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Document Number: 99A

Date: 08 Sep 2022

Revision Number: 16

Anti-Harassment and Anti-Discrimination Policy

 Chinook Consulting / Chinook Petroleum Services (“the Company”) is committed to providing an environment free of discrimination and harassment, where all individuals are treated with respect and dignity, can contribute fully, and have equal opportunities.

Every person has the right to be free from harassment and discrimination. Harassment and discrimination will not be tolerated, condoned, or ignored at the Company. If a claim of harassment or discrimination is proven, disciplinary measures will be applied, up to and including termination of employment.

The Company is committed to a comprehensive strategy to address harassment and discrimination, including:

  • providing training and education to make sure everyone knows their rights and responsibilities
  • regularly monitoring organizational systems for barriers relating to Code grounds
  • providing an effective and fair complaints procedure
  • always promoting appropriate standards of conduct.

Policy Objectives

The objectives of this Policy are to:

  • Make sure that members, clients and associates of the Company are aware that harassment and discrimination are unacceptable practices and are incompatible with the standards of this organization, as well as being a violation of the law
  • Set out the types of behaviour that may be considered offensive and are prohibited by this policy.

Policy Application

The right to freedom from discrimination and harassment extends to all employees, including full-time, part-time, temporary, probationary, casual and contract staff, as well as volunteers, co-op students, interns and apprentices.

It is also unacceptable for members of the Company to engage in harassment or discrimination when dealing with clients, or with others they have professional dealings with, such as suppliers or service providers.

This policy applies at every level of the organization and to every aspect of the workplace environment and employment relationship, including recruitment, selection, promotion, transfers, training, salaries, benefits and termination. It also covers rates of pay, overtime, hours of work, holidays, shift work, discipline and performance evaluations.

This policy also applies to events that occur outside of the physical workplace such as during business trips or company parties.

Roles and responsibilities

All persons present in the Company are expected to uphold and abide by this policy, by refraining from any form of harassment or discrimination, and by cooperating fully in any investigation of a harassment or discrimination complaint.

Managers and supervisors have the additional responsibility to act immediately on observations or allegations of harassment or discrimination. Managers and supervisors are responsible for creating and maintaining a harassment- and discrimination-free organization and should address potential problems before they become serious.

Protected Grounds

This policy prohibits discrimination or harassment based on the following grounds, and any combination of these grounds:

  • Age
  • Creed (religion)
  • Sex (including pregnancy and breastfeeding)
  • Sexual orientation
  • Gender identity
  • Gender expression
  • Family status (such as being in a parent-child relationship)
  • Marital status (including married, single, widowed, divorced, separated, or living in a conjugal relationship outside of marriage, whether in a same-sex or opposite-sex relationship)
  • Disability (including mental, physical, developmental or learning disabilities)
  • Race
  • Ancestry
  • Place of origin
  • Ethnic origin
  • Citizenship
  • Color
  • Record of offences (criminal conviction for a provincial offence, or for an offence for which a pardon has been received)
  • Association or relationship with a person identified by one of the above grounds
  • Perception that one of the above grounds applies.

Key Concepts

The following behavior is prohibited: discrimination, harassment, sexual and gender-based harassment, sexual solicitation, poisoned environment

Discrimination: means any form of unequal treatment based on a Code ground, whether imposing extra burdens or denying benefits. It may be intentional or unintentional. It may involve direct actions that are discriminatory on their face, or it may involve rules, practices or procedures that appear neutral, but disadvantage certain groups of people. Discrimination may take obvious forms, or it may happen in very subtle ways. Even if there are many factors affecting a decision or action, if discrimination is one factor, that is a violation of this policy.

Harassment: means a course of comments or actions that are known, or ought reasonably to be known, to be unwelcome. It can involve words or actions that are known or should be known to be offensive, embarrassing, humiliating, demeaning or unwelcome, based on a ground of discrimination identified by this policy. Harassment can occur based on any of the grounds of discrimination.

Examples of harassment include:

  • Epithets, remarks, jokes or innuendos related to a person’s race, gender identity, gender expression, sex, disability, sexual orientation, creed, age, or any other ground
  • Posting or circulating offensive pictures, graffiti or materials, whether in print form or via e-mail or other electronic means
  • Singling out a person for humiliating or demeaning “teasing” or jokes because they are a member of a Code-protected group
  • Comments ridiculing a person because of characteristics that are related to a ground of discrimination. For example, this could include comments about a person’s dress, speech or other practices that may be related to their sex, race, gender identity or creed.

If a person does not explicitly object to harassing behaviour, or appears to be going along with it, this does not mean that the behaviour is okay. The behaviour could still be considered harassment under the Code.

Sexual and gender-based harassment: sexual harassment is a form of harassment that can include:

  • Gender-related comments about a person’s physical characteristics or mannerisms
  • Paternalism based on gender which a person feels undermines his or herself respect or position of responsibility
  • Unwelcome physical contact
  • Suggestive or offensive remarks or innuendoes about members of a specific gender
  • Propositions of physical intimacy
  • Gender-related verbal abuse, threats or taunting
  • Leering or inappropriate staring
  • Bragging about sexual prowess or questions or discussions about sexual activities
  • Offensive jokes or comments of a sexual nature about an employee or client
  • Rough and vulgar humour or language related to gender
  • Display of sexually offensive pictures, graffiti or other materials including through electronic means
  • Demands for dates or sexual favours.

Sexual Solicitation: this policy prohibits sexual solicitations or advances by any person who is in a position to grant or deny a benefit to the recipient of the solicitation or advance. This includes managers and supervisors, as well as co-workers where one person is in a position to grant or deny a benefit to the other. Reprisals for rejecting such advances or solicitations are also not allowed.

Poisoned environment: a poisoned environment is created by comments or conduct (including comments or conduct that are condoned or allowed to continue when brought to the attention of management) that create a discriminatory work environment. The comments or conduct need not be directed at a specific person, and may be from any person, regardless of position or status. A single comment or action, if sufficiently serious, may create a poisoned environment.