Workplace Viol Policy PROPAKCY Poli Fcc [Rasika eae —— Tessa its Workplace ViolencePolk Die Zboriallsiies/HumanResouroas (and) APC Section 15 1. Objective of Policy To convey Propak’s commitment to a safe and healthy workplace; to promote anti- violence education; to communicate that an act of workplace violence is a serious offence for which disciplinary actions will take place; to encourage those subjected to acts of workplace violence to seek assistance; to advise individuals of available recourse if they are subjected to or become aware of acts of workplace violence as per OHS Code, Part 27 and Alberta Human Rights Act Section 7. 2. Scope All employees, contractors and visitors at the workplace. 3, Our Commitment Propak is committed to investigating reported incidents of workplace violence in an objective and timely manner, taking necessary action to respond to those incidents, and providing support for complainants. 4, Definitions a) Workplace: includes, but is not limited to, all areas of the actual worksite; Propak related social functions outside the company facilities or job sites; work assignments outside of Propak; at work-related conferences or training sessions; during work-related travel; away from work but related to work and internal and external workplace ‘communications whether through company owned or personal internet sites/email and/or telephone or text messaging, b) Workplace Violence means the threatened, attempted, or actual conduct of a person that causes or is likely to cause physical injury or intimidation, whether work related or at a work site. Examples of workplace violence include, but are not limited to: i. threatening behavior such as shaking fists, destroying property or throwing objects verbal or written threats that express intent to inflict harm horseplay and practical jokes physical attacks v. any other act that would arouse fear in a reasonable person in the circumstances Vi. possession of a weapon, explosive devises, imitation explosive devises, imitation Weapon, firearm or firearm replica at the workplace. ©) Horseplay means any rough or rowdy behavior including practical jokes and the misuse of materials and equipment. d) Health and Safety Committee The Health and Safety Committee is made up of employees and managers representing the shops. The purpose of the Health and Safety Committee is to help promote safe work practices, review incidents and other safety issues and make recommendations. €) Investigation Coordinator is a senior staff member who, in conjunction with the Human Resources and Safety Departments, is responsible for ensuring appropriate personnel are conducting all aspects of the investigation. Please check with Safety or Human Resources for the name of the current Investigation Coordinator.| Workplace Violence Policy z PROPAKCY Policy # Revlon Dae JTS, 2070 [Page ai3 ‘TporalsitesTlumanRtesources/Polcies/Documen's/ Workplace Violenceoik (and ) APC Section 15 ) Mediation: An informal process whereby a neutral party assists participants to voluntarily negotiate a solution that will address their concems. 8, Prohibited Conduct No employee or any other individual affiliated with Propak shail subject any other person to workplace violence, or allow or create conditions that support workplace violence. 6. Procedures a) If you or someone else is subjected to workplace violence the following steps will tell you what to do and exactly what you can expect from the complaint process, what the possible remedies and penalties for workplace violence are, and how to give feedback on the policy to Propak: i, Removal: if you feel you are in danger of physical harm remove yourself from the situation as quickly as possible and seek assistance. Review Appendix A, Tips for Preventing and Managing Incidents of Violence or Harassment ii, Speak up: let your objections to the behaviour be known to the alleged a. offender either directly or ask a third party such as a supervisor, Human Resources or Safety representative for assistance. iii, Make notes: carefully record details of the incident including the date and time of the incident, the nature of the violent behaviour, and names of people who may have witnessed the incident. These will be useful later, if there is an investigation. b) Informal procedures i. Speak to your Supervisor, Human Resources Advisor or Health, Safety and Environment Advisor or Safety Department personnel. It may be that ‘communicating directly with the person will not be enough, or that you feel unable to deal with her or him directly. ji, The person you speak to will ask you for details of what happened, make sure you understand the policy and ask how you want to proceed. ili, You may ask them to help you write a letter or to speak to the other party on your behalf. iv. You may ask them to arrange for mediation between you and the other party. v. If these attempts to resoive the situation don't work, you can also ask the Human Resources Advisor or Health, Safety and Environment Advisor to help you file a formal complaint. ¢) Mediation: If the circumstances permit it, mediation can come before a formal investigation. If you want to work toward a mediated settlement, the Human Resources Advisor will mediate or if the Human Resources Advisor is a party to the complaint the Health and Safety Advisor in conjunction with the Investigation Coordinator will appoint a qualified mediator who is acceptable to both parties, is not otherwise involved in the complaint, and who will not be asked to represent the company at any stage of any proceedings related to the complaint. However, either party has the right to refuse mediation. If mediation does occur, each person has the right to be accompanied during the sessions by a co-worker or supervisor with whom they