Health and Safety at SB Partners LLP

Management of SB Partners is vitally interested in the health and safety of its workers. Protection of workers from injury or occupational disease is a major continuing objective.

SB Partners will make every effort to provide a safe, healthy work environment. All managers and employees must be dedicated to the continuing objective of reducing risk and injury.

SB Partners, as employer, is ultimately responsible for the health and safety. As Managing Partner of SB Partners, I give you my personal commitment that I will comply with my duties under the Act, such as taking every reasonable precaution for the protection of the employees in the workplace.

Managers will be held accountable for the health and safety of workers under their supervision. Managers are subject to various duties in the workplace, including the duty to ensure that the office and equipment are safe and that workers work in compliance with established safe work practices and procedures.

Every employee must protect his or her own health and safety by working in compliance of the law and with safe work practices and procedures established and required by the employer. Workers will receive information, training and competent supervision in their work tasks to protect their health and safety.

It is the best interest of all workplace parties to consider health and safety in every activity. Commitment to health and safety must form an integral part of this organization, from the partnership to the workers.

This policy outlines the responsibilities of all parties in maintaining a safe and healthy work environment. SB Partners LLP will act in compliance with all applicable workplace health and safety legislation.

SB Partners acknowledges it has a statutory duty to take all reasonable precautions to protect employees, contractors, visitors, and all other individuals onsite. Protecting employees from injury or occupational disease from accidents or incidents is a continuing objective. We will make every effort to provide a safe and healthy work environment for all team members. We believe all accidents are preventable and active participation at all levels will help ensure accidents are avoided. Managers/supervisors and workers must refrain from any actions or activities that could jeopardize the health and safety of others and must work to reduce the risk of injury.

Communication

SB Partners encourages open communication on health and safety issues. Open communication is essential to providing an accident-free and productive work environment.

• Employees who voice or identify a health and safety concern will not be subject to reprisal or retaliation.
• Employees should inform their supervisor or human resources of any matter they perceive to be an actual or potential workplace hazard. Either HR or the Joint Health and Safety Committee (JHSC) will initiate an investigation on each reported or potential hazard.
• Communication can be written or verbal, and may be anonymous, if so desired.

Responsibilities

Employers will:

• Manage the occupational health and safety concerns of the firm
• Allocate and govern resources properly to achieve the health and safety requirements of employees and ensure that policies comply with the company’s legal obligations
• Foster a workplace culture of safety with appropriate leadership
• Review policies annually for compliance and revise where necessary
• Provide all relevant parties with a copy of all orders or reports issued to the employer by a Ministry of Labour inspector and inform the JHSC of any work-related incidents involving injury, death, or occupational illness

Managers and supervisors will:

• Help develop, implement, and enforce company policies and procedures
• Continually promote health and safety awareness with instruction, information, training, and supervision to ensure the safe performance of employees
• Use the process of hazard identification, risk management, and incident investigation
• Represent management on the JHSC and participate in health and safety inspections of the workplace to identify and control any and all hazards to employees
• Be accountable for the health and safety of employees under their supervision
• Ensure that equipment is safe and that employees work in compliance with established safe work practices and procedures
• Ensure that employees receive adequate training in their specific work tasks to protect their health and safety

Human Resources (HR) will:

• Liaise with government agencies to ensure workplace health and safety compliance
• Advise management on safety and health policy issues
• Lead or participate in workplace investigations
• Develop best practices that support a strong health and safety program
• Maintain an up-to-date knowledge of applicable health and safety regulations as mandated locally, provincially, or federally
• Design and develop company policies and procedures related to workplace safety and health issues
• Review injury and illness trends to identify problem areas and solutions

All employees will:

• Comply with occupational health and safety policies/procedures and training requirements
• Notify managers of any health and safety concerns, so they may be dealt with promptly
• Protect their own health and safety and that of others by working in compliance with the law, safe work practices, and procedures established by the company
• Use appropriate personal protective equipment (PPE), as required
• Report unsafe or potentially hazardous conditions, including workplace violence or harassment, without fear of reprisal, to their manager or human resources
• Perform duties in a manner conducive to a safe workplace, following all safety practices and procedures
• Report any incident, injury, or hazard as outlined in company procedures

Joint health and safety committee members will:

• Commit to improving health and safety conditions in the workplace
• Recognize and identify workplace risks and hazards
• Develop recommendations for management to address risks and hazards
• Conduct regular workplace inspections and make written recommendations
• Develop and implement accident prevention and health and safety programs
• Listen to employee complaints, concerns, and suggestions
• Participate in health and safety inquiries and investigations
• Advise on health and safety matters, such as personal protective equipment
• Maintain accurate and detailed records of near misses, accidents, and injuries
• Promote and monitor compliance with health and safety regulations
• Monitor the effectiveness of existing health and safety programs and policies, and assist with the implementation of improvements
• Attend regular committee meetings

Reporting Structures

Any concerns or near misses should be reported to the joint health and safety committee, HR and the appropriate manager. Employees who voice or identify a health and safety concern will not be subject to reprisal or retaliation.

If an emergency occurs, employees must immediately report the incident to the Managing Partner and HR. Appropriate responses will be dictated by the severity of the event and its effect on the health and safety of employees, visitors, and property.

An emergency is any number of unsafe conditions that pose a threat to people or property. This includes, fire or smoke, natural disaster or severe weather, chemical, biological, or radiological incidents, severe injury or death, and structural failures.

This policy outlines the firm’s commitment to preventing violence and harassment, including how incidents of violence and harassment are handled and investigated.

SB Partners LLP is committed to building and preserving a safe, productive, and healthy working environment for its employees, free from violence and harassment. The firm takes all reasonable measures to ensure job candidates, employees, managers, and clients are not subject to any form of violence or harassment. This commitment applies to all areas of business, including training, performance, assessment, promotions, layoffs, remuneration, and all other employment practices and working conditions.

Acts of violence or harassment against or by any employee are neither condoned nor tolerated by the company.

Definitions

Complainant: A person who has made a complaint about another individual who they believe committed an act of violence or harassment against them.

Respondent: A person whom another individual has accused of committing an act of violence or harassment.

Workplace harassment: 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, or workplace sexual harassment. This includes, but is not limited to, bullying, displaying or circulating offensive materials, intimidating or offensive jokes/innuendoes, phone calls, emails, or other communications.

Workplace sexual harassment: 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. This includes, but is not limited to, unwelcome physical contact such as touching, patting or pinching, propositions or demands of physical intimacy, sexually suggestive remarks or unwelcome gender-related comments.

Workplace violence: The exercise of, or attempt to exercise, physical force by a person against a worker, in a workplace, that causes or could cause physical injury to the worker; or a statement or behaviour that 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.

Guidelines

This policy has been developed in consultation with the joint health and safety committee (JHSC). It is reviewed annually, or more frequently if necessary to ensure that it accurately represents the SB Partners prevention program.

The company provides all employees with appropriate training and information regarding the violence and harassment prevention practices and procedures. Employees are responsible for adhering to this policy and should report every incident of violence or harassment immediately to management. This includes any incidents that have been witnessed, experienced by, or reported to an employee.

For the purposes of this policy, workplace harassment or violence can occur:

• At the workplace
• In a virtual workplace environment and communications
• At work-related social functions
• Outside the workplace in the course of work assignments
• During work-related travel
• Over the telephone, if the conversation is work-related
• Elsewhere, if the person is there as a result of work-related responsibilities or a work-related relationship

*In the event you experience workplace harassment or violence at any of the locations or situations listed above, please ensure to follow the reporting procedures listed below.*

Reasonable day-to-day actions by a manager that help manage, guide, or direct workers or the workplace and appropriate employee performance reviews, counselling, or discipline by a manager do not constitute harassment.

