Unlawful Harassment

In accordance with applicable law, OWLS prohibits sexual harassment and harassment because of race, colour, national origin, ancestry, religion, creed, physical or mental disability, marital status or age. All such harassment is unlawful and will not be tolerated. OWLS is committed to taking all reasonable steps to prevent harassment from occurring.

Prohibited Harassment Defined

Unlawful harassment because of sex, race, colour, national origin, ancestry, religion, creed, physical or mental disability, marital status, age or any other protected characteristic includes, but is not limited to:

• Verbal conduct such as epithets, derogatory comments, slurs, or unwanted sexual advances, invitations, or comments.

• Visual conduct such as derogatory posters, photography, cartoons, drawings, or gestures.

• Physical conduct such as unwanted touching, blocking normal movement, or interfering with work directed at you because of your sex or any other protected basis.

• Threats and demands to submit to sexual requests in order to keep your job or avoid some other loss and offers of job benefits in return for sexual favours.

• Retaliation for opposing, reporting or threatening to report harassment, or for participating in an investigation, proceeding or hearing conducted by an investigating agency.

Prohibited harassment is not necessarily limited to the loss of a job or some other economic benefit. Prohibited harassment that impairs your working ability or emotional well-being at work violates this policy and will not be tolerated.

The Company's Reporting Procedure

Our reporting procedure provides for an immediate, thorough and objective investigation of any harassment claim, appropriate disciplinary action against one found to have engaged in prohibited harassment and appropriate remedies to any employee subject to harassment. An employee may have a claim of harassment even if he or she has not lost a job or some economic benefit.

If any employee believes he/she has been harassed on the job, or is aware of the harassment of others, the employee should provide a written or verbal report to his/her supervisor as soon as possible. The report should include details of the incident(s), the names of individuals involved, the names of any witnesses, direct quotes when relevant, and any documentary evidence (notes, pictures, cartoons, etc). All incidents of harassment that are reported will be investigated. OWLS will endeavor to protect the privacy and confidentiality of all parties involved to the extent possible consistent with a thorough investigation.

If OWLS determines that harassment has occurred, it will take remedial action commensurate with the circumstances. Appropriate action will also be taken to deter any future harassment. If a complaint of harassment is substantiated, appropriate disciplinary action, up to and including discharge, will be taken.

Protection Against Retaliation

Applicable law also prohibits retaliation against any employee by another employee or by OWLS for reporting, filing, testifying, assisting or participating in any manner in any investigation, proceeding or hearing conducted by the company. Employees should report any retaliation to a Director. Any complaint will be immediately objectively and thoroughly investigated in accordance with the investigation procedure outlined above. If a report of retaliation is substantiated, appropriate disciplinary action, up to and including discharge, will be taken.

Liability for Harassment

Any employee, including any supervisor or manager, who is found to have engaged in unlawful harassment is subject to disciplinary action up to and including discharge from employment. An employee who engages in harassment may be held personally liable for monetary damages.

Compiled by : D Parkinson & D Parkinson

Review date: August 2025