Workplace Complaint Procedure

Velvet Edge Inc., doing business as Velvet Edge Entertainment
2137 Dougall Ave., Windsor, Ontario N8X 1S5
https://velvetedge.ca

Document Number: VE-PRO-004
Effective Date: July 1, 2026
Version: 1.0
Approved By: Joe Jelasic, President
Review Cycle: Reviewed at least annually, as required by the Occupational Health and Safety Act (Ontario).


1. Purpose

This Procedure sets out how Velvet Edge Inc. (the "Company") receives, manages, investigates, and resolves workplace complaints. It constitutes the workplace harassment program required by section 32.0.6 of the Occupational Health and Safety Act (Ontario) ("OHSA"), and the reporting and investigation elements of the workplace violence program required by section 32.0.2, and it implements the measures described in the Ontario Ministry of Labour, Immigration, Training and Skills Development's Code of Practice to Address Workplace Harassment. It must be read together with the Company's Workplace Harassment and Violence Policy (VE-POL-001), Code of Conduct (VE-POL-002), and Policy Against Discrimination (VE-POL-003).

2. What May Be Complained About, and by Whom

This Procedure is available to every worker of the Company, meaning employees (full-time and part-time), independent contractors and their personnel (including all performers and event personnel), volunteers, interns, and students on placements. It covers complaints and incident reports about:

  • workplace harassment, including workplace sexual harassment (VE-POL-001);
  • workplace violence, threats, and domestic violence that may enter the workplace (VE-POL-001);
  • discrimination, poisoned environment, reprisal, and failures to accommodate (VE-POL-003);
  • breaches of the Code of Conduct (VE-POL-002), including impairment, misuse of property, breaches of confidentiality, conflicts of interest, and misconduct involving clients, guests, or children;
  • conduct by any person, including managers, the Company's officers, co-workers, performers, clients and their personnel, event guests, vendors, and venue staff;
  • any other work-related concern a worker wishes to raise; no worker will be turned away because their concern does not fit a category.

The Company will address incidents it becomes aware of even where no formal complaint is made, and third parties (for example, a client or a guest) who raise concerns about the conduct of a Company worker will have those concerns handled under this Procedure as well.

3. Emergencies

Where anyone is in immediate danger, call 911. Then notify the on-site Company contact and the Director of Operations and Logistics as soon as it is safe. Nothing in this Procedure delays or replaces emergency response, first aid, or any report required by law, including reports to the Workplace Safety and Insurance Board for workplace injuries and notices to the Ministry of Labour, Immigration, Training and Skills Development where the OHSA requires them.

4. Where to Complain: Reporting Routes

A complaint or incident report may be made verbally or in writing (email is sufficient) to either of the following, at the complainant's choice:

  1. Mike Dupuis, Director of Operations and Logistics
    [email protected], 226.444.1449 ext. 104 (primary contact); or
  2. Joe Jelasic, President
    [email protected], 226.444.1449 ext. 101.

So that no worker ever has to report to, or be investigated by, a person involved in their complaint:

  • if the complaint involves the Director of Operations and Logistics, it must be made to the President, who will handle it or retain an external investigator;
  • if the complaint involves the President, it must be made to the Director of Operations and Logistics, who will retain a qualified external workplace investigator who is not under the President's direction or control to conduct the investigation, and the President will have no role in selecting the investigator or deciding the outcome of the investigation;
  • if the complaint involves both named contacts, the complaint may be given to either of them in sealed or written form addressed to the external investigator, and an external investigator will be retained to conduct the investigation and recommend the outcome;
  • a worker may at any time also contact the external bodies listed in section 12; using this Procedure is encouraged but is never a precondition to exercising statutory rights.

5. What to Include in a Complaint

A complaint may be made in any form, and help will be provided to put a verbal complaint into writing. To support a fair and speedy investigation, the complainant is asked to provide, to the best of their ability:

  • their name and contact information (see section 6 regarding anonymous reports);
  • the name of the person(s) whose conduct is complained of and their relationship to the complainant (for example, co-worker, manager, client, guest);
  • what happened: the specific words, behaviour, or events, in as much detail as possible;
  • when and where each incident happened (date, time, event, venue), and whether it is ongoing;
  • the names of any witnesses;
  • any relevant documents, messages, photographs, or recordings (for example, texts, emails, social media posts, schedules, call sheets);
  • what outcome the complainant is seeking, if known.

An incomplete complaint will still be received and addressed; missing details can be gathered during the investigation.

