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MUNICIPALITY OF THE COUNTY OF ANNAPOLIS
POLICY AND ADMINISTRATION MANUAL
Policy 137
Subject
Respectful Workplace Policy
November 2025
Page 1 of 11
1. APPLICATION
This policy applies to all employees of the Municipality of County of Annapolis (the
"Municipality"), including all managers and bargaining unit employees.
2. PURPOSE
The Municipality is committed to a healthy, safe and supportive workplace and is
committed to providing a work environment that values diversity and where all persons
are treated with respect and dignity. Harassment, sexual harassment, and
discrimination (referred to collectively as "workplace harassment") affect the
workplace and the well-being of individuals in the workplace. Workplace harassment
will not be tolerated in the workplace.
This policy seeks to:
- provide a work environment that is free from all forms of workplace harassment;
- educate employees and create understanding as to what is considered workplace
harassment;
- provide a mechanism to have workplace harassment addressed and eliminated
from the workplace.
Any allegation of workplace harassment is significant and will be taken seriously. The
Municipality has an obligation to take appropriate action to protect their employees in
the workplace and to put a stop to any workplace harassment they are aware of,
whether or not a complaint has been filed.
Employees have an obligation to treat all persons with respect and dignity and are
encouraged to take appropriate action to ensure workplace harassment is not
tolerated or condoned. Violations of the Respectful Workplace Policy will result in
disciplinary action, up to and including termination of employment.
3. AUTHORITY
This policy is enacted pursuant to sub-section 48(3) of the Municipal Government Act,
as amended, and in accordance with Part 27 of the Workplace Health and Safety
Regulations (the "Regulations") under section 82 the Occupational Health and Safety
Act.
4. DEFINITIONS
a) COMPLAINT - A written allegation of workplace harassment.
b) COMPLAINANT - An employee or third party who has brought forward or filed a
complaint under this policy alleging that workplace harassment has occurred.
c) DISCRIMINATION - Nova Scotia's Human Rights Act defines discrimination as
follows: a person discriminates where the person makes a distinction, whether
MUNICIPALITY OF THE COUNTY OF ANNAPOLIS
POLICY AND ADMINISTRATION MANUAL
Policy 137
Subject
Respectful Workplace Policy
November 2025
Page 2 of 11
intentional or not, based on age; race; colour; religion; creed; sex (gender, including
pregnancy); sexual orientation; gender identity; gender expression; physical
disability or mental disability; an irrational fear of contracting an illness or disease;
ethnic, national or aboriginal origin; family status; marital status; source of income;
political belief, affiliation or activity; association with another individual or class of
individuals having characteristics named above, that has the effect of imposing
burdens, obligations or disadvantages on an individual or a class of individuals not
imposed upon others or which withholds or limits access to opportunities, benefits
and advantages available to other individuals or classes of individuals in society.
d) EMPLOYEE - Means any person directly employed by the Municipality (excluding
councillors, citizen appointees, volunteers and contractors).
e) INVESTIGATOR - A neutral individual(s) appointed by the Chief Administrative
Officer to investigate, through fact finding, complaints of workplace harassment.
f) MEDIATION - A voluntary process used to resolve conflict by having a neutral
person help the parties to the dispute attempt to arrive at a mutually acceptable
solution.
g) "REASONABLY TO BE KNOWN" - The "reasonably to be known" standard refers
to an objective assessment of how a specific behaviour might generally be viewed
by a reasonable person in roughly the same situation as the Complainant.
h) RESPONDENT - An employee (excluding councillors, members of the public and
contractors) against whom allegations of workplace harassment are made.
i) SEXUAL HARASSMENT - Means sexual harassment as legislated under the
Human Rights Act. Sexual harassment includes comments, gestures or physical
conduct of a sexual nature, or actions or comments with a sexual connotation or
component that are directed at no person in particular but that create an intimidating,
demeaning or offensive work environment, where an individual knows or ought to
reasonably know that the behaviour is unwelcome and offensive. Examples of
conduct that fall within the definition of sexual harassment are:
- inappropriate or derogatory comments, humour, insults or behaviour based on
gender and/or sexual orientation;
- inappropriate, lewd, or sexually offensive written, graphic or behavioural
displays;
- inappropriate conversation, physical touching, or leering that could be construed
to be a sexual advance, particularly, but not limited to, where the individual
making the sexual solicitation or advance is in a position to confer a benefit on,
or deny a benefit to, the individual to whom the solicitation or advance is made;
- any implied or expressed reward for complying with a sexually-oriented advance
or request;
MUNICIPALITY OF THE COUNTY OF ANNAPOLIS
POLICY AND ADMINISTRATION MANUAL
Policy 137
Subject
Respectful Workplace Policy
November 2025
Page 3 of 11
- a reprisal or threat of reprisal against an individual for rejecting a sexual
solicitation or advance.
