12.1. Organizational reviews, policies and education
Corporate liability involves more than individual instances of discrimination and harassment. Organizations also risk violating the Code if they do not address underlying problems such as systemic barriers, a poisoned environment or an organizational culture that condones discrimination.
There are several steps organizations can take to make sure they are following the Code and human rights principles related to pregnancy and breastfeeding. Strategies include developing and implementing:
- A barrier prevention, review and removal plan
- Anti-harassment and anti-discrimination policies
- An accommodation policy and procedure
- An internal complaints procedure
- An education and training program
- Ongoing monitoring and evaluation.
Under the Occupational Health and Safety Act, all workplaces in Ontario are expected to develop harassment policies and review these at least annually. Harassment policies should specifically recognize protection for pregnancy and breastfeeding under the ground of sex, among other Code grounds.
For more information about these types of strategies, see the OHRC’s, A policy primer: Guide to developing human rights policies and procedures.
 (2013) online: OHRC www.ohrc.on.ca/en/policy-primer-guide-developing-human-rights-policies-a....