Federally Regulated Harassment & Violence Prevention Policy: Template + Steps

Every federally regulated employer must have a workplace harassment and violence prevention policy aligned with the Canada Labour Code, Part II, and the Work Place Harassment and Violence Prevention Regulations (SOR/2020-130). This guide covers all mandatory elements, two ready-to-adapt templates, workplace assessment requirements, training obligations, investigation frameworks, 10-year record retention rules, and annual reporting deadlines.

What Must Be in a Federal Workplace Harassment and Violence Prevention Policy?

A federal workplace harassment and violence prevention policy is required for federally regulated employers under the federal harassment and violence prevention framework. According to the Government of Canada guidance provided, these requirements took effect on January 1, 2021 and apply to federally regulated industries and workplaces. Your policy should normally include the following elements: - the employer’s commitment to prevent and protect employees against harassment and violence - a description of the roles of workplace parties in relation to harassment and violence in the workplace - a description of the risk factors that contribute to workplace harassment and violence - a list of the training that will be provided about workplace harassment and violence - the resolution process employees should follow if they witness or experience workplace harassment or violence - the reason for which a review and update of the workplace assessment must be conducted - the emergency procedures that must be implemented when an occurrence poses an immediate danger to the health and safety of an employee, or when there is a threat of such an occurrence - a description of how the employer will protect the privacy of the persons involved in an occurrence and in the resolution process - a description of any recourse that may be available to persons involved in an occurrence - a description of the support measures available to employees - the name of the person designated to receive complaints related to the employer’s non-compliance with the Code or Regulations.

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Who Must Develop the Federal Harassment and Violence Prevention Policy?

The Government of Canada guidance states that the employer must develop the policy with the applicable partner, depending on organization size: - up to 19 employees: the health and safety representative - 20 to 299 employees: the workplace committee - 50 or more employees: the policy committee The workplace risk assessment must also be conducted with the applicable partner. If the risk assessment is conducted with the policy committee, the federal guidance says you should inform the workplace health and safety committee of the results.

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Understanding the Legal Definition of Workplace Harassment and Violence

Before drafting your policy, you need to anchor it in the statutory definition. According to Part II of the Canada Labour Code, harassment and violence means:

"Any action, conduct or comment, including of a sexual nature, that can reasonably be expected to cause offence, humiliation or other physical or psychological injury or illness to an employee, including any prescribed action, conduct or comment."

This definition is deliberately broad. It encompasses:

What Is Not Harassment and Violence

Your policy should also clarify what does not constitute harassment and violence. The Government of Canada's guidance specifies that the following supervisory actions, when performed respectfully, professionally, and in good faith, are appropriate:

Including these clarifications in your policy helps prevent frivolous complaints and ensures managers understand the boundaries of legitimate workplace management.

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Conducting the Mandatory Workplace Risk Assessment

A workplace risk assessment is required and must be conducted with the applicable partner: the health and safety representative, workplace committee, or policy committee, depending on organization size. The federal guidance provided confirms that your policy should include the reason for which a review and update of the workplace assessment must be conducted. Employers should consult the Workplace Harassment and Violence Prevention Regulations (SOR/2020-130) for the specific review triggers and requirements that apply to their workplace assessment. You may refer readers to the Government of Canada’s sample workplace risk assessment tool for guidance.

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Training Requirements Under the Federal Harassment and Violence Prevention Framework

The federal guidance states that employers must inform and instruct employees about the policy, and that everyone in the workplace, including the employer, must participate in training about harassment and violence. Employers should provide training that covers the definitions of harassment and violence, the resolution process, and emergency procedures as outlined in the Regulations. The Regulations require employers to retain records of harassment and violence occurrences — including investigation reports, police reports, and annual reports — for a period of 10 years.

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Our sister platform, TrainGuard Academy, offers online training courses designed for Canadian workplaces — including workplace violence and harassment prevention, Bill C-65 compliance training, and hazard assessment. Courses are aligned with federal and provincial requirements.

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The Resolution Process: From Notice to Investigation

Your policy should describe the resolution process. The federal guidance defines 'resolution process' as all the avenues of resolution: negotiated resolution, conciliation and investigation. Negotiated resolution is defined as any form of communication between the participating parties to discuss the occurrence and attempt to reach agreement on possible actions to resolve the occurrence. Conciliation is defined as a discussion or series of discussions mediated by a neutral third party to facilitate discussion and assist the parties in reaching resolution. All parties involved in conciliation must mutually agree to participate and must mutually agree on the person acting as conciliator. The guidance notes that a conciliator can be a professional mediator, a supervisor, an Elder, a religious figure, a colleague, etc. Investigator qualifications and conflict-of-interest rules should align with the applicable regulatory requirements. Key definitions from the federal guidance include: - Occurrence: an occurrence of harassment and violence in the workplace - Principal party: an employee or employer who is the object of an occurrence - Responding party: the person alleged to have been responsible for the occurrence - Designated recipient: the individual, or work unit, designated by the employer to receive a notice of an occurrence - Workplace: any place where an employee is engaged in work for the employee’s employer as per subsection 122(1) of the Code.

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Template 1: Minimum-Compliant Federal Harassment and Violence Prevention Policy

The following template covers every mandatory element required under Part II of the Canada Labour Code and SOR/2020-130. Adapt the bracketed sections to your organization.

Policy Statement

[Organization Name] is committed to preventing and protecting all employees against harassment and violence in the workplace. This policy applies to all employees, managers, and the employer, in all locations where employees are engaged in work.

Definitions

Harassment and violence means any action, conduct or comment, including of a sexual nature, that can reasonably be expected to cause offence, humiliation or other physical or psychological injury or illness to an employee, including any prescribed action, conduct or comment, as defined in Part II of the Canada Labour Code.

Roles and Responsibilities

Risk Factors

[Insert findings from your workplace risk assessment, including physical, organizational, and external risk factors identified.]

Training

All workplace parties, including the employer, will receive training on: the definition of harassment and violence; this policy; the resolution process; how to report an occurrence; privacy protections; support measures; and emergency procedures. Training will be provided during onboarding and [annually / as determined by the applicable partner].

Resolution Process

  1. Negotiated Resolution: The principal party and responding party attempt to resolve the occurrence through direct communication.
  2. Conciliation: If negotiated resolution is unsuccessful, a mutually agreed-upon neutral third party facilitates discussion.
  3. Investigation: If conciliation is unsuccessful or inappropriate, a qualified investigator conducts a formal investigation.

Emergency Procedures

If an occurrence poses an immediate danger to the health and safety of an employee, or there is a threat of such an occurrence, employees must: remove themselves from danger; call 911 if necessary; notify their supervisor or the designated recipient immediately. The employer will take all reasonable measures to protect affected employees.

Privacy Protection

[Organization Name] will protect the privacy of all persons involved in an occurrence and the resolution process, to the extent possible and consistent with the Canada Labour Code and applicable privacy legislation.

Recourse

Persons involved in an occurrence may access: the internal resolution process described above; the Labour Program's complaint process; and any other recourse available under applicable law.

Support Measures

The following support measures are available to employees: [Employee Assistance Program (EAP) contact information; mental health resources; community support services; union representative contact, if applicable].

Workplace Assessment Review

The workplace assessment will be reviewed and updated when: there is a significant change in workplace conditions; an occurrence reveals a new risk factor; or as part of the annual review cycle.

Policy Review Date

This policy will be reviewed annually by [date] in collaboration with the [applicable partner].

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Template 2: Enhanced Federal Harassment and Violence Prevention Policy

This enhanced template goes beyond minimum compliance to reflect best practices for organizations seeking a robust, culture-driven approach. It includes all mandatory elements plus additional provisions.

Preamble and Commitment

[Organization Name] believes that every employee has the right to a workplace free from harassment and violence. We are committed not only to meeting our obligations under Part II of the Canada Labour Code and SOR/2020-130, but to fostering a culture of respect, dignity, and psychological safety. This policy applies to all employees, contractors, volunteers, and any person in the workplace, across all locations where work is performed.

Expanded Definitions

In addition to the statutory definition, this policy recognizes the following specific forms of harassment and violence:

Roles and Responsibilities (Enhanced)

Comprehensive Risk Assessment Framework

Our risk assessment evaluates: physical environment factors; organizational and cultural factors; work arrangement factors; historical occurrence data; external factors including domestic violence; and intersectional risks affecting equity-deserving groups. Results are shared with the workplace health and safety committee and inform targeted preventive measures.

Training Program (Enhanced)

All workplace parties, including the employer, must participate in training. Our program includes:

Resolution Process (Enhanced)

  1. Early Intervention: Managers are trained to address concerning behaviour before it escalates to a formal occurrence
  2. Negotiated Resolution: Direct communication between parties, with support from the designated recipient if requested
  3. Conciliation: Mediated by a mutually agreed-upon neutral third party
  4. Investigation: Conducted by a qualified, impartial investigator with no conflict of interest
  5. Post-Resolution Follow-Up: The designated recipient checks in with all parties within 30 days of resolution to ensure the situation has been effectively addressed and no retaliation has occurred

Anti-Retaliation Provision

[Organization Name] strictly prohibits retaliation against any person who reports an occurrence, participates in a resolution process, or cooperates with an investigation. Retaliation will be treated as a separate occurrence of harassment and violence.

Emergency Procedures, Privacy, Recourse, and Support Measures

[Include all elements from Template 1, plus:]

Annual Review and Continuous Improvement

This policy and the workplace assessment will be reviewed annually by [date] in collaboration with the [applicable partner]. The review will consider: annual occurrence report data; employee feedback; changes in legislation or government guidance; and emerging best practices.

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Record Retention: The 10-Year Obligation

One of the most frequently overlooked requirements is the record retention obligation. Under the federal framework, all records of harassment and violence occurrences must be kept by the employer for a period of 10 years. This includes:

Practical Record-Keeping Tips

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Annual Reporting: The March 1st Deadline

Each year by March 1st, all federally regulated employers must submit their completed Employer's Annual Harassment and Violence Occurrence Report (EAHVOR, form LAB1206) to the Labour Program for the preceding calendar year. This obligation applies even if there are no occurrences to report.

What the Annual Report Covers

The report captures aggregate data about occurrences in your workplace, including the number of occurrences, the types of harassment and violence, the resolution methods used, and the outcomes. It does not identify individuals.

Employer Action Steps for Annual Reporting

  1. Set a calendar reminder for no later than mid-January to begin compiling data
  2. Review all occurrence records from the preceding calendar year
  3. Complete form LAB1206 accurately and completely
  4. Submit to the Labour Program by March 1st
  5. Retain a copy of the submitted report for 10 years

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Employer Compliance Checklist: Federal Harassment and Violence Prevention Policy

Use this checklist to verify your organization's alignment with monitored government sources under Part II of the Canada Labour Code and SOR/2020-130:

How This Differs from Provincial Requirements

If your organization operates across multiple jurisdictions, it is important to understand that the federal framework under Bill C-65 and SOR/2020-130 is distinct from provincial workplace violence and harassment legislation. For example, employers in Alberta who are not federally regulated must comply with the Occupational Health and Safety Act (Alberta) and its specific requirements for violence and harassment prevention plans. For guidance on provincial obligations, see our detailed guide on Alberta harassment prevention.

Key differences between the federal and provincial frameworks often include:

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Implementation Steps: From Policy to Practice

Step 1: Identify Your Applicable Partner

Determine whether you work with a health and safety representative (up to 19 employees), workplace committee (20–299 employees), or policy committee (50+ employees).

Step 2: Conduct the Workplace Risk Assessment

Work jointly with your applicable partner to identify risk factors. Use the Government of Canada's sample risk assessment tool as a starting point. Document all findings.

Step 3: Draft the Policy

Use Template 1 (minimum-compliant) or Template 2 (enhanced) from this guide as your foundation. Customize all bracketed sections to reflect your organization's specific circumstances, risk factors, and support resources.

Step 4: Joint Review and Approval

Present the draft to your applicable partner for review, input, and approval. Document the collaborative process.

Step 5: Communicate the Policy

Distribute the policy to all employees. Post it in accessible locations—both physical and digital. Ensure it is available in both official languages if required.

Step 6: Deliver Training

Provide training to everyone in the workplace, including the employer. Cover all mandatory topics. Document attendance and content.

Step 7: Designate the Recipient

Formally appoint and announce the designated recipient—the individual or work unit who will receive notices of occurrences and non-compliance complaints.

Step 8: Establish Record-Keeping Systems

Set up secure, access-controlled systems for storing occurrence records, investigation reports, training records, and annual reports for the mandatory 10-year retention period.

Step 9: Submit Annual Reports

Complete and submit the EAHVOR (form LAB1206) to the Labour Program by March 1st each year, even if there were no occurrences.

Step 10: Annual Review

Review the policy and workplace assessment annually with your applicable partner. Update as needed based on occurrence data, employee feedback, workplace changes, and evolving government guidance.

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Non-Compliance Consequences

The Labour Program follows a graduated compliance approach under the Canada Labour Code. Responses to non-compliance can include:

Beyond regulatory consequences, failure to maintain an effective federal workplace harassment and violence prevention policy exposes your organization to civil liability, reputational damage, increased employee turnover, and diminished workplace morale.

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Get Started with a Policy Aligned to Federal Requirements

Building a federal workplace harassment and violence prevention policy from scratch is complex, but it does not have to be overwhelming. The templates and implementation steps in this guide are designed to help federally regulated employers move from obligation to action.

For ready-to-use, professionally drafted policy templates that are aligned with monitored government sources—including the Canada Labour Code, Part II, and SOR/2020-130—explore Canada Policy Manual. Our policy library is built specifically for Canadian employers and updated as federal and provincial requirements evolve.

Take a free preview of Canada Policy Manual to see how our templates can save you hours of drafting time while keeping your organization aligned with current federal requirements.

You can also download free policy templates to get started immediately.

Key Takeaways