Workplace Harassment and Violence Policy
Velvet Edge Inc., doing business as Velvet Edge Entertainment
2137 Dougall Ave., Windsor, Ontario N8X 1S5
https://velvetedge.ca
Policy Number: VE-POL-001
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), and whenever there is a significant change to our operations.
1. Purpose and Commitment
Velvet Edge Inc. (the "Company") is committed to providing a working environment in which every worker is treated with dignity and respect, and which is free from workplace harassment, workplace sexual harassment, and workplace violence. Harassment and violence in any form are unacceptable and will not be tolerated in any workplace of the Company, whether that workplace is our premises at 2137 Dougall Ave., Windsor, Ontario, a client site, an event venue, a rehearsal or production space, a vehicle used for work, or a virtual or remote setting in which work is performed.
This Policy is made pursuant to sections 32.0.1 through 32.0.8 of the Occupational Health and Safety Act, R.S.O. 1990, c. O.1 ("OHSA"), and is intended to operate together with the Ontario Human Rights Code, R.S.O. 1990, c. H.19 (the "Code"), the Employment Standards Act, 2000, S.O. 2000, c. 41, the Workplace Safety and Insurance Act, 1997, and, where conduct constitutes a criminal offence (including assault, sexual assault, uttering threats, or criminal harassment), the Criminal Code of Canada, R.S.C. 1985, c. C-46. Nothing in this Policy limits or replaces any right or remedy available to a worker under those statutes.
2. Application and Scope
This Policy applies to every person who performs work for or supplies services to the Company, in any capacity, including:
- employees, whether full-time, part-time, seasonal, or casual;
- independent contractors, subcontractors, and their personnel, including musicians, dancers, actors, aerialists, ground acrobats, prop manipulators, jugglers and juggling instructors, costumed characters, hosts, models, disc jockeys, audio-visual technicians, riggers, stagehands, designers, fabricators, and all other performers and event personnel engaged by the Company;
- volunteers, interns, co-op students, and persons on work placements;
- officers and directors of the Company, including the President and the Director of Operations and Logistics.
All of the persons listed above are referred to in this Policy as "workers." This Policy protects workers from harassment and violence by any person, including supervisors, managers, owners, co-workers, other performers, clients and client personnel, event guests and members of the public, vendors, venue staff, and any other third party present in a workplace of the Company.
This Policy applies:
- at the Company's premises at 2137 Dougall Ave., Windsor, Ontario;
- at every client event, brand activation, production, rehearsal, site visit, load-in, load-out, and equipment delivery or pick-up;
- at the Company's own publicly ticketed events, including recurring events such as the Regency-era Ball and the annual Halloween party, before, during, and after event hours;
- in vehicles used for Company work and during work-related travel;
- at work-related social functions;
- in any virtual or electronic setting connected to work, including email, text and instant messaging, telephone and video calls, social media, collaborative platforms, and any other information and communications technology. Consistent with the amendments made to the OHSA by the Working for Workers Five Act, 2024, workplace harassment and workplace sexual harassment include conduct that occurs virtually through the use of information and communications technology.
3. Definitions
3.1 Workplace Harassment
"Workplace harassment" means engaging in a course of vexatious comment or conduct against a worker in a workplace, including virtually through the use of information and communications technology, that is known or ought reasonably to be known to be unwelcome, and includes workplace sexual harassment. A "course" of conduct usually involves repeated behaviour, but a single serious incident, such as an unwelcome sexual solicitation or a threat, may also constitute workplace harassment.
3.2 Workplace Sexual Harassment
"Workplace sexual harassment" means:
- engaging in a course of vexatious comment or conduct against a worker in a workplace, including virtually through the use of information and communications technology, because of sex, sexual orientation, gender identity, or gender expression, where the course of comment or conduct is known or ought reasonably to be known to be unwelcome; or
- making a sexual solicitation or advance where the person making the solicitation or advance is in a position to confer, grant, or deny a benefit or advancement to the worker, and the person knows or ought reasonably to know that the solicitation or advance is unwelcome.
3.3 Workplace Violence
"Workplace violence" means:
- the exercise of physical force by a person against a worker, in a workplace, that causes or could cause physical injury to the worker;
- an attempt to exercise physical force against a worker, in a workplace, that could cause physical injury to the worker; or
- a statement or behaviour that it is reasonable for a worker to interpret as a threat to exercise physical force against the worker, in a workplace, that could cause physical injury to the worker.
3.4 What Harassment Is Not
Reasonable action taken by the Company, a manager, or a supervisor relating to the management and direction of workers or the workplace is not workplace harassment. This includes reasonable direction on performance and conduct, scheduling and casting decisions made in good faith, safety instructions (including instructions relating to rigging, spotting, and acrobatic work), coaching, performance feedback, and disciplinary measures applied in good faith. Ordinary artistic direction, choreography notes, and rehearsal corrections delivered respectfully are not harassment. Legitimate physical contact that is an agreed and rehearsed part of an act (for example, spotting an aerialist, basing a ground acrobat, or partnered choreography) is not harassment or violence when it is performed as rehearsed and with the continuing consent of those involved.
4. Examples of Prohibited Conduct
The following are examples only and do not limit the definitions above.
4.1 Workplace Harassment
- bullying, intimidation, humiliating or demeaning comments, name-calling, or slurs;
- spreading malicious rumours or gossip about a worker, including about a performer's personal life;
- sabotaging a worker's equipment, costume, props, rigging, or work product;
- persistent unwarranted criticism, shouting, or public belittling that goes beyond legitimate direction;
- offensive or intimidating messages, images, or posts directed at or about a worker through any electronic or virtual means, including social media commentary about a performer's appearance or performance that is vexatious and unwelcome;
- practical jokes or hazing that embarrass, endanger, or single out a worker;
- isolating, excluding, or ignoring a worker in a vexatious manner.
4.2 Workplace Sexual Harassment
- unwelcome sexual remarks, jokes, innuendo, or taunting about a worker's body, appearance, costume, clothing, sex, sexual orientation, gender identity, or gender expression;
- unwelcome touching, patting, pinching, brushing against, or any unnecessary physical contact, including contact under the pretext of adjusting a costume, applying makeup, fitting a harness, or spotting, where that contact is not a consented and necessary part of the work;
- leering, staring, or gestures of a sexual nature;
- displaying, sending, or sharing sexually suggestive or explicit images or messages;
- photographing or recording a worker in a state of undress or while changing, or in any sexualized manner, without consent, including in dressing, changing, or backstage areas;
- requests or pressure for dates or sexual favours, including any suggestion, express or implied, that bookings, casting, shifts, pay, or other advantages depend on tolerating or granting sexual attention (a form of harassment sometimes called "quid pro quo," which is strictly prohibited and will be treated as gross misconduct);
- sexual solicitation or advances by any person in a position to grant or deny a benefit, including a manager, director, choreographer, booking coordinator, or client representative.
4.3 Workplace Violence
- hitting, pushing, kicking, spitting, or throwing objects at a worker;
- physically blocking, cornering, or restraining a worker;
- threatening statements or gestures, whether in person, in writing, or electronically, including threats made by intoxicated event guests;
- brandishing a weapon or any object used as a weapon;
- deliberately tampering with rigging, aerial equipment, lifts, staging, electrical systems, or safety equipment in a way that could injure a worker.
5. Event-Specific Risks and Precautions
The Company acknowledges that its work environments carry particular risks: workers perform at public and private events where alcohol may be served; performers, including aerialists, acrobats, dancers, and costumed characters, work in close proximity to guests; costumed characters may have restricted vision and mobility; and workers handle cash, valuable equipment, and late-night load-outs. In accordance with section 32.0.3 of the OHSA, the Company assesses the risks of workplace violence arising from the nature of the workplace, the type of work, and the conditions of work, including these event-specific circumstances, and reassesses those risks as often as necessary and whenever the nature of our events or venues changes materially. The results of these assessments will be communicated to workers.
Measures the Company takes and expects at events include, as applicable to the engagement:
- a designated on-site Company contact for every event, identified to all workers before the event begins;
- coordination with venue security or client security personnel, including agreed procedures for removing aggressive or intoxicated guests;
- a rule that no guest is entitled to touch a performer; performers may end an interaction at any time, and costumed characters and roving performers may be assigned a handler or escort where the risk assessment warrants it;
- secure, private changing and dressing areas for performers, off limits to guests, clients, and any worker who has no work-related reason to be there;
- working alone protocols for late load-outs, deliveries, and equipment pick-ups, including check-in procedures;
- immediate access to a means of summoning assistance (on-site contact, venue security, or 911).
6. Domestic Violence
If the Company becomes aware, or ought reasonably to be aware, that domestic violence that would likely expose a worker to physical injury may occur in the workplace, the Company will take every precaution reasonable in the circumstances to protect the worker, as required by section 32.0.4 of the OHSA. Workers who fear that domestic violence may follow them into a workplace, including an event site, are encouraged to confide in the Director of Operations and Logistics or the President so that a safety plan can be put in place. Such information will be kept confidential to the greatest extent possible.
7. Reporting an Incident or Complaint
Any worker who experiences or witnesses workplace harassment, workplace sexual harassment, or workplace violence is strongly encouraged to report it. No worker will be penalized, reprised against, or disciplined for making a report in good faith or for participating in an investigation.
Where there is immediate danger to any person, call 911 first, then notify the on-site Company contact and the Director of Operations and Logistics as soon as it is safe to do so.
Reports and complaints may be made verbally or in writing to:
- 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, in particular where the complaint involves, or the worker is not comfortable reporting to, the Director of Operations and Logistics.
Where a complaint involves the President, it will be referred to a qualified external workplace investigator who is not under the direction or control of the President, and the Director of Operations and Logistics will retain that investigator. Full reporting routes, the information to include in a complaint, and the investigation process are set out in the Company's Workplace Complaint Procedure (VE-PRO-004), which forms the workplace harassment program and part of the workplace violence program required by sections 32.0.2 and 32.0.6 of the OHSA and should be read together with this Policy.
8. Investigation
The Company will ensure that an investigation appropriate in the circumstances is conducted into every incident and complaint of workplace harassment or workplace violence of which it becomes aware, whether or not a formal complaint is made, as required by section 32.0.7 of the OHSA. Investigations will be conducted in accordance with the Workplace Complaint Procedure and will be objective, confidential to the extent possible, and completed within ninety (90) calendar days of the complaint or incident coming to the Company's attention, unless there are extenuating circumstances. The worker who alleges harassment and the alleged harasser, if a worker of the Company, will be informed in writing of the results of the investigation and of any corrective action taken or that will be taken, within ten (10) calendar days of the conclusion of the investigation.
9. Confidentiality
Information obtained about an incident or complaint of workplace harassment or workplace violence, including identifying information about any individuals involved, will not be disclosed unless the disclosure is necessary to protect workers, to investigate the complaint or incident, to take corrective action, or as otherwise required by law. All persons involved in an incident, complaint, or investigation are expected to keep the matter confidential, subject to their right to seek legal advice, to consult a medical or counselling professional, or to exercise statutory rights.
10. No Reprisal
Reprisal or retaliation against any person for reporting an incident in good faith, for participating in an investigation, or for exercising any right under this Policy, the OHSA, the Code, or the Employment Standards Act, 2000 is itself a serious violation of this Policy and is prohibited. Reprisal includes termination or threatened termination of employment or of a contract, reduction or withdrawal of bookings or shifts, demotion, blacklisting, intimidation, and any other adverse treatment. Any person found to have engaged in reprisal will be subject to corrective action up to and including termination of employment or of contract.
11. Responsibilities
- The President is accountable for this Policy, approves it, ensures resources are available to implement it, and acts as the alternate recipient of complaints.
- The Director of Operations and Logistics administers this Policy, receives reports and complaints, arranges investigations, implements interim and corrective measures, ensures risk assessments are conducted, and ensures workers receive information and instruction on this Policy and the Workplace Complaint Procedure as required by sections 32.0.5 and 32.0.8 of the OHSA.
- All workers, including contractors, performers, and volunteers, must treat others with respect, must not engage in harassment or violence, must report incidents they experience or witness, and must cooperate honestly in investigations.
- Clients, guests, vendors, and venue personnel are expected to respect this Policy. The Company reserves the right to remove any person from an event, to suspend or terminate services under a client agreement, and to refuse admission to or eject any guest from a Company event, where that person harasses or threatens a worker.
12. Corrective Action and Discipline
A worker who engages in workplace harassment, workplace sexual harassment, workplace violence, or reprisal will face corrective action proportionate to the conduct, which may include an apology, coaching or training, a written warning, removal from an event or engagement, suspension, reassignment, termination of employment for cause, or termination of a contract for services. Conduct that may be criminal will be reported to police where appropriate. A complaint made in bad faith, meaning a complaint the complainant knows to be false and makes for an improper purpose, is itself misconduct and may attract discipline; an unproven complaint made in good faith is not misconduct and will never attract discipline.
13. Training, Communication, and Acknowledgment
This Policy and the Workplace Complaint Procedure will be provided to every worker at the start of their employment or engagement, will be reviewed with workers as part of event briefings where relevant, and are published at https://velvetedge.ca. Every worker, including every contractor and performer, will be asked to sign an acknowledgment confirming that they have read and understood this Policy, and contractor agreements will incorporate compliance with this Policy as a term of engagement.
14. Review
The Company will review this Policy, and the program set out in the Workplace Complaint Procedure, at least once each calendar year and whenever a deficiency is identified, an investigation reveals a gap, or the Company's operations change materially. The current version will always be the version published at https://velvetedge.ca.
15. Related Documents and Legislation
- Code of Conduct for Acceptable Workplace Behaviour (VE-POL-002)
- Policy Against Discrimination (VE-POL-003)
- Workplace Complaint Procedure (VE-PRO-004)
- Occupational Health and Safety Act, R.S.O. 1990, c. O.1, Part III.0.1
- Ontario Human Rights Code, R.S.O. 1990, c. H.19
- Employment Standards Act, 2000, S.O. 2000, c. 41
- Workplace Safety and Insurance Act, 1997, S.O. 1997, c. 16, Sched. A
- Criminal Code, R.S.C. 1985, c. C-46 (Canada)
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
| Version | Date | Description | Approved By |
|---|---|---|---|
| 1.0 | July 1, 2026 | Initial policy issued. | Joe Jelasic, President |
Workplace Harassment and Violence Policy
Velvet Edge Inc., doing business as Velvet Edge Entertainment
2137 Dougall Ave., Windsor, Ontario N8X 1S5
https://velvetedge.ca
Policy Number: VE-POL-001
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), and whenever there is a significant change to our operations.
1. Purpose and Commitment
Velvet Edge Inc. (the "Company") is committed to providing a working environment in which every worker is treated with dignity and respect, and which is free from workplace harassment, workplace sexual harassment, and workplace violence. Harassment and violence in any form are unacceptable and will not be tolerated in any workplace of the Company, whether that workplace is our premises at 2137 Dougall Ave., Windsor, Ontario, a client site, an event venue, a rehearsal or production space, a vehicle used for work, or a virtual or remote setting in which work is performed.
This Policy is made pursuant to sections 32.0.1 through 32.0.8 of the Occupational Health and Safety Act, R.S.O. 1990, c. O.1 ("OHSA"), and is intended to operate together with the Ontario Human Rights Code, R.S.O. 1990, c. H.19 (the "Code"), the Employment Standards Act, 2000, S.O. 2000, c. 41, the Workplace Safety and Insurance Act, 1997, and, where conduct constitutes a criminal offence (including assault, sexual assault, uttering threats, or criminal harassment), the Criminal Code of Canada, R.S.C. 1985, c. C-46. Nothing in this Policy limits or replaces any right or remedy available to a worker under those statutes.
2. Application and Scope
This Policy applies to every person who performs work for or supplies services to the Company, in any capacity, including:
- employees, whether full-time, part-time, seasonal, or casual;
- independent contractors, subcontractors, and their personnel, including musicians, dancers, actors, aerialists, ground acrobats, prop manipulators, jugglers and juggling instructors, costumed characters, hosts, models, disc jockeys, audio-visual technicians, riggers, stagehands, designers, fabricators, and all other performers and event personnel engaged by the Company;
- volunteers, interns, co-op students, and persons on work placements;
- officers and directors of the Company, including the President and the Director of Operations and Logistics.
All of the persons listed above are referred to in this Policy as "workers." This Policy protects workers from harassment and violence by any person, including supervisors, managers, owners, co-workers, other performers, clients and client personnel, event guests and members of the public, vendors, venue staff, and any other third party present in a workplace of the Company.
This Policy applies:
- at the Company's premises at 2137 Dougall Ave., Windsor, Ontario;
- at every client event, brand activation, production, rehearsal, site visit, load-in, load-out, and equipment delivery or pick-up;
- at the Company's own publicly ticketed events, including recurring events such as the Regency-era Ball and the annual Halloween party, before, during, and after event hours;
- in vehicles used for Company work and during work-related travel;
- at work-related social functions;
- in any virtual or electronic setting connected to work, including email, text and instant messaging, telephone and video calls, social media, collaborative platforms, and any other information and communications technology. Consistent with the amendments made to the OHSA by the Working for Workers Five Act, 2024, workplace harassment and workplace sexual harassment include conduct that occurs virtually through the use of information and communications technology.
3. Definitions
3.1 Workplace Harassment
"Workplace harassment" means engaging in a course of vexatious comment or conduct against a worker in a workplace, including virtually through the use of information and communications technology, that is known or ought reasonably to be known to be unwelcome, and includes workplace sexual harassment. A "course" of conduct usually involves repeated behaviour, but a single serious incident, such as an unwelcome sexual solicitation or a threat, may also constitute workplace harassment.
3.2 Workplace Sexual Harassment
"Workplace sexual harassment" means:
- engaging in a course of vexatious comment or conduct against a worker in a workplace, including virtually through the use of information and communications technology, because of sex, sexual orientation, gender identity, or gender expression, where the course of comment or conduct is known or ought reasonably to be known to be unwelcome; or
- making a sexual solicitation or advance where the person making the solicitation or advance is in a position to confer, grant, or deny a benefit or advancement to the worker, and the person knows or ought reasonably to know that the solicitation or advance is unwelcome.
3.3 Workplace Violence
"Workplace violence" means:
- the exercise of physical force by a person against a worker, in a workplace, that causes or could cause physical injury to the worker;
- an attempt to exercise physical force against a worker, in a workplace, that could cause physical injury to the worker; or
- a statement or behaviour that it is reasonable for a worker to interpret as a threat to exercise physical force against the worker, in a workplace, that could cause physical injury to the worker.
3.4 What Harassment Is Not
Reasonable action taken by the Company, a manager, or a supervisor relating to the management and direction of workers or the workplace is not workplace harassment. This includes reasonable direction on performance and conduct, scheduling and casting decisions made in good faith, safety instructions (including instructions relating to rigging, spotting, and acrobatic work), coaching, performance feedback, and disciplinary measures applied in good faith. Ordinary artistic direction, choreography notes, and rehearsal corrections delivered respectfully are not harassment. Legitimate physical contact that is an agreed and rehearsed part of an act (for example, spotting an aerialist, basing a ground acrobat, or partnered choreography) is not harassment or violence when it is performed as rehearsed and with the continuing consent of those involved.
4. Examples of Prohibited Conduct
The following are examples only and do not limit the definitions above.
4.1 Workplace Harassment
- bullying, intimidation, humiliating or demeaning comments, name-calling, or slurs;
- spreading malicious rumours or gossip about a worker, including about a performer's personal life;
- sabotaging a worker's equipment, costume, props, rigging, or work product;
- persistent unwarranted criticism, shouting, or public belittling that goes beyond legitimate direction;
- offensive or intimidating messages, images, or posts directed at or about a worker through any electronic or virtual means, including social media commentary about a performer's appearance or performance that is vexatious and unwelcome;
- practical jokes or hazing that embarrass, endanger, or single out a worker;
- isolating, excluding, or ignoring a worker in a vexatious manner.
4.2 Workplace Sexual Harassment
- unwelcome sexual remarks, jokes, innuendo, or taunting about a worker's body, appearance, costume, clothing, sex, sexual orientation, gender identity, or gender expression;
- unwelcome touching, patting, pinching, brushing against, or any unnecessary physical contact, including contact under the pretext of adjusting a costume, applying makeup, fitting a harness, or spotting, where that contact is not a consented and necessary part of the work;
- leering, staring, or gestures of a sexual nature;
- displaying, sending, or sharing sexually suggestive or explicit images or messages;
- photographing or recording a worker in a state of undress or while changing, or in any sexualized manner, without consent, including in dressing, changing, or backstage areas;
- requests or pressure for dates or sexual favours, including any suggestion, express or implied, that bookings, casting, shifts, pay, or other advantages depend on tolerating or granting sexual attention (a form of harassment sometimes called "quid pro quo," which is strictly prohibited and will be treated as gross misconduct);
- sexual solicitation or advances by any person in a position to grant or deny a benefit, including a manager, director, choreographer, booking coordinator, or client representative.
4.3 Workplace Violence
- hitting, pushing, kicking, spitting, or throwing objects at a worker;
- physically blocking, cornering, or restraining a worker;
- threatening statements or gestures, whether in person, in writing, or electronically, including threats made by intoxicated event guests;
- brandishing a weapon or any object used as a weapon;
- deliberately tampering with rigging, aerial equipment, lifts, staging, electrical systems, or safety equipment in a way that could injure a worker.
5. Event-Specific Risks and Precautions
The Company acknowledges that its work environments carry particular risks: workers perform at public and private events where alcohol may be served; performers, including aerialists, acrobats, dancers, and costumed characters, work in close proximity to guests; costumed characters may have restricted vision and mobility; and workers handle cash, valuable equipment, and late-night load-outs. In accordance with section 32.0.3 of the OHSA, the Company assesses the risks of workplace violence arising from the nature of the workplace, the type of work, and the conditions of work, including these event-specific circumstances, and reassesses those risks as often as necessary and whenever the nature of our events or venues changes materially. The results of these assessments will be communicated to workers.
Measures the Company takes and expects at events include, as applicable to the engagement:
- a designated on-site Company contact for every event, identified to all workers before the event begins;
- coordination with venue security or client security personnel, including agreed procedures for removing aggressive or intoxicated guests;
- a rule that no guest is entitled to touch a performer; performers may end an interaction at any time, and costumed characters and roving performers may be assigned a handler or escort where the risk assessment warrants it;
- secure, private changing and dressing areas for performers, off limits to guests, clients, and any worker who has no work-related reason to be there;
- working alone protocols for late load-outs, deliveries, and equipment pick-ups, including check-in procedures;
- immediate access to a means of summoning assistance (on-site contact, venue security, or 911).
6. Domestic Violence
If the Company becomes aware, or ought reasonably to be aware, that domestic violence that would likely expose a worker to physical injury may occur in the workplace, the Company will take every precaution reasonable in the circumstances to protect the worker, as required by section 32.0.4 of the OHSA. Workers who fear that domestic violence may follow them into a workplace, including an event site, are encouraged to confide in the Director of Operations and Logistics or the President so that a safety plan can be put in place. Such information will be kept confidential to the greatest extent possible.
7. Reporting an Incident or Complaint
Any worker who experiences or witnesses workplace harassment, workplace sexual harassment, or workplace violence is strongly encouraged to report it. No worker will be penalized, reprised against, or disciplined for making a report in good faith or for participating in an investigation.
Where there is immediate danger to any person, call 911 first, then notify the on-site Company contact and the Director of Operations and Logistics as soon as it is safe to do so.
Reports and complaints may be made verbally or in writing to:
- 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, in particular where the complaint involves, or the worker is not comfortable reporting to, the Director of Operations and Logistics.
Where a complaint involves the President, it will be referred to a qualified external workplace investigator who is not under the direction or control of the President, and the Director of Operations and Logistics will retain that investigator. Full reporting routes, the information to include in a complaint, and the investigation process are set out in the Company's Workplace Complaint Procedure (VE-PRO-004), which forms the workplace harassment program and part of the workplace violence program required by sections 32.0.2 and 32.0.6 of the OHSA and should be read together with this Policy.
8. Investigation
The Company will ensure that an investigation appropriate in the circumstances is conducted into every incident and complaint of workplace harassment or workplace violence of which it becomes aware, whether or not a formal complaint is made, as required by section 32.0.7 of the OHSA. Investigations will be conducted in accordance with the Workplace Complaint Procedure and will be objective, confidential to the extent possible, and completed within ninety (90) calendar days of the complaint or incident coming to the Company's attention, unless there are extenuating circumstances. The worker who alleges harassment and the alleged harasser, if a worker of the Company, will be informed in writing of the results of the investigation and of any corrective action taken or that will be taken, within ten (10) calendar days of the conclusion of the investigation.
9. Confidentiality
Information obtained about an incident or complaint of workplace harassment or workplace violence, including identifying information about any individuals involved, will not be disclosed unless the disclosure is necessary to protect workers, to investigate the complaint or incident, to take corrective action, or as otherwise required by law. All persons involved in an incident, complaint, or investigation are expected to keep the matter confidential, subject to their right to seek legal advice, to consult a medical or counselling professional, or to exercise statutory rights.
10. No Reprisal
Reprisal or retaliation against any person for reporting an incident in good faith, for participating in an investigation, or for exercising any right under this Policy, the OHSA, the Code, or the Employment Standards Act, 2000 is itself a serious violation of this Policy and is prohibited. Reprisal includes termination or threatened termination of employment or of a contract, reduction or withdrawal of bookings or shifts, demotion, blacklisting, intimidation, and any other adverse treatment. Any person found to have engaged in reprisal will be subject to corrective action up to and including termination of employment or of contract.
11. Responsibilities
- The President is accountable for this Policy, approves it, ensures resources are available to implement it, and acts as the alternate recipient of complaints.
- The Director of Operations and Logistics administers this Policy, receives reports and complaints, arranges investigations, implements interim and corrective measures, ensures risk assessments are conducted, and ensures workers receive information and instruction on this Policy and the Workplace Complaint Procedure as required by sections 32.0.5 and 32.0.8 of the OHSA.
- All workers, including contractors, performers, and volunteers, must treat others with respect, must not engage in harassment or violence, must report incidents they experience or witness, and must cooperate honestly in investigations.
- Clients, guests, vendors, and venue personnel are expected to respect this Policy. The Company reserves the right to remove any person from an event, to suspend or terminate services under a client agreement, and to refuse admission to or eject any guest from a Company event, where that person harasses or threatens a worker.
12. Corrective Action and Discipline
A worker who engages in workplace harassment, workplace sexual harassment, workplace violence, or reprisal will face corrective action proportionate to the conduct, which may include an apology, coaching or training, a written warning, removal from an event or engagement, suspension, reassignment, termination of employment for cause, or termination of a contract for services. Conduct that may be criminal will be reported to police where appropriate. A complaint made in bad faith, meaning a complaint the complainant knows to be false and makes for an improper purpose, is itself misconduct and may attract discipline; an unproven complaint made in good faith is not misconduct and will never attract discipline.
13. Training, Communication, and Acknowledgment
This Policy and the Workplace Complaint Procedure will be provided to every worker at the start of their employment or engagement, will be reviewed with workers as part of event briefings where relevant, and are published at https://velvetedge.ca. Every worker, including every contractor and performer, will be asked to sign an acknowledgment confirming that they have read and understood this Policy, and contractor agreements will incorporate compliance with this Policy as a term of engagement.
14. Review
The Company will review this Policy, and the program set out in the Workplace Complaint Procedure, at least once each calendar year and whenever a deficiency is identified, an investigation reveals a gap, or the Company's operations change materially. The current version will always be the version published at https://velvetedge.ca.
15. Related Documents and Legislation
- Code of Conduct for Acceptable Workplace Behaviour (VE-POL-002)
- Policy Against Discrimination (VE-POL-003)
- Workplace Complaint Procedure (VE-PRO-004)
- Occupational Health and Safety Act, R.S.O. 1990, c. O.1, Part III.0.1
- Ontario Human Rights Code, R.S.O. 1990, c. H.19
- Employment Standards Act, 2000, S.O. 2000, c. 41
- Workplace Safety and Insurance Act, 1997, S.O. 1997, c. 16, Sched. A
- Criminal Code, R.S.C. 1985, c. C-46 (Canada)
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
| Version | Date | Description | Approved By |
|---|---|---|---|
| 1.0 | July 1, 2026 | Initial policy issued. | Joe Jelasic, President |