j) THIRD PARTIES - Persons who are engaged in work activities at a county
workplace who are not direct employees of the county. They include, but are not
limited to, volunteers, citizen appointees, members of the public and contractors.
k) WORKPLACE - Any place occupied by an employee as part of their employment
which includes, but is not limited to, county offices and sites, county-owned
vehicles, work-related social gatherings, work-related functions or other locations
where an employee is engaged in activity associated with their employment or
conducting county business.
l) WORKPLACE HARASSMENT - Part 27.1 of the Regulations defines workplace
harassment as a single significant occurrence or a course of repeated occurrences
of objectionable or unwelcome conduct, comment or action in the workplace,
including bullying, that, whether intended or not, degrades, intimidates or
threatens, and includes all of the following, but does not include any action taken
by an employer or supervisor relating to the management and direction of an
employee or the workplace:
i.
workplace harassment or bullying that is based on any personal
characteristic, including, but not limited to a characteristic referred to the
following characteristics in clauses 5(1)(h) to (v) of the Human Rights Act:
age; race; colour; religion; creed; sex (gender, including pregnancy); sexual
orientation; physical disability or mental disability; an irrational fear of
contracting an illness or disease; ethnic, national or aboriginal origin; family
status; marital status; source of income; political belief, affiliation or activity;
association with another individual or class of individuals having
characteristics named above.
ii.
inappropriate sexual conduct, including, but not limited to, sexual solicitation
or advances, sexually suggestive remarks or gestures, circulating or
sharing inappropriate images or unwanted physical contact.
m) WORKPLACE RESTORATION - Promoting and/or restoring positive work
environment and respectful workplace relationships.
5. POLICY PRINCIPLES
a) All employees are entitled to employment that is free of workplace harassment;
b) The Municipality will ensure, so far as is reasonably practicable, that no employee
will be subjected to workplace harassment;
c) All employees have an obligation to not engage in workplace harassment;
d) All employees are encouraged to report incidents of workplace harassment; and
e) All employees will be trained with respect to the implementation of this Policy.
MUNICIPALITY OF THE COUNTY OF ANNAPOLIS
POLICY AND ADMINISTRATION MANUAL
Policy 137
Subject
Respectful Workplace Policy
November 2025
Page 4 of 11
Creation of an environment that is free from workplace harassment is achieved
through awareness and training. Councillors, the Chief Administrative Officer,
Directors and Managers shall lead by example and take reasonable measures to
ensure a work environment that is free from workplace harassment. If the Chief
Administrative Officer is made aware of a violation of this policy, they required to take
action even in the absence of a complaint.
It is the intent of this policy to promote employee involvement in resolving situations
as appropriate to the circumstance. The use of resolution options, including
mediation, is encouraged at any stage of this policy. Resolution to a situation should
be sought as soon as possible and must occur within twelve (12) months of the
workplace harassment. In extenuating circumstances, the Chief Administrative Officer
may consider complaints beyond twelve (12) months. Nothing in this policy shall be
deemed to restrict the authority of the Chief Administrative Officer, Directors,
Managers or Supervisors in performance management, counselling, disciplinary
action or other appropriate interactions between employees and their supervisors.
6. CONFIDENTIALITY
Subject to any limits or disclosure requirements imposed by law or required by this
Policy, any and all information, oral and written, gathered, received or compiled
through the course of a complaint is to be treated as confidential by the Employer, the
Respondent and Complainant, their representatives, and witnesses. Where an
Employee is named in a Complaint, the Complaint and the results of any investigation
will only form part of the Employee's personnel file if the complaint is substantiated.
Information obtained in relation to a complaint of workplace harassment will also only
be disclosed if necessary for the purposes of investigating the Complaint or necessary
for the purposes of taking corrective action with respect to the Complaint.
7. ADVISORY SERVICES
Employment Assistance Program (EAP) Consultants shall be available to provide
information and support to employees on a confidential basis. This service will be
accessible to employees who need not identify themselves when requesting advice.
