Bullying and Harassment Policy and Procedures

Westland Insurance is committed to providing a work environment that is characterized by
professionalism, collegiality, and cooperation and free from bullying and harassment. Bullying and
harassment, whether or not based on a prohibited ground under the Human Rights Code, will not be
tolerated in any interactions connected to work with Westland and where such harassment is found
to have occurred, it may take remedial action. This Policy is not intended to constrain normal social
interactions.
This Policy applies to all permanent and temporary employees of Westland; it is applicable to all
situations where activities are connected to work with Westland. This includes:
 Activities on Westland premises
 Work assignments outside of Westland premises
 Work-related conferences, training sessions, or seminars
 Work-related travel
 Work-related social functions that Westland sponsors or organizes
whether or not the conduct in question occurs during or outside of our business hours.
Every employee, including every manager, has a responsibility to adhere to this policy. This policy will be
applied without regard to status or seniority.
Harassment means any inappropriate and unwelcome conduct (including comments, displays, actions,
or gestures) by a person towards another person that the conductor knew or reasonably ought to have
known would cause the recipient(s) of the conduct to be humiliated or intimidated. THE INTENT IS
IRRELEVANT – HOW THE RECIPIENT RECEIVES THE MESSAGE IS KEY.
Bullying is defined in the Policy as including "any inappropriate conduct or comment by a person
towards a worker that the person knew or reasonably ought to have known would cause that worker to
be humiliated or intimidated, but excludes any reasonable action taken by an employer or supervisor
relating to the management and direction of workers or the place of employment.
Bullying and harassment includes:
 Verbal aggression or insults; calling someone derogatory names

 Vandalizing a worker's belongings, work space, or work equipment
 Sabotaging a person's work
 Spreading malicious gossip or rumors about a person
 Engaging in harmful or offensive initiation practices
 Physical assault or threats (this would also constitute "violence" or "improper activity or
behavior")
 Making personal attacks based on someone's private life and/or personal traits
 Making aggressive or threatening gestures
Bullying and Harassment does not include:
 Expressing differences of opinion
 Offering constructive feedback, guidance, or advice about work‑related behavior
 Reasonable action taken by an employer or supervisor relating to the management and

direction of workers or the place of employment (e.g., managing a worker’s performance, taking
reasonable disciplinary actions, assigning work)
Discriminatory Bullying or Discriminatory Harassment means bullying or harassment that is related to a

prohibited ground of discrimination under the Human Rights Code as set out above.
Sexual harassment is harassment that is based on the prohibited ground of sex.
All employees, including managers, must:
 not engage in bullying or harassment in breach of this policy;
 proactively maintain a workplace free from harassment and bullying;
 promptly report breaches or potential breaches of this policy, whether experienced or observed,
and whether involving persons who perform work at Westland Insurance or who attend our
office or any work-related setting outside of our office;
 fully cooperate with the Westland Insurance’s investigations into potential bullying or
harassment; and
 comply with this policy and any other policy implemented by Westland Insurance that is related
to preventing and addressing bullying and harassment in the workplace.
Workers must:
 Not engage in the bullying and harassment of other workers

 Report if bullying and harassment is observed or experienced
 Apply and comply with the employer’s policies and procedures on bullying and harassment
What is the Complaint Procedure?
The following complaint procedure applies to all employees, including managers, at Westland Insurance
who bring or who respond to a complaint under this policy. This is the procedure that will be followed in
MOST cases. There may be situations that require deviation from this procedure, as outlined in the full
policy.
Step 1. When a person experiences conduct in breach of this policy, the person should, if comfortable
doing so safely, make it known to the person engaged in the conduct that the conduct is unwelcome and
is in breach of this policy.
Step 2. If the conduct persists, if the person is not comfortable expressing objection directly, or if there
is uncertainty with respect to whether the conduct in question is in breach of this policy, then the
person must promptly report the conduct to their manager or to People and Performance. If the
complaint involves their manager or People and Performance, then the complainant should refer the
matter to a manager or to a member of People and Performance who is not the subject of the
complaint.
Step 3. If informal resolution is not acceptable to the alleged victim of the harassment / bullying, is not
achieved, or is determined to be inappropriate by Westland Insurance, then the complainant must
promptly prepare a formal written complaint to provide to Westland Insurance (their manager or People
and Performance).
Step 4. If there is a sufficient basis in the written complaint or if Westland Insurance otherwise deems it
necessary to do so, Westland Insurance, or a person designated by Westland Insurance, will carry out a
formal investigation into the conduct complained of in a prompt, fair and impartial manner. The
investigation will be confidential to the extent possible and information gathered during the
investigation will be disclosed to persons only as necessary to carry out a full and fair investigation and
to address the findings from the investigation. All complaint statements, response statements, witness
statements, interview notes and other documentation gathered as part of an investigation will be
securely stored in a confidential investigation file. In most circumstances, it will not be possible to
investigate or resolve a complaint without disclosure of the complainant's identity to the alleged
harasser or bully. In addition, those persons involved in the investigation or resolution of a complaint
will be aware of the matter.
Step 5. Once an investigation is complete, Westland Insurance, or the person designated by Westland
Insurance, will determine whether the conduct complained of is in breach of this policy and may do one
or more of the following:
 attempt to resolve the problem in an informal manner;
 take whatever action necessary to attempt to remedy the harm caused or prevent further
harm, including disciplinary action;
 dismiss the complaint if the conduct complained of is found not to be in breach of this policy
The alleged victim of the harassment / bullying and the alleged harasser / bully will be advised of the
results of the investigation.
Consequences of Breaching this Policy
Anyone who is found to have engaged in conduct in breach of this policy will be subject to discipline up
to and including termination of employment. Anyone who makes false or reckless allegations of
harassment or bullying or who makes such allegations for improper purposes will be subject to discipline
up to and including termination of employment. Anyone who retaliates against a person for bringing a
complaint under this policy or for participating in a complaint investigation will be subject to discipline
up to and including termination of employment. Corrective action will also be taken against persons
who are not employed or engaged by Westland Insurance, including revoking access to Westland
Insurance workplaces if deemed appropriate.

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Westland Insurance is committed to providing a work environment that is characterized by

 Activities on Westland premises

 Work assignments outside of Westland premises

 Work-related conferences, training sessions, or seminars

 Work-related social functions that Westland sponsors or organizes

Bullying and harassment includes:

 Verbal aggression or insults; calling someone derogatory names

 Expressing differences of opinion

 Offering constructive feedback, guidance, or advice about work‑related behavior

 Reasonable action taken by an employer or supervisor relating to the management and

Discriminatory Bullying or Discriminatory Harassment means bullying or harassment that is related to a

Sexual harassment is harassment that is based on the prohibited ground of sex.

All employees, including managers, must:

 not engage in bullying or harassment in breach of this policy;

 proactively maintain a workplace free from harassment and bullying;

 Not engage in the bullying and harassment of other workers

What is the Complaint Procedure?

 attempt to resolve the problem in an informal manner;

Consequences of Breaching this Policy

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