Responsibilities

SB Partners LLP has a duty to: 

• Provide information, instruction, and supervision to workers to protect their health and safety as it relates to workplace violence and harassment
• Take every reasonable precaution to protect workers from workplace violence and harassment
• Review and update this policy at least annually, and develop and maintain a workplace violence and harassment program to eliminate identified hazards from the workplace
• Post a copy of this policy in a conspicuous location in the workplace
• Ensure supervisors are competent in dealing with workplace violence and harassment matters
• Investigate all incidents and complaints for workplace violence and harassment
• Assist the JHSC in carrying out functions related to workplace violence and harassment, and provide them with copies of any relevant reports, investigations, or documents related to workplace violence and harassment

Managers have a duty to: 

• Advise workers of all potential or real hazards and dangers they are aware of involving workplace violence and harassment
• Provide workers with written instruction, when necessary, to prevent workplace violence and harassment
• Take every reasonable precaution to protect workers from workplace violence and harassment

All employees are expected to:

• Work in compliance with all applicable legislation and all policies and procedures related to workplace violence and harassment prevention
• Report all instances of workplace violence and harassment they become aware of to their manager
• Never commit acts of workplace violence or harassment

Workers have the right to refuse work if they have a reason to believe they are in danger from workplace violence.

Risk Assessment and Prevention

SB Partners works together with the JHSC to conduct a risk assessment of the work environment to identify potential risks that could affect the firm and the health and safety of employees and institutes measures to eliminate or control any identified risks to employee health and safety.

The following factors are considered during the assessment:

• Past incidents of violence
• Violence that is known to occur in similar workplaces
• The circumstances in which work takes place, including the type and conditions of work
• The interactions that occur in the course of performing work
• The physical location and layout of the workplace

The risk assessment may include reviews of records, security reports, employee incident reports, health and safety inspection reports, first aid records, or other related records. Areas that are considered and may contribute to risk of violence or harassment include but are not limited to contact with the public, exchange of money, and working alone or at night.

The firm reassesses risks as often as necessary to ensure the related program and policy protect employees from workplace violence and harassment.

The firm discloses information to workers who are likely to encounter a person with a known history of violence in the performance of their job duties, or if there is a potential risk of workplace violence as a result of interactions with the person with a history of violence. However, the firm only discloses personal information that is deemed reasonably necessary to protect the worker from physical harm.

Control Measures and Procedures

The following measures have been implemented to eliminate or reduce the identified risks of workplace violence:

• FOB access to all doors other than reception
• Parking lot lighting that is adjusted based on daylight savings time
• Visitors are required to sign in with reception before entering the office and be accompanied by a team member for the duration of their visit
• Encourage everyone to report any and all workplace violence or harassment incidents
• All workstations and meeting rooms are equipped with a telephone
• Office wide alarm system is used after hours
• Client drop off only occurs during regular business hours, otherwise they can use the lockboxes provided

We prefer that team members do not work alone in the office. However, we realize that from time to time projects may require team members to work later/come in after hours or arrive early etc. If you are staying late at work or coming in on a weekend, always advise someone and have them contact you periodically to ensure that you are safe. Make sure that your car is parked in a well-lit area if you will be leaving after dark.  The same applies if you are arriving early in the morning.

After business hours the office is locked down and nobody can enter unless they have an access code.  It is critical that team members do not share access codes.

Reporting Incidents of Workplace Violence and Harassment

An employee who believes they have been subject to violence or harassment should submit a complaint to any management team member, Director, Human Resources or the Managing Partner. The complaint should be made as soon as possible after the incident and must include the following information:

• The date and time of the incident
• The name of any persons involved in the incident
• The name of any persons who witnessed the incident
• A thorough description of what occurred

An employee who believes they have been subject to harassment may also choose to confront the harasser without filing a complaint. They can confront the harasser directly or through writing, detailing the unwelcome behaviour and requesting it to stop.

Immediate Assistance Procedures

The following measures and procedures should be followed when an incident of violence has occurred or is likely to occur and immediate assistance is required:

• Immediately remove yourself from the situation and get to a safe space
• Place an immediate call to emergency services by dialing 911
• Phone a JHSC member, any member of the management team or HR team
• Yell for assistance from a co-worker

The firm provides appropriate assistance to any employee who is a victim of violence or harassment. Team members involved in these types of situations are asked to document the situation in writing, including any involved parties or witnesses. SB Partners recommends that a worker who has been harmed as a result of an incident of violence at the workplace consult their healthcare provider for treatment.