8. COMPLAINTS PROCESS & RESOLUTION OPTIONS
The following resolution options are available to all employees, and third parties in
limited circumstances.
a) Informal Complaint - Made directly to the person or manager or director;
b) Written Complaint - Submitted in writing directly to the Chief Administrative
Officer or their designate.
The foregoing options are not the only avenues for resolution that an employee
may take. This policy is not intended to discourage, prevent or preclude a
MUNICIPALITY OF THE COUNTY OF ANNAPOLIS
POLICY AND ADMINISTRATION MANUAL
Policy 137
Subject
Respectful Workplace Policy
November 2025
Page 5 of 11
complainant from exercising other legal rights under any other law. The choice to
file a complaint therefore does not supersede or eliminate the right of an Employee
to:
- file a complaint with the Nova Scotia Human Rights Commission;
- report the incident to the Police where there is an indication that a criminal
offence has been committed;
- file a complaint with the Workers' Compensation Board; and/or
- file a grievance, if the employee is a member of a bargaining unit.
Additionally, the Municipality is committed to investigating all complaints of workplace
harassment.
a) Parties to Complaints
Complainant
- All Employees and third parties may file a complaint against an employee in
appropriate circumstances.
Respondent - Informal (Municipality will not conduct an investigation)
- All Employees and third parties may be Respondents to an informal complaint
made by another employee or third party in appropriate circumstances.
Respondent - Formal (Municipality will conduct an investigation)
- In terms of who may be a respondent to a workplace harassment complaint, it
is typically limited to employees.
- However, where a volunteer or citizen appointee is clearly acting in a manner
or role consistent with that of an employee, a volunteer or citizen appointee
may be a respondent in a workplace harassment complaint, and the following
sections apply accordingly.
- Where a third party or any other individual does not qualify as a respondent
(e.g., a contractor) the Municipality will not conduct an investigation.
Complainants are encouraged to pursue their complaint elsewhere and will be
referred to the appropriate forum by the Municipality to file their complaint.
b) Informal Complaint: Communicating concerns directly to the person
- All Employees and third parties may initiate an informal complaint by
communicating their concerns directly to the person.
- Employees and third parties who believe they are experiencing workplace
harassment should keep a written record of the date, time, location, nature of
the behaviour and names of any witnesses. This summary of events and
circumstances should be prepared as soon as possible after the event so that
accurate details are recorded for future reference.
MUNICIPALITY OF THE COUNTY OF ANNAPOLIS
POLICY AND ADMINISTRATION MANUAL
Policy 137
Subject
Respectful Workplace Policy
November 2025
Page 6 of 11
- Employees and third parties who believe they are experiencing workplace
harassment may choose to speak directly with the person(s) and inform them
that their behaviour is unwelcome and must stop.
- If done in person, the Employee or third party may want to be accompanied by
another person.
- The Employee or third party should document any discussion with the
person(s) concerned and keep a record of any written correspondence.
- A matter dealt with to the Employee's or third party's satisfaction is considered
resolved.
c) Informal Complaint: Communicating concerns to Manager or Director
- Employees and third parties who believe they are experiencing offensive
behaviour and do not feel comfortable speaking directly with the person(s)
regarding their behavior may choose to approach their Manager or Director,
and ask for their assistance in resolving the situation.
- If the discussion is done in person, the Employee or third party may find it
helpful to be accompanied by another person.
- The Employee or third party should document any discussion they have with
the Manager or Director and keep a copy of any correspondence.
Complaint against contractor and / or contractor's employee
- If a complaint is made by an Employee or third party against a contractor and /
or contractor's employee, the Municipality will not investigate the complaint.
Instead, within ten (10) working days of being informed of the situation, the
Municipality will inform the contractor of the complaint and advise that it expects
the contractor to take the appropriate steps.
- Depending on the nature and seriousness of the complaint, the matter may be
brought to the attention of the Police or other relevant authority.
- In addition to that step, the Municipality may choose not to renew the contract
of the contractor.
Complaint against Employee
- Within ten (10) working days of being informed of the situation, the Manager or
Director shall consider the Employee's concerns and take steps to resolve the
situation in accordance with this policy. This may include requesting the
Complainant to submit a written complaint to the Chief Administrative Officer.
- The Manager or Director may ask the Chief Administrative Officer for
assistance in resolving the situation. This may include the Chief Administrative
Officer intervening directly to mediate or investigate the matter, or the Chief
Administrative Officer designating another employee to do so.
