Layla's Anti-Harassment, Anti-Discrimination, and Workplace Violence Policy

Last Updated: July 28, 2025

1. Purpose of Document 

Layla Care Inc. ("Layla" or the "Company")  is committed to providing a safe, respectful, inclusive, and harassment-free workplace. This policy outlines our expectations, defines prohibited behaviors, and establishes procedures for addressing violations. 

1.1 Compliance

This policy complies with applicable legislation, including Ontario's Occupational Health and Safety Act (OHSA) and Human Rights Code, Alberta's Occupational Health and Safety Act, British Columbia's Workers Compensation Act, and Nova Scotia's Occupational Health and Safety Act.

2. What’s Covered & Definitions

Layla prohibits all forms of harassment, discrimination, and workplace violence based on protected characteristics, including race, ethnicity, gender identity, sexual orientation, disability, religion, age, and other grounds outlined by applicable federal or provincial legislation.

  • Harassment: Includes unwanted conduct, comments, or actions that demean, humiliate, intimidate, or threaten individuals. Part of the test for determining if harassment has occurred is whether the person knew or should have known that the comments or conduct were unwelcome. The test is met if:
    • The recipient specifically says the behaviour is unwelcome;
    • The recipient makes it clear through conduct or body language that the behaviour is unwelcome; or
    • A reasonable person would have recognized that the behaviour would be unwelcome to that specific recipient under the circumstances.

Although commonly the case, the harasser does not necessarily have to have power or authority over the victim. Harassment can occur from co-worker to co-worker, manager to employee, employee to manager, or involve a Third Party. 

  • Not Harassment: Workplace harassment should not be confused with legitimate, reasonable management actions that are part of the normal work function, including:
    • Direction of workers
    • Setting employee or team performance targets, and managing employees accordingly
    • Measures to correct performance deficiencies, such as placing someone on a performance improvement plan
    • Imposing discipline for workplace infractions
    • Requesting medical documents in support of an absence from work

It also does not include normal workplace conflict or differences of opinion between individuals. Differences of opinions or political views, when expressed respectfully, do not constitute harassment. Employees are encouraged to exercise respect and remain open to diverse perspectives.

  • Workplace Violence: Includes the exercise of, attempt to exercise, or threat to exercise physical force by a person against a worker that causes or could cause physical injury. Workplace violence includes:
    • Physically threatening behaviour (e.g. destroying property, throwing objects)
    • Verbal or written threats to physically attack a worker
    • Leaving notes or sending emails threatening of violence 
    • Wielding a weapon at work
    • Stalking
    • Physically aggressive behaviors (e.g., hitting, shoving, aggressive standing, pushing, kicking, throwing objects, physically restraining someone, physical or sexual assault)

3. Internal Violations

3.1 If You Experience or Witness Internal Violations:

  • Immediately report incidents to your direct manager, HR, or a member of Layla’s leadership team.

3.2 What Happens Next:

  • Layla will promptly investigate all reports.
  • Investigations will involve discussions with relevant parties, maintaining confidentiality as much as possible.
  • Outcomes may include training, counseling, disciplinary actions up to and including termination, and/or other appropriate corrective measures.
  • Layla strictly prohibits retaliation against anyone reporting a violation in good faith.

4. Third Party Violations

4.1 If You Experience or Witness Third Party Violations:

  • Employees are empowered, to their comfort level, to directly address third-party behavior that violates Layla's values by clearly explaining expectations and setting boundaries.
  • Always document violation incidents clearly and objectively.
  • Report the incident to your manager or a senior leader in your area as soon as practicable. 

4.2 What Happens Next:

  • Layla will take immediate steps to address the behavior with the third party involved.
  • Possible outcomes include warnings, modification or termination of services (e.g. reassigning a patient), or cessation of services (except as restricted by applicable laws). Layla may also decide that no further action is necessary if the initial steps taken by the employee sufficiently address the situation.  
  • Layla will provide necessary support and protections to affected employees.

5. Seeking Clarity

Employees who have questions or need further clarification about this policy are encouraged to reach out to their direct manager, HR representative, or any member of the leadership team.

6. Policy Review & Updates

Layla will review this policy annually or whenever significant legislative or organizational changes occur. Any updates will be communicated clearly to all employees and stakeholders.

Layla remains committed to maintaining an environment built on respect, dignity, and inclusion, reflecting our values of quality, compliance, and care.

Layla Internal Guidelines: Handling Third-Party Harassment and Discrimination

Purpose: This guideline provides practical tools and recommendations for the Client Care and Program Operations Team to effectively manage and respond to third-party harassment or discrimination, prioritizing employee safety, dignity, and respectful client engagement.

