Policy Against Discrimination
Velvet Edge Inc., doing business as Velvet Edge Entertainment
2137 Dougall Ave., Windsor, Ontario N8X 1S5
https://velvetedge.ca
Policy Number: VE-POL-003
Effective Date: July 1, 2026
Version: 1.0
Approved By: Joe Jelasic, President
Review Cycle: Reviewed at least annually and whenever operations change materially.
1. Commitment
Velvet Edge Inc. (the "Company") is committed to a workplace, and to events, in which every person is treated with dignity and respect and enjoys equal treatment without discrimination. Discrimination in any aspect of employment or engagement, or in the services the Company provides, is prohibited and will not be tolerated, whether it comes from the Company, a manager, a co-worker, a performer, a client, a guest, a vendor, or any other person.
This Policy is grounded in the Ontario Human Rights Code, R.S.O. 1990, c. H.19 (the "Code"), which has primacy over other Ontario legislation and applies to every employer and service provider in Ontario, and reflects the values of the Canadian Charter of Rights and Freedoms. As a provincially regulated Ontario business, the Company's obligations arise principally under the Code; where the Company deals with federally regulated organizations, the parallel protections of the Canadian Human Rights Act, R.S.C. 1985, c. H-6, apply to those organizations. The Company also complies with the Accessibility for Ontarians with Disabilities Act, 2005 ("AODA") and its Integrated Accessibility Standards in the conduct of its business and its public events.
2. Application and Scope
This Policy applies to every person who performs work for or supplies services to the Company, including employees (full-time and part-time), independent contractors and their personnel (including all performers and event personnel), volunteers, interns, and students on placements (collectively, "workers"), and to the Company's officers and directors. It applies to every aspect of the working relationship, including:
- recruitment, auditions, casting, and hiring, including advertisements, application forms, and interviews;
- selection, booking, and assignment of contractors and performers to engagements;
- terms of engagement, rates of pay, hours, scheduling, and shift assignment;
- training, promotion, and access to opportunities and roles;
- costumes, appearance standards, facilities, and changing arrangements;
- discipline, termination of employment, and termination or non-renewal of contracts;
- every workplace identified in the Workplace Harassment and Violence Policy (VE-POL-001), including client sites, event venues, vehicles, and virtual settings.
Because the Company also provides services to the public, including publicly ticketed events, this Policy likewise commits the Company to equal treatment without discrimination of clients, guests, and members of the public in the provision of services, accommodation of guests with disabilities, and admission to events, in accordance with section 1 of the Code and the AODA.
3. Protected Grounds
Under section 5 of the Code, every worker has a right to equal treatment in employment without discrimination or harassment because of:
- race;
- ancestry;
- place of origin;
- colour;
- ethnic origin;
- citizenship;
- creed (religion);
- sex (including pregnancy and breastfeeding);
- sexual orientation;
- gender identity;
- gender expression;
- age (18 and over in employment);
- record of offences (a conviction for which a pardon or record suspension has been granted, or a conviction under provincial law);
- marital status (including common-law and same-sex partnerships);
- family status (a parent-and-child relationship, including caregiving responsibilities);
- disability (physical, mental, learning, or sensory disabilities, injuries for which benefits were claimed under the Workplace Safety and Insurance Act, 1997, and perceived disabilities, including past, present, and perceived conditions and substance dependencies).
Discrimination is equally prohibited where it is based on a person's association or relationship with a person identified by one of these grounds, or on the perception that a person belongs to one of these groups.
4. Definitions
4.1 Discrimination
"Discrimination" means any distinction, exclusion, preference, or adverse treatment, whether intentional or not, based in whole or in part on a protected ground, that imposes burdens on or withholds benefits from a person. It includes:
- direct discrimination, such as refusing to book a performer because of their race or age;
- indirect discrimination, accomplished through another person or arrangement;
- constructive (adverse effect) discrimination, where a requirement, rule, or standard that appears neutral (for example, a costume, grooming, scheduling, or lifting requirement) disadvantages people identified by a protected ground and is not a good-faith bona fide requirement that cannot be accommodated without undue hardship;
- systemic discrimination, arising from patterns of behaviour, policies, or practices that create or perpetuate disadvantage.
