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| ANTI-HARASSMENT POLICY | ANTI-HARASSMENT POLICY |
|-------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------|
| Effective Date December 2, 1991 | Approved by Council Motion # 251215.04 |
| Revision Date: October 2, 2006; February 5, 2007; July 18, 2016; February 20, 2024; December 15, 2025 | Revision Date: October 2, 2006; February 5, 2007; July 18, 2016; February 20, 2024; December 15, 2025 |
## 1 POLICY STATEMENT
- 1.1 Town of Middleton is committed to fostering a harassment-free workplace where all employees are treated with respect and dignity. The Nova Scotia Human Rights Act protects employees from harassment based on race, national or ethnic origin, colour, religion, age, sex, sexual orientation, marital status, family status, disability, or pardoned conviction. The Nova Scotia Occupational Health and Safety Act and Harassment in the Workplace Regulations also provide protection against harassment that may not be based on protected characteristics.
- Harassment in the Town of Middleton is not tolerated. Employees who are found to have harassed another individual may be subject to disciplinary action. This includes any employee who: interferes with the resolution of a harassment complaint; engages in reprisal against an individual for filing a harassment complaint; or files an unfounded harassment complaint intended to cause harm.
## 2 APPLICATION
- 2.1 This policy applies to all current Council Members and employees of Town of Middleton, including full and part-time, casual, contract, permanent and temporary employees. This policy also applies to job applicants. This policy applies to all behaviour that is in some way connected to work, including during off-site meetings, training and on business trips.
## 3 DEFINITIONS
## 3.1 Harassment is:
- demeaning or embarrassing someone;
- offending or humiliating someone physically or verbally;
- threatening or intimidating someone; or
- making unwelcome jokes or comments about someone's race, national or ethnic origin, colour, religion, age, sex, sexual orientation, marital status, family status, disability, or pardoned conviction.
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- 3.2 Harassment also includes a single significant incident or a course of repeated conduct, comment, or action that a reasonable person would know is unwelcome and that humiliates, degrades, intimidates, or threatens.
- 3.3 Examples of harassment include, but are not limited to:
- Sexual harassment
- Bullying or psychological harassment
- Displaying offensive or threatening material
- Online, digital, or electronic harassment
- Unwelcome touching or invasion of personal space
- 3.4 The following is not harassment:
- Reasonable management actions, including performance management, supervision, work direction, and disciplinary action taken appropriately.
For details on how to recognize, report and deal with sexual harassment please refer to the Sexual Harassment Policy, # D 3.4.
## 4 RESPONSIBILITIES
- 4.1 Town of Middleton is responsible for:
- 4.1.1 providing all employees with a harassment-free workplace;
- 4.1.2 Taking every reasonable step to prevent harassment;
- 4.1.3 Ensuring all employees receive training on this policy and how to recognize, report, and prevent harassment;
- 4.1.4 Ensuring investigations are fair, timely, and impartial.
- 4.2 Management is responsible for:
- 4.2.1 ensuring that this policy is applied in a timely, consistent, and confidential manner;
- 4.2.2 determining whether allegations of harassment are substantiated; and
- determining what corrective action is appropriate where a harassment complaint has been substantiated.
- 4.2.4 the administration of this policy;
- 4.2.5 reviewing this policy at least every three years, or as required; and
- 4.2.6 making necessary adjustments to ensure that this policy meets the needs of the organization.
- 4.3 Supervisors are responsible for:
- 4.3.1 fostering a harassment-free work environment and setting an example about appropriate workplace behaviour;
- 4.3.2 communicating the process for investigating and resolving harassment complaints made by employees;
- 4.3.3 dealing with harassment situations immediately upon becoming aware of them;
- 4.3.4 taking appropriate action during a harassment investigation, including separating the parties to the harassment complaint, when appropriate;
- 4.3.5 offering an alternate reporting path if the complaint involves a supervisor; and
- 4.3.6 ensuring harassment situations are dealt with in a sensitive and confidential manner.
- 4.4 Employees are responsible for:
- 4.4.1 treating others with respect;
- reporting harassment to their direct supervisor or an alternate designated person if the supervisor is involved or if the employee is uncomfortable reporting to them;
- 4.4.3 cooperating with harassment investigations and respecting the confidentiality related to the investigation process;
- 4.5 Employees can expect:
- 4.5.1 to be treated with respect;
- 4.5.2 that reported harassment will be dealt with promptly;
- 4.5.3 to have a fair process and confidentiality respected except where disclosure is necessary for investigation, corrective action, or required by law; and
- 4.5.4 to be protected against reprisal.
## 5 REPORTING PROCEDURE
- 5.1 Filing a Complaint
- 5.1.1 An employee may file a harassment complaint by contacting their direct supervisor or the designated harassment officer/CAO/Human Resources if appropriate or necessary.
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- 5.1.2 Complaints may be written or verbal.
- 5.1.3 Complaints should be made as soon as possible but no later than within one year of the last incident, unless exceptional circumstances exist.
- 5.1.4 The Town will acknowledge receipt of the complaint IN WRITING.
- 5.1.5 Every effort will be made to resolve harassment complaints within 20 business days. If this is not possible, the parties will be advised.
## 6 INVESTIGATION
- 6.1 Investigation
- 6.1.1 If mediation is inappropriate or unsuccessful, an investigation will be conducted by a trained individual.
- 6.1.2 The town may engage an external investigator to ensure impartiality, particularly where a supervisor or senior staff member is involved.
- 6.1.3 The investigator will prepare a written report.
- 6.1.4 Both parties will receive a copy of the report to the extent permitted by privacy law.
## 7 CORRECTIVE ACTION AND REMEDIES
- 7.1 Substantiated Complaint
- 7.1.1 If harassment is substantiated, corrective action may include education, coaching, reprimand, suspension, transfer, demotion or termination.
- 7.1.2 Remedies for the complainant may include apology, restored benefits, or other appropriate measures.
## 8 CONFIDENTIALITY
- 8.1 All parties are expected to respect confidentiality.
- 8.2 The Town will keep information confidential except where disclosure is necessary to conduct the investigation, take corrective action, or is required by law. Access to information will be limited to those who need it to carry out their duties.
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## 9 OTHER REDRESS
- 9.1 Employees may file complaints with:
- 9.1.1 Nova Scotia Human Rights Commission;
- 9.1.2 CUPE (if applicable);
- 9.1.3 The Nova Scotia Department of Labour, Skills & Immigration - Occupational Health & Safety Division;
- 9.1.4 Police, in the case of potential criminal activity.
## 10 REPEAL, REPLACE, OR AMEND
- 10.1 A policy known as Harassment, policy number D 3.4, having an effective date of December 2, 1991, is hereby amended.
Ashley Crocker \_ Chief Administrative Officer of the Town of Middleton, do hereby certify that the Policy, of which the foregoing is a true copy, was duly passed at a duly called meeting of the Town Council of the Town of Middleton held on the 15* day of December 2025.
Chief Administrative Officer
Policy Adoption
Date of 7-day notification to Council
Date of Approval
December 1, 2025
December 15, 2025