Harassment and Discrimination Policy

Policy Statement

It is the policy of HiPoint Financial that all staff and independent contractors have a right to a work and study environment that is safe and respectful, free from discrimination, hate and harassment including that which is related to any of the prohibited grounds in the Ontario Human Rights Code including race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, age, marital status, family status, disability, sexual orientation (and same sex partnership status) and record of offences.

Scope

This policy applies to all staff and independent contractors of HiPoint Financial including agents, employees, members of the Board of Directors, members of committees, volunteers, interns, visitors and guests (including guest speakers).

This policy covers incidents that occur both on and off HiPoint Financial’s premises, in both physical and virtual environments, which affect the working environment.

Definitions

Caste-based Discrimination

Discrimination based on social constructs or hierarchies that determine an individual’s or group’s social class or standing in a community rooted in historical, political, social, cultural and economic structures within some cultural and religious communities.

Creed

Creed refers to religious beliefs and practices. Creed may also include non-religious belief systems that substantially influence a person’s identity, worldview and way of life.

Discrimination

Actions or behaviours creating harmful, adverse or differential treatment related to prohibited grounds. This includes stereotypical assumptions or actions that exclude individuals or deny benefits or opportunities.

Harassment

A series of unwelcome comments or conduct related to prohibited grounds that may be offensive, intimidating or hostile. Examples include gestures, remarks, jokes, taunting, verbal assault, hazing, exclusion and other inappropriate behaviour.

Hate

Expressions involving vilification and detestation of identifiable groups implying individuals should be despised, denied respect or subjected to ill treatment.

Negative or Poisoned Environment

A pattern of conduct creating a hostile or offensive environment for individuals or groups. Examples include exposure to offensive materials such as emails, videos, signs, remarks or messages.

Racial Discrimination

Discrimination due to race or socially constructed categorization of people. Examples include Anti-Black racism, Anti-Asian racism, Anti-Indigenous racism, Anti-Semitism and Islamophobia.

Sexual Harassment

Unwelcome conduct or communication based on sex, gender, gender identity or sexual orientation. This includes unwanted advances, inappropriate remarks, promises of benefits for sexual favors, or threats of retaliation.

Workplace Harassment

Defined by Ontario’s Occupational Health and Safety Act as engaging in a course of vexatious comment or conduct against a worker that is known or ought reasonably to be known as unwelcome.

Policy

HiPoint Financial provides an internal mechanism for receiving complaints of discrimination or harassment and setting out a process for addressing them.

  1. Intersectional Approach: Discrimination experiences may involve multiple identities and intersections which must be considered.
  2. Timelines: Complaints must be reported within six (6) months of the incident unless extenuating circumstances exist.
  3. Procedural Fairness: Individuals will be notified of allegations and given opportunity to respond.
  4. Confidentiality: The company will maintain confidentiality wherever possible while ensuring fair investigation.
  5. Anonymous Complaints: Anonymous reports may be accepted, though investigation may be limited.
  6. Exceptional Circumstances: The company may diverge from procedures if safety risks exist.
  7. Intersection with Other Policies: This policy works alongside other company policies including those regarding freedom of speech.
  8. Parallel Processes: Complaints may also be pursued through the Ontario Human Rights Commission.
  9. Protection from Retaliation: Retaliation against individuals who file complaints or participate in investigations is prohibited.
  10. Balance of Probabilities: Decisions will be based on credible evidence showing the allegation is more likely true than not.
  11. Unsubstantiated Complaints: Complaints filed in good faith but unsupported by evidence will not result in disciplinary records.
  12. Frivolous or Bad Faith Complaints: Complaints intended to harm others may result in disciplinary action.
  13. Right to Withdraw: A complainant may withdraw a complaint, although the company may continue investigation if required.
  14. Referrals: Complaints may be referred to the Ontario Ombudsman if unresolved.
  15. Annual Reporting: Reports may be provided annually to the Board of Directors or relevant regulatory authorities.

Relevant Legislation

  • Ontario Human Rights Code
  • Occupational Health & Safety Act
  • Financial Services Regulatory Authority of Ontario