4.2 Harassment Because of a Protected Ground
"Harassment" means engaging in a course of vexatious comment or conduct against a person because of a protected ground that is known or ought reasonably to be known to be unwelcome. Harassment because of sex, sexual orientation, gender identity, or gender expression, and sexual solicitation by a person in a position to grant or deny a benefit (Code, sections 7(2) and 7(3)), are dealt with in detail in the Workplace Harassment and Violence Policy (VE-POL-001), which should be read together with this Policy.
4.3 Poisoned Environment
A "poisoned environment" is created where comment or conduct connected to a protected ground (for example, slurs, stereotyping, degrading jokes, or offensive imagery) makes the workplace hostile or oppressive for a person or group, even where the conduct is not directed at a specific person. A single serious incident can poison a work environment. A poisoned environment is a form of discrimination and is prohibited.
4.4 Reprisal
"Reprisal" means any adverse treatment, or threat of adverse treatment, of a person because they have claimed or enforced a right under the Code or this Policy, made or supported a complaint, refused to discriminate against another person, or participated in an investigation or proceeding. Reprisal is prohibited by section 8 of the Code and by this Policy.
5. Specific Commitments of the Company
- Casting and booking. Decisions about which performers and workers are engaged, booked, and assigned will be made on legitimate criteria: skill, suitability for the artistic requirements of the act or role, availability, reliability, safety, and cost. Where a genuine artistic or dramatic requirement of a role relates to a personal characteristic (for example, casting a character of a particular age range or appearance for a themed event), the Company will apply that requirement only to the extent the Code permits, in good faith, and as narrowly as the artistic purpose allows.
- Client and guest preferences are not a defence. The Company will not accept or act on a client's, guest's, or venue's request to exclude, remove, or reassign a worker for a reason connected to a protected ground. Client preference does not excuse discrimination, and the Company will refuse such requests and, where necessary, will decline or end an engagement rather than give effect to them.
- Equal pay and terms. Rates, terms, and conditions will not differ because of a protected ground. The Company also complies with the equal-pay-for-equal-work provisions of the Employment Standards Act, 2000 and the Pay Equity Act (Ontario) to the extent they apply.
- Recruitment. Job postings, audition notices, application forms, and interviews will not ask for or rely on information about protected grounds except as the Code permits (for example, a special program under section 14 of the Code, or a bona fide requirement after a conditional offer).
- Facilities and costumes. Changing facilities, costumes, and appearance standards will respect workers' gender identity and gender expression, creed-based dress, and disability-related needs.
- Public events. Admission, ticketing, service, and accessibility at the Company's own events will be provided without discrimination, and the Company will provide accessible customer service consistent with the AODA, including accommodating service animals and support persons as the law requires.
6. Duty to Accommodate
The Company will accommodate the needs of workers, applicants, clients, and guests that are connected to a protected ground, most commonly disability, creed, sex (including pregnancy), family status, and gender identity, to the point of undue hardship, as required by the Code. Accommodation may include, for example: modified duties, scheduling, or call times; adjustments to costumes, staging, or equipment; accessible venues and facilities; time and space for religious observance; breaks and facilities for breastfeeding or expressing milk; and modified arrangements for workers with caregiving responsibilities.
The accommodation process is a shared responsibility:
- a worker who needs accommodation should tell the Director of Operations and Logistics (or the President) what need is connected to a protected ground, in as much detail as is reasonably necessary; a diagnosis need not be disclosed, only the functional needs and restrictions;
- the Company will accept accommodation requests in good faith, will respond promptly, will obtain expert opinion or information where needed (at the Company's expense), will keep the information confidential and separate from general files, and will implement the most appropriate accommodation short of undue hardship, considering the worker's dignity, individualization, and full participation;
- the worker will cooperate in the process, provide reasonably required information, and work with the Company on reasonable accommodation options; the worker is entitled to reasonable accommodation, not necessarily their preferred accommodation;
- undue hardship is assessed only on the factors the Code permits: cost (considering outside sources of funding), and health and safety requirements. Inconvenience, morale, or customer or client preference are not undue hardship.
7. Responsibilities
- The President is accountable for this Policy and for ensuring the Company's practices, contracts, and event operations comply with it.
- The Director of Operations and Logistics administers this Policy, receives accommodation requests and complaints, ensures workers and clients are informed of it, and ensures engagements are staffed and conducted consistently with it.
- All workers must not discriminate, must not harass, must support an inclusive working environment, must report discrimination they experience or witness, and must cooperate in investigations and in accommodation processes affecting their work.