feel comfortable.PROPAK: E ‘Workplace Violence Policy —] cy Policy # __| Rowson Date Jay 15 2570 [Page sof 5 iparalsites/HumanResources Polies/Documbents/WorkolaceViolencePolicy pd (and) APC Section 15 : 4) Formal Complaints: The Complainant may choose to file a formal written complaint ‘that documents their concerns to the Health Safety and Environment Advisor or the Human Resources Advisor. You will need to provide the following information: i, name and position; ji, the name and position of the alleged offender, il, details of what happened; iv. dates, times, and how often these things occurred; v. where they happened; and vi. the names of any witnesses. The Health, Safety and Environment Advisor or the Human Resources Advisor will conduct a meeting as soon as possible with the employee(s) who has been subjected to workplace violence. The employee may be advised to seek medical assistance and will be encouraged to use the Employee and Family Assistance Program as per OHS Part 18, 8392(2) 7. The Investigation and Subsequent Action ) Upon receipt of a formal complaint of workplace violence the Health and Safety Manager and/or the Human Resources Manager will i. _ advise both parties involved in writing of the investigation and nature and specifics of the complaint; ii. assign the investigation to an internal person, either a member of the Health and Safety Team or Human Resources, or if necessary, an external person to investigate. ili, advise all parties to the investigation that they may have representation from a trusted supervisor or a peer. iv. explore all allegations by interviewing the Complainant, the Respondent, and a. others who may have knowledge of the incident(s) or circumstances that led to the complaint, or are responsible for the workplace. ) The investigator may make a finding of i. sufficient evidence to support a finding of violation of this policy, ji. insufficient evidence to support a finding of violation of this policy, or no violation of this policy. ©) Separation of the Complainant and Respondent: If the Complainant and the Respondent are in a subordinate/supervisor relationship, one or both of them may be assigned to a different work area during mediation or investigation. Co-workers may also be separated during an investigation. The Respondent may be sent home with pay pending investigation. This is not a punitive measure but, rather, a step intended to deescalate the situation. The respondent may be required to take part in a mandatory Employee Assistance Program. Acts of Workplace violence may result in Drug and Alcoho! Testing for reasonable cause. Please refer to drug and alcohol policy. ) Conclusion of Investigation: The investigator will prepare a written report of the investigation’s finding, and forward that report to the Human Resources Manager, Health, Safety and Environment Advisor; Investigations Coordinator or the appropriate VP within thirty (30) working days from the time the employee accused of violence isWorkplace Violence Policy PROPAKcCY Policy # - __ — Revision Dato July 13,200 | Pageaots | hilpupertalsitesMiumant [ces/Documents/Workplace ViolenceP oli. od 1 {and ) APC Section 18 Eocene advised of the complaint. The Safety Advisor in consultation with Human Resources and Management will make a decision whether to dismiss or act upon the report from the investigator within thirty (30) working days of receiving the report and advise both parties in writing of the outcome, 4) Record Keeping: The documents corresponding to the investigation will be kept on file in a secured location, separate from the Complainant and Respondent's personnel files, for two years from the date of the incident to be readily available for inspection by anyone directly affected by the incident, or an Occupational Health and Safety Officer ‘The investigation report may be kept in a secured location for longer than two years when itis reasonable to do so in the circumstances. Examples of reasonable circumstances include: for the program manager to evaluate the workplace violence policy, and to monitor persons of ongoing concern. 8. Corrective Action and Discipline ) The following conditions will be considered when determining corrective action: i. the impact of the incident on the Complainant; ii, the nature of the incident; iii, the degree of aggressiveness and physical contact iv. the period of time and frequency of the incidents; v. _ the vulnerability of the complainant (example: an imbalance of power, or the complainant has a disability) b) Someone who has committed an act of workplace violence against another person will be subject to one or more of the following forms of discipline, depending on the severity of the incident: vi, training i. reassignment or relocation suspension, with or without pay criminal charges x. awritten reprimand xi. ademotion xii, mandatory referral to EAP xiii, termination ¢) A post incident follow-up with the complainant will take place with the Human Resources advisor or the Health, Safety and Environment Advisor within 14 days of incident and within 30 days of resolution. 8.1 Unsubstantiated complaints: If a person, in good faith, files a complaint that is not ‘supported by evidence gathered during an investigation, that complaint will be dismissed, and no record of it will be put in the accused employee's file. As long as the complaint was made in good faith, there will be no penalty to the person who complained, and no record in her or his file.evision Date Juy 18,2010 [Page 59 i rxnlace ViolencePoli PRO P, A K Cy Workplace Violence Policy i Lend) APC Section 15 8.2 Complaints made in bad faith: If an investigation results in a finding that the ‘Complainant falsely acoused the Respondent of workplace violence knowingly or in a malicious manner, the Complainant will be subject to appropriate sanctions, including the possibility of termination. Such action is considered a violation of the policy, and the investigation results and any disciplinary action will be recorded in the Complainant's personnel records. 