Employer:

• Ensure that measures and procedures in the violence and harassment prevention program are carried out. Hold its management accountable for responding to and resolving complaints of violence.
• Ensure compliance by all who have a relationship with the organization, such as physicians, contractors, volunteers, etc.
• Post a copy of this policy in the workplace.
• In consultation with the JHSC, conduct regular risk assessments.
• In consultation with the JHSC, establish control measures.
• In consultation with the JHSC, establish and deliver training and education for all workers.
• Integrate safe behaviour into day-to-day operation
• Develop a reporting process for incidents of workplace violence and harassment.
• Investigate all reports or threats of violence/harassment in a prompt, objective and sensitive way.
• Report incidents of workplace violence to the JHSC within four days if a worker is disabled from performing their own work or receives medical attention as a result of an incident.
• Take corrective action.
• Provide response measures.
• Facilitate medical attention and support for those involved directly or indirectly.
• Ensure any deaths or critical injuries are reported to a Ministry of Labour (MOL) inspector, the police (as required), JHSC or H&S representative and any trade unions, as well as investigated with the JHSC. Send the report explaining the circumstances to all parties in writing within 48 hours of the occurrence. Include information and particulars prescribed by the Occupational Health and Safety Act and regulation
• Ensure a report goes to WSIB of all accidents where a worker loses time from work, requires healthcare, earns less than regular pay for regular work, requires modified work at less than regular pay or performs modified work at regular pay for more than seven days.

Directors/managers/supervisors:

• Enforce policy and procedures and monitor worker compliance.
• Identify and alert staff to violent persons and hazardous situation
• Investigate all workplace violence using the organization’s accident investigation procedure and form, and contact the police as required.
• Facilitate medical attention for worker(s) as required.
• Debrief those involved in the incident either directly or indirectly.
• Contact human resources to ensure the worker receives further counselling about her/his legal rights.
• Track and analyze incidents for trending and prevention
• Immediately report a death or critical injury to an MOL inspector, the police (as required), JHSC, H&S representative and trade union, and investigate with JHSC Report the circumstance to all parties in writing within 48 hours. Include information and particulars prescribed by the regulation
• Issue a report to the employer and WSIB on all lost-time accidents where a worker requires healthcare, earns less than regular pay for regular work, requires modified work at less than regular pay or performs modified work at regular pay for more than seven days. Copies of accident information where there is no critical injury must be provided to the JHSC and the trade union within four days of the occurrence, as prescribed by the Occupational Health and Safety Act. 
• Ensure the workplace violence and harassment prevention program is reviewed at least once a year.

Workers:

• Participate in education and training programs so they can respond suitably to any incident of workplace violence or harassment.
• Understand and comply with the violence and harassment prevention policies and related procedures.
• Report all incidents or injuries of violence/harassment or threats of violence/harassment to your supervisor immediately. Complete the Workplace Violence Incident Report.
• Inform the JHSC or the worker member of the JHSC about your concerns regarding the potential for violence/harassment in the workplace.
• Contribute to risk assessments.
• Seek support when confronted with violence/harassment or threats of violence.
• Get medical attention.
• At least once a year, participate in a review of the workplace violence and harassment prevention

Joint Health and Safety Committee (JHSC):

• Ensure you are consulted about the development, establishment and implementation of violence prevention measures and procedures (the violence and harassment prevention program).
• Make recommendations to the employer for developing, establishing, and providing training in violence prevention measures and procedures.
• At least once a year, take part in a review of the workplace violence and harassment prevention
• The worker-designate should investigate all critical violence-related injuries.
• Immediately review reports of critical injury or death. Outline in writing the circumstances and particulars within 48 hours of the occurrence.
• Within four days, review written notices lesser injuries where any person is disabled from performing his or her usual work or requires medical attention.

Reporting and Investigation

• Workers are to report all violence-related incidents or hazards to their manager or supervisor. This report can be made confidentially at the worker’s request. However, sharing information to ensure the safety of others and prevent recurrence may be necessary (e.g., contents of a police report).
• The reporting worker may make the report confidentially without leaving a copy in the log, indicating the need for confidentiality to her/his direct manager or supervisor (or in that person’s absence, to another manager or supervisor).
• The manager or supervisor receiving the report investigates it and ensures that measures are taken to safeguard workers and curtail the violence or harassment. No report of workplace violence/harassment or risks of violence may be the basis of reprisal against the reporting worker.
• The employer reports all injuries to the MOL and WSIB as required by the Occupational Health and Safety Act and Workplace Safety and Insurance Act.

Response Procedures

• Using the incident investigation form, the director, manager, or supervisor documents all reports of workplace violence/harassment, hazards and measures taken to address them.
• If the resolution of the incident is beyond the authority of a director, manager or supervisor, she/he must make the CEO or equivalent aware of the report. The CEO or equivalent involves other directors, managers, or supervisors in the investigation as appropriate (e.g., when the incident involves clients or workers under another manager’s or supervisor’s area of responsibility).
• Management reviews all incident reports, monitors trends and makes recommendations to the CEO or equivalent for prevention and enhancements to the workplace violence and harassment prevention
• These findings are shared with the JHSC, which is consulted about any revision to the violence and harassment prevention and training program.
• The CEO or equivalent reviews reports of workplace violence/harassment and ensures that actions are taken.
• The directors, managers or supervisors who investigate the reported incident warn all workers who might be affected about dangerous situation They also tell the reporting worker about the outcome of the investigation to help minimize the chance of similar incidents.
• If a violent incident results in a critical injury to a worker, the JHSC representative or worker-designate investigates the incident or injury (Section 9(31) OHSA) and reports to the MOL and JHSC.

Emergency Response Measures
Refer to the Step Training Inc. emergency response procedure.

Support for Workers Affected by Workplace Violence
Management will respond promptly, assess the situation, and ensure that these interventions are followed:

• facilitation of medical attention
• debriefing (by skilled professional)
• referrals to community agencies, treating practitioner and worker assistance program
• referral to trade union
• completion of incident reports, WSIB reports, reports to MOL (critical injury or fatality)
• reporting to police (as required)
• team debriefing

Risk Assessment
Management (with worker involvement) assesses workplace violence hazards in the job, and in the workplace as a whole. It reviews risk assessments annually, as well as when new positions are created, or position descriptions are changed substantially.

Education
New workers will receive both general and site-specific orientation to the workplace violence and harassment prevention program. In addition, all workers will receive an annual review of the program’s general and site-specific components.

Any training developed, established, and provided will be done in consultation with, and in consideration of, the recommendations of the JHSC.

Program Evaluation
The effectiveness of the workplace violence and harassment prevention program is evaluated annually by management and reviewed by the JHSC.

Directors, managers, supervisors and workers are accountable for establishing and implementing the policy and procedures related to workplace violence and harassment. Responsibility for complying with the health and safety policy is part of a directors’, manager’s, supervisor’s, and worker’s job description. Included in the health and safety components of job descriptions are management responsibilities for enforcing policy and procedures, investigating, and responding to workplace violence and harassment.

Accountability
All workplace parties are accountable for complying with the policy, program, measures, and procedures related to workplace violence.

Records
All records of reports and investigations of workplace violence and harassment are kept for five years.

Policy Review
This workplace violence and harassment prevention policy and program will be reviewed annually.