Purple Carrots Drama Studio Inc. (herein referred to as ‘Purple Carrots’) 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. We are a community built on inclusion and diversity, and we are committed to creating an environment that does not discriminate based on race, sex, gender, age or ability. We have zero tolerance for racism, homophobia, transphobia, misogyny or ableism of any kind. We acknowledge that these systems of oppression are complex and weave through many areas of our work, which is why we are actively working to combat them and provide a safer space for our staff and participants. We recognize that in working with children and vulnerable adults, either directly or indirectly, we have a moral and legal responsibility to protect those within our care from both intentional and unintentional harm. In addition, we are focused on keeping children, consumers, and vulnerable peoples, in our programs safe from sexual, physical and mental abuse.

Under the Ontario Human Rights Code, every person has the right to be free from harassment, discrimination, and abuse. Harassment, discrimination and/or abuse of any kind will not be tolerated, condoned or ignored at Purple Carrots Drama Studio Inc.. If a claim of harassment or discrimination is proven, disciplinary measures will be applied, up to and including termination of employment.

Purple Carrots 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 – SEE BELOW
• promoting appropriate standards of conduct at all times.

The objectives of this Policy are to:

• Make sure that members, clients and associates of Purple Carrots 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.

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 Purple Carrots 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 (but not limited to) during business trips or company parties & events, as well as, via social media comments, direct messages and posts.

The Human Rights Code prohibits discrimination in five parts of society, called “social areas” – employment, housing, services, contracts and membership in trade, vocational and professional associations. Protection is offered based on 17 grounds (see below). This policy prohibits discrimination or harassment based on the following grounds, and any combination of these grounds:

• Age
• Creed (religion, etc.)
• Sex (including pregnancy and breastfeeding, etc.)
• Sexual orientation
• Gender identity
• Gender expression
• Family status (such as being in a parent-child relationship, etc.)
• 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, etc.)
• Disability (including mental, physical, neuro, developmental or learning disabilities)
• Race
• Ancestry
• Place of origin
• Ethnic origin
• Citizenship
• Colour
• 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.

As an Employee or Participant of Purple Carrots, the following behaviour is prohibited:

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, but are not limited to:

• 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 her self 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.

All persons 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.

ABUSE POLICY

Purple Carrots Drama Studio Inc. is fully committed to safeguarding the welfare of all children in our care, as well as vulnerable adults accessing our programs and services.  We recognize that in working with children and vulnerable adults, either directly or indirectly, we have a moral and legal responsibility to protect those within our care from both intentional and unintentional harm.     

Purple Carrots is committed to ensuring that it:

• Provides a safe environment for children and vulnerable adults
• Identifies children, young people and vulnerable adults who are suffering or likely to suffer or be harmed 
• Takes appropriate action to see that such children, young people and vulnerable adults are kept safe

As such, the Purple Carrots will:

• Respect the dignity and privacy of children  and vulnerable adults participating in our programs and services,
• Create an environment in which children  and vulnerable adults are valued, encouraged and affirmed
• Provide programming that promotes the health and safety of everyone and, as part of ongoing vigilance and continuous improvement, review practices and procedures to ensure this    
• Recruit, orient, train, supervise and support employees and volunteers to adopt best practices that safeguard and protect children  and vulnerable adults from abuse
• Require staff and volunteers, on an annual basis, to adopt and abide by this Abuse Protection Policy and Procedures, as well as any other code of ethics specific to their field
• Provide consistent procedures about identifying, reporting and dealing with allegations of  suspected abuse and neglect
• Monitor and evaluate the implementation of this Policy and these procedures, and adapt them as per legislative changes or to ensure best practices. 

