FRANÇAIS

Policy for the prevention of psychological and sexual harassment at work and complaints handling mechanism

The masculine generic is used in this text solely for the purpose of simplifying its form and making it easier to read.

1. POLICY OBJECTIVES

Entretien de Bureaux Martine inc. knows that the involvement and well-being of its employees are essential to the proper functioning of the company. In order to promote good collaboration between colleagues, we want to ensure that we promote values such as respect, equality and fairness.

This policy aims to ensure the physical and psychological integrity of its employees, to ensure a healthy and safe work environment, to prevent harassment and, if necessary, to offer support and intervene to stop it. Entretien de Bureaux Martine inc. has a “zero tolerance” approach towards all forms of harassment and is committed to taking the necessary and reasonable means to respond to it.

The objective of this policy is to establish a clear, effective and confidential process for reporting a situation of harassment observed or experienced and for processing complaints.


2. SCOPE OF APPLICATION

This policy applies to all employees - permanent or temporary, full-time or part-time - members of management, team leaders, customers, suppliers and subcontractors of Entretien de Bureaux Martine Inc.

It applies in the workplace, outside the workplace (on the road or at the head office) and on social media, during and beyond normal working hours when the situation may have repercussions in the workplace. This includes, but is not limited to, corporate or other co-worker events.


3. DEFINITION

This policy targets psychological and sexual harassment at work. The Act respecting labor standards defines harassment as vexatious conduct manifested by repeated behaviors, words or gestures:

  • who are hostile or unwanted;
  • which harm the dignity or psychological or physical integrity of the employee and
  • which make the workplace harmful.
This definition explicitly includes any vexatious conduct of a sexual nature and/or words with a sexual connotation.

A single serious conduct may constitute psychological or sexual harassment if it causes very significant harm and produces a continuing harmful effect on the employee.


4. SHARED RESPONSIBILITIES

A healthy, safe and harassment-free workplace is everyone's business. This implies that the employer, team leaders, employees and partners each have their own responsibilities to ensure proper application of the policy.


✔ Employer responsibilities
  • Appoint a person responsible for writing, disseminating, applying and interpreting the policy;
  • Distribute the policy to customers, suppliers and subcontractors;
  • Train employees and team leaders on harassment;
  • Appoint a person responsible for handling complaints;
  • Provide support to employees affected by a harassment complaint.
✔ Responsibilities of team leaders
  • Ensure pleasant working relationships within your team;
  • Treat any denunciation or situation seriously; And
  • Inform the person responsible for applying the policy of any complaint brought to their attention or of any behavior that could be considered harassment.
✔ Employee Responsibilities
  • Show respect towards employees, team leaders, employers, customers, suppliers, partners, etc.;
  • Report any situation of harassment experienced or brought to their attention;
  • Respect the policy.
✔ Partner Responsibilities
  • Show respect towards employees, team leaders, employers, customers, suppliers, etc.
  • Report any situation of harassment experienced or brought to their attention;
  • Respect the policy.

5. REPORTING AND PROCESSING COMPLAINTS

Entretien de Bureaux Martine Inc. wishes to regulate the process of denouncing, complaining and investigating a situation of harassment so that everyone is aware of the procedure to apply when an event of harassment is alleged.

In order to prevent situations of harassment, Entretien de Bureaux Martine inc. encourages anyone affected by an uncomfortable situation to report the situation to their team leader or management. The person who has been informed of a problematic situation must then become actively involved, in particular, to obtain their version of the facts and inform them of the informal and formal process of filing a complaint. With the complainant's agreement, Management may informally meet with the alleged harasser and attempt to reach a mutually satisfactory solution.


6. COMPLAINT HANDLING PROCESS

The employee, team leader or any other person covered by this policy who experiences a situation of psychological or sexual harassment may file a formal complaint.

To do this, the person who believes they are a victim of harassment must ask Management for a copy of the form provided for this purpose. All elements provided for in the form must have been completed before being submitted to Management.

Upon receipt of the complaint, Management must ensure that the complainant can indeed continue his work in a healthy and safe environment. To this end, all temporary measures deemed relevant by Entretien de Bureaux Martine inc. can be implemented such as a change of schedule or a suspension with pay.
While ensuring the confidentiality of the complainant, the Department informs the alleged harasser(s) of the complaint and the process that will be undertaken, of its impartiality and of the fact that they will have the opportunity to be heard if an investigation is necessary.

All actions taken in connection with an investigation will be confidential, unless required to be disclosed to permit an impartial investigation.


Investigation
Within a reasonable period of receipt of the complaint, the Directorate itself undertakes or, if it deems it more appropriate given its relationship with the persons involved, appoints a person responsible for the investigation process in order to collect the facts relevant to the processing of the complaint.
Entretien de Bureaux Martine inc. reserves the right to initiate an investigation on its own initiative if it has reason to believe that this policy has been violated.
In order to objectively handle the complaint, the following steps must be followed:

Step 1: Admissibility analysis
The admissibility analysis makes it possible to rule out complaints that are frivolous or which directly relate to the employer's right of management.

Step 2: Relevance to proceed with an investigation
If the complaint is clearly frivolous, an investigation does not need to be initiated. Management must then ask itself whether the problematic situation should be addressed outside the framework of this policy and notify the people concerned.
If the complaint is admissible, the formal investigation process must be triggered.

Step 3: Investigation
Following the initiation of the investigation, the person responsible draws up an investigation plan which identifies the people to meet and the documents to analyze. The entire process must be documented in writing. The preparation of interview outlines and invitations to interviews precede meetings with the identified parties, which are always conducted confidentially.

Step 4: Analysis, report and recommendations
The person responsible for the investigation then analyzes the information collected to write his report. The report is sent only and under confidential cover to the Management who will announce the conclusions of the investigation to the people concerned.

Entretien de Bureaux Martine inc. undertakes to act as quickly and diligently as possible in the face of any potential situation of harassment. An employee or team leader who applies this policy in good faith will under no circumstances be subject to retaliation by the employer.

Those involved in a complaint and investigation process recognize that their collaboration is essential to promote a workplace free of harassment.

In the interest of integrity and to ensure the relevance of this policy, any false or misleading statement made with the aim of harming a colleague or partner will be subject to disciplinary measures which may include dismissal.


7. CORRECTIVE MEASURES

In order to put an end to any situation of harassment, the employer undertakes to take the necessary and reasonable means, which may include, without limitation, depending in particular on the seriousness of the situation and the attitude of the people concerned:

  • Schedule change
  • Change of team leader or work team
  • Disciplinary measures depending on the seriousness of the actions (verbal or written notice, suspension)
  • Dismissal if necessary

8. POLICY ENFORCEMENT AND OTHER RESOURCES

The Management, represented by Martine Gascon (president) and Daniel Charlebois (vice-president), is responsible for the application, interpretation, updating and dissemination of the policy. Any employee or team leader is invited to contact her with any questions or to report an incident of harassment.

9. EVALUATION AND REVIEW

An evaluation report on the application of the policy will be carried out every 2 years or when required. Based on the results of the evaluation, Management determines whether it revises certain aspects of the policy. If applicable, any person covered by the policy will have to sign a new acknowledgment of receipt.

EFFECTIVE DATE OF THIS POLICY: 1 December 2023