Annex 10: Non-Discrimination Policy
Table of Contents
Chapter 1: Introduction
Chapter 2: Purpose and Scope
Chapter 3: Definitions and Protected Characteristics
Chapter 4: Zero-Tolerance for Discrimination
Chapter 5: Procedures for Reporting Discrimination
Chapter 6: Investigation and Resolution
Chapter 7: Responsibilities of Leadership and Staff
Chapter 8: Monitoring and Compliance
Chapter 9: Review and Continuous Improvement
Chapter 10: Policy Amendments and Updates
Chapter 1: Introduction
1.1 Background
Refugee Pathways & Integration Canada (RefPIC) is committed to fostering a workplace and community environment free from discrimination. This Non-Discrimination Policy serves as a foundational document to ensure equity, inclusion, and respect across all organizational activities. It underscores RefPIC’s dedication to aligning with national and international human rights standards, including the Canadian Human Rights Act and the Universal Declaration of Human Rights.
(a) Discrimination, in any form, undermines the values and mission of RefPIC.(b) This policy provides a framework to address and prevent discriminatory practices, ensuring fairness in all interactions.
1.2 Objective
The primary objective of this policy is to establish clear guidelines and expectations for behavior within RefPIC. By adopting this policy, the organization aims to:(a) Promote a culture of equity, diversity, and inclusion.(b) Prevent and address discriminatory practices effectively.(c) Ensure accountability and transparency in all organizational activities.
Chapter 2: Purpose and Scope
2.1 Policy Application
This policy applies to all individuals associated with RefPIC, including:(a) Employees, volunteers, and interns engaged in the organization’s operations.(b) Partners, contractors, and third-party vendors involved in delivering services.(c) Beneficiaries and community stakeholders interacting with RefPIC programs.
The policy extends to all organizational activities, whether conducted:(i) On RefPIC premises.(ii) At off-site locations during official duties.(iii) Online through digital platforms or communications.
2.2 Stakeholder Engagement
RefPIC recognizes the importance of engaging all stakeholders in fostering a culture of non-discrimination. To achieve this:(a) Employees and volunteers are required to undergo training on diversity and inclusion.(b) Beneficiaries and partners are encouraged to provide feedback on their experiences with the organization.(c) Regular consultations are held to align the policy with evolving community needs and expectations.
Chapter 3: Definitions and Protected Characteristics
3.1 Protected Groups
The policy explicitly prohibits discrimination based on the following characteristics:(a) Race, ethnicity, or national origin.(b) Gender, gender identity, or sexual orientation.(c) Age, religion, or belief system.(d) Disability, marital status, or socioeconomic background.
These protected groups reflect RefPIC’s commitment to ensuring equity and dignity for all individuals.
3.2 Types of Discrimination
Discrimination includes, but is not limited to:(a) Direct Discrimination: Treating an individual less favorably due to their protected characteristics.(b) Indirect Discrimination: Implementing policies or practices that disadvantage certain groups, even if unintended.(c) Harassment: Engaging in unwanted conduct that violates the dignity of an individual or creates a hostile environment.(d) Victimization: Retaliating against an individual for raising concerns about discriminatory practices.
RefPIC is committed to addressing all these forms of discrimination through a structured, zero-tolerance approach.
Chapter 4: Zero-Tolerance for Discrimination
4.1 Organizational Stance
Refugee Pathways & Integration Canada (RefPIC) maintains a zero-tolerance policy toward any form of discrimination. This commitment aligns with the organization's mission to promote equity, dignity, and inclusion in all aspects of its operations.
(a) Discriminatory behaviors, whether intentional or unintentional, are strictly prohibited and will result in immediate action.(b) RefPIC ensures that its zero-tolerance stance is integrated into:(i) Recruitment, hiring, and promotion practices.(ii) Interactions with beneficiaries, partners, and stakeholders.(iii) Organizational policies, programs, and day-to-day operations.
4.2 Consequences for Violations
To uphold the integrity of this policy, violations are subject to:(a) Investigation by an independent committee.(b) Disciplinary actions proportionate to the severity of the offense, including:(i) Verbal or written warnings.(ii) Suspension or termination of employment.(iii) Reporting to appropriate legal or regulatory bodies.(c) Consistent enforcement across all levels of the organization to ensure fairness and accountability.
Chapter 5: Procedures for Reporting Discrimination
5.1 Reporting Channels
RefPIC provides accessible and secure channels for reporting instances of discrimination, ensuring that every individual feels empowered to voice their concerns.
(a) Internal Reporting Mechanisms:(i) Dedicated email addresses and phone hotlines for confidential reporting.(ii) Submission boxes placed in accessible areas for anonymous reporting.
(b) Third-Party Options:RefPIC collaborates with independent organizations to offer neutral reporting mechanisms, ensuring impartiality and confidentiality.
5.2 Confidentiality and Anonymity
To protect complainants and encourage reporting:(a) All complaints are treated with the highest level of confidentiality.(b) Whistleblowers are guaranteed anonymity where requested and appropriate.(c) Retaliation against individuals who report discriminatory behavior is strictly prohibited, with immediate action taken against violators.
Chapter 6: Investigation and Resolution
6.1 Investigation Procedures
All reported incidents are subject to a thorough and impartial investigation, conducted in accordance with RefPIC’s internal guidelines.
(a) Initial Assessment:(i) The designated investigator evaluates the complaint to determine its validity and scope.(ii) Preliminary findings are reviewed to decide the next steps.
(b) Formal Investigation:(i) Evidence is gathered, including witness statements, documents, and digital records.(ii) Both the complainant and the accused are given the opportunity to present their accounts.
(c) Outcome and Recommendations:(i) Findings are presented to RefPIC’s management or an oversight committee.(ii) Recommendations for disciplinary actions or remedial measures are made based on the investigation results.
6.2 Resolution and Remedies
The resolution process ensures:(a) Remedies are provided to the affected parties, including:(i) Apologies or public acknowledgments.(ii) Restitution where appropriate.(b) Corrective measures are implemented to prevent future incidents.
Chapter 7: Responsibilities of Leadership and Staff
7.1 Role of Leadership
Leaders within RefPIC play a crucial role in fostering an environment free from discrimination and promoting a culture of respect.
(a) Leadership responsibilities include:(i) Setting a positive example by adhering to the policy.(ii) Ensuring that all team members are aware of and understand the policy.(iii) Actively addressing and resolving complaints of discrimination.
(b) Leaders are required to undergo regular training on diversity, equity, and inclusion to remain effective in their roles.
7.2 Role of Staff
Every staff member and volunteer has an obligation to uphold the principles of this policy.
(a) Staff responsibilities include:(i) Treating colleagues, beneficiaries, and stakeholders with respect and dignity.(ii) Reporting any observed or experienced instances of discrimination.(iii) Actively participating in training programs to enhance awareness and understanding.
(b) Non-compliance or failure to act upon known violations may result in disciplinary action.
Chapter 8: Monitoring and Compliance
8.1 Compliance Audits
To ensure adherence to the Non-Discrimination Policy, Refugee Pathways & Integration Canada (RefPIC) conducts regular compliance audits across all levels of the organization.
(a) Frequency and Scope:(i) Audits are conducted biannually to evaluate the implementation and effectiveness of the policy.(ii) They cover recruitment practices, workplace interactions, reporting channels, and case resolutions.
(b) Audit Process:(i) Independent auditors or internal compliance officers are assigned to review records and interview employees, volunteers, and beneficiaries.(ii) Audit findings are documented in detailed reports and shared with the senior leadership team.
(c) Outcome Utilization:(i) Audit results are used to identify gaps or areas requiring improvement.(ii) Corrective actions are implemented promptly to address deficiencies.
8.2 Regular Reporting
Continuous monitoring is supported by regular reporting mechanisms.
(a) Internal Reports:(i) Monthly internal updates are provided to the leadership team on the number and nature of reported cases.(ii) Trends and patterns in reported incidents are analyzed to proactively address potential risks.
(b) Annual Report:(i) An annual summary of policy compliance is included in RefPIC’s organizational performance report.(ii) Transparency is ensured by making key findings publicly available on the organization's website, fostering accountability to stakeholders and donors.
Chapter 9: Review and Continuous Improvement
9.1 Feedback Mechanisms
RefPIC recognizes the importance of ongoing feedback to ensure the policy remains relevant and effective.
(a) Stakeholder Input:(i) Employees, volunteers, and beneficiaries are encouraged to provide feedback on the policy and its implementation.(ii) Anonymous surveys are conducted annually to assess satisfaction and identify concerns.
(b) Partnership Reviews:(i) Feedback from partner organizations and donors is actively sought to align with best practices and global standards.(ii) Collaborative discussions are held to refine and enhance policy measures.
9.2 Policy Review Schedule
The Non-Discrimination Policy is regularly reviewed to incorporate new insights, address emerging challenges, and remain compliant with evolving legal standards.
(a) Annual Review:(i) The policy is reviewed annually by RefPIC’s governance team, incorporating feedback from audits, reports, and stakeholder surveys.(ii) Updates are made to address gaps, integrate new legal requirements, or reflect organizational changes.
(b) Approval Process:(i) Revisions are presented to the Board of Directors for approval before implementation.(ii) Updated versions are communicated to all staff, volunteers, and partners through official channels, including training sessions and policy briefings.
(c) Emergency Reviews:(i) In the event of a major incident or regulatory change, an emergency review may be conducted outside the regular schedule.
Chapter 10: Policy Amendments and Updates
10.1 Policy Amendments
RefPIC is committed to ensuring the policy evolves to meet changing needs and circumstances.
(a) Criteria for Amendments:(i) Significant changes in legislation, such as updates to Canadian anti-discrimination laws or international human rights standards.(ii) Lessons learned from audits, reported cases, or external recommendations.
(b) Amendment Process:(i) Proposed changes are drafted by the compliance and legal teams.(ii) Drafts are reviewed in consultation with employees, volunteers, and other stakeholders.(iii) Final approval is sought from the Board of Directors.
10.2 Timeline for Review
(a) Annual reviews are conducted as scheduled to maintain the policy's effectiveness and relevance.(b) Emergency amendments, when required, are implemented within 30 days to address pressing issues or align with legal mandates.