Non-Discrimination and Anti-Harassment Policy

Policy owner: Publisher, North Wall Media
Effective date: January 1, 2024
Last reviewed: May 1, 2026
Review cycle: Annual
Applies to: All employees, contractors, freelancers, contributors, interns, and any other person performing work for or on behalf of North Wall Media

1. Purpose and Commitment

North Wall Media is committed to providing a work environment that is free of discrimination and harassment. The Company prohibits discrimination and harassment of workers on the basis of race, colour, creed, age, sex, gender, gender identity, gender expression, sexual orientation, ethnic or national origin, ancestry, place of origin, citizenship, religion, political belief or affiliation, union membership or activity, marital status, family status, pregnancy (including breastfeeding), record of offences, disability (mental or physical), genetic characteristics, covered veteran status, and any other ground or characteristic protected by applicable human rights or employment laws in the jurisdictions in which we operate.

This prohibition applies to every aspect of the working relationship, including recruitment, hiring, job assignment, compensation, benefits, training, professional development, promotion, discipline, termination, and the day-to-day conditions of work.

2. Scope

This Policy applies to all workers engaged by North Wall Media in any capacity, including employees, independent contractors, freelance contributors, columnists, event speakers under contract, interns, and volunteers. It also governs the conduct of the Company toward applicants for work, vendors, partners, subscribers, event attendees, and other third parties encountered in the course of business.

The Policy applies in every location and setting where work is performed or business is conducted, including the Company’s premises, home offices, client and partner sites, conference venues, virtual events, business travel, business meals, after-hours work functions, and all electronic and online channels used for work purposes (including email, messaging platforms, video calls, and social media).

3. Legal Framework

This Policy is designed to meet or exceed the requirements of:

• The Ontario Human Rights Code, R.S.O. 1990, c. H.19;
• The Occupational Health and Safety Act (Ontario), R.S.O. 1990, c. O.1, including its workplace harassment and workplace violence provisions;
• The Canadian Human Rights Act, R.S.C. 1985, c. H-6, where applicable;
• The Employment Standards Act, 2000 (Ontario), S.O. 2000, c. 41; and
• Any other federal, provincial, or local human rights, employment, and occupational health and safety laws that apply to a worker’s location or engagement.

Where any applicable law provides greater protection than this Policy, that law prevails.

4. Definitions

4.1 Discrimination
Discrimination means any distinction, exclusion, restriction, or preference, whether intentional or unintentional, that is based on one or more of the protected characteristics listed in Section 1 and that has the effect of impairing equality of opportunity or treatment in employment or engagement. Discrimination includes both direct discrimination and constructive (adverse-effect) discrimination arising from rules, practices, or requirements that appear neutral but disadvantage a protected group.

4.2 Harassment
Harassment means engaging in a course of vexatious comment or conduct against a worker that is known or ought reasonably to be known to be unwelcome. A single serious incident may also constitute harassment. Harassment includes conduct based on any protected characteristic and may take verbal, written, visual, physical, or electronic form.

4.3 Sexual Harassment
Sexual harassment means a course of vexatious comment or conduct against a worker because of sex, sexual orientation, gender identity, or gender expression, where the conduct is known or ought reasonably to be known to be unwelcome. It also includes a sexual solicitation or advance made by a person in a position to confer, grant, or deny a benefit or advancement, and any reprisal or threat of reprisal for rejecting such a solicitation or advance.

4.4 Reprisal
Reprisal means any adverse action, threat, or detrimental treatment taken against a worker because the worker has, in good faith, reported discrimination or harassment, participated in an investigation, refused to participate in conduct prohibited by this Policy, or otherwise exercised rights under this Policy or applicable law.

5. Prohibited Conduct

The following conduct is prohibited and will be treated as a violation of this Policy:

• Making employment decisions, including hiring, assignment, compensation, advancement, or termination, on the basis of any protected characteristic.
• Using slurs, epithets, stereotypes, or derogatory comments related to a protected characteristic.
• Displaying, sharing, or circulating images, written material, or electronic content that demeans or stereotypes individuals on the basis of a protected characteristic.
• Unwelcome physical contact, gestures, or proximity of a sexual nature, or that is otherwise based on a protected characteristic.
• Unwelcome sexual solicitations, advances, requests for sexual favours, or comments about a person’s body, appearance, or sexual activity.
• Bullying, intimidation, ostracism, or persistent unjustified criticism directed at a worker because of a protected characteristic.
• Reprisal or threats of reprisal against any worker who reports a concern in good faith or participates in an investigation.

6. Hiring and Employment Practices

In every hiring and engagement decision, North Wall Media:

• Bases recruitment, selection, and engagement decisions solely on bona fide job-related qualifications, skills, experience, and performance.
• Does not ask applicants or contributors about protected characteristics except where strictly required by law or where an accommodation is being arranged.
• Provides accommodation to the point of undue hardship for applicants and workers based on any protected ground, including disability, religion, family status, and pregnancy.
• Provides equal pay for substantially the same work and reviews compensation practices to ensure they are free of discriminatory bias.
• Provides equal access to training, professional development, advancement, and assignments without regard to any protected characteristic.

7. Accommodation

North Wall Media will accommodate the needs of workers and applicants related to any protected characteristic, including disability, religious observance, family status, pregnancy, and gender identity or expression, up to the point of undue hardship. Workers seeking accommodation should contact the Publisher. Accommodation requests are treated confidentially, and the Company will engage in a good-faith, collaborative process to identify appropriate accommodations.

8. Reporting Concerns

Any worker who believes they have experienced or witnessed discrimination, harassment, sexual harassment, or reprisal in connection with the Company is encouraged to report it as soon as practicable. Reports may be made:

• Directly to the Publisher, in person, by phone, or in writing (including by email);
• Where the concern involves the Publisher, to a designated external advisor (such as the Company’s legal counsel), whose contact information will be provided on request; or
• Through any reporting mechanism required by applicable law.

Reports should include, where possible, a description of what occurred, when and where it occurred, the names of any individuals involved or who witnessed the conduct, and any relevant documents or messages. Workers are not required to confront the alleged respondent before making a report.

9. Investigation and Response

North Wall Media will investigate every report of discrimination or harassment in a manner that is appropriate to the circumstances. The investigation process will:

• Begin promptly after a report is received;
• Be conducted impartially and with appropriate confidentiality, sharing information only with those who need to know to investigate and respond;
• Give the complainant and the respondent a reasonable opportunity to be heard and to respond to relevant information;
• Use an external investigator where required by law, where a conflict of interest exists, or where the seriousness of the allegations warrants it; and
• Result in a written summary of findings and, where the conduct is substantiated, in appropriate corrective action.

Corrective action may include training, coaching, a written warning, reassignment, suspension, termination of employment or engagement, or any other measure reasonably necessary to stop the conduct and prevent its recurrence. The complainant and respondent will each be informed in writing of the outcome of the investigation and of any corrective action that affects them directly, to the extent permitted by law.

10. Confidentiality

Information obtained about a report, including identifying information about any person involved, will not be disclosed unless disclosure is necessary to investigate or take corrective action, or is otherwise required by law. All persons involved in the investigation are expected to maintain confidentiality.

11. No Reprisal

Reprisal against any person who makes a good-faith report under this Policy or who participates in an investigation is strictly prohibited and will itself be treated as a violation of this Policy. This protection applies regardless of the outcome of the underlying investigation, provided the report was made in good faith.

12. Responsibilities

12.1 The Publisher
The Publisher is responsible for maintaining this Policy, communicating it to all workers, receiving and responding to reports, ensuring investigations are conducted appropriately, and reviewing the Policy at least annually.

12.2 All Workers
Every worker is responsible for: complying with this Policy in their own conduct; treating colleagues, contributors, subjects, sources, and third parties with dignity and respect; reporting conduct they reasonably believe violates this Policy; and cooperating in investigations conducted under this Policy.

13. External Recourse

Nothing in this Policy limits a worker’s right to file a complaint with, or seek a remedy from, an external body, including the Human Rights Tribunal of Ontario, the Ontario Ministry of Labour, Immigration, Training and Skills Development, the Canadian Human Rights Commission, or any other body of competent jurisdiction.

14. Policy Review

This Policy will be reviewed at least once per year and updated as necessary to reflect changes in applicable law, the Company’s operations, or experience gained through the application of the Policy.

Todd Humber
Publisher and Editor-in-Chief
North Wall Media
Date: May 1, 2026