We will, if we think a child is being abused, neglected or is at risk of significant harm, abide by our legal duty to report our concerns to the Ministry of Children, Community and Social Services (Ministry).                                                                                                                                             

TERMINOLOGY

Purple Carrots Drama Studio Inc. recognizes the following definitions:

A child is a person under 19 years of age and includes youth.  Note that a child may also be a staff or volunteer. A child in need of protection is defined by the Child, Family and Community Services Act and must be reported if:

• The child has been, or is likely to be, physically harmed by the child’s parent;
• The child has been, or is likely to be, sexually abused or exploited by the child’s parent;
• The child has been, or is likely to be, physically harmed, sexually abused or sexually exploited by another person, and if the child’s parent is unwilling or unable to protect the child;
• The child has been, or is likely to be, physically harmed because of neglect by the child’s parent;
• The child is emotionally harmed by: o the parent’s conduct, or o living in a situation where there is domestic violence by or towards a person with whom the child resides;
• The child is deprived of necessary health care;
• The child’s development is likely to be seriously impaired by a treatable condition and the child’s parent refuses to provide or consent to treatment;
• The child’s parent is unable or unwilling to care for the child and has not made adequate provision for the child’s care;
• The child is or has been absent from home in circumstances that endanger the child’s safety or well-being;
• The child’s parent is dead and adequate provision has not been made for the child’s care;
• The child has been abandoned and adequate provision has not been made for the child’s care;
• The child is in the care of a director or another person by agreement and the child’s parent is unwilling or unable to resume care when the agreement is no longer in force. 

Child abuse is any form of physical harm, emotional deprivation, neglect or sexual mistreatment which can result in injury or psychological damage to a child. The following definitions and examples will help you understand and respond to child abuse and neglect:

Physical abuse is any physical action by a person that harms, or could harm, a child. It includes hitting, kicking, slapping, shaking, burning, pinching, biting, choking, throwing, shoving and whipping. It also includes using unreasonable force to punish children or to prevent them from harming themselves or others. The child’s injuries may range from minor bruises, burns, welts or bite marks to broken bones or – in extreme cases – death.

Emotional harm is the most difficult to define and recognize.  It may range from habitual humiliation of the child to withholding life-sustaining nurturing.  It can include acts or omissions by those responsible for the care of a child, or others in contact with a child, that are likely to have serious, negative emotional impacts.  Emotional harm may occur separately from, or along with, other forms of abuse and neglect.

Emotional abuse can include a pattern of:

• Scapegoating;
• Rejection;                                                                                                                                                      
• Verbal attacks on the child;
• Threats;
• Insults; and
• Humiliation. 

Sexual abuse is when a person uses a child for sexual purposes. It can include:

• Sexually touching a child or inviting a child or  to touch; 
• Intercourse (vaginal, oral or anal); 
• Threatening sexual acts, obscene gestures or communications, or stalking; 
• Sexual references to the child’s body or behaviour with words or gestures;
• Asking the child to expose their body for sexual purposes; 
• Deliberate exposure of the child to sexual activity or material; or 
• Exposure to sexual aspects of organized or ritual abuse.

Sexual exploitation is when a child becomes involved in sexual activity, usually through manipulation or coercion, in exchange for things like money, drugs, food or shelter. Sexual activities include:

• Sexual acts; 
• Sex for the purpose of entertainment; 
• Escort or massage parlour services; and 
• Appearing in pornographic images.   

Neglect is failure to provide for a child’s basic needs by the parent or guardian, to the point where the child is, or could be, harmed. Neglect includes failing to provide a child with food, shelter, basic health care, supervision, nurturing or protection from risks.  Neglect is not always intentional, as it may be a result of insufficient resources or other circumstances beyond a person’s control.  The Ministry’s fundamental guiding principle is the safety and well-being of children, which states that a child needs protection if the child has been, or is likely to be, physically harmed due to neglect by the child’s parent.

Confidentiality – in most cases, your duty to report suspected child abuse or neglect overrides your duty to protect the privacy of clients, students, staff or colleagues. The only exceptions are: Solicitor-client privilege; and Confidentiality provisions of the federal Criminal Justice Act

All information relating to an abuse situation is considered confidential. Information concerning the allegation should not be shared with anyone who is not directly involved with the investigation or not directly involved with the care of the child. Discussion about the case among other staff and/or volunteers is not acceptable.

Please be warned: Discussing an allegation with any other individual can leave you open to liability for slander.

