A harassment policy that predates Bill 132 does not meet today’s OHSA standard.
Neither does a generic template from the internet.
Certain policies are required by Ontario law. Most employers do not know which ones, or have policies that no longer reflect current legislation. Custom policies, drafted to the current legislative requirements of your specific workplace, are the compliance baseline, not a nice-to-have.
Bill 132 came into force September 8, 2016. If your workplace harassment policy has not been updated since, it does not meet the current OHSA program requirement.
Legally Required Policies
These policies are required by Ontario statute. Not having them -- or having a version that does not reflect current legislative requirements, is a specific compliance gap that a Ministry of Labour inspector will identify on first contact.
Workplace Harassment and Violence Policy
Must include a program with complaint procedures, investigation procedures, and review process. Generic templates do not meet the requirement.
Workplace Violence Policy
Required in every Ontario workplace. Must include a risk assessment process and procedures for workers to report threats.
Accessibility Policy
Required for employers with 1 or more employees. Multi-Year Accessibility Plan required for employers with 20 or more employees.
Pay Equity Plan
Employers with 10 or more employees must establish and maintain pay equity. Documentation requirements vary by workforce size.
Best Practice Policies
Not required by statute but standard practice in well-managed Ontario workplaces. These policies protect the employer by establishing clear expectations and creating the documentation framework needed for effective discipline and termination.
Pricing
Standalone policy drafted to legislative requirements. Includes one round of revisions.
Coordinated suite of related policies, typically harassment/violence, accommodation, and progressive discipline. Consistent in format and cross-referenced.
Complete employee handbook from scratch, covering all legally required policies plus core operational policies. Formatted for distribution and acknowledgment.
Review and update of an existing handbook to reflect current Ontario legislation, recent case law, and current workplace practices.
What to Expect
Every policy engagement starts with a scoping conversation to understand your workplace, size, industry, unionized or non-union, any known compliance gaps, and the specific situation that prompted the request. Generic policies built without context miss the specific risks of your workplace.
Policies are drafted to current Ontario legislative requirements, not to a template. Harassment policies reference the correct OHSA sections, accommodation policies reflect the current Ontario Human Rights Code framework and relevant case law from the HRTO, and discipline policies are built around the evidentiary standard that matters if you ever need to defend a termination.
Every policy includes one round of revisions. Policies are delivered in Word format for ease of implementation and future maintenance.
Scott’s knowledge of labour law and expertise in arbitration is outstanding. His ability to navigate complex workplace disputes with professionalism and fairness is exceptional. I have always been impressed by his very thorough knowledge and his ability to understand and resolve complex situations.
Not sure what your workplace actually needs?
Use the free Ontario HR Compliance Checklist to assess your current policy gaps, or book a free consultation to discuss your specific situation.