Step 1: Setting Boundaries in non-severe situations

When confronted with inappropriate behavior, employees are empowered - at their comfort level - to respectfully set clear boundaries.

Practical Examples of Setting Boundaries:

  • Aggressive Tone on an Intake Call:
    • "I’m here to help you, but I ask that we both speak respectfully. If this tone continues, we'll need to end this conversation."
  • Discriminatory Requests:
    • "At Layla, we provide care in a way that respects everyone. We can’t accommodate requests that exclude therapists based on their race, ethnicity, age, gender, or any protected characteristic. We’d be happy to discuss other preferences you might have related to therapy effectiveness"

Step 2: Report Incident

Employees' safety and well-being is a Layla priority. You are encouraged and asked to raise any incidents and concerns with your manager promptly by calling or requesting a meeting with your manager. 

Step 3: Manager Supports Next Steps in Consultation with Clinical Team 

When you report a concern to your manager, Layla will take immediate steps to address the behavior with the third party involved. Possible outcomes include warnings, modification or termination of services (e.g. reassigning a patient), or cessation of services (except as restricted by applicable laws). Layla may also decide that no further action is necessary if the initial steps taken by the employee sufficiently address the situation. 

Next steps by the Care Team lead or manager should always be assessed in consultation with a Clinical Manager (e.g. Clinical Program Manager, Clinical Product Manager, Clinical Director, or Designate)

As a healthcare provider, Layla cannot deny or terminate services lightly. However, it is our duty to protect our employees and foster a safe work environment. Complete termination decisions should used in serious and/or persistent behaviors, such as:

  • Repeated aggressive behavior after clear boundary-setting.
  • Direct harassment or discriminatory actions against employees.

Any decision to terminate services must be reviewed and approved by a Manager or Director from the Clinical Team.

Step 4: Documentation and Reporting

All incidents of third-party harassment or discrimination must be documented objectively (e.g., using direct quotes instead of paraphrasing), promptly, and thoroughly. Always escalate to your manager or senior leader, who will determine the appropriate follow-up actions.

Additional Considerations:

Not Enabling Discrimination

Layla must not accommodate discriminatory preferences. It is critical to distinguish between discriminatory requests and clinically relevant requests related to equity-seeking groups.

  • Appropriate Client Preference:
    • Example: A client requests an Arab therapist for culturally competent care. This request is appropriate as it aligns with shared cultural understanding and client engagement with therapy.
  • Inappropriate Client Preference:
    • Example: A client requests to exclude Arab therapists due to discriminatory views. This request cannot be accommodated. Explain clearly and respectfully that such preferences conflict with Layla’s values and anti-discrimination commitments.
  • Sometimes it’s not obvious for one person on the team if the client request is appropriate or not (e.g. a personal reason or traumatic history resulting in the client preference). In such situations the Care Coordinator / TL / Clinical Manager should review and make a case-by-case determination on the path forward. 

Protecting Therapist Safety

Layla has a duty to protect therapists’ safety and dignity. If a client is known to hold discriminatory views against specific therapist identities, the following practices should be considered, on a case-by-case basis

  • Proactive Risk Management: If risk is deemed high, in necessary situations assign alternative therapists.
  • Transparency: If deemed safe and appropriate, inform the therapist discreetly and clearly about potential risks, allowing them to assess their comfort and safety. Therapists should never feel pressured into situations where they feel unsafe.
  • Documentation and Reporting: Clearly document all decisions and incidents, immediately reporting them to your manager (by phone or requesting a meeting) for appropriate follow-up.

Seeking Guidance

If you're unsure about how to handle a particular situation, immediately consult your manager or a Clinical Manager at Layla for clarity and support.

Last Updated: July 28, 2025

Your Acceptance of these Terms of Use

Discrimination, violence, harassment and sexual harassment in the workplace are strictly prohibited at Layla Care Inc. (“Layla”). Layla has ZERO tolerance for any physical acts or verbal threats of violence or harassment of any kind, nor any discrimination made by or against employees, customers or visitors on premises or through Layla’ communications channels. It is the responsibility of every employee to report any incident of discrimination, violence, harassment or sexual harassment in the workplace. To help address issues of discrimination, violence, harassment and sexual harassment in the workplace, the Company has established a policy for recognizing, reporting and responding to incidents.

Layla is committed to assessing, minimizing and, to the extent possible, eliminating the risk of discrimination, violence, harassment and sexual harassment in the workplace. It is recognized that discrimination, violence, harassment and sexual harassment are an occupational health and safety hazard and can result in physical and emotional harm. The Workplace Discrimination, Violence, Harassment & Sexual Harassment Policy ensures that violence and all harassment in the workplace will not be tolerated and provides a process to prevent and respond to incidents of violence, harassment and sexual harassment.