8.3 Confidentiality: While Propak cannot guarantee confidentiality, the company will pursue confidentiality in ali aspects of the procedure. Investigators, Human Resources Advisors and managers will not disclose a complainant's or respondent's name, or any circumstances related to a complaint, to anyone, except as necessary to investigate the ‘complaint or take disciplinary action related to the complaint, or as required by law. Gossiping about an incident seriously undermines the privacy of all parties involved and. will not be tolerated. Those with questions or concerns about an incident should speak to the Human Resources Advisor or the Health and Safety Advisor. 8.4 Retaliation: All persons involved in the processing of a complaint will ensure that the Complainant is neither penalized nor subjected to any prejudicial treatment as a result of making the complaint. Disciplinary action will be taken against any person who takes any reprisal against a person who reports workplace violence. 8.5 Other Options: Nothing in this policy precludes a victim of violent behaviour from seeking assistance of outside agencies or laying criminal charges. 9. Responsibil a) Managers’ Responsibilities This section contains an outline of how you should conduct yourself in relation to employment, and how to handle cases of workplace violence i. report all incidents of workplace violence to the Safety Department; develop workplace arrangements that minimize the risk of workplace violence; promote a non-violent workplace; ensure that this policy is explained to all employees that you supervise or manage: v. identify training needs for employees; vi. ensure that employees understand who to contact regarding concerns about the policy or when reporting an incident, vii, ensure your own immediate physical safety if an incident of workplace violence ‘occurs, then report criminal behavior to the appropriate law enforcement agency; vil, ensure the security and safety of all parties invoived during an investigation of an incident of workplace violence. ix. Communicate Emergency Response Plan to employees. x. Execute evacuation procedures as necessary following the appropriate Emergency Response Plan b) Employees’ Responsibilities i,” attend all violence and harassment related training including emergency response plan trainingWorkplace Violence Policy PROPAKCY Policy # | Raison Da aS ODT Page sot ‘it /poralsies/Humeniesources/Polices/Documents/NVorkplace ViolencePolicy nat i (and ) APC Section 15. | abide by this policy at all times participate in education programs ensure your own immediate physical safety in the event of workplace violence, and then report the incident to a supervisor or manager or the police as the situation warrants; V. co-operate with investigations and resolutions vi. be familiar with Emergency Response Plan and follow as directed. vii Inform Safety and/or Human Resources departments of all acts of workplace violence c) Human Resources and Safety Departments’ Responsibilities i. promote respectful workplace ii, educate all staff on policy iii, assist Managers in educating employees on emergency response procedures iv. investigate all incidents in a timely fashion v. _ make appropriate use of internal and external resources. 4d) Shared Responsibilities i. act respectfully towards other individuals while at work and participating in any work-related activity; maintain confidentiality when appropriate while investigations of violence are in process ili, participate in post abuse debriefing sessions as directed iv. provide moral support to co-workers who are victims of abuse v. _ in the case of serious injury or death reporting procedures as per OHS Code Section 18 will be followed 10. Consequences Violation of the workplace Violence Policy will result in disciplinary measures up to and including termination and criminal charges. Weapons, imitation weapons, explosive devises, imitation explosive devises, firearms and/or firearms replicas brought to the workplace, or the threat of these devices being brought into the workplace, will result in immediate dismissal. This policy will be reviewed on an annual basis to ensure that it conforms with any changes to the ‘Occupational Health and Safety Act, Code and Regulations and that it continues to address the needs of the organization regarding workplace violence. Departments: All Approval Date, Sups 07, 2010 a \ Biren. 6 Ay pllh‘Workplace Violence Poli PROPAKcCY Policy # Revision Date July 13,2010. [Fase TofS Hiioviporalk uments/WorkplaceViolencePolicy pdf (and ) APC Section Appendix A Adapted from the Government of Alberta's Workplace Health and Safety Bulletin “Preventing Violence and Harassment at the Workplace" Although no incident of workplace violence is deserved, there are steps that you can take to reduce such incidents in your workplace. The following practical suggestions are from a guide entitled "Violence in the Workplace” from the Canadian Centre for Occupational Health and Safety (1999), Dealing with a potentially violent person 1, Tips for verbal communication: + Focus your attention on the other person to let them know you are interested in what they have to say. + Do not giare or stare, which may be perceived as a challenge. + Remain calm and try to calm the other person. Do not allow the other person's. anger to become your anger. + Remain conscious of how you are delivering your words. + Speak slowly, quietly and confidently + Speak simply. + Avoid communicating a lot of technical and complicated information when emotions. are high. + Listen carefully. Do not interrupt or offer unsolicited advice or criticism. + Encourage the person to talk. Do not tell the person to relax or caim down. + Remain open-minded and objective. * Use silence as a calming tool. + Acknowledge the person's feelings. Indicate that you can see he or she is upset. 