, urgency, jurisdiction, and reporting requirements — you receive the written fee and scope before work begins.
The written scope sets the expected investigation timeline. Timing depends on participant availability, evidence volume, complexity, and any parallel legal or workplace process. Findings are made, owned, and signed by the named investigator of record.
Contained, two-party matters
Single complainant, single respondent, a small witness set, and a contained document volume. Many workplace harassment complaints fit here. Individually quoted; written fee and scope before work begins.
Multi-party matters
Multiple complainants or respondents, a wider witness circle, and a larger document volume. Many discrimination and pattern-of-conduct investigations sit here. Individually quoted; written fee and scope before work begins.
Senior-leader and multi-site matters
Senior-leader, multi-site, or cross-functional matters, heavy document volume, counsel involved on both sides, or an active parallel grievance or litigation. Individually quoted above $15,000; written fee and scope before work begins.
Four mistakes that compromise the file.
When a workplace complaint is filed, the four most damaging employer mistakes are: letting a conflicted HR team investigate, failing to preserve electronic records immediately, inadequate interim protection for the complainant, and direct communication with the parties.
Most engagements are easier when employers avoid these four pre-investigation missteps. None of them are fatal — but each one adds time, cost, and risk to the matter. We flag them on the intake call regardless of who you eventually retain.
Letting HR investigate when the complainant reports to HR
A conflict at the intake desk compromises the process before the first interview. The fix is simple — bring in an external investigator the moment the conflict is visible.
Not preserving documents and electronic records
Slack messages auto-delete, emails get cleared, badge logs roll. Preserve records as soon as a complaint is received — and confirm with counsel what a preservation obligation requires in your specific situation.
Inadequate interim measures
Employers are expected to protect complainants while the investigation runs. Doing nothing invites one kind of criticism; over-reacting (e.g., suspending the respondent without basis) invites another. Interim measures deserve deliberate, documented decisions — take advice where the call is close.
Direct communication with complainant or respondent
Once a complaint is filed, every conversation with the parties is potential evidence — and potential reprisal risk. Communications should flow through the investigator or designated counsel, not through the manager involved in the underlying events.
Five steps. No shortcuts.
A workplace investigation in Ontario follows five phases: scoping and conflict check, written plan and party notification, evidence collection, balance-of-probabilities analysis, and a written report with findings and remediation recommendations.
- 01
Intake & scope
An intake call within one business day to triage the matter and identify the framework that applies — Ontario’s OHSA (Bill 168 / Bill 132) and Human Rights Code for provincially regulated employers, the Canada Labour Code (Bill C-65 framework) for federally regulated ones. We screen for conflicts, propose methodology, name the investigator of record, and issue a written fee and scope before work begins — within 48 hours on urgent matters.
- 02
Plan & notify
Investigation plan signed by the employer before any interview is scheduled. Written notices issued to complainant and respondent with confidentiality and no-reprisal obligations, plain-language explanations of the process, and timelines for response.
- 03
Evidence
Interviews of complainant, respondent, and material witnesses — on the record, recorded where consented, with counsel present where appropriate. Documentary review, chain of custody preserved, and a contemporaneous note of every exchange.
- 04
Analysis
Findings on each allegation against the balance-of-probabilities standard. Credibility assessment grounded in evidence (not impressions), policy and legal framework applied allegation by allegation, and a clear record of what we relied on for each conclusion.
- 05
Report
Written report with findings, rationale, and remediation recommendations. Debrief to the employer (and counsel, when engaged), documented so an independent reviewer can follow the evidence to the findings — a private record the employer can rely on for the discipline, mediation, or restructuring that follows.
Active matter?
Triage call within one business day. Written scope within 48 hours.
Confidential. Documented. Closed.
Workplace Investigation in a Recreation Organization
Independent investigation and systematic culture remediation transformed a recreation organization facing multiple harassment allegations into a model of workplace accountability.
Workplace Investigation in the Public Sector
Independent review of 47 promotion decisions and systemic hiring-equity remediation in a provincial government agency.
Workplace Investigation at a Canadian Tech Company
Independent harassment investigation in a 300-person tech company, with a separately scoped remediation program that followed the findings.
A documented investigation process designed to support fair decision-making and independent review.
The 1205 process standard
What employers ask before they retain us.
Before retaining a workplace investigator, employers typically ask about Ontario jurisdiction, response time, what makes an investigation reliable, cost, and which laws apply — all answered in full below.
- Do you handle workplace investigations across Ontario?
- Yes. We investigate matters anywhere in Ontario — Toronto, the GTA, Ottawa, Hamilton, Kitchener-Waterloo, and beyond. Evidence-gathering is hybrid where appropriate: in-person interviews where they matter, video where logistics call for it.
- How quickly can you start an urgent investigation?
- Active complaints get a triage call within one business day and a written scope within 48 hours — including conflict screening, proposed methodology, and a named investigator of record. The written scope sets the expected investigation timeline. Timing depends on participant availability, evidence volume, complexity, and any parallel legal or workplace process.
