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Prime International College Workplace Anti-violence, Harassment and Sexual Harassment Policy

Updated: Mar 21

Intent

Prime International College of Health Care and Technology is committed to building and preserving for its students and employees a safe, productive, and healthy working environment based on mutual respect. In pursuit of this goal, Prime International College of Health Care and Technology does not condone and will not tolerate acts of violence, harassment, or bullying against or by any Prime International College of Health Care and Technology student or employee. 


Our Anti-violence, Harassment, and Sexual Harassment Policy is not meant to stop free speech or to interfere with everyday interactions. However, what one person finds inoffensive, others may not. Usually, harassment can be easily distinguished from normal, mutually acceptable socializing. It is important to remember that it is the perception of the receiver that determines whether the potentially offensive message is acceptable or not, be it spoken, gestural, pictorial, or some other form of communication which may be deemed objectionable or unwelcome. 


Definitions

School violence: school violence is the exercise, statement, or behaviour of physical force by a person against a student, in a school or clinical placement facility, that causes or could cause physical injury to the student, such as:

  • Physical acts (e.g., hitting, shoving, pushing, kicking, sexual assault, throwing an object at a student, or trying to run down a student using a vehicle or equipment); 

  • Any threat, behaviour, or action which is interpreted to carry the potential to harm or endanger the safety of others, result in an act of aggression, or destroy or damage property; or

  • Disruptive behaviour that is not appropriate to the school environment (e.g., yelling or swearing). 

Domestic violence: a person who has a personal relationship with a student—such as a spouse or former spouse, current or former intimate partner or a family member—may physically harm, or attempt or threaten to physically harm, that student in school. In these situations, domestic violence is considered school violence. 


Personal harassment: any unsolicited, unwelcome, disrespectful, or offensive behaviour that has an underlying sexual, bigoted, ethnic, or racial connotation and can be typified as:

  • Behaviour that is hostile in nature, or intends to degrade an individual based on personal attributes, including age, race, nationality, disability, family status, religion, gender, sexual orientation, gender identity, gender expression, or any other protected ground under human rights legislation. 

  • Sexual solicitation or advance made by a person in a position to confer, grant, or deny a benefit or advancement to the person, where the person making the solicitation or advance knows or ought reasonably to know that it is unwelcome;

  • Reprisal or a threat of reprisal for the rejection of a sexual solicitation or advance where the reprisal is made or threatened by a person in a position to confer, grant, or deny a benefit or advancement to the person. 

  • Unwelcome remarks, jokes, innuendos, propositions, or taunting about a person’s body, attire, sex or sexual orientation, or religion;

  • Suggestive or offensive remarks;

  • Bragging about sexual prowess;

  • Offensive jokes or comments of a sexual nature about an employee;

  • Unwelcome language related to gender;

  • Displaying of pornographic or sexist pictures or materials;

  • Leering (suggestive persistent staring);

  • Physical contact such as touching, patting, or pinching, with an underlying sexual connotation;

  • Sexual assault:

  • For the most part, victims of sexual harassment are female; however, conduct directed by female students towards males or between persons of the same sex can also be held to constitute sexual harassment;

  • Any actions that create a hostile, intimidating, or offensive workplace, which may include physical, verbal, written, graphic, or electronic means; and

  • Any threats of physical violence that endanger the health and safety of the student. 

Racial/ethnic harassment: any conduct or comment which causes humiliation to a student because of their racial or ethnic background, their colour, place of birth, citizenship, or ancestry. Examples of conduct which may be racial or ethnic harassment include:

  • Unwelcome remarks, jokes, or innuendos about a person’s racial or ethnic origin;

  • Colour, place of birth, citizenship, or ancestry;

  • Displaying racist or derogatory pictures or other offensive material;

  • Insulting gestures or practical jokes based on racial or ethnic grounds which create awkwardness or embarrassment; and

  • Refusing to speak to or work with someone or treating someone differently because of their ethnic or racial background.

Guidelines

Prime International College of Health Care and Technology is committed to providing a safe and healthy school environment, free from violence, threats of violence, discrimination, harassment, sexual harassment, intimidation, and any other misconduct. Similarly, weapons are strictly prohibited from the school premises; violators will be subject to disciplinary action, and the incident will be reported to the police. 


It is also a violation of the Anti-violence, Harassment, and Sexual Harassment Policy of Prime International College of Health Care and Technology for anyone to knowingly make a false complaint of violence or harassment or to provide false information about a complaint. Individuals who violate this policy are subject to disciplinary and corrective action, up to and including counseling, formal warning, or dismissal.


This policy prohibits reprisals against individuals acting in good faith who report incidents of workplace violence or act as witnesses. Management will take all reasonable and practical measures to prevent reprisals, threats of reprisal, or further violence. Reprisal is defined as any act of retaliation, either direct or indirect. 


Prime International College of Health Care and Technology has developed the Anti-violence, Harassment and Sexual Harassment Policy with student input. A copy of this policy will be made available to all students as part of the enrolment contract and is posted within school premises visible to students. The college will provide or make available training on its sexual violence and harassment policy to owners, managers, staff and students.


Application of this Policy

This policy applies to all students and individuals working for the college, including employees, instructors, managers, officers, and directors. The organization will not tolerate violence or harassment, whether engaged in by students, employees, managers, officers, and directors of the college. 


Prime International College of Health Care and Technology will not tolerate any form of harassment or discrimination against students and employees on any grounds listed in the definitions for violence and harassment, whether during enrolment, classes, clinical placement, hiring process, or during employment. This commitment applies to such areas as training, performance assessment, transfers, remuneration, and all other instruction practices and working conditions. 


All Prime International College of Health Care and Technology students and employees are personally accountable and responsible for enforcing this policy and must make every effort to prevent discrimination or harassing behaviour and to intervene immediately if they observe a problem or if a problem is reported to them. 


For the purposes of this policy, harassment and bullying can occur in:

  • school campus

  • clinical placement facility

  • At school-related social functions;

  • In the course of work assignments outside school;

  • During school-related travel;

  • Over the telephone, if the conversation is school related; or

  • Elsewhere, if the person is there as a result of school related responsibilities or a school-related relationship.

Violence Risk Assessment

Prime International College of Health Care and Technology will conduct a risk assessment of the school environment to identify any issues related to potential violence that may affect the operation of the college, and will institute measures to control any identified risks to student safety. This information will be provided to the joint health and safety committee or safety representative.


The risk assessment may include review of records and reports: e.g., security reports, incident reports, health and safety inspection reports, first aid records, or other related records. Specific areas that may contribute to risk of violence may include, but are not limited to, contact with the public, exchange of money and working alone or at night. Research may also include a review of similar workplaces with respect to their history of violence.


Prime International College of Health Care and Technology will communicate information relating to a person with a history of violence where:

  • Students may reasonably be expected to come into contact with the person in the performance of their job duties; and

  • There is a potential risk of campus violence as a result of interactions with the person with a history of violence. 

The college will only disclose personal information that is deemed reasonably necessary to protect the student from physical harm.


Reporting Violence or Bullying

If you are either directly affected by or witness to any violence on campus, it is imperative for the safety of all Prime International College of Health Care and Technology students that the incident be reported without delay. Reporting any violence or potentially violent situations should be done immediately to management, or the Human Resources department.


Investigating Reports of Violence or Bullying

Prime International College of Health Care and Technology shall:

  • Investigate all reported acts and incidents of violence, and consult with other parties (e.g., legal counsel, health and safety consultants, JHSCs, student assistance provider, human rights office, local police services).

  • Take all reasonable measures to eliminate or mitigate risks identified by the incident.

  • Document the incident, its investigation, and corrective action taken. 

  • Provide information to the Superintendent concerning :

  1. the number of times supports, services, and accommodation relating to sexual violence are requested and obtained by student;

  2. any initiatives and programs to promote awareness of supports and services available to students, and ;

  3. the number of incidents and complaints of sexual violence reported by students and the implementation and effectiveness of its sexual violence policy.

  • Upon providing information to the Superintendent, shall not include personal information within the meaning of Freedom of Information and Protection of Privacy Act.

  • Review this policy and hazard assessment at least once every three (3) years and to amend it as appropriate. 

Reporting Discrimination or Harassment

The college will accommodate the needs of students affected by sexual violence at no cost to the students.

A formal report of an incident of sexual violence is not necessary to access supports, services, or accommodations.


Informal Procedure

If you believe you have been personally harassed you may:


Confront the harasser personally or in writing pointing out the unwelcome behaviour and requesting that it stop; or

  • Discuss the situation with the harasser’s instructor, your instructor or any other instructor other than your own. 

Any student who feels discriminated against or harassed can and should, in all confidence and without fear of reprisal, personally report the facts directly to your instructor or school administrator, or to another member of management if the complaint relates to your instructor or administrator. 


Formal Procedure

If you believe you have been personally harassed, you may make a written complaint. The written complaint must be delivered to (College Representative/Job Title). Your complaint should include:

  • The approximate date and time of each incident you wish to report;

  • The name of the person or persons involved in each incident;

  • The name of any person or persons who witnessed each incident; and

  • A full description of what occurred in each incident.