An employee who contravenes any provision of this policy may be subject to disciplinary action, up to and including termination of employment without notice, as well as possible civil, criminal or regulatory action. Such contravention may also impact an employee’s performance assessment, reputation and compensation.

Non-employees who engage in violence in the workplace will be reported to the proper authorities. Layla reserves the right to pursue any and all available civil remedies.

I. Key Policy Definitions

1) Workplace:
For the purposes of this policy, workplace is defined as follows:
- All Layla premises and immediate environments, e.g., parking lots, smoking areas, lunchrooms, the Company’s communication channels such as email, telephone, Slack, etc.
-All non- Layla premises used for work-related activities such as customer or partner workplaces, seminars, conferences, business meetings, social functions, and/or any place where an employee is paid to work such as Layla car, home office and the like.

2) Discrimination:
Workplace discrimination includes any distinction, exclusion or preference based on the protected grounds in the Provincial Human Rights Code, which nullifies or impairs equality of opportunity in employment, or equality in the terms and conditions of employment.

The protected grounds of discrimination are:
- Race, colour, ancestry, citizenship, ethnic origin or place of origin
- Gender, gender identity, and gender expression
- Creed, religion
- Age
- Sexual orientation  
-Gender identity, gender expression
- Family, marital or same-sex partnership status
- Disability or perceived disability
- A record of offence(s) for which a pardon has been granted under the Criminal Records Act (Canada) and has not been revoked, or an offence in respect of any provincial enactment

3) Discriminatory Harassment:

Harassment is defined as “engaging in a course of vexatious (insulting, demeaning, annoying, provoking, threatening, or resulting in some other form of discomfort) comments or conduct on a prohibited ground of discrimination that is known or ought to reasonably be known to be unwelcome, offensive, inappropriate, intimidating or hostile.” For purposes of this practice, discriminatory harassment may result from one incident or a series of incidents. It may be directed at specific individuals or groups but may also include any comments or conduct which creates an environment that is hostile, intimidating or offensive.

Discriminatory Harassment may include (but is not limited to):

- Unwelcome jokes, remarks, taunting or innuendos with respect to a prohibited ground of discrimination as outlined in Section 2) above.
- The display of racist, derogatory or offensive pictures or material
- Refusal to converse with or work with another staff member because of such things as ethnic origins, sexual orientation, etc.
- Leering, suggestive gestures or unnecessary physical contact such as unwelcomed touching, patting or pinching
- Offensive sexual flirtation; advances; propositions
- Sexual assault
- Viewing or distribution of offensive materials by mail, email, phone or fax

4) Workplace Harassment:

Workplace harassment is sometimes called psychological harassment or bullying. It usually has some or all of the following components:
- It is generally repetitive, although a single serious incident may constitute workplace harassment if it undermines the recipient’s psychological or physical integrity and has a lasting harmful effect
- It is hostile, abusive or inappropriate
- It may involve vexatious or inappropriate comments, conducts or display, gestures, actions or some combination of all of these
- It affects the person’s dignity or psychological or physical integrity
- It results in a poisoned or harmful work environment

In addition, behaviour that intimidates, isolates or discriminates against the recipient may also be included.

Some examples of workplace harassment are:
- Verbally abusive behaviour such as yelling, insults, ridicule and name calling including remarks, jokes or innuendos that demean, ridicule, intimidate or offend
- Workplace pranks, vandalism, bullying, hazing or horseplay
- Gossiping or spreading malicious rumours
- Excluding or ignoring someone, including persistent exclusion of a particular person from workplace-related social gatherings
- Deliberately withholding information that would enable a person to do their job
- Sabotaging someone else’s work
- Displaying or circulating offensive pictures or materials
- Offensive or intimidating phone calls or emails
- Impeding an individual’s efforts at promotions or transfers for reasons that are not legitimate
- Making false allegations about someone in memos or other work-related documents.

Part of the test for determining if harassment has occurred is whether the person knew or should have known that the comments or conduct were unwelcome.

The test is met if:
-The recipient specifically says the behaviour is unwelcome;
-The recipient makes it clear through conduct or body language that the behaviour is unwelcome; or
- A reasonable person would have recognized that the behaviour would be unwelcome to that specific recipient under the circumstances.
Although it is commonly the case, the harasser does not necessarily have to have power or authority over the victim. Harassment can occur from co-worker to co-worker, Manager to employee, and employee to Manager.

Workplace Sexual Harassment:

Workplace harassment also includes workplace sexual harassment which can be defined in two parts:

1. “Engaging in a course of vexatious comment or conduct against a worker in a workplace because of sex, sexual orientation, gender identity or gender expression, where the course of comment or conduct is known or ought reasonably to be known to be unwelcome;”
2. “Making a sexual solicitation or advance where the person making the solicitation or advance is in a position to confer, grant or deny a benefit or advancement to the worker and the person knows or ought reasonably to know that the solicitation or advance is unwelcome.”