The Age of Consent for sexual activity is 16 years, however the age of consent is 18 years where the sexual activity “exploits” the young person, when it involves prostitution or pornography or occurs in a relationship of authority, trust or dependency.  The Criminal Code prohibits:

• Any sexual activity between an adult and a child under the age of 16;
• Any sexual activity between an adult in a position of trust, authority or dependency towards a child under the age of 18 years
• Any sexual activity without the consent of a child of any age.  (Depending on the activity, non-consensual sexual activity may constitute the criminal offence of sexual assault.)
• Use of children in prostitution and pornography. 

The criminal law recognizes that consensual “peer sex” is not an offence in the following situations:

• A 14 or 15 year old can consent to sexual activity with a partner as long as the partner is less than five years older and there is no relationship of trust, authority or dependency or any other exploitation of the young person, or 
• A 12 or 13 year old can consent to sexual activity with another young person who is less than two years older and with whom there is no relationship of trust, authority or dependency or other exploitation of the young person. 

DISCLOSURES

Direct disclosures: Sometimes children will tell you directly that they are being abused or neglected. They might begin with one example and see how you react. Research shows that children often tell about their experiences many times before action is taken to respond.   

Indirect disclosures: In other cases, children do not tell directly, but communicate what they have experienced indirectly – through their behaviours, emotions, art, writing, appearance, or inquiries or discussions about fears, concerns or relationships.  Children also divulge information through indirect statements, statements with conditions (e.g., “promise not to tell”) or third-party statements (e.g., “my friend’s parent is hurting her”).

3rd Party Disclosure:  In the event that a parent (or another individual) shares information around a disclosure or suspicion of abuse, the obligation to report also lies with the parent.  The parent needs to be informed of their duty to report and be encouraged to make the report to the Ministry.  The staff member who has been informed of the situation has the legal duty to report unless they witness the parent making the report.  If this does not occur, the staff member must follow the procedures to report the disclosure or suspicion of abuse.

Duty to Report:  If you think a child is being abused or neglected or is likely to suffer from abuse or be at risk of harm, as set out in the Act, you have the legal duty to report your concern to your local child welfare worker or Ministry. Failing to promptly report suspected abuse or neglect is a serious offence under the Child, Family and Community Service Act.  No action for damages will be brought against you for reporting information under the Child, Family and Community Service Act, unless you knowingly reported false information.                                                                                                                                                     

Ministry refers to the Ministry of Children, Community and Social Services. The Ministry has the lead responsibility for responding to suspected child abuse and neglect. It also delegates authority for child protection and family support to Aboriginal Child and Family Services Agencies, which provide services to their communities.

Position of trust or authority is created when an individual’s relationship with someone else has any of the following characteristics:  decision-making power, unsupervised access, closeness inherent in the relationship, a personal nature of the activity itself.

Risk of harm is the risk that a child or vulnerable adult is likely to be physically, sexually or emotionally abused or neglected.

Suspicion of abuse occurs when you have reason to believe a child or vulnerable adult is being abused or is at risk of harm.  Anyone who has reason to believe a child may be at risk – and the child’s parent is unwilling or unable to protect the child – has a legal duty to report that belief to a child welfare worker.  You do not have to be certain.  It is the Ministry’s role to investigate and determine abuse or neglect occurred.

A vulnerable adult is any adult aged 19 or over who:

• Receives or may need community care services because of a disability, age or illness, and/or 
• Is or may be unable to take care of themselves or protect themselves against significant harm or exploitation 

Examples of vulnerable adults may include:

• Older people, especially those who are unwell, frail, confused and unable either to stand up for themselves or keep track of their affairs, and 
• People who are open to abuse because of learning difficulties, physical disabilities or mental illness   

COMPLAINT & RESOLUTION POLICY & PROCEDURES

Seeking Immediate Assistance

Canada’s Criminal Code deals with matters such as violent acts, threats, and behaviours. The police should be contacted immediately when an act of violence has occurred in the workplace or when someone in the workplace is threatened with violence. If an employee feels threatened by a co-worker, volunteer, contractor, student, vendor, visitor, client, or customer, then an immediate call to “911” is required in addition to notifying your Supervisor.

