Anti-Abuse & Harassment
Procurement Directive Policy
Vita Community Living Services and Mens Sana Families for Mental Health (VITA) will abide to the Broader Public Sector (BPS) Procurement Directive issued by the Management Board of Cabinet under the authority of the Broader Public Sector Accountability Act, 2010, (Section 12).
The purpose of the Directive is:
- To ensure that VITA’s publicly funded goods and services, including construction, consulting services, and information technology will be outlined through a process that is open, fair, and transparent.
- To ensure that VITA’s responsibilities will be outlined throughout each stage of the procurement process.
- To ensure that VITA’s procurement processes are managed consistently throughout this Broader Public Sector Procurement Directive Policy.
- To provide guidelines for entering into contracts and to establish internal controls over the authorization of procurement processes.
- To ensure that VITA shall endeavour to receive value for money when procuring goods, services and consulting services.
This Directive is based on the five key principles that will allow VITA to achieve value for money while following a procurement process that is fair and transparent to all stakeholders:
VITA will be accountable for the results of its procurement decisions and the appropriateness of the processes.
VITA will be transparent to all stakeholders. Wherever possible, stakeholders will have equal access to information on procurement opportunities, processes and results.
- Value for Money
VITA will maximize the value it receives from the use of public funds. A value-for-money approach aims to deliver goods and services at the optimum total life-cycle cost.
- Quality Service Delivery
VITA will ensure that front-line services provided by VITA staff, such as teaching and member care, will receive the right product, at the right time, in the right place.
- Process Standardization
VITA will ensure that standardized processes will remove inefficiencies and create a level playing field.
"Goods and services" means any goods, construction, and services, including but not limited to IT and consulting services.
"Members of an Organization" means all trustees, members of the Board of Directors, Senior Executives, and employees of the organization, or their equivalent.
"Supply Chain Activities" means all activities directly or indirectly related to the organization’s planning, sourcing, procurement, moving, and payment processes.
"Consultant" means a person or entity that under an agreement, other than an employment agreement, provides expert or strategic advice and related services for consideration and decision-making.
"Consulting Services" means the provision of expertise or strategic advice that is presented for consideration and decision-making.
"Contract" means an obligation, such as an accepted offer, between competent parties upon a legal consideration, to do or abstain from doing some act. It is essential to the creation of a contract that the parties intend that their agreement shall have legal consequences and be legally enforceable. The essential elements of a contract are an offer and an acceptance of that offer; the capacity of the parties to contract; consideration to support the contract; a mutual identity of consent or consensus ad idem; legality of purpose; and sufficient certainty of terms.
SUPPLY CHAIN CODE OF ETHICS (CODE):
This Code does not supersede Codes of Ethics that VITA currently has in place, but supplements VITA’s Codes of Ethics with the Supply Chain specific standards of practice.
VITA has formally adopted and will abide to the Code in accordance with its governance processes. This policy’s intent is to establish the conduct of all VITA staff that are involved with the Supply Chain Activities in accordance with the Code.
This Code will be made available and visible to all VITA staff, as well as to all suppliers and other stakeholders involved with the Supply Chain Activities. This Code will be posted on VITA’s website.
Ontario Broader Public Sector (BPS) Supply Chain Code of Ethics
Goal: VITA will ensure an ethical, professional and accountable BPS Supply Chain.
- Personal Integrity and Professionalism
All VITA staff involved with the Supply Chain Activities will act, and be seen to act, with integrity and professionalism. Honesty, care and due diligence will be integral to all Supply Chain Activities within and between VITA, suppliers and other stakeholders. Respect will be demonstrated for each other and for the environment. Confidential information will be safeguarded. Participants will not engage in any activity that may create, or appear to create, a conflict of interest, such as accepting gifts or favours, providing preferential treatment, or publicly endorsing suppliers or products.
- Accountability and Transparency
VITA will ensure that the Supply Chain Activities will be open and accountable. In particular, contracting and purchasing activities will be fair, transparent and conducted with a view to obtaining the best value for public money. VITA will ensure that public sector resources are used in a responsible, efficient and effective manner.
- Compliance and Continuous Improvement
VITA will ensure that individuals involved with purchasing or other Supply Chain Activities will comply with this Code of Ethics and the laws of Canada and Ontario. VITA staff involved will continuously work to improve supply chain policies and procedures, to improve its supply chain knowledge and skill levels, and to share leading practices.
VITA will ensure that all contracts entered by, or in the name of Vita Community Living Services and Mens Sana families for Mental Health, will follow the requirements set forth in the Broader Public Sector (BPS) Procurement Directive.
CONTRACTS AND CONSULTANT AGREEMENTS GUIDELINES:
All contracts over $100,000 and all consultant agreements of any dollar value must be preceded by, and result from, a Request for Proposal (RFP) and a 3 bid quote. All contracts and consultant agreements must be consistent with VITA’s Mission, Vision, Values, conform to the Conflict of Interest Policy, and conform to all other applicable VITA policies.
AUTHORITY TO SIGN CONTRACTS AND CONSULTANT AGREEMENTS:
The following thresholds and approval levels are required for the procurement of goods, services and consulting services:
- Up to $180.00 – approval by Supervisors.
- Up to $300.00 – approval by Managers.
- Up to $1,000 – approval by Directors.
- Over $1,000 – $99,999 approval by Executive Director.
- Over $100,000 –following the completion of the required Procurement Process, the selection of the winning bid is done by the Executive Management Team (minimum three members) and recommendations are presented to the ED for approval.
- For all open tender invitations over $1,000,000, recommendations must be forwarded to the Executive Director and to the Board of Directors for approval. The requirements must be defined properly and clearly and in compliance with the procedures covered in the BPS Procurement Directive.
See attached BPS Procurement Directive Guidelines for additional information on mandatory requirements for Procurement Process.
- All contracts entered into by VITA that exceed $5,000, but under $1,000,000 and/or binds VITA for more than one year, but less than 5 years, must be reviewed and approved by the Executive Director.
- All contracts entered into VITA that exceed $1,000,000 and or that binds VITA for more than 5 years must be reviewed by the Executive Director and approved by the Board of Directors.
- Any purchase with a gross value greater than $25,000 and not approved in the budget shall be reviewed and authorized by the Executive Director and forwarded to the Board of Directors for final approval.
- It is the responsibility of the individual with the signing authority involved in the purchase and reimbursement of goods and services to ensure compliance with this policy and procedure. The Finance Department is responsible for verifying that the amount requested is supported by the attached documents and that the signature is by the appropriate signing authority.
- The Supervisor or Manager of the department the purchase is related to approve the requisition. Special authorization is required if the amount of the requisition is over a certain limit or an unbudgeted expense. Only individuals with the appropriate level of authority are able to approve the cheque requisition.
CONTRACTS NOT PREVIOUSLY INCLUDED IN THE ANNUAL BUDGET:
All contracts and/or other expenditures up to $25,000 for which prior budget approval has not been given will require a budget proposal to be prepared, reviewed by the Finance Department (to allocate to the appropriate program budget) and submitted to the Executive Director for approval. Contracts and/or other expenditures that exceed $1,000,000 must be reviewed by the Executive Director and forwarded to the Board of Directors for final approval.
SIGNING OF CONTRACTS:
The Executive Director or the designate, who has obtained prior written approval from the Board of Directors and has been granted signing authority, shall sign each contract. Each contract will be witnessed and dated and may be embossed with the corporate seal.
LOCATION OF ORIGINAL CONTRACTS:
An original signed copy of all contracts that bind VITA must be provided to the Finance Department located at VITA’s Head Office for filing and monitoring.
PURCHASE OF SERVICE CONTRACTS:
A “purchase of a service contract” is a written agreement between VITA and an individual or organization in which specific services are to be provided. The following shall apply to all contracts signed by VITA:
- All purchases are within the approved budget.
- The Board of Directors authorizes the annual expenses of the agency by approving the annual budget.