2. Tips for non-verbal behavior and communication + Use calm body language — relaxed posture with hands unclenched, attentive expression. + Arrange yourself so that your exit is not blocked. + Position yourself at a right angle rather than directly in front of the other person. + Give the person enough physical space... this varies by culture, but normally 1-2 metres is considered an adequate distance. + Get on the other person's physical level. If they are seated try kneeling or bending over, rather than standing over them. Do not pose a challenging stanch such as Standing directly opposite someone Putting your hands on your hips Pointing your finger Waving your arms ‘Crossing your arms. Do not make sudden movements which can be seen as threatening, Do not fight. Walk or run away. Get assistance from security or police vvvVVYYPROPAKG Worklace Violence Policy _ Revision Gale July 15, 2070. [Pace 8ofS i 2=/Documents Workplace! umanResourcesi (and ) APC Section 15 Responding to a physical attack you are attacked: + Make a scene, yell or scream as loudly as possible. Try shouting words like STOP, FIRE, or HELP. + If you are being pulled along or dragged, fall to the ground and roll. + Blow a whistle, activate your personal security alarm or push the security alarm, + Give bystanders specific instructions to help you. Single someone out and send them for help. For example, “You in the yellow shirt, call the police.” + If someone grabs your purse, briefcase or other belongings, do not resist. Throw the item to the ground several feet away from the thief and run in the opposite direction, yelling “help” or “fire’. * Do not chase a thief. + Run to the nearest safe piace, a safe office or an open store. + Call security or the police immediately after the incident. + Ifthe attack does not warrant calling the police, inform your supervisors or the authorities at your workplace. + File an incident report. Be Prepared + Take a self-defense course. + Try to imagine yourself responding successfully to different types of attacks, Practice your responses. Working Off-Site If you work away from a traditional office setting you must exercise extra caution. In many cases you have less or no ability to control your work environment. You may require special training to avoid violence by using conflict resolution and mediation tactics. Nevertheless, the following specific prevent prevent risks associated with working off-site: + Have access to a cellular telephone or similar means of communication. + Use an established check-in procedure that allows you to manage typical situations. you may encounter off-site. + Prepare a daily work plan so that you and others know where and when you are ‘expected somewhere. + Arrange to meet in a safe environment + Be alert and make mental notes of your surroundings when you arrive at a new or different setting, + Use the “buddy system’, especially when you feel your personal safety may be threatened + Determine under which circumstances unaccompanied visiting would involve unacceptable risk. + Exercise your right to refuse to work in clearly hazardous situations. + Disclose any feelings of discomfort or apprehension about an impending appointment to your supervisor. + Do not enter any situation or location where you feel threatened or unsafe. + Carry hand-held alarms, noise devices or other effective alarm devices. tactics or procedures will minimize orPROPAKG kia Woenee Boer Policy # i Revision Date Ju 73,2010] Page Sof Tporaliies! Poisies/DocumentsMWorkolaceViciencePoicy pa a (and )_ APC Section 15 When you are in unfamiliar premises: + Check for escape routes and position yourself near an escape route. + Mentally rehearse what you will do if an individual becomes aggressive or hostile. Decide what your best preventive tactic will be. + Take control of the seating arrangements. If possible, seat yourself near the door. + Maintain a “reactionary gap" between you and the person — out of reach of the average person's kicking distance. Increase the gap by sitting at a table. Be aware of the person's proximity at all times, + Be well prepared for an appointment. Review the available information about the individuals) you are meeting. + Terminate the appointment in a non-confrontational manner if the individual appears to be: Intoxicated Under the influence of drugs Emotionally disturbed and threatening or out of control Do not allow yourself to be backed into a corner. Leave a clear path to the exit. Do not venture too far into the premises e.g. remain near an exit. Do not turn your back on the person or enter a room first viv Terminating a Potentially Violent interaction + Interrupt the conversation firmly but politely + Tell the person that you: - Do not like the tone of the conversation - Will not accept such treatment - Willend the conversation if necessary. + Tell the person that you will ask them to leave the building, or that you will leave (if working off-site). + If the behavior persists, end the conversation + Ask the person to leave the building or leave yourself. + If the person does not agree to leave, remove yourself from the scene and inform your manager or supervisor immediately, + Do not return to the person if you believe they pose a physical threat. + Advise other staff and have them leave the immediate area. + Call security or your local police + File an incident report. Always Report Incidents of Violence to the Health and Safety Department.