Purple Carrots Drama Studio Inc. will:

Not engage in any form of bullying, harassment, violence, discrimination, or improper activity or behaviour;

Develop and maintain policy statements on bullying, harassment, and violence; take steps to prevent and minimize bullying, harassment, violence, discrimination, and improper activity or behaviour; Develop, implement, and maintain procedures for reporting incidents and complaints, including alternative reporting mechanisms where an alleged harasser is an employee’s manager; Develop, implement, and maintain procedures for investigating incidents and complaints; Ensure supervisors and employees are aware of steps to prevent bullying, harassment, violence, discrimination, and improper activity or behaviour in the workplace; Ensure employees and supervisors are properly trained in recognizing the potential for bullying, harassment, violence, discrimination, and improper activity or behaviour; Ensure supervisors and employees are aware of how to respond to incidents, and procedures for reporting; and Review this policy and procedures annually.

Supervisors/Management will:

Not engage in bullying, harassment, violence, discrimination, or improper activity or behaviour of any kind;

Comply with company policies and procedures regarding bullying, harassment, violence, discrimination, and improper activity or behaviour; Ensure employees adherence to policies and procedures regarding bullying, harassment, violence, discrimination, and improper activity or behaviour; Promote a respectful and safe working environment; Investigate complaints of bullying, harassment, violence, discrimination, and improper activity or behaviour promptly and impartially; Maintain a confidential file for complaints of harassment, bullying, violence, discrimination, and improper activity or behaviour investigations completed, and actions taken; Report the incident to police where appropriate; and apply appropriate disciplinary action where appropriate.

Employees will:

Treat others with respect, and contribute to a respectful and safe work environment; Report all acts of bullying, harassment, violence, discrimination, and improper activity or behaviour to management; and

Comply with company policies and procedures regarding workplace bullying, harassment, violence, discrimination, and improper activity or behaviour.

Witnessing Bullying, Harassment, Violence, Discrimination, or Improper Activity or Behaviour

It is the responsibility of all employees of Purple Carrots to promote a respectful and productive workplace. When employees do not speak up about the presence of bullying, harassment, violence, discrimination, or improper activity or behaviour, the employees tacitly condone the actions, and such actions may become more widespread.

Any employee who witnesses bullying, harassment, violence, discrimination, or improper activity or behaviour is directed to:

Offer the person support and inform them that you witnessed the incident; Encourage the person to come forward and let them know that you will be a witness and provide a statement in the event of an investigation.

In some cases, where the person decides to confront the individual informally, you may be asked to be a witness to the conversation (or as support).

Where the person does not wish to make a complaint, it is still important that management is aware of the bullying, harassment, discrimination, violent act, or improper activity or behaviour taking place in the workplace. Tell your manager what you witnessed so that this type of behaviour can be eliminated.

Reporting Bullying, Harassment, Violence, Discrimination, or Improper Activity or Behaviour

Informal:

If you are being bullied or harassed, or have been a victim of violence, discrimination, or improper activity or behaviour: Immediately inform the person perpetrating the actions that their actions are unacceptable to you.

Describe the specific actions that they took that caused you to feel uncomfortable. When confronted, in many instances, the person will stop. Sometimes a person is unaware that they are acting unacceptably. This may also prevent the act from escalating and possibly becoming dangerous. It is important to keep a record of dates and times where you have spoken to the person who has committed the act of bullying, harassment, violence, discrimination, or improper activity or behaviour and inform your manager or supervisor of what occurred.

If the actions continue, employees should use the formal reporting process.

Formal:

If bullying, harassment, violence, discrimination, or improper activity or behaviour either continues to occur after a conversation with the individual, or is extreme or dangerous in nature, employees must report it immediately to their supervisor or upper management.

Process:

Speak with your supervisor or manager, and report the incident. If your supervisor or manager is the cause of the concern, speak with another member of management to report the incident. Write out a statement detailing the incidents including: the names of the parties involved; any witnesses to the incident; the location, date, and time of the incident; details about the incident (behaviour or words used); and any additional details that would help with an investigation. An investigation will be initiated. Where it is determined that the person has breached the law, the appropriate authorities will be contacted.

All complaints will be taken seriously and investigated fairly.

Employees who submit a report or complaint of bullying, harassment, violence, discrimination, or improper activity or behaviour will not be subject to any form of reprisal or retaliation as a result of the complaint.

Employees should be aware that the company does not support any retaliation even where the complainant has not used any of the reporting mechanisms.

Investigating Reports of Bullying, Harassment, Violence, Discrimination, or Improper Activity or Behaviour

Once a written complaint has been received, the company will complete a thorough investigation. The investigation will begin immediately after receiving the complaint. Bullying, harassment, violence, discrimination, and improper activity or behaviour will not be ignored. Silence can be, and often is, interpreted as acceptance. The investigation will be conducted in a timely manner.

For the purposes of this section, the following definitions apply:

Complainant: The person who has made a complaint about another individual whom they believe has bullied or harassed them, or committed an act of violence, discrimination, or improper activity or behaviour against them.

Respondent: The person whom another individual has accused of committing an act of bullying, harassment, violence, discrimination, or improper activity or behaviour.

The investigation will include:

Informing the respondent of the complaint; Interviewing the complainant, any person involved in the incident, and any identified witnesses. Interviewing any other person who may have knowledge of the incidents related to the complaint or any other similar incidents.

A copy of the complaint, detailing the complainant’s allegations, will then be provided to the respondent.

The respondent is invited to reply in writing to the complainant’s allegations, and the reply will be made known to the complainant before the case proceeds further.

The company will do its best to protect from unnecessary disclosure the details of the incident being investigated and the identities of the complaining party and alleged respondent.

During the investigation, the complainant and the respondent will be interviewed, as will any possible witnesses. Statements from all parties involved will be taken and a decision will be made.

Where it is determined that harassment has occurred, a written report of the remedial action will be given to the employees concerned.

All documents related to the formal investigation will be maintained in a sealed envelope within a locked cabinet.

Disciplinary Actions

If the findings of the investigation indicate that a violation of this policy has occurred, immediate and appropriate disciplinary action, up to and including dismissal, will be administered. Other corrective actions may include an employee transfer (where the complainant desires the transfer, it will be provided to them but in all other cases, the respondent will be transferred). In addition, the company will monitor the situation between the employees to ensure that the action does not reoccur. In the event of an incident with a participant, all employees or volunteers identified in such incidents of inappropriate behaviour or alleged incidents of Abuse will immediately be redeployed away from all “vulnerable persons” pending the outcome
of the investigation conducted by the appropriate authorities. Corrective actions will be proportional to the severity or frequency of the offence.

Appeal Process

If the complainant or respondent feel that the process has failed at some point, or that the corrective action is not consistent with the incident that led to the original complaint, they can appeal the final decision or outcome. The employee must complete a written complaint form and submit it to senior management. The form should include all of the reasons why the employee did not feel that the process was equitable. Where necessary, further investigation will be initiated.

Fraudulent or Malicious Complaints

This policy must never be used to bring fraudulent or malicious complaints against employees. It is important to realize that unfounded or frivolous allegations of bullying, harassment, violence, discrimination, or improper activity or behaviour may cause both the respondent and the company significant damage. If the company determines that any employee has knowingly made false statements regarding an allegation of bullying, harassment, violence, discrimination, or improper activity or behaviour, immediate disciplinary action will be taken. As with any case of dishonesty, disciplinary action may include immediate dismissal without further notice.

Confidentiality

Purple Carrots will attempt, in all cases, to maintain the confidentiality of the complainant and respondent. While it is not always possible to do so when soliciting witness statements, the company will not release any information to other employees which would jeopardize the confidentiality of the parties involved. Where it is determined that legislation or law was contravened, the company will supply any and all evidence to the authorities as necessary, in accordance with applicable legislation.

Providing Support

Purple Carrots is committed to the wellbeing of all employees. Where there has been an incident of bullying, harassment, violence, discrimination, or improper activity or behaviour, the company will ensure that the necessary support is provided to employees. Employees who feel adverse symptoms as a result of an incident are encouraged to speak with a member of management so necessary support can be provided.

Report neglect or abuse If you have reason to believe a child is being abused or neglected, call the Ministry of Children, Community and Social Services – see below:

Local Number(s): 416-325-5666 and/or 416-325-5225

Toll-Free Number: 1-888-789-4199

TTY: 1-888-387-5559