MUNICIPALITY OF THE COUNTY OF ANNAPOLIS
POLICY AND ADMINISTRATION MANUAL
Policy 137
Subject
Respectful Workplace Policy
November 2025
Page 7 of 11
- An Employee or third party has the option to submit a written complaint to the
Chief Administrative Officer if the above resolution options are not effective in
resolving the situation to the satisfaction of the Employee, or if the Employee
prefers to file a written complaint immediately.
- An Employee or third party should also submit a written complaint to the Chief
Administrative Officer if the Employee is experiencing workplace harassment
from their Manager or Director, and therefore, do not feel comfortable making
a complaint to their Manger or Director.
d) Written Complaint
Filing a Complaint
- Employees and third parties who believe they are experiencing workplace
harassment may choose to submit a written complaint to the Chief
Administrative Officer. Written complaints must be signed by the Complainant
and delivered to the Chief Administrative Officer in an envelope marked
"Personal & Confidential".
- If an Employee or third party believes the workplace harassment they are
experiencing is being perpetrated by the Chief Administrative Officer, the same
process applies, but the complaint is submitted to, and reviewed by, the
Warden or a designated Councillor.
- If the Warden is unable to review the complaint, the same process applies,
whereas the complaint is submitted to, and reviewed by, the Deputy Warden or
a designated Councillor.
- Upon receipt of the complaint, the Chief Administrative Officer will inform the
Director of the service group(s) of the Complainant and the Respondent that a
complaint has been filed and that the Chief Administrative Officer (or designate)
will be conducting a preliminary investigation. The Director or Manager and the
Respondent shall be provided with a copy of the complaint.
- Within ten (10) working days of the written complaint being received, the Chief
Administrative Officer (or designate) shall review the complaint and if
necessary, seek additional information to determine whether the allegations, if
proven, are workplace harassment. At the discretion of the Chief
Administrative Officer, this time period may be extended if required and
reasonable according to the circumstances.
- If the Chief Administrative Officer determines that the allegations are well
founded but do not constitute workplace harassment, the Complainant, the
Respondent, and the Director shall be so informed in writing by the Chief
Administrative Officer. The Chief Administrative Officer may redirect the
Complainant to other appropriate avenues of recourse or may suggest other
means of resolving the situation.
- If the Chief Administrative Officer determines that the allegations are well
founded and do constitute workplace harassment, the option of mediation may
MUNICIPALITY OF THE COUNTY OF ANNAPOLIS
POLICY AND ADMINISTRATION MANUAL
Policy 137
Subject
Respectful Workplace Policy
November 2025
Page 8 of 11
be offered to the Complainant and the Respondent. Both parties must agree
to the mediation in order for the process to begin.
- Within twenty (20) working days of initiating the mediation process, the
Complainant and the Respondent will have resolved the situation or the
mediation will be suspended. A report will be provided by the mediator to the
Chief Administrative Officer indicating the results of the mediation.
- If mediation fails to resolve the situation, or the parties do not agree to
mediation, or the Chief Administrative Officer determines that formal
investigation is the more appropriate action to be taken, the Chief
Administrative Officer will inform the Director, the Complainant, and the
Respondent that an investigation will be conducted. The Chief Administrative
Officer may carry out the investigation or assign an investigator(s).
- The Chief Administrative Officer will inform the Complainant and the
Respondent that they have the option of being accompanied during the
investigation interview by a union official (if a bargaining unit employee), a co-
worker or other support person.
e) Formal Investigation
- The Investigator will interview the Complainant, the Respondent, and any
witnesses, and will review all relevant documentation and evidence.
- The Investigator must complete the investigation and file a report of their
findings to the Chief Administrative Officer within thirty (30) working days of
being assigned the complaint for investigation.
f) Decision / Discipline
- Within twenty (20) working days of receiving the Investigator's report, the Chief
Administrative Officer on the basis of the Investigator's report will determine
whether the Complaint is valid and what disciplinary action, if any, is to be taken
up to and including termination.
- The Complainant and Respondent will each receive, in writing, a letter advising
of the Chief Administrative Officer's decision in regard to resolving the
Complaint.
g) Withdrawal of Complaint
- If at any time after filing a complaint, the Complainant wishes to abandon the
complaint, he or she must communicate this is writing to the Chief
Administrative Officer. However, depending on the circumstances, it may be
necessary for the County to continue investigating the complaint. The Chief
Administrative Officer will determine whether the investigation is to be
continued.
