HOW GOOD IS YOUR POLICY?

Is your policy reflective of current law and practise?

If your company is registered in Ontario, is your current policy consistent with the Ontario Human Rights Commission Guidelines for Internal Human Rights Complaint Resolution Procedures? If your company operates elsewhere, does its policy conform to local, provincial (or state) requirements?

Remember that in most Canadian jurisdications, a sexual harassment policy is inadequate. You must establish a comprehensive human rights policy that address the breadth of issues covered in your provincial human rights code.

Does your policy really protect your employees from being harassed and discriminated against? Does it provide protection for your managers from being named in human rights complaints. If you operate under a collective agreement, is the union supportive of the policy?

Do all employees know about the policy?

Does your policy establish a problem solving approach to human rights?

Rather than direct employees involved in a human rights dispute into a complaint mode, emphasize problem solving as the best, most efficient and effective way to resolve these types of conflicts. Empower employees to take direct action by approaching the person causing the problem and "working it out." If that is viable, then invite staff to go to either a manager or the policy coordinator to get advice and assistance. Only if the wide range of informal problem solving approaches fail, should a formal complaint be submitted.

When was the last time that training about harassment and the policy take place?

Are managers familiar with their responsibilities under the policy? When did senior management receive a report on the operation of the policy?

When was the policy last reviewed?

The liability of individual managers as well as the corporation increases when a policy is in place but inadequately implemented. Human Rights Commission staff are much more critical in their analysis if on one hand they find that a policy is in place, but, on the other, they find that it operates with serious deficiencies.

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