Bullying and harassment is any inappropriate conduct or comment that the person knew, or reasonably ought to have known, would cause humiliation or intimidation. Bullying and harassment can be a single incident, or multiple incidents over time. It can come from different sources such as internal (co-workers, supervisor, employer) and external (patients, visitors, other workers), and in many forms such as online, social, verbal, and physical. 

Workplace bullying and harassment is neither acceptable nor tolerated at [Insert clinic name]. 

Purpose 

The purpose of this document is to ensure the clinic is free from workplace bullying and harassment. Individuals will have the confidence to address bullying and harassment, should it arise, with the knowledge that their concerns will be dealt with appropriately and fairly. The procedure outlines steps to be followed by [Insert clinic name], if an employee believes they are being bullied or harassed in the course of their work or because of their employment.

Policy 

[Insert clinic name] is committed to providing and supporting a diverse and inclusive workplace where all individuals conduct themselves professionally, in a respectful environment free of discrimination and bullying and harassment. Bullying and harassment are not acceptable or tolerated. All incidents must be reported and will be investigated. 

Scope

The Bullying and Harassment Policy and Procedure applies to all [Insert clinic name] employees including locums, PCN clinicians, medical students and residents, and applies to interpersonal and electronic communications, including email and text messaging.

Definitions

Bullying and harassment	Any inappropriate conduct or comment by a person towards an employee that the person knew or reasonably ought to have known would cause that employee to be humiliated or intimidated, but excludes any reasonable action taken by an employer or supervisor relating to the management and direction of employees or the place of employment.   Bullying and harassing behaviour can include:   • Verbal aggression, insults, or threats. • Humiliating initiation practices or hazing. • Spreading malicious rumors. • Calling someone derogatory names. • Vandalizing personal belongings. • Isolation and/or exclusion from work-related activities. The above list is not exhaustive, and harassment can also take place on the grounds of a person’s age, religion, political affiliation, sex, or any other characteristics protected under the B.C. Human Rights Code. Bullying and harassing behaviour does not include: • Expressing differences in opinion. • Offering constructive feedback, guidance, or advice about work-related behaviour. • Reasonable action taken by an employer or supervisor relating to the management and direction of employees or the place of employment (e.g., managing a worker’s performance, taking reasonable disciplinary actions, or assigning work).
Complainant	Someone who makes a complaint or files a formal objection. This could be a person who experienced bullying or harassment or a witness to the bullying or harassment.
Education	Knowledge acquired by learning and instruction.
Employee	A person employed to perform a function or duty. For the purposes of this procedure, employee means any permanent, locum, PCN clinician, temporary, casual, contractor, medical student, or supervisor.
External Investigator	Someone outside the clinic hired to investigate a reported incident.
Internal Investigator	Someone within the clinic assigned or designated to investigate a reported incident.
Supervisor	A person who instructs, directs, and controls staff in the performance of their duties.
Respondent	The person who is accused of engaging in bullying or harassing behaviour. They are required to respond to the allegations, providing their account of events to the investigator to ensure a fair and thorough investigation.
Target	Person who is the recipient of bullying or harassment.
Workplace	Workplace is not confined to the building where business of [Insert clinic name] is being carried out. Harassment can occur during or after working hours, on or off [Insert clinic name] property.  Harassment can occur during business travel, work-related social gatherings, through internet communications, or any other locations where the prohibited conduct may have a subsequent impact on work relationships, environment, or performance of any person to whom this policy applies.

Responsibilities 

Employer

• Support, understand, adopt, and implement this policy and procedure when necessary.
• Ensure time and resources are available for staff to attend training and participate with investigations.
• Complete all required paperwork for incidents of bullying or harassment.
• Assist in the investigation of any incidents of bullying or harassment where necessary or required.
• Do not engage in bullying or harassment of staff, supervisors, staff, or other persons. 
• Gather all required information to conduct a full and comprehensive investigation.
• Complete investigations free of judgement and bias. 
• Provide follow up and recommendations to assist in eliminating reoccurrence.

Supervisor

• Apply and comply with this policy procedure.
• Inform and train workers on this procedure.
• Ensure the policy and procedure is available, understood, and promoted.
• Take steps to prevent bullying and harassment.
• Promote the process to report incidents and complaints of bullying and harassment. 
• Complete all required paperwork for incidents of bullying or harassment.
• Assist in the investigation of any incidents of bullying and harassment where necessary or required.
• Not engage in bullying and harassment of staff, supervisors, or other persons.

Employee

• Not engage in bullying or harassment of other staff, supervisors, or other persons.
• Report bullying and harassment observed or experienced in the workplace.
• Complete all required paperwork for incidents of bullying or harassment.
• Apply and comply with the employer’s policies and procedures on bullying and harassment.

Procedure 

This procedure includes:

1. Complainant Process for Reporting 
2. Employer Process for Investigating 
3. Training 
4. Confidentiality
5. Annual Review

1. Complainant Process for Reporting

• All incidents of bullying and harassment must be reported immediately, in writing, to a supervisor. 
• The attached Appendix A: Bullying and Harassment Complaint Form can be used to identify the complainant, respondent, and details of complaint including dates, names, location, witnesses, and any other relevant information to the complaint.
• Where the supervisor is the alleged bully, it is recommended the individual directly reports to WorkSafeBC at 1-888-967-5377.

2. Employer Process for Investigating

2.1 Investigator Selection

Most investigations at [Insert clinic name] will be conducted internally. Depending on the situation, the employer will be the lead investigator. A safety representative may also be involved. The Bullying and Harassment Investigation Form is shown in Appendix B.

2.2 Incident Review

Investigations will include interviews with the alleged target, the alleged bully, and any witnesses. If the alleged target and the alleged bully agree on what happened, then [Insert clinic name] will not investigate further and will determine what corrective action to take, if necessary. 

2.3 Follow Up

All investigations of alleged bullying and harassment will be responded to and documented. Follow up will include a description of corrective actions, a timeframe, and a method to address adverse symptoms. The complainant will be advised of the outcomes and support available. 

A complainant is not obligated to continue with a formal complaint at any point throughout the process. However, [Insert clinic name] reserves the right to pursue an investigation and resolution process, with or without, the complainant’s consent when it has sufficient concerns about the alleged behaviour.

The process for investigating incidents and complaints of bullying and harassment will: 

• Be prompt and diligent, and be as thorough as necessary, given the circumstances.
• Be fair and impartial, providing both the complainant and respondent equal treatment in evaluating the allegations.
• Be sensitive to the interests of all parties involved and maintain confidentiality.
• Focus on finding facts and evidence, including interviews of the complainant, respondent, and any witnesses.
• Incorporate, where appropriate, any need or request from the complainant or respondent for assistance during the investigation process. 

3. Training

Training for supervisors and staff will include the following:

• How to recognize bullying and harassment.
• How staff who experience or witness bullying and harassment should respond.
• Procedures for reporting, and how the employer responds to incidents or complaints of bullying and harassment. 
• How to report and document bullying and harassment. 
• Training will occur as required and will be included in clinic orientation.

4. Confidentiality

Allegations of bullying and harassment involve sensitive disclosures. Confidentiality must be maintained at all times. All information is confidential with disclosure only to those who are direct parties to the investigation, or where disclosure is required by law. Confidentiality cannot be guaranteed for individuals who initiate proceedings or make comments outside the [Insert clinic name] internal procedures.

5. Annual Review

This procedure will be reviewed annually. All employees will be advised and educated on the procedure when they are hired through the new employee orientation process.

Approval: