Workplace Harassment and Discrimination – Complaints Procedure
1.0 Responsibility
Director, Human Rights and Investigations Department (HRID)
2.0 Purpose
To outline the process and procedures for submitting, managing and resolving complaints under the Workplace Harassment and Discrimination Policy (the “Policy”).
3.0 Complaints Procedures
3.1 Persons who feel they have experienced a violation under the Policy, or who witness a violation of the Policy, the Code or the OHSA, are encouraged to immediately report, in detail, the actions, behaviour or incident(s).
3.2 Complaint Time Limits
Complaints must be filed within one year of the incident (or last incident in a series of incidents). Incidents that happened more than a year before a complaint is filed will not be considered, unless they are part of a continuing series that includes at least one incident within the past year of the complaint.
Complaints filed more than one year after the incident will not be investigated. Should HRID determine the delay in filing was justified and incurred in good faith, they may consider investigating the complaint.
3.3 Employees Filing a Complaint
Employees should report and file their complaint with:
- their immediate supervisor,
- any member of their departmental management,
- HRID, or
- the Integrity Line (for anonymous complaints)
3.4 Members of the Public Filing a Complaint
Members of the Public should report and file their complaint through:
- the online Customer Relationship Management (CRM) reporting system,
- the customer service centre, at 416-393-3030 or online,
- the Integrity Line (for anonymous complaints), or
- In cases of emergency, members of the public must call 9-1-1.
3.5 Persons conducting business with or performing work on behalf of the TTC
Complaints regarding any violation of the Policy by any person who is not an employee while still performing work at a TTC Workplace should be brought to TTC Management and HRID. TTC management will then notify that person’s company. These complaints may be investigated and addressed as deemed appropriate depending on the alleged actions, behaviour or incident.
3.6 Complaints Filed with HRID
3.6.1 If a complaint falls within HRID jurisdiction, complainants may use the online HRID Case Management Portal to file a complaint or scan the QR Code below:
3.6.2 HRID will receive complaints which can be filed by any Persons. HRID also receives anonymous complaints. Persons involved with a HRID complaint, including the person making the complaint (Complainant), the person who the complaint is about (Respondent), Support Persons, Witnesses, management, union/association representatives and investigators are expected to treat the matter as confidential.
3.6.3 All Persons involved with a HRID complaint should maintain confidentiality, specifically not ask individuals if they have participated in an investigation process, share the existence of a complaint, or discuss any details about the complaint or any investigation interviews.
• Employees involved with a HRID complaint are expected to review, understand, and adhere to the confidentiality agreement.
• Employees may be disciplined if confidentiality is breached.
3.7 Complaints Filed through the Integrity Line
If you wish to file an anonymous complaint, please submit your report through Clearview Connects, here or visit www.clearviewconnects.com. Please review the Whistle Blower Reporting and Protection Policy for more information.
Your identity will not be revealed by the Integrity Line to the TTC unless you include it with your submission.
3.8 Complaints Against Members of the Executive Team and the Chief Executive Officer
3.8.1 If the Respondent includes any member of the executive team, with the exception of the Chief Executive Officer (“CEO”), the Complainant may use any of the above methods for reporting, but it is advised to immediately report directly to HRID’s complaint portal.
3.8.2 If the Respondent includes the CEO, the Complainant is encouraged to immediately report their complaint following the procedures outlined in the TTC CEO Misconduct Policy. Complaints of misconduct by the CEO may be submitted:
- by completing the Workplace Harassment and Discrimination Complaint Form and submitting it to the HRID via email or mail; or
- through the TTC’s Integrity Line Program (see Whistle Blower Reporting and Protection Policy).
A copy of the complaint will be forwarded to TTC’s General Counsel and Chief People and Culture Officer.
3.9 What to Include in a Complaint
When filing a complaint of an alleged violation of the Policy, you should provide as much information as possible, including but not limited to:
- the details of what happened, including when and where;
- the name of the Respondent(s);
- the names of any Witnesses;
- any relevant documentation; and
- current contact information.
3.10 What to Do When a Complaint is Received
3.10.1 Anyone receiving a complaint about an alleged Policy violation shall ensure that the complaint is immediately reported to HRID.
3.10.2 Allegations involving a risk to any Persons’ safety (for example, stalking or self-harm) must be reported immediately to Transit Control (416-393-3555) who will immediately dispatch the appropriate police services, emergency personnel and supervisory personnel.
3.10.3 Any Person who is a victim of a criminal act may also directly contact the appropriate police services. HRID may have a responsibility to contact additional authorities if an allegation of criminality is brought forward.
3.11 Other Avenues for Related Complaints
Making a complaint under this Policy does not limit Persons from pursuing other avenues of complaints for the same matter, such as an HRTO application or a grievance. To avoid contradictory results, HRID may, under its discretion, hold an HRID investigation in abeyance to allow the related complaint to be resolved.
3.12 Reprisal
TTC strictly prohibits any reprisal, either direct or indirect, or clear threat of retaliation against an individual for engaging in the complaint and early resolution process, including but not limited to any Persons:
- initiating a complaint in good faith;
- investigating a complaint;
- being a decision maker in a complaint;
- participating as a Witness in an investigation;
- being a Respondent to a complaint; or
- having been associated with, or representing a Complainant, Witness or Respondent.
TTC also strictly prohibits any threat of Reprisal where the intention is to prevent or discourage an individual from participating in an investigation.
4.0 Intake and Early Resolution
4.1 Intake Assessment
Once a complaint is received, HRID’s Intake and Early Resolution Office (“IERO”) will conduct an initial intake, which may include meeting Complainants to gather more information, and determine next steps in the assessment process. IERO will then conduct a preliminary assessment of the complaint and determine:
- Whether the allegations, if true, would amount to a violation of the Policy, or any policy in the case of Special Constables and Provincial Offences Officers.
- If yes, whether the investigation should be conducted by Management, with HRID’s assistance, investigated by HRID directly, or referred to an external investigator. Please refer to the Investigations Procedure for additional information.
- If no, the complaint will be referred to management to address, as appropriate, with assistance from Employee Relations, if required. HRID may also provide guidance on whether Mediation or another form of dispute resolution would be appropriate.
4.2 Mediation
If a complaint has been submitted by a TTC employee and against a TTC employee, and where appropriate, the parties involved are both willing to try to resolve the matter, HRID can conduct or coordinate the resolution including Mediation where necessary. Mediation is a voluntary process whereby employees can meet with a mediator to determine whether their complaint can be resolved in a mutually satisfactory manner.
Informal Mediation is a voluntary, collaborative process that helps parties address concerns, improve communication, and work toward a mutually acceptable resolution. Unlike formal investigations, it does not focus on allegations, findings of fact, or assigning blame. Instead, it provides a safe, structured environment where parties can share perspectives, explore issues, and identify constructive paths forward.
HRID, trained in informal Mediation, serves as an impartial facilitator to guide these conversations. Mediation may be used proactively-before a formal investigation-to resolve concerns collaboratively or following an investigation as a restorative measure.
It is important to note that serious incidents, such as sexual harassment or workplace violence, are not eligible for informal resolution. This process is reserved for situations where one employee has submitted a complaint against another. If informal Mediation does not lead to resolution, the matter may proceed to a formal investigation.
4.3 Early Resolution Steps
a) Preliminary Assessment:
Upon receiving a request or identifying a situation suitable for informal Mediation, HRID conducts a preliminary assessment to determine eligibility. The assessment includes reviewing the nature of the concern, potential risks, and whether the matter is appropriate for informal resolution. HRID will then confirm what participation is voluntary, and that both parties are willing to participate in good faith.
If the matter is not appropriate for informal Mediation, HRID advises the parties on next steps, which may include a formal investigation (see Appendix B for more details of the Investigation process).
b) Pre-Mediation Meeting:
HRID will schedule separate pre-mediation meetings with each party. During each meeting, HRID will:
• Explain the purpose and structure of the informal Mediation.
• Outline confidentiality expectations.
• Review roles and responsibilities.
• Identify key issues, concerns, and goals.
• Support each party in preparing for the Mediation.
c) Mediation Agreement
Before the session, HRID establishes a signed Mediation agreement with both parties. The agreement confirms:
- Voluntary participation
- Confidentiality parameters
- Communication expectations
- Goals for the session
- Consent to proceed
d) Mediation Session
HRID facilitates the Mediation session in a confidential setting agreed upon by all parties. HRID will outline the structure of the setting and review ground rules before allowing each party an opportunity to share perspectives, clarify concerns, and discuss impact. HRID will act as a neutral facilitator and guides the conversation toward mutual understanding, identification of shared goals, and develop workable next steps.
e) Post-Mediation Follow-Up (optional)
HRID may schedule a follow-up check-in with the parties to assess progress and offer additional support if needed. This is dependent on the complexity of the matter.