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Anti-Racism Policy

Liver Canada believes in treating all people equally and fairly. We are committed to supporting an anti-racist culture by ensuring an anti-racist approach to all policies and procedures, behaviours and beliefs throughout the organization.

Anti-Racism Policy

Purpose

This policy is to support and ensure an anti-racist culture at Liver Canada by identifying, addressing and eliminating any signs of discrimination and racism.

Scope

This policy applies to all employees and volunteers of Liver Canada whether they are working or volunteering for the organization on or off the premises.

This policy is also part of Liver Canada’s commitment to diversity, equality and inclusion.

In addition, this policy is part of Liver Canada’s commitment to ensuring the health, safety and well-being of all employees and volunteers.

Definitions

Race is defined as one’s colour, nationality, ethnicity or national origins.

Racism means prejudice, discrimination or antagonism directed against someone of a different race.

It is a serious form of discrimination that violates human rights, dignity and integrity, and can negatively affect the work environment.

Anti-racism is defined as the practice of actively opposing racism and promoting racial equality. The goal of anti-racism is to actively change policies, procedures, behaviors and beliefs that perpetuate racist ideas and actions.

Policy

Liver Canada believes that it is the right of all employees and volunteers within the organization to be free from all forms of racism and discrimination and to be treated equally, fairly and with respect. To this end, Liver Canada is committed to identifying, removing and preventing racism and discrimination in the work environment and will promote racial equality. Liver Canada will ensure that all policies, procedures, practices, as well as behaviours and beliefs in the work environment, will be free from all forms of racism.

All employees and volunteers will be made aware of, and are required to follow and commit to, this policy. Anyone found to have discriminated against or harassed any other person because of race will be held accountable.

Procedure

Responsibilities of Liver Canada:

Liver Canada will ensure that all employees and volunteers are aware of this policy and will enforce it. A copy will be made available to all employees and volunteers and will be provided to all new employees during the on-boarding process. The policy will be available in French and also in accessible formats upon request.

Liver Canada will hold all employees and volunteers responsible and accountable for their behaviours and conduct. Racist behaviour will not be tolerated. A finding of discriminatory or racist behaviour may result in disciplinary action.

All complaints made under this policy will be investigated and addressed in a timely manner.

Liver Canada will provide all employees and volunteers with anti-racism induction, education and training, to be supplemented with written resources and guidance as required. This will include information on what constitutes racism, expected behaviours and strategies to eliminate or prevent racism. For managers and supervisors, training will also cover their particular responsibilities, including anti-racism practices for recruitment, performance review and promotion, among other relevant processes.

Liver Canada will periodically review its policies and procedures to ensure they conform to anti-racism and anti-discriminatory principles and practices. Recruitment, performance review, recognition, promotion practices, compensation and other policies will be reviewed to make sure they are non-discriminatory and anti-racist, providing equality and fairness for all.

Liver Canada will determine ways to measure and monitor progress on anti-racism initiatives, including using feedback from employee surveys, and will work towards continual improvement.

Responsibilities of the leadership team:

The leadership team has a particular responsibility to recognize and model anti-racist behaviour including building, fostering and practicing a culture of accountability.

The leadership team will “call out” any behaviour deemed to be racist that they witness and will explain to the perpetrator why the behaviour is considered to be racist and unacceptable.

Responsibilities of all employees and volunteers:

All employees and volunteers will demonstrate respectful and inclusive behaviours, never behaving or acting in ways that marginalize, isolate, demean, humiliate, and/or subject another person to microaggressions, hostility, and/or to undermine or make it difficult for a person to access opportunities. Such actions are unacceptable and will not be tolerated.

Each employee and volunteer also has a personal responsibility to:

  • ensure they understand this policy and what racist behaviour is, including subtle racial discrimination and microaggressions
  • be aware of how their behaviour may affect others and to uphold the standards of behaviour set within the team
  • be aware of racism and challenge unacceptable behaviour, whenever it is safe to do so.
  • challenge or report any behaviour that does not conform to this policy
  • work within the policy guidelines including co-operating fully in any investigation undertaken.

Possible ways of intervening in a racist situation include:

  • ‘calling out’ the racist behaviour if it is safe to do so, make it clear that it is unacceptable
  • reporting incidents of racist behaviour whether one is the target of the racist behaviour or one has witnessed it, and co-operating in an investigation into racist behaviour. Reporting is necessary in order to ensure the well-being of all concerned.
  • being aware of one’s own conduct and avoiding colluding with inappropriate behaviour.

Responding to Complaints of Racism:

One does not have to be the target of the racist behaviour to make a complaint about it. If an employee or volunteer sees it happening or become aware of the problem, they have the right to complain about it. Tackling racism is everybody’s responsibility and active bystanders can have an especially important role in combatting racism.

Some people are unaware that their behaviour in some circumstances is racist. If it is clearly pointed out to them that their behaviour is unacceptable, the problem can sometimes be resolved in discussion. With this in mind, this policy includes informal as well as formal actions to deal with complaints of racism.

An employee or volunteer may deal with racist behaviour first by verbally asking the person to stop, explaining why the behaviour is racist. If informal action does not put a stop to the racist behaviour a formal complaint should be made.

If the employee or volunteer feels unable to approach the person responsible for the racist behaviour directly, they should formally complain verbally or in writing to their manager/supervisor. Note that a witness to an act of racism may also file a complaint.

Filing a Complaint:

When a complaint is reported verbally or in writing to the manager/supervisor, Liver Canada will provide for a fair, thorough, and prompt investigation without fear of reprisal, provided that the complaint is not found to be frivolous or vexatious. Full details of what is being alleged will be investigated and all parties involved will have the opportunity to respond to the allegations. Decisions made will be unbiased and consistent.

When submitting a written complaint, the organization’s complaint form should be filled out and submitted. When reporting verbally, the manager/supervisor along with the person filing the complaint will complete the complaint form.

The manager/supervisor must immediately report the incident to Human Resources, providing the complaint form and including any supporting documentation.

The report of the incident should include the following information:

  1. Name of the individual who has allegedly experienced racism or witnessed racism and contact information (the complainant)
  2. Name of the alleged perpetrator(s), position and contact information
  3. Names of the witness(es) (if any) or other person(s) with relevant information to provide about the incident (if any) and contact information (if known)
  4. Details of what happened including date(s), frequency and location(s) of the alleged incident(s)
  5. Any supporting documents of the complainant that are relevant to the complaint
  6. List any documents a witness, another person or the alleged perpetrator may have in their possession that are relevant to the complaint.

If the complainant’s manager/supervisor is the person engaging in the workplace racism, contact Human Resources directly. If the CEO is the person engaging in the workplace racism, contact the Chair of the Board of Directors.

Investigating a Complaint:

An investigation into all reported incidents, appropriate in the circumstances, will be undertaken immediately along with any additional steps necessary to resolve the problem.

All incidents or complaints of racism shall be kept confidential except to the extent necessary to protect employees/volunteers, to investigate the complaint or incident, to take corrective action or otherwise as required by law.

Human Resources with the CEO will make a decision as to who will conduct the investigation. If the allegations of racism involve the CEO, the investigation will be referred to an external investigator by Human Resources in order to conduct an impartial investigation.

All parties involved will be interviewed, including any individuals who may be able to provide additional and relevant information. Once all relevant information has been collected and recorded, it will be reviewed to determine whether racism has taken place.

The investigator must prepare a written report summarizing the steps taken during the investigation, the complaint, the allegations of racism, the response from the accused, the evidence of any witnesses, and the evidence gathered. The report must set out findings of fact and come to a conclusion about whether racism occurred or not.

Within ten (10) days of the investigation being completed, the individual who allegedly experienced the racism and the accused will be informed in writing of the results of the investigation and any corrective action taken, or that will be taken by the employer to address the racism. If racism is found to have taken place, appropriate disciplinary action up to and including termination of employment (for employees) and termination of one’s volunteer role (for volunteers) will be considered and undertaken.

Record Keeping

Human Resources will keep records of all investigations including:

  1. a copy of the complaint or details about the incident
  2. a record of the investigation, including notes
  3. a copy of the investigation report (if any)
  4. a summary of the results of the investigation that was provided to the employee/volunteer who allegedly experienced the racist behaviour, the complainant (who may be a witness or the person who allegedly experience the racist behaviour), and the alleged offender.
  5. a copy of any corrective action taken to address the complaint or incident of racist behaviour.

All records of the investigation will be kept confidential. The investigation documents will not be disclosed unless necessary to investigate an incident or complaint, take corrective action, or otherwise as required by law.

Records will be kept for a period of two (2) years and then destroyed.

Intentionally accusing someone of racism when it is known to be false is also a serious offence that may be subject to disciplinary action. Liver Canada reserves the right to discipline those whose complaints are frivolous or vexatious. If a complaint is found to be frivolous or vexatious, no reference to the incident will appear in the personnel file of the person who had the complaint lodged against them.

Should an investigation fail to find any fault, all documents will be destroyed and both parties will be notified of the results of the investigation.

Policy Compliance

Any employee not complying with this policy may be subject to disciplinary action, including but not limited to termination of their employment with Liver Canada. Any volunteer not complying with this policy may be subject to disciplinary action up to and including termination of their volunteer role.

Policy Review

This policy will be reviewed and revised as needed every three (3) years.

Created: March 2025

Reviewed: Jennifer Nebesky, President and CEO