MUNICIPALITY OF THE COUNTY OF ANNAPOLIS
POLICY AND ADMINISTRATION MANUAL
Policy 137
Subject
Respectful Workplace Policy
November 2025
Page 9 of 11
9. FREEDOM OF INFORMATION AND PROTECTION OF PRIVACY
Part XX of the Municipal Government Act, which addresses Freedom of Information
and Protection of Privacy, still applies with full force and effect to information collected
in an investigation. However, personal and/or confidential information shared in such
an investigation will not be disclosed pursuant to sections 480 and 481 of the Municipal
Government Act.
10. RETALIATION
Retaliation against anyone who has reported workplace harassment or participated in
an investigation is prohibited. Retaliation shall result in disciplinary action, up to and
including termination.
10. BAD FAITH COMPLAINTS
Complaints should be undertaken with great care because they may result in damage
to the respondent's reputation and disruptions in the workplace. Complaints made
which are frivolous, vexatious or in bad faith may result in disciplinary action, up to
and including termination.
No disciplinary action will be taken against a complainant who makes a workplace
harassment complaint in good faith and exercises his or her rights under this Policy,
even if the complaint cannot be verified or is not workplace harassment pursuant to
this Policy.
11. REPRESENTATION
During the interview process employees have the option of being accompanied by a
union official (in the case of bargaining unit employees). Employees who are excluded
from bargaining units may seek legal counsel. The cost of such legal representation
will be borne by the employee.
12. TIMELINES
In most cases, the procedural steps will be completed within the timelines outlined
above. However, at the request of any of the parties, the Chief Administrative Officer
may agree to extend the time limits specified at any stage of the process. The Chief
Administrative Officer will ensure that the appropriate parties are notified of any time
limit extensions.
13. WORKPLACE HARASSMENT BY EMPLOYEES TOWARD THIRD PARTIES OR CUSTOMERS
Though third parties and customers cannot access the complaint process described
in the Policy, Managers are to ensure that their employees do not act offensively
toward these parties. In addressing these situations Managers are expected to abide
MUNICIPALITY OF THE COUNTY OF ANNAPOLIS
POLICY AND ADMINISTRATION MANUAL
Policy 137
Subject
Respectful Workplace Policy
November 2025
Page 10 of 11
by the spirit of the Policy and ensure that where internal procedures exist to deal with
the complaint they are followed.
14. ACCOUNTABILITY
Directors and Managers are responsible for:
- ensuring all employees are provided with an opportunity to attend respectful
workplace training;
- being familiar with the requirements of this Policy and all other relevant policies
and procedures;
- taking steps to create and maintain an environment free from workplace
harassment;
- setting a good example and maintaining a high standard of conduct in all dealings
with others;
- assisting the Chief Administrative Officer in determining appropriate disciplinary
action;
- take action to address workplace harassment, even if no complaint has been
made;
- setting a positive example;
- taking action to protect employees and others from workplace harassment;
- responding to allegations of workplace harassment;
- maintaining confidentiality wherever possible.
Employees are responsible for:
- attending respectful workplace training;
- treating all persons with respect and dignity;
- intervening and/or reporting instances of workplace harassment;
- co-operating fully with any and all investigations under this Policy.
Human Resources staff are responsible for:
- evaluating the effectiveness of this policy;
- educating employees about harassment and workplace harassment;
- providing advice as required to the Chief Administrative Officer and Directors;
- providing policy advice to Municipal Council as authorized or requested by the
Chief Administrative Officer;
MUNICIPALITY OF THE COUNTY OF ANNAPOLIS
POLICY AND ADMINISTRATION MANUAL
Policy 137
Subject
Respectful Workplace Policy
November 2025
Page 11 of 11
- responding to employees and managers inquiries;
- providing referrals to EAP Advisory Services.
The Chief Administrative Officer is responsible for:
- reviewing and processing all written complaints;
- assigning mediators and / or investigators;
- providing advice or direction as required to Directors on workplace restoration
actions.
Municipal Clerk's Annotation for Official Policy Book
I certify that this policy was adopted by Municipal Council as indicated below:
Seven (7) Day Notice
November 10, 2025
Council Approval
November 18, 2025
Dawn Campbell November 18, 2025
Municipal Clerk
Date
At Annapolis Royal Nova Scotia