Investigating Reports of Discrimination or Harassment

Once a written complaint has been received, Prime International College of Health Care and Technology will complete a thorough investigation. Harassment should not be ignored, as silence can and often is interpreted as acceptance. Students will not be suspended, dismissed, or disciplined because they rejected sexual advances or because they lodged a complaint when they honestly believed they were being harassed or discriminated against.


Prime International College of Health Care and Technology will ensure that all information obtained during the course of an investigation will not be disclosed, unless the disclosure is necessary for the purposes of investigating or taking corrective action, or is otherwise required by law.


For the purposes of this section the following definitions apply:

Complainant – The person who has made a complaint about another individual whom they believe committed an act of violence, discrimination, or harassment against them. 

Respondent – The person whom another individual has accused of committing an act of violence, discrimination, or harassment. 


The investigation will include:

  • Informing the respondent of the complaint;

  • Interviewing the complainant, any person involved in the incident, and any identified witnesses; and

  • 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, is then 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 investigation proceeds further. 

  • The college will protect from unnecessary disclosure the details of the incident being investigated and the identities of the complainant and the 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 documented, and a decision will be made. 

  • If necessary, the college may employ outside assistance or request the use of legal counsel.

  • Students will not be suspended, dismissed, disciplined because they rejected sexual advances of another student or school employee or because they lodged a harassment complaint when they honestly believed they were being harassed. 

  • Upon completion of the investigation, Prime International College of Health Care and Technology will inform both the complainant and respondent in writing of the findings of the investigation and any corrective action that has been or will be taken as a result of the investigation.

If the complainant decides not to lay a formal complaint, senior management may decide that a formal complaint is required (based on the investigation of the incident) and will file such documents with the person against whom the complaint is laid (the respondent). 


If it is determined that harassment in any form has occurred, appropriate disciplinary measures will be taken as soon as possible. 


Seeking Immediate Assistance

Canada’s Criminal Code addresses violent acts, threats, and behaviours, such as stalking. The police should be contacted immediately when an act of violence has occurred on campus or when someone on campus is threatened with violence. If a student feels threatened by another student, instructor, school employee, visitor, an immediate call to “911” is required.


Special Circumstances 

Should a student have a legal court order (e.g., a restraining order, or “no-contact” order) against another individual, the student is encouraged to notify his or her instructor and to supply a copy of that order to the Human Resources department. This will be required in instances where the student strongly feels that the aggressor may attempt to contact that student at Prime International College of Health Care and Technology, in direct violation of the court order, so that Prime International College of Health Care and Technology may take all reasonable actions to protect the student. Such information shall be kept confidential and protected in accordance with all applicable legislation.


If any visitor to the Prime International College of Health Care and Technology campus is seen with a weapon (or is known to possess one), or makes a verbal threat or assault against a student or another individual, student witnesses are required to immediately contact the police, emergency response services, their instructor, and the Human Resources department. 


All records of harassment and subsequent investigations are considered confidential and will not be disclosed to anyone except to the extent required by law. 

In cases where criminal proceedings are forthcoming, Prime International College of Health Care and Technology will assist police agencies, lawyers, insurance companies, and courts to the fullest extent.


Fraudulent or Malicious Complaints 

This Anti-violence, Harassment, and Sexual Harassment Policy must never be used to bring fraudulent or malicious complaints against students. It is important to realize that unfounded or frivolous allegations of personal harassment may cause both the accused person and the school significant damage. If it is determined by the college that any student has knowingly made false statements regarding an allegation of personal harassment, immediate disciplinary action will be taken.


Disciplinary Measures

If it is determined by the college that any student has been involved in a violent behaviour, unacceptable conduct, or harassment of another student, immediate disciplinary action will be taken. Such disciplinary action may involve counselling, a formal warning, suspension, or dismissal. 


Confidentiality

Prime International College of Health Care and Technology will do everything it can to protect the privacy of the individuals involved and to ensure that complainants and respondents are treated fairly and respectfully. Prime International College of Health Care and Technology will protect this privacy so long as doing so remains consistent with the enforcement of this policy and adherence to the law. Neither the name of the person reporting the facts nor the circumstances surrounding them will be disclosed to anyone whatsoever, unless such disclosure is necessary for an investigation or disciplinary action. Any disciplinary action will be determined by the school and will be proportional to the seriousness of the behaviour concerned. 


Prime International College of Health Care and Technology will also provide appropriate assistance to any student who is the victim of violence, discrimination, or harassment. 


Managing and Coaching

Counselling, performance appraisal, work assignment, and the implementation of disciplinary actions are not forms of harassment, and this policy does not restrict the school administrator's responsibilities in these areas.


Policy Review

Prime International College of Healthcare and Technology will review this policy at least every three years and will post the policy in a conspicuous place in school campus.


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