8. Complaints
Any worker who believes they have experienced or witnessed discrimination, a poisoned environment, or reprisal should report it under the Company's Workplace Complaint Procedure (VE-PRO-004):
- Mike Dupuis, Director of Operations and Logistics, [email protected], 226.444.1449 ext. 104; or
- Joe Jelasic, President, [email protected], 226.444.1449 ext. 101, where the complaint involves the Director of Operations and Logistics.
Complaints will be investigated promptly, fairly, and confidentially to the extent possible, and corrective action will be taken where discrimination is found, up to and including termination of employment or of contract. No person will suffer reprisal for a good-faith complaint or for participating in an investigation.
This Policy does not take away any person's right to seek advice or file an application with the Human Rights Tribunal of Ontario within the time limits set out in the Code, to contact the Ontario Human Rights Commission or the Human Rights Legal Support Centre, or to pursue any other remedy available at law, whether or not they use the Company's internal procedure.
9. Training, Communication, and Review
This Policy will be provided to every worker at the start of their employment or engagement, published at https://velvetedge.ca, incorporated by reference into contractor agreements, and reviewed at least annually by the President and the Director of Operations and Logistics. Questions about this Policy may be directed to either of the contacts named above.
10. Related Documents and Legislation
- Workplace Harassment and Violence Policy (VE-POL-001)
- Code of Conduct for Acceptable Workplace Behaviour (VE-POL-002)
- Workplace Complaint Procedure (VE-PRO-004)
- Ontario Human Rights Code, R.S.O. 1990, c. H.19
- Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11
- Employment Standards Act, 2000, S.O. 2000, c. 41
- Canadian Human Rights Act, R.S.C. 1985, c. H-6 (federally regulated organizations)
- Ontario Human Rights Commission, A policy primer: Guide to developing human rights policies and procedures
11. Approval
Approved and signed electronically on behalf of Velvet Edge Inc.
Joe Jelasic, President
Velvet Edge Inc. d.b.a. Velvet Edge Entertainment
Date: July 1, 2026
Revision History
| Version | Date | Description | Approved By |
|---|---|---|---|
| 1.0 | July 1, 2026 | Initial policy issued. | Joe Jelasic, President |
Policy Against Discrimination
Velvet Edge Inc., doing business as Velvet Edge Entertainment
2137 Dougall Ave., Windsor, Ontario N8X 1S5
https://velvetedge.ca
Policy Number: VE-POL-003
Effective Date: July 1, 2026
Version: 1.0
Approved By: Joe Jelasic, President
Review Cycle: Reviewed at least annually and whenever operations change materially.
1. Commitment
Velvet Edge Inc. (the "Company") is committed to a workplace, and to events, in which every person is treated with dignity and respect and enjoys equal treatment without discrimination. Discrimination in any aspect of employment or engagement, or in the services the Company provides, is prohibited and will not be tolerated, whether it comes from the Company, a manager, a co-worker, a performer, a client, a guest, a vendor, or any other person.
This Policy is grounded in the Ontario Human Rights Code, R.S.O. 1990, c. H.19 (the "Code"), which has primacy over other Ontario legislation and applies to every employer and service provider in Ontario, and reflects the values of the Canadian Charter of Rights and Freedoms. As a provincially regulated Ontario business, the Company's obligations arise principally under the Code; where the Company deals with federally regulated organizations, the parallel protections of the Canadian Human Rights Act, R.S.C. 1985, c. H-6, apply to those organizations. The Company also complies with the Accessibility for Ontarians with Disabilities Act, 2005 ("AODA") and its Integrated Accessibility Standards in the conduct of its business and its public events.
2. Application and Scope
This Policy applies to every person who performs work for or supplies services to the Company, including employees (full-time and part-time), independent contractors and their personnel (including all performers and event personnel), volunteers, interns, and students on placements (collectively, "workers"), and to the Company's officers and directors. It applies to every aspect of the working relationship, including:
- recruitment, auditions, casting, and hiring, including advertisements, application forms, and interviews;
- selection, booking, and assignment of contractors and performers to engagements;
- terms of engagement, rates of pay, hours, scheduling, and shift assignment;
- training, promotion, and access to opportunities and roles;
- costumes, appearance standards, facilities, and changing arrangements;
- discipline, termination of employment, and termination or non-renewal of contracts;
- every workplace identified in the Workplace Harassment and Violence Policy (VE-POL-001), including client sites, event venues, vehicles, and virtual settings.