6. Anonymous and Third-Party Reports

Anonymous reports will be received and assessed. The Company will act on an anonymous report to the extent the information allows, but anonymity may limit the ability to investigate fully and to report results back. A worker may also ask another person (for example, a co-worker or representative) to raise a concern on their behalf; the Company will follow up directly with the affected worker wherever possible.

7. Initial Handling, Interim Measures, and Informal Resolution

  1. Acknowledgment. The person receiving a complaint will acknowledge it promptly, normally within three (3) business days, confirm what happens next, and provide a copy of this Procedure.
  2. Assessment. The recipient will promptly assess whether the complaint, if true, would breach a Company policy or the law, whether interim measures are needed, whether the matter must be investigated (all complaints and incidents of workplace harassment and workplace violence must be investigated appropriately under OHSA section 32.0.7), and who should investigate (see section 8).
  3. Interim measures. Where appropriate to protect any person or the integrity of the investigation, the Company may implement interim measures pending the outcome, such as: adjusting schedules, casting, or event assignments so the parties do not work together; supervising interactions; restricting a person's attendance at events or premises; removing a guest or requesting a client remove a representative from an event; or placing an employee on paid leave. Interim measures are protective, not disciplinary, and will be applied so as to minimize disadvantage to the complainant; a complainant will not be transferred or have engagements reduced against their wishes as an interim measure unless there is no reasonable alternative.
  4. Informal resolution. Where the complainant wishes it and the matter is suitable (for example, a misunderstanding or a first, less serious incident), the Company may facilitate an informal resolution such as a facilitated conversation, coaching, or clarification of expectations. Informal resolution is always voluntary for the complainant, is never a precondition to a formal investigation, and will not be used for allegations of violence, sexual harassment, serious discrimination, or reprisal, which will proceed to investigation. Even where informal resolution is attempted, the Company will still ensure any incident of workplace harassment or violence is investigated as the OHSA requires.

8. Investigation

8.1 Who Investigates

The investigation will be conducted by a person who is impartial, is not involved in the allegations, is not under the direction or control of any person involved in the allegations, and has, or is supported by someone who has, appropriate knowledge of how to conduct a workplace investigation. Depending on the matter, the investigator will be the Director of Operations and Logistics, the President, or a qualified external investigator. An external investigator will be retained where the complaint involves an officer of the Company, where the allegations are of serious sexual harassment or violence, where specialized expertise is needed, or where impartiality could otherwise reasonably be doubted.

8.2 How the Investigation Is Conducted

The investigator will, at minimum:

  1. keep the investigation confidential, disclose information only as necessary, and instruct all participants not to discuss the matter except to obtain legal advice, medical or counselling support, or as the law allows;
  2. thoroughly interview the complainant and the respondent (the person complained about), separately;
  3. give the respondent particulars of the allegations sufficient to respond, and a full opportunity to respond to each allegation;
  4. interview relevant witnesses, including witnesses who are not workers of the Company (for example, client personnel, venue staff, or guests) where they can reasonably be identified and are willing to participate;
  5. collect and review relevant documents and records, including messages, photographs, video, schedules, call sheets, and equipment or incident logs;
  6. take notes of all interviews and obtain written statements where practicable;
  7. prepare a written investigation report summarizing the steps taken, the allegations, the responses, the evidence, and findings of fact on each allegation, on a balance of probabilities.

8.3 Timelines

  • Investigations will begin as soon as practicable and will be completed within ninety (90) calendar days of the complaint or incident coming to the Company's attention, unless there are extenuating circumstances (for example, more than two respondents, key witness unavailability, or an ongoing police investigation), in which case the parties will be told the revised timeline and the reasons for it.
  • The complainant and the respondent will be given periodic status updates during the investigation.

8.4 Results in Writing

Within ten (10) calendar days of the investigation concluding, the Company will inform the complainant and the respondent (if the respondent is a worker of the Company), in writing, of the results of the investigation and of any corrective action that has been or will be taken as a result. The written results will state the findings; the full investigation report and the specific discipline imposed on another person need not be disclosed, and personal information will be shared only as necessary and as privacy law allows.

9. Outcomes and Corrective Action

Where a complaint is substantiated in whole or in part, the Company will take corrective action proportionate to the conduct, which may include one or more of: a verbal or written apology; education or training; coaching or counselling; a written warning; changes to schedules, casting, duties, or reporting arrangements; removal from particular events or clients; suspension; termination of employment (including for cause); termination of a contract for services; barring a guest from future Company events; ending or restructuring a client or vendor relationship; and reporting conduct to police or regulators where appropriate. The Company will also consider and address any systemic issues the investigation reveals, such as gaps in event security, staffing, supervision, or training, and will correct them.