What Isn’t Harassment

Workplace harassment should not be confused with legitimate, reasonable management actions that are part of the normal work function, including:
- Direction of workers
- Setting of employee or team performance targets, and managing employees accordingly
- Measures to correct performance deficiencies, such as placing someone on a performance improvement plan
-Imposing discipline for workplace infractions
-Requesting medical documents in support of an absence from work

It also does not include normal workplace conflict that may occur between individuals or differences of opinion between co-workers.

5) Workplace and Domestic Violence:

ffWorkplace and domestic violence that may occur in the workplace are health and safety issues, which are covered under the various provincial health and safety acts.a)    Workplace ViolenceWorkplace violence includes the exercise of, attempt to exercise, or threat to exercise physical force by a person against a worker that causes or could cause physical injury to that worker.Workplace violence can be defined broadly enough to include acts that may be considered criminal. Workplace violence includes:•     Physically threatening behaviour such as shaking a fist at someone, finger pointing, destroying property, throwing objects•     Verbal or written threats to physically attack a worker•     Leaving threatening notes or sending threatening emails•     Wielding a weapon at work•     Stalking someone•     Physically aggressive behaviors including hitting, shoving, standing excessively close to someone in an aggressive manner, pushing, kicking, throwing an object at someone, physically restraining someone or any other form of physical or sexual assaultViolence that occurs outside the normal workplace, but which has an impact on the working environment, including working relationships, may also be considered violence in the workplace.Workplace violence may come from many different sources:•     Strangers or people with no ties to the workplace•     Members, clients, customers, stakeholders or suppliers•     Other employees•     Intimate relationships  outside of work (such as intimate partners, family, friends)b)    Domestic ViolenceIf an employee is experiencing domestic violence that would likely expose him or her, or other workers, to physical injury that may occur in the workplace, Layla will take every precaution reasonable to protect the employee and his or her co-workers in the circumstances. This may include some or all of the following:•     Creating a safety plan•     Contacting the police•     Establishing enhanced security measures such as a panic button, code words, and door and access security measures•     Screening calls and blocking calls, telephone numbers or certain email addresses•     Setting up priority parking or providing escorts to the vehicle or to public transportation•     Adjusting the employee working hours and location so that they are not predictable•     Facilitating the employee access to counselling community programs•     Recommending  that the employee consult with his/her health care professionalLayla appreciates the sensitivity of these issues and will do its best to assist the employee as discreetly as possible while maintaining his or her privacy.

Workplace and domestic violence that may occur in the workplace are health and safety issues, which

are covered under the various provincial health and safety acts.

a)    Workplace Violence

Workplace violence includes the exercise of, attempt to exercise, or threat to exercise physical

force by a person against a worker that causes or could cause physical injury to that worker.

Workplace violence can be defined broadly enough to include acts that may be considered criminal.

Workplace violence includes:

•     Physically threatening behaviour such as shaking a fist at someone, finger pointing,

destroying property, throwing objects

•     Verbal or written threats to physically attack a worker

•     Leaving threatening notes or sending threatening emails

•     Wielding a weapon at work

•     Stalking someone

•     Physically aggressive behaviors including hitting, shoving, standing excessively close to

someone in an aggressive manner, pushing, kicking, throwing an object at someone, physically

restraining someone or any other form of physical or sexual assault

Violence that occurs outside the normal workplace, but which has an impact on the working

environment, including working relationships, may also be considered violence in the workplace.

Workplace violence may come from many different sources:

•     Strangers or people with no ties to the workplace

•     Members, clients, customers, stakeholders or suppliers

•     Other employees

•     Intimate relationships  outside of work (such as intimate partners, family, friends)

b)    Domestic Violence

If an employee is experiencing domestic violence that would likely expose him or her, or other

workers, to physical injury that may occur in the workplace, Layla will take every precaution

reasonable to protect the employee and his or her co-workers in the circumstances. This may include

some or all of the following:

•     Creating a safety plan

•     Contacting the police

•     Establishing enhanced security measures such as a panic button, code words, and door and

access security measures

•     Screening calls and blocking calls, telephone numbers or certain email addresses

•     Setting up priority parking or providing escorts to the vehicle or to public transportation

•     Adjusting the employee working hours and location so that they are not predictable

•     Facilitating the employee access to counselling community programs

•     Recommending  that the employee consult with his/her health care professional

Layla appreciates the sensitivity of these issues and will do its best to assist the employee as

discreetly as possible while maintaining his or her privacy.