- What makes an investigation reliable?
- A written plan before any interview, evidence gathered with contemporaneous notes and a preserved chain of custody, and findings reasoned against the balance of probabilities, allegation by allegation. Matters are led by an AWI-trained investigator of record — Ghaleb El Masri — named in the engagement letter. A documented investigation process designed to support fair decision-making and independent review.
- Do you work with law firms or directly with employers?
- Both. We are engaged directly by employers, by in-house counsel, and by external employment counsel. Before accepting an investigation, 1205 assesses whether the firm, the proposed investigator, or any current client relationship creates an actual or perceived conflict. If independence could reasonably be questioned, we recommend a separate investigator or firm.
- What does a workplace investigation cost?
- Most matters are quoted on a fixed-fee basis of $9,500–$15,000. Executive, board, multi-party, or litigation-adjacent matters are individually quoted above $15,000. You receive a written fee and scope before work begins.
- Which workplace laws do your investigations cover?
- Ontario provincially regulated workplaces investigate under the Occupational Health and Safety Act (OHSA); federally regulated workplaces follow the Canada Labour Code framework introduced by Bill C-65. The written scope identifies which framework applies to the matter. Within Ontario, the OHSA harassment and violence provisions (Bill 168 / Bill 132), the Ontario Human Rights Code, and the Employment Standards Act frame the analysis.
- When should an employer hire an external investigator vs. handling it internally?
- When the complaint involves a senior leader, when HR has a real or perceived conflict, when the matter may proceed to the Human Rights Tribunal or Ministry of Labour, or when the parties have requested external review. In each of these situations, independence — and the appearance of independence — is the deliverable itself.
- Can a workplace investigator be sued by the complainant or respondent?
- Any investigator can face a claim; structure is the real protection. That means a written scope, an investigator outside the parties’ reporting lines, contemporaneous notes, and findings reasoned from documented evidence. Whether a specific protection such as privilege applies to your matter depends on how it is structured and on the advice of your counsel — confirm before relying on it.
- Do I need to notify the Ministry of Labour or HRTO about an internal investigation?
- There is no general requirement to notify the Ministry of Labour or the Human Rights Tribunal that an internal investigation is under way — the process is private to the workplace. External involvement typically arises when a party files externally, when the statutory duty to investigate under OHSA Section 32.0.7 is not met, or when a matter involves a reportable incident. How the rules apply to your specific situation is a question for your counsel.
- What happens after the investigation report is delivered?
- You receive findings on each allegation, recommended remedial actions, and a debrief. From there, the decisions are yours — discipline, mediation, policy review, or restructuring. The investigation mandate is limited to independent fact-finding and the agreed report. Any remediation, training, policy, or HR support is separately scoped after findings are delivered and only where independence, fairness, and client counsel permit it.
Three free tools to triage the matter.
Workplace Investigation Quiz · Ontario
Free Ontario workplace investigation quiz — understand which legal framework applies, how complex the matter is, and the next three steps in 5 minutes.
Workplace Investigation Readiness Checklist · Ontario
Free Ontario workplace investigation readiness checklist — six phases, 25 checkpoints across policy, documentation, and process before a complaint lands.
HR Compliance Scorecard · Ontario
Free Ontario HR compliance scorecard — score your posture across ESA, OHSA, AODA, pay equity, and human rights, with a prioritized remediation order.
The Human-Attested standard
AI in the workflow. A person on the hook.
AI assists. It never decides.
We use AI to move faster on research, drafting, and pattern-finding. It is a tool in the workflow — not the analyst, not the judgment, and not the author of what we deliver.
A senior human reviews and owns the work.
Every deliverable is reviewed and stood behind by a senior 1205 practitioner. The findings, the recommendations, and the file are human work product — attributable to a named person, not a model.
We escalate when the matter needs it.
Where a question crosses into regulated territory, we say so and route it to employment counsel. We would rather hand off than overreach.
We are clear about our boundaries.
1205 conducts independent investigations and delivers findings — it does not provide legal advice, decide discipline, or implement management decisions.
See how 1205 handles AI-assisted work, human review, regulated partner routing, and confidentiality in the Human-Attested Trust Pack.
From the same family. Often scoped together.
Outsourced HR
Enterprise-grade HR. Without the fixed cost.
Outsourced HR for mid-market Canadian companies — compliance, ER, talent, and culture run end-to-end by a named senior lead. Onboarding timing confirmed in the written scope.
HR Services
Compliance. Culture. Capacity.
HR services for Ontario employers — workplace investigations, culture transformation, and outsourced HR. Senior practitioners, one-business-day triage on active issues.
Culture Transformation
The program, not the report.
Culture transformation programs in Canada — we lead the work, coach leaders weekly, and hold accountability until the new culture is embedded. Not a report.
Call today. Scope within 48 hours.
We triage active complaints within one business day and issue a written scope within 48 hours — including conflict screening and a named investigator of record.