Where a complaint is not substantiated, no record of the complaint will be placed in the respondent's personnel or contractor file, and the complainant will not be disciplined for a complaint made in good faith. A complaint that the investigator finds was made in bad faith (knowingly false and for an improper purpose) is misconduct and may attract discipline under the Code of Conduct.

10. Confidentiality and Records

  1. Information about a complaint, incident, or investigation, including identifying information about the individuals involved, will not be disclosed except as necessary to protect workers, to investigate, to take corrective action, or as required by law (for example, to the Workplace Safety and Insurance Board, the Ministry of Labour, Immigration, Training and Skills Development, a court, or a tribunal).
  2. Records of complaints, incident reports, investigation notes, witness statements, investigation reports, written results, interim measures, and corrective actions will be kept secure and confidential, separate from ordinary personnel files, accessible only to those who need them, and retained for at least two (2) years from the conclusion of the matter, or longer where litigation, a tribunal proceeding, or the law requires.
  3. Investigation records are not health and safety reports that must be shared with a joint health and safety committee or representative, and will not be posted or circulated.

11. Protection Against Reprisal

No worker will be penalized, disciplined, threatened, denied bookings or shifts, or otherwise disadvantaged for making a complaint in good faith, reporting an incident, providing information in an investigation, or exercising any right under this Procedure, the OHSA, the Ontario Human Rights Code, or the Employment Standards Act, 2000. Reprisal is itself grounds for discipline up to and including termination of employment or of contract. A worker who believes they have suffered reprisal should report it under this Procedure and may also pursue the external remedies in section 12, including a reprisal complaint to the Ontario Labour Relations Board under section 50 of the OHSA.

12. External Rights and Resources

This Procedure does not limit, delay, or replace any external right or remedy. At any time, a worker may contact:

  • Ministry of Labour, Immigration, Training and Skills Development (Health and Safety Contact Centre, 1-877-202-0008) regarding workplace harassment or violence, or to report unsafe work;
  • Human Rights Tribunal of Ontario, to file an application under the Ontario Human Rights Code within the time limits set out in the Code, and the Human Rights Legal Support Centre (1-866-625-5179) for free advice;
  • Ontario Labour Relations Board, for reprisal complaints under the OHSA;
  • Workplace Safety and Insurance Board, for injuries arising out of employment, including chronic or traumatic mental stress arising from workplace harassment, where eligible;
  • Police (911 or Windsor Police Service non-emergency line), where conduct may be criminal, including assault, sexual assault, uttering threats, or criminal harassment;
  • the Employment Standards Program (1-800-531-5551) regarding rights under the Employment Standards Act, 2000;
  • a lawyer, union, or advisor of their choosing; workers are always free to seek independent legal advice.

13. Roles and Responsibilities

  • The President owns this Procedure, receives complaints (including all complaints involving the Director of Operations and Logistics), ensures external investigators are retained where required, and ensures corrective actions are implemented.
  • The Director of Operations and Logistics is the primary complaint recipient, manages intake, interim measures, investigations, records, and timelines, retains the external investigator where the complaint involves the President, and reports annually to the President on complaint trends and program effectiveness.
  • All workers must report incidents they experience or witness, participate honestly in investigations when asked, respect confidentiality, and refrain from reprisal.

14. Information, Instruction, and Review

Every worker will receive this Procedure, together with VE-POL-001, VE-POL-002, and VE-POL-003, at the start of their employment or engagement, and will be given information and instruction appropriate to their role on its contents, as required by sections 32.0.5 and 32.0.8 of the OHSA. This Procedure is published at https://velvetedge.ca. The Company will review this Procedure at least once each calendar year, and whenever an investigation, inspection, or change in the law or in our operations shows a need, and will maintain the current version on the website.

15. Related Documents

  • Workplace Harassment and Violence Policy (VE-POL-001)
  • Code of Conduct for Acceptable Workplace Behaviour (VE-POL-002)
  • Policy Against Discrimination (VE-POL-003)
  • Ontario Ministry of Labour, Immigration, Training and Skills Development, Code of Practice to Address Workplace Harassment under Ontario's Occupational Health and Safety Act

16. 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

VersionDateDescriptionApproved By
1.0July 1, 2026Initial procedure issued.Joe Jelasic, President