- For any purchases not incorporated into the fiscal budget, the Board of Directors delegates authorization responsibility to the Executive Director. However, the Board of Directors shall be informed of major purchases that have the potential to affect the direction or financial results of the agency.
Prior to the commencement of any contract, VITA will ensure:
- Contracts are entered into when there is an advantage to the agency by doing so.
- A full range of potential arrangements is investigated before entering into an exclusive contract.
- Legal assistance or advice is obtained if necessary for any non-standard clauses.
- All contracts entered into by the agency are reviewed and approved by the Executive Director or designate. Special authorization is required if the amount of the contract is over a certain limit or an unbudgeted expense. Only individuals with the appropriate level of authority can approve and sign a contract.
- As best practice, contractor must provide proof of liability insurance and WSIB coverage where appropriate.
- Each contract is dated, witnessed or embossed with the agency’s corporate seal if required.
- The agency also ensures that a completed copy of the final contract is made available to all other signatories.
- The original copy of a signed contract is kept in a secure place at the agency’s finance department.
- All Purchase of Service contracts must meet the agency’s conflict of interest guidelines as referred to in policy #2.28 “Conflict of Interest”.
- At least 3 months prior to the completion of the contract, the Executive Director or designate reviews and plans for the renewal or tendering of the contract following the above procedures.
Content of Contract:
At a minimum each Purchase of Service Contract entered into by VITA shall provide the following information:
- The nature of the service.
- Anticipated outcomes.
- Reporting requirements.
- Period of time covered by contract (no contract can be established in perpetuity).
- Invoicing procedure and payment schedule.
- Termination and escape clause.
- Table of content regarding negotiated work plan.
- Name(s) of VITA staff who have been given the authority to act on VITA’s behalf in relation to the services provided and the service provider.
- Description of monitoring process.
- Confidentiality Agreement.
- Warranty for completed services meeting the quality standards specified.
- Allowable expenses as per VITA’s Policy #18.01 Perquisites Policy and Policy #18.2 Expenses Policy.
INFORMATION REQUIRED FOR PROPER PAYMENT AUTHORIZATION:
All invoices must be reviewed and approved prior to payment by the staff authorized to sign. Authorization is to include:
- Date- Date of request.
- Completed by- Name of the person completing the form (if a cheque requisition).
- Payable to- The name and complete address of the payee.
- Description- Reason for payment cross-referenced to supporting details or documents and attached to the requisition.
- Coding section- The account code or codes to be debited and the corresponding amounts with taxes (PST and GST) identified separately.
- Amount– Total amount of the cheque to be issued.
- Approved by- Requires authorized signature on purchase order (PO).
- Special delivery instructions- If the cheque is not to be directly routed to the payee then the appropriate routing instructions need to be reported in this space.
- Date required– Record date cheque is required if different from regular cheque run.
CONSISTENCY WITH ALL OTHER VITA POLICIES, PROCEDURES AND GUIDELINES:
A Purchase of Service contract must adhere to all other VITA policies, procedures and guidelines with respect to financial support, expense rules (hospitality and incidental expenses), levels of approval authority, levels of signing authority and location of originally signed contract.
In no circumstances can hospitality, incidental for food expenses be considered allowable expenses for consultants and contractors under the rules or in any contract between an organization and a consultant or contractor. Therefore, they cannot claim or be reimbursed for such expenses, including:
- Meals, snacks and beverages.
- Laundry or dry cleaning.
- Valet services.
- Dependent care.
- Home Management.
- Personal telephone calls.
PROCUREMENT RECORD RETENTION:
VITA will handle, store and maintain vendor’s confidential and communicational sensitive information in an appropriate and legal matter.
VITA will conduct procurement activities according to the law in Ontario, including contract law, the law of competitive processes, privacy legislation, accessibility legislation and any other legislation as may be applicable.
VITA will also be subject to various trade agreements, including but not limited to the Agreement on Internal Trade (AIT) and the Ontario–Quebec Trade and Cooperation Agreement (Ontario–Quebec Agreement).
This policy will be evaluated and reviewed annually by management.
- Request for Proposal (RFP).
- Policy #2.28 “Conflict of Interest Policy”.
- Policy #18.01 “Perquisites Policy”.
- Policy #18.02 “Expenses Policy”.
- VITA’s Standard Consultant Agreement.
Copy of the Broader Public Sector (BPS) Procurement Directive Policy Guidelines.
Anti-Abuse & Harassment Policy
PURPOSE OF THE POLICY
These Policies and Procedures have been developed in order to ensure the protection and the rights of our members and employees. They are intended to give members and employees clear procedural guidelines in identifying and reporting abuse and harassment.
These policies and procedures apply to all employees as well as to all directors, officers, students and volunteers. It applies to discrimination, harassment or abuse, which may occur during the course of VITA's business, activities and/or events.
Anyone in a position of authority, responsibility, supervision, control or management who knows or ought reasonably to know that a person has experienced or is experiencing discrimination, harassment or abuse is required to take reasonable steps to prevent the discrimination, harassment or abuse as described in the process outlined herein.
VITA encourages the prompt reporting of all incidents of harassment and abuse, regardless of who the respondent may be.
Any employee who abuses a member WILL BE DISMISSED.
- VITA is committed to providing a safe environment for all employees and members. VITA promotes equal opportunities to all employees and members and prohibits all types of harassment, discrimination and abuse;
- VITA is committed to maintain an environment that is free from harassment, discrimination and abuse. Harassment is a form of discrimination. Harassment is prohibited by human rights legislation in each province in Canada. In its most extreme forms, harassment can be an offense under Canada's Criminal Code.
- These policies are intended to alert all employees and members of VITA to the fact that all types of harassment, discrimination or abuse as defined herein will not be tolerated and will be punishable to the full extent of the law as possible.
- These policies set out the types of behaviours that may be considered offensive.
- These policies establish a mechanism for receiving complaints and to provide a procedure by which VITA will deal with these complaints.
It is the policy of VITA that every member can expect to share, live and participate in a safe environment in which all members are treated with respect and dignity. All members will be provided with an environment free of harassment and abuse and will be protected from any form of harassment or abuse including discriminatory harassment based on age, gender, ancestry, place of origin, color, ethnic origin, citizenship, creed, sexual orientation, disability, marital status, or family status.
VITA recognizes that people with disabilities need to be safe in care. The first and primary goal that all services must have regarding people in care is the provision of a safe environment, with staff who support without control, with policies that place "freedom from harm" as a priority for the organization.
There will be zero tolerance for harassment or abuse at VITA and any employee who abuses a member WILL BE DISMISSED.
This policy also includes sexual harassment and gender based harassment, both of which forms of discrimination are based on sex and are prohibited by the Ontario Human Rights Code.
VITA will not accept a hostile or poisoned environment. This may be defined as an atmosphere in which there is behaviour, language, audio or visual material or treatment of individuals, which undermines their personal power, creates personal discomfort or jeopardizes their aspirations to achieve their personal goals.
VITA will act quickly on any complaint of harassment and/or abuse, brought to its attention, with the goal of resolving the situation fairly and of preventing future occurrences.
VITA will be pro-active in ensuring that its members and employees are aware of their rights and obligations as outlined in this policy. VITA is committed to the education of all its members and employees in the area of harassment and abuse.
Nothing in this policy shall be construed as removing any statutory rights or obligations.
CONFIDENTIALITY & PRIVACY:
VITA understands that it can be extremely difficult to come forward with a complaint of harassment or abuse and that it can be devastating to be wrongly convicted of harassment or abuse. VITA recognizes the interests of both the complainant and the respondent in keeping the matter confidential.
Confidentiality will be maintained throughout the investigatory process to the extent practicable and appropriate under the circumstances. All records, notes and files will be kept confidential except where disclosure is required by a disciplinary or other remedial process, or as is required by law.
Confidentiality will also be maintained as the jurisdiction of any individual making an allegation that needs to be investigated. Outside the reporting to police, they will have control in determining who is told within their family and friend circle. If they are their own guardian, then family will only be informed if the individual gives permission for that information to be shared. If the individual is not their own guardian, the guardian must be informed - in this case the individual will be informed that the guardian is being told but consent will not be asked for this to be done.
An individual with a disability, like any citizen, has reasonable expectations of privacy. In reference to sexual offenses or being a victim of a sexual offense a provision of the Criminal Code, specifically section 278.1 to 278.91 makes it clear that the agency's records regarding an individual are made with the member's expectation of privacy. These documents cannot be released unless there has been a court procedure that required them to be released or if the individual has given permission for them to be so released. The Criminal Code also has provisions which strictly limit evidence of a victim's sexual history.
Comments, conduct, or gestures that are insulting, intimidating, humiliating, malicious, degrading, offensive, or discriminatory, directed toward an individual or group of individuals.
2. Sexual Harassment
Comments or conduct of a sexual nature undertaken with the intent of causing offence or humiliation. It is important to recognize that people with disabilities do not choose to live within care and cannot often choose to leave care, the atmosphere of respect that comes from purposefully avoiding jokes or language that others might find distressing is important to foster.
The unwarranted and/or inappropriate use of physical force, psychological stress or sexual involvement, or any unwarranted inappropriate act of omission, by employees interacting with members and includes action, which leaves no physical scars, but results in emotional damage.
4. Sexual Abuse
Sexual abuse is the unwanted touching of a person's sexual body parts. The lack of consent is the defining feature. Here it is important to note that the hierarchy makes it impossible for there to be consent between a person with a disability and their care provider.
5. Physical Abuse
Acts of assault or threats of assault, such as hitting, slapping, and burning that cause or could cause physical injury or fear of physical injury. An intellectual or physical disability often results in a need for people to be physically close to provide personal assistance. Physical abuse is more terrifying for those who cannot, physically, flee or escape.
6. Verbal Abuse
Demeaning language, name-calling or negative verbal depictions of disability or attractiveness are all forms of verbal abuse. Words like 'retard' or 'spaz' cause considerable hurt and are never acceptable.7. Emotional Abuse
The constant criticism, insulting, threatening, degrading, humiliating, intimidation or terrorizing of a person. Of all the 'abuses' this is the most difficult to define. Emotional abuse is the misuse of power, in any way, to cause a person to lose respect for self. Any other form of abuse is also emotional abuse.
8. Financial Abuse
The misuse or misappropriation of someone' s financial assets for personal gain. It is impossible to 'borrow' money from someone who is under your care as the power imbalance makes it difficult for the individual to simply say 'no'.
9. Spiritual Abuse
The demeaning of another's faith or the imposition of care providers faith into the life of the person with a disability. Forced religious activity or the denial of religious activity.
The failure to provide the necessities of life such as food, clothing, shelter, care or supervision. People with disabilities, in care, have a right to expect that their basic needs will be met and they will be provided with the supervision which is appropriate to their age and their developmental and intellectual needs.
Taking advantage of a person's disability to trick or manipulate for personal benefit. The persuasion to do things that are illegal or not in the individual's best interest.
MEMBER TO MEMBER ABUSE:
We note that it is entirely possible that the abuse may be occurring between members with disabilities within VITA. Injury may occur to an individual with a disability from another person with a disability in one of two ways. Each way requires a different action taken by the agency:
Criminal Abuse: When an individual with a disability specifically targets another individual and this results in hurt, harm or victimization (see definitions above) of that specific person then it is clear that a criminal act has occurred and the policies outlined below for the reporting of criminal acts are followed.
Accidental Hurt: When an individual in the course of a behavioural outburst accidentally hurts someone or randomly strikes out at those in the environment, the accidental, spontaneous nature of the event makes the action without intent and as such is viewed as a behavioural incident. The clinical team is contacted immediately and the incident is reviewed and a risk reduction plan is put into place. The goal of the risk reduction plan is to reduce the risk that any further harm will come to anyone as a result of a behavioural outburst. Each VITA program where someone who has behavioural challenges resides has the risk reduction strategies implemented in order to keep everyone safe.
Within 48 hours of hire, all new staff will be given the policy on how to respond to a complaint of abuse:
- Supervisors will go over the policy and take questions
- Staff will be encouraged to ask questions
- Supervisors will have staff sign and date a form indicating that they have reviewed the policy
Within 3 months of hire all new staff will undergo a training lasting at least three hours on abuse and abuse prevention.
- The training will involve a pre and a post test
- Those failing the post test will be required to retake the training at the earliest opportunity
Supervisors/Management will review the policies and protocols on a 6-month basis at regular staff or team meetings
- The training will be documented in team meeting minutes
- Staff who miss the team meeting will be required to set a time for individual talk
Supervisors will be trained, within 48 hours, in how to handle an abuse report. Supervisors will collect information without questioning the staff or doing an investigation. Agency investigation will begin after police investigation and conclusion.
Upon admission, all people with disabilities in care will:
- Undergo some form of abuse prevention training every six to eight months while in care.
- Will be offered the opportunity to take sex education /relationship training classes through the agency.
- Will be offered the opportunity to attend or belong to a self-advocate group.
HANDLING A REPORT: STAFF
- Staff receiving the report or witnessing abuse will notify the police immediately
- If the staff believes that the person is at imminent risk, he/she will immediately inform the police of possible danger
- Staff receiving the report will notify their supervisor only after contacting the police
- Staff when receiving the report, will not ask leading questions or attempt to do an investigation
- Staff will ask for guidance from supervisor regarding the safety of the individual making the allegation
- Staff will follow through to ensure that the individual is not placed at risk
- Staff will not discuss the allegation with supervisor (beyond the basics of the report) or with other staff (at all) until they have been interviewed by the police
- Staff will fully document the allegation once the phone call has been made
- Staff will document both the member's allegation and their own questions
HANDLING A REPORT: SUPERVISORS
Supervisors will be trained, within 48 hours, in how to handle an abuse report.
Supervisors will collect information without questioning the staff or doing an investigation. Agency investigation will begin after police investigation and conclusion.
- Supervisors will immediately suspend the alleged abuser, with pay, for the period of the investigation.
- Upon completion of police investigation, supervisor and HR will meet with alleged abuser.
- Meeting will take place only at the head office. Supervisor/HR will document the content of the discussion with the alleged abuser.
- Supervisor will meet with the staff member who took the initial report to ensure that the staff is feeling supported and offer counselling services if necessary.
Supervisor will ensure that the reporting staff is not subject to:
- Workplace harassment;
HANDLING A REPORT: AGENCY
- The agency will follow through with the Ministry's guidelines for reporting abuse to them
- The agency will communicate, through training and orientation, that all reported abuse will be reported
- The agency will support staff through the process of reporting abuse by:
- Ensuring that training on abuse happens on a regular basis
- Ensuring that abuse policies and reporting protocols are regularly reviewed
- Ensuring that staff who report abuse are not subject to peer or supervisor ostracism or punishment
- The agency will review the abuse reporting procedure at board level once yearly
- The agency will develop a relationship with the local police force to discuss any issues of concerns or support
FALSE ALLEGATIONS OF ABUSE BY A MEMBER
Once a member has been determined, through a police investigation, to have made a series of false allegations a different process will be utilized. An individualized protocol approved by the Executive Director will be implemented.
The protocol will include the following:
First, when a new allegation is made, there will be a brief investigation (within an hour) to determine if the abuse alleged could possibly have happened. If the investigation finds out that the allegation is not possible (i.e. staff not on duty at time; an independent staff had eyes on during the time or on the location of where the abuse was alleged to have occurred) then the allegation will be seen as a behaviour issue not an allegation and the individual will receive behaviour programming regarding appropriate ways to deal with situations. If the investigation finds that the abuse could have happened, the police will be called.
In NO WAY will the actual event be investigated - the investigation will focus on the situation only. The individual or individual accused will not be questