WPEG's D,B & H Prevention Policy

WPEG's D,B & H Prevention Policy

WPEG's D,B & H Prevention Policy





Approval date:


Nov 20, 2019

Last amendment:



Last reviewed:


Nov 20, 2021

Next review date:


Nov 20, 2022




Approval Authority


Responsible Executive

President / Human Resources Officer

Related Policies / Legislation

Discrimination, Bullying and Harassment Prevention Procedures

Human Rights Code

Workers’ Compensation Act

Occupational Health and Safety Regulation



The purpose of this policy is to aid in the prevention of discrimination, bullying and harassment and to enable Western Pacific Engineering Group Ltd. (WPEG) to act upon complaints of such behavior promptly, fairly, judiciously and with due regard to confidentiality for all parties concerned.



This policy applies to all members of WPEG engaged in work-related activities. It applies to all interpersonal communications, including electronic communications, such as email, posts, and texts.



In this policy and its procedures, the following definitions apply:


Bullying or Harassment: Behavior that includes any inappropriate conduct or comment (including electronic) by a person who knew or reasonably ought to have known that the behavior would cause humiliation or intimidation. Harassment excludes interpersonal conflict, any reasonable action taken by the employer or supervisor relating to the management and direction of employees or the workplace, any reasonable action taken by the employer or supervisor relating to the management of any particular assignment of work, or action where the harm by any objective standard is fleeting.


Examples of behavior or comments that might constitute bullying and harassment include verbal aggression or insults, calling someone derogatory names, harmful hazing or initiation practices, vandalizing personal belongings, and spreading malicious rumors.


Examples of reasonable management action might include decisions relating to job duties, workloads, deadlines, transfers, reorganizations, work instructions or feedback, work evaluation, performance management, and/or disciplinary actions.


Discrimination: Discrimination is any form of unequal adverse treatment of a person or group, whether intentional or not, on the basis of one or more prohibited grounds set out in the British Columbia Human Rights Code, namely: age, ancestry, colour, family status, marital status, physical or mental disability, place of origin, political belief (applicable to employment advertisement and employment), race, religion, sex (including gender identity), sexual orientation or criminal conviction unrelated to employment or program of study; and which has the effect or purpose of unreasonably interfering with that person’s or group’s access to the employment opportunities, benefits and advantages available to other members of society.


Discrimination includes harassment based on a prohibited ground of discrimination, including sexual harassment. The prohibited grounds under this Policy will be interpreted in the same manner as they are interpreted by the British Columbia Human Rights Tribunal. For example, the ground of “sex” has been interpreted to include gender identity, gender expression, sexual harassment, sexual assault and the actuality or possibility of pregnancy, breastfeeding and childbirth, and will be so interpreted under this policy.


Harassment based on a prohibited ground of discrimination: Behavior directed towards another person that is abusive or demeaning, including a direct or indirect reference to a prohibited ground of discrimination, and would be viewed by a reasonable person experiencing the behavior as interfering with the person’s participation in a work-related activity or as creating an intimidating, humiliating or hostile environment.


Members of our company: The following are considered members of WPEG for this policy:

  • All employees of the company
  • Any person appointed by WPEG (whether or not that person is an employee), or engaged in activities arising directly out of the operations of our business
  • Persons employed under contracts who provide Engineering, supervision or administrative services
  • Members of the Board of Governors
  • Service providers, contractors, independent societies and associations operating on our office, and their employees, agents and visitors


Retaliation: Retaliation is an adverse action taken against a member of our company for:

  1. having invoked this policy or procedures in good faith whether on behalf of oneself or another individual.
  2. having participated or cooperated in any investigation under this policy or procedures; or,
  3. having been associated with a person who has invoked this policy or participated in the procedures.


WPEG-Related Activity: Any activity directly related to or arising out of the operations of our

business at any location.



Members of WPEG have the right to work and participate in activities at the company office in an environment free of discrimination, bullying and harassment. Discrimination, bullying and harassment are neither acceptable nor tolerated at WPEG.  


All parties to proceedings under this policy will be treated in a fair and respectful manner.  WPEG will protect from retaliation anyone who, in good faith, brings or supports a complaint of discrimination, bullying or harassment.  This policy and related procedures do not prevent anyone from pursuing other available legal avenues. 




All members of WPEG must:

  • not engage in discrimination, bullying or harassment
  • report discrimination, bullying or harassment they observe or experience; and
  • apply and comply with WPEG’s policies and procedures on discrimination, bullying and

Directors have the primary responsibility for maintaining a working environment free from discrimination, bullying and harassment. They are expected to model appropriate behavior and to act on this responsibility whenever necessary, whether or not they are in receipt of a complaint.

Human Resources Officer is responsible to:

  • develop and maintain procedures necessary to give effect to this policy. Such procedures will include:
    • confidential consultation and advice for all members of WPEG
    • educational and pro-active approaches to informal resolution, and
    • fair, transparent investigation and adjudication procedures.


  • communicate this policy and accompanying procedures to all employees of WPEG


Complaints under this policy

Barring exceptional circumstances, complaints under this policy must be made within six (6) months of the last incident of Discrimination, Bullying or Harassment.


All complaints must be made in good faith. Any complaint that is found to be malicious, vexatious, or submitted in bad faith may be considered harassment under this policy. 


Subject to limits imposed by law, this policy or procedures, or concerns of an individual’s health, safety, and security, information which is created, gathered, received, or compiled from a complaint and through the course of an investigation shall be treated as confidential by WPEG, the parties and witnesses.


Any person found in breach of this policy may be subject to corrective action and/or formal disciplinary action up to and including dismissal from employment or suspension from WPEG.


All employees of WPEG will be provided with a copy of the policy and an up-to-date policy shall

be published on WPEG website.


Annual Review

This policy will be reviewed annually by the President and Human Resources of the company.



Discrimination, Bullying and Harassment Prevention Procedures can be found in at separate document provided by WPEG’s human resources department.

(Taken and adapted from WorkSafeBC and U.F.V. Procedures)

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