Employees can also use the company-provided employee assistance program (EAP) through Workplace Options or Advica. Details and information on accessing this program can be found in the Employee Benefits policy, by contacting HR, or on the bulletin boards in the lunchroom.

Investigation Procedures

Once a complaint has been received, SB Partners completes a thorough investigation as soon as possible. If necessary, the firm may employ outside assistance or request the use of legal counsel during the investigation. The investigation includes:

• Informing the respondent of the complaint
• Interviewing the complainant and any persons involved in the incident
• Identifying and interviewing any witnesses
• Obtaining statements from all parties involved

All of the above information is documented and used to determine whether an incident of violence or harassment occurred. The JHSC is not involved in investigations of harassment and is not provided with any identifying information of the parties involved.

A copy of the complaint, detailing the complainant’s allegations is provided to the respondent, who is invited to reply in writing to the complainant’s allegations. The reply is made known to the complainant before the case proceeds.

The company takes all measures to prevent any disclosure of the incident and the identities of the parties involved, unless the disclosure is required for the investigation, for taking corrective action, or by law.

Results of Investigation

Upon completion of an investigation, SB Partners provides both the complainant and respondent a written summary of the results of the investigation and any corrective action that has been or will be taken. This written notification is provided within seven (7) business days of the investigation being completed and does not include the investigation report unless required by law.

Where SB Partners determines that violence or harassment has occurred, control measures are implemented to eliminate or control the risk of violence or harassment to a worker as a result of the investigation. These control measures are determined on a case-by-case basis. Any control measure enacted are communicated to the complainant and respondent, as well as any other employees the measure affects.

Disciplinary Measures

If the firm determines that an employee has been involved in an incident of violence or harassment towards another employee, immediate disciplinary action will be taken, up to and including termination. Any disciplinary action will be proportional to the seriousness of the behaviour or action involved in the incident.

Recordkeeping

SB Partners ensures that appropriate records of complaints and investigations relating to incidents of violence and workplace harassment are kept, including:

• A copy of the complaint or details about the incident
• Any records related to the investigation, including notes
• A copy of the investigation report (if applicable)
• A summary of the investigation results, including what was provided to the complainant and respondent
• A copy of any corrective action taken to address the complaint or incident

Domestic Violence

If SB Partners becomes aware that domestic violence is likely to expose an employee to physical injury in the workplace, the firm will take every precaution reasonable in the circumstances for the protection of the worker.

Fraudulent or Malicious Complaints

It is a violation of this policy for anyone to knowingly make a false complaint, or to provide false information about a complaint. Unfounded or frivolous allegations may cause both the respondent and the company significant damage. Any employee who knowingly makes a false allegation related to violence or harassment will be subject to immediate disciplinary action up to and including termination of employment.

Confidentiality

SB Partners does not disclose the name of a complainant or a respondent or the circumstances related to the complaint to any person except where disclosure is necessary to investigate the complaint or take corrective action with respect to the complaint, or where required by law. The firm only discloses the minimum amount of personal information or details necessary for these purposes.

All records of harassment, and subsequent investigations, are considered confidential and are not disclosed to anyone except to the extent required by law. The firm does everything reasonably possible to protect the privacy of any individuals involved and to ensure that complainants and respondents are treated fairly and respectfully.

Training

SB Partners ensures all workers are trained and educated on violence and harassment and that they are clear about their roles and responsibilities as well as this policy and its procedures. In addition, a copy of this policy is made available to all workers.

SB Partners LLP provides workers with training and education, which include:

• How to recognize a potentially violent situation
• Procedures, work practices, administrative arrangements, and engineering controls that have been developed to mitigate the associated risks
• Appropriate responses to incidents of violence and harassment, including how to get help when required
• How to report incidents of workplace violence and harassment

SB Partners LLP is committed to the health and safety of its employees and has adopted this policy to communicate its expectations and guidelines surrounding substance use and work.

Definitions

Fit to work: Able to complete their assigned duties and responsibilities safely and effectively

Impairment: An abnormal physical, mental or emotional state that renders an individual unfit to perform their work safely

Substance use: Includes the use of alcohol, legal or illegal drugs, prescription medication, or over-the-counter medication that affects how an employee thinks, feels or acts.

Policy Details

Guidelines

Employees are expected to arrive to work fit to work and remain fit to work for the duration of their shift. Substance use is a workplace health and safety hazard where it affects or could affect an employee’s ability to perform their job duties safely and productively. Substance use can result in physical or mental impairment, which increase the risk of workplace incidents and accidents.

Employees who use legitimate prescription medication, including medical cannabis, or over-the-counter medication are expected to consult with a healthcare professional to determine whether the medication can cause impairment and affect their ability to work safely. Any concerns regarding impairment should be reported to the Director, HR as soon as reasonably possible so reasonable accommodations can be arranged.

An employee who believes that they are not fit to work before the start of their shift must follow the appropriate absence reporting procedure. If they realize they are unfit to work at any point during their shift, they must report this to their manager immediately. If an employee suspects someone in the workplace is impaired, they should report this to their direct manager or the Director, HR.

Responsibilities

SB Partners will:

• Set out standards for substance use and work
• Arrange appropriate accommodations where an employee discloses substance use concerns
• Review and update this policy regularly

Managers will:

• Monitor compliance with this policy
• Identify and assess scenarios where an employee is suspected of being unfit for work
• Implement, review and modify accommodation measures
• Maintain employee confidentiality and privacy regarding substance use concerns

All team members must:

• Abide by this policy
• Arrive to work fit for duty, and remain so for the duration of their shift
• Decline a request to work if they are unfit to do so
• Not use, possess, distribute or sell drugs or alcohol during working hours, including during paid and unpaid breaks
• Report any person in the workplace they reasonably suspect is unfit to work
• Report any concerns regarding impairment related to the legitimate use of prescription medication or over-the-counter medication
• Abide by the firms Code of Conduct & Ethics and/or other relevant professional codes of conduct, where applicable
• Remember that if they choose to consume alcohol at firm or client functions where it is being served, to consume alcohol responsibly

As is required by law, no person shall drive while in an impaired condition. SB Partners, at their expense, provides the use of taxi services from firm and client functions to the employee’s home.

Suspicion of Impairment

The following procedure may be enacted if there is reasonable belief that an employee is impaired at work:

1. If possible, the employee’s manager will first seek another manager’s or Human Resources’ opinion to confirm the employee’s status.
2. Next, Human Resources will consult privately with the employee to determine the cause of the observation, including whether substance abuse has occurred. Suspicions of an employee’s ability to function safely may be based on specific personal observations. If the employee exhibits unusual behaviour including but not limited to slurred speech, difficulty with balance, watery or red eyes, or dilated pupils, or if there is an odour of alcohol, the employee should not be permitted to return to their assigned duties in order to ensure their safety and the safety of other employees or visitors to the workplace.
3. If an employee is considered impaired and deemed “unfit for work,” this decision is made based on the best judgement of two members of management and DOES NOT require a breathalyser or blood test. The employee may be advised that SB Partners has arranged a taxi or shuttle service to safely transport them to their home address or to a medical facility, depending on the determination of the observed impairment. The employee may be accompanied by a manager or another employee, if necessary.
4. An impaired employee will not be allowed to drive. The employee should be advised if they choose to refuse SB Partners organized transportation and decide to drive their personal vehicle, the firm is obligated to and will contact the police to make them aware of the situation.
5. A meeting may be scheduled for the following workday to review the incident and determine a course of action which may include a monitored referral program as part of a treatment plan.

Possession at Work

Possession of alcohol, drugs, and drug paraphernalia on firm property is prohibited. Firm property encompasses all firm owned or leased property used by employees, including without limitation parking lots, vehicles, desks, cabinets, and closets.

Possession of alcohol, drugs, and drug paraphernalia is also prohibited while employees are acting on behalf of the firm off of firm premises. This includes, but is not limited to, client sites or attending events as a firm representative.

Accommodation and Support

SB Partners will support team members who are experiencing substance use concerns. The firm will work with the individual who requests accommodation in an effort to ensure that the measures taken are both effective and mutually agreeable, up to the point of undue hardship. Team members are encouraged to disclose the need for accommodation to the Director, HR. Where a need for accommodation is not disclosed by an employee but the firm suspects that one is required, arrangements will be made to speak with the employee privately to inquire about their situation. The firm may request medical documentation from a medical professional.

The firm supports employees in addressing their substance use concerns and encourages them to seek appropriate treatment. The firm provides the following resources to support employees experiencing substance use issues: use of our EAP program, paramedical coverage through our group benefits provider and use of our wellness benefits.

Employees who disclose substance use concerns will not be discriminated against or subject to reprisals. All information related to the disclosure will be kept confidential and will only be shared with others where necessary for accommodation.

Medical Cannabis

Where an employee uses medical cannabis, it is expected they provide a copy of their medical documentation for use at SB Partners to the Director, HR and abide by the provisions of this policy.

Agreement for the Continuation of Employment

SB Partners reserves the right to invoke an agreement for the continuation of employment in accordance with an employee’s commitment to become and remain alcohol-free and drug- free. The agreement will outline the conditions governing the employee’s return to work and the consequences for failing to meet the conditions.

An agreement for the continuation of employment may include a requirement for drug or alcohol testing.

Disciplinary Action

Employees may be subject to disciplinary action up to and including termination of employment for failure to adhere to the provisions of this policy, including but not limited to:

• Failure to meet prescribed safety standards as a result of impairment from alcohol, drugs or other substances; and
• Engaging in illegal activities (for example, selling drugs or alcohol during working hours or while on firm premises).

To ensure that any workplace incidents/accidents or injuries are reported in compliance with legislated requirements.

Definitions

Accident: Any unplanned event that has resulted in damage, injury, or harm.

Incident: Any unplanned event that did or potentially could cause significant risk, including accidents and near-misses.

Occupational injury: Any cut, fracture, sprain, or amputation resulting from a workplace accident.

Occupational illness: Any abnormal condition or disorder caused by exposure to environmental factors associated with employment.

Near-miss: Any safety incident that did not result in injury, illness, or death but had the potential to do so.

Incidents and Injury Reporting

Team members are responsible for reporting all incidents or injuries in the workplace to their manager as soon as practicably possible following the incident. A member of the joint health and safety committee (JHSC) should also be notified.

The manager and JHSC will then be responsible for completing the Health & Safety Incident Report Form and investigating the incident, as required. A copy of the completed report will be provided to the team member for their own records. The completed report must then be provided to human resources who will be responsible for reporting the incident to the appropriate legislative or regulatory body, where required, within the timeframe required.

In the event of a critical injury or death, the area will immediately be sealed following the treatment of the injured party and no personnel will be allowed to enter the area until government officials give authorization. The Managing Partner and Director, HR need to be notified immediately of a critical injury or death in the workplace.

Team members who purposely fail to report incidents or injuries and who provide false or misleading information will be disciplined up to and including dismissal.

Incident and Injury Investigations

In the event of an incident resulting in death, critical injury or injury requiring medical attention, the first priority of any team member or manager is to ensure that the injured party receives prompt medical attention and care. In the event of a spill or damage to property, the first priority will be to diffuse the situation by containing and cleaning up the spill or neutralizing equipment that has been damaged, so it does not continue to pose a safety hazard.

The manager is responsible for ensuring that each team member understands their obligation to report an incident. Team members are responsible for reporting any incident to their manager.

The JHSC will investigate incidents/accidents within 24 hours of the occurrence. The person(s) investigating the incident shall complete a list of recommendations at the conclusion of the investigation and follow up as required until all recommendations are implemented where possible. The firm will be responsible for advising the proper authorities consistent with applicable legislation.