Because the Company also provides services to the public, including publicly ticketed events, this Policy likewise commits the Company to equal treatment without discrimination of clients, guests, and members of the public in the provision of services, accommodation of guests with disabilities, and admission to events, in accordance with section 1 of the Code and the AODA.
3. Protected Grounds
Under section 5 of the Code, every worker has a right to equal treatment in employment without discrimination or harassment because of:
- race;
- ancestry;
- place of origin;
- colour;
- ethnic origin;
- citizenship;
- creed (religion);
- sex (including pregnancy and breastfeeding);
- sexual orientation;
- gender identity;
- gender expression;
- age (18 and over in employment);
- record of offences (a conviction for which a pardon or record suspension has been granted, or a conviction under provincial law);
- marital status (including common-law and same-sex partnerships);
- family status (a parent-and-child relationship, including caregiving responsibilities);
- disability (physical, mental, learning, or sensory disabilities, injuries for which benefits were claimed under the Workplace Safety and Insurance Act, 1997, and perceived disabilities, including past, present, and perceived conditions and substance dependencies).
Discrimination is equally prohibited where it is based on a person's association or relationship with a person identified by one of these grounds, or on the perception that a person belongs to one of these groups.
4. Definitions
4.1 Discrimination
"Discrimination" means any distinction, exclusion, preference, or adverse treatment, whether intentional or not, based in whole or in part on a protected ground, that imposes burdens on or withholds benefits from a person. It includes:
- direct discrimination, such as refusing to book a performer because of their race or age;
- indirect discrimination, accomplished through another person or arrangement;
- constructive (adverse effect) discrimination, where a requirement, rule, or standard that appears neutral (for example, a costume, grooming, scheduling, or lifting requirement) disadvantages people identified by a protected ground and is not a good-faith bona fide requirement that cannot be accommodated without undue hardship;
- systemic discrimination, arising from patterns of behaviour, policies, or practices that create or perpetuate disadvantage.
4.2 Harassment Because of a Protected Ground
"Harassment" means engaging in a course of vexatious comment or conduct against a person because of a protected ground that is known or ought reasonably to be known to be unwelcome. Harassment because of sex, sexual orientation, gender identity, or gender expression, and sexual solicitation by a person in a position to grant or deny a benefit (Code, sections 7(2) and 7(3)), are dealt with in detail in the Workplace Harassment and Violence Policy (VE-POL-001), which should be read together with this Policy.
4.3 Poisoned Environment
A "poisoned environment" is created where comment or conduct connected to a protected ground (for example, slurs, stereotyping, degrading jokes, or offensive imagery) makes the workplace hostile or oppressive for a person or group, even where the conduct is not directed at a specific person. A single serious incident can poison a work environment. A poisoned environment is a form of discrimination and is prohibited.
4.4 Reprisal
"Reprisal" means any adverse treatment, or threat of adverse treatment, of a person because they have claimed or enforced a right under the Code or this Policy, made or supported a complaint, refused to discriminate against another person, or participated in an investigation or proceeding. Reprisal is prohibited by section 8 of the Code and by this Policy.
5. Specific Commitments of the Company
- Casting and booking. Decisions about which performers and workers are engaged, booked, and assigned will be made on legitimate criteria: skill, suitability for the artistic requirements of the act or role, availability, reliability, safety, and cost. Where a genuine artistic or dramatic requirement of a role relates to a personal characteristic (for example, casting a character of a particular age range or appearance for a themed event), the Company will apply that requirement only to the extent the Code permits, in good faith, and as narrowly as the artistic purpose allows.
- Client and guest preferences are not a defence. The Company will not accept or act on a client's, guest's, or venue's request to exclude, remove, or reassign a worker for a reason connected to a protected ground. Client preference does not excuse discrimination, and the Company will refuse such requests and, where necessary, will decline or end an engagement rather than give effect to them.
- Equal pay and terms. Rates, terms, and conditions will not differ because of a protected ground. The Company also complies with the equal-pay-for-equal-work provisions of the Employment Standards Act, 2000 and the Pay Equity Act (Ontario) to the extent they apply.
- Recruitment. Job postings, audition notices, application forms, and interviews will not ask for or rely on information about protected grounds except as the Code permits (for example, a special program under section 14 of the Code, or a bona fide requirement after a conditional offer).
- Facilities and costumes. Changing facilities, costumes, and appearance standards will respect workers' gender identity and gender expression, creed-based dress, and disability-related needs.
- Public events. Admission, ticketing, service, and accessibility at the Company's own events will be provided without discrimination, and the Company will provide accessible customer service consistent with the AODA, including accommodating service animals and support persons as the law requires.
6. Duty to Accommodate
The Company will accommodate the needs of workers, applicants, clients, and guests that are connected to a protected ground, most commonly disability, creed, sex (including pregnancy), family status, and gender identity, to the point of undue hardship, as required by the Code. Accommodation may include, for example: modified duties, scheduling, or call times; adjustments to costumes, staging, or equipment; accessible venues and facilities; time and space for religious observance; breaks and facilities for breastfeeding or expressing milk; and modified arrangements for workers with caregiving responsibilities.
The accommodation process is a shared responsibility:
- a worker who needs accommodation should tell the Director of Operations and Logistics (or the President) what need is connected to a protected ground, in as much detail as is reasonably necessary; a diagnosis need not be disclosed, only the functional needs and restrictions;
- the Company will accept accommodation requests in good faith, will respond promptly, will obtain expert opinion or information where needed (at the Company's expense), will keep the information confidential and separate from general files, and will implement the most appropriate accommodation short of undue hardship, considering the worker's dignity, individualization, and full participation;
- the worker will cooperate in the process, provide reasonably required information, and work with the Company on reasonable accommodation options; the worker is entitled to reasonable accommodation, not necessarily their preferred accommodation;
- undue hardship is assessed only on the factors the Code permits: cost (considering outside sources of funding), and health and safety requirements. Inconvenience, morale, or customer or client preference are not undue hardship.
7. Responsibilities
- The President is accountable for this Policy and for ensuring the Company's practices, contracts, and event operations comply with it.
- The Director of Operations and Logistics administers this Policy, receives accommodation requests and complaints, ensures workers and clients are informed of it, and ensures engagements are staffed and conducted consistently with it.
- All workers must not discriminate, must not harass, must support an inclusive working environment, must report discrimination they experience or witness, and must cooperate in investigations and in accommodation processes affecting their work.
8. Complaints
Any worker who believes they have experienced or witnessed discrimination, a poisoned environment, or reprisal should report it under the Company's Workplace Complaint Procedure (VE-PRO-004):
- Mike Dupuis, Director of Operations and Logistics, [email protected], 226.444.1449 ext. 104; or
- Joe Jelasic, President, [email protected], 226.444.1449 ext. 101, where the complaint involves the Director of Operations and Logistics.
Complaints will be investigated promptly, fairly, and confidentially to the extent possible, and corrective action will be taken where discrimination is found, up to and including termination of employment or of contract. No person will suffer reprisal for a good-faith complaint or for participating in an investigation.
This Policy does not take away any person's right to seek advice or file an application with the Human Rights Tribunal of Ontario within the time limits set out in the Code, to contact the Ontario Human Rights Commission or the Human Rights Legal Support Centre, or to pursue any other remedy available at law, whether or not they use the Company's internal procedure.
9. Training, Communication, and Review
This Policy will be provided to every worker at the start of their employment or engagement, published at https://velvetedge.ca, incorporated by reference into contractor agreements, and reviewed at least annually by the President and the Director of Operations and Logistics. Questions about this Policy may be directed to either of the contacts named above.
10. Related Documents and Legislation
- Workplace Harassment and Violence Policy (VE-POL-001)
- Code of Conduct for Acceptable Workplace Behaviour (VE-POL-002)
- Workplace Complaint Procedure (VE-PRO-004)
- Ontario Human Rights Code, R.S.O. 1990, c. H.19
- Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11
- Employment Standards Act, 2000, S.O. 2000, c. 41
- Canadian Human Rights Act, R.S.C. 1985, c. H-6 (federally regulated organizations)
- Ontario Human Rights Commission, A policy primer: Guide to developing human rights policies and procedures
11. Approval
Approved and signed electronically on behalf of Velvet Edge Inc.
Joe Jelasic, President
Velvet Edge Inc. d.b.a. Velvet Edge Entertainment
Date: July 1, 2026
Revision History
| Version | Date | Description | Approved By |
|---|---|---|---|
| 1.0 | July 1, 2026 | Initial policy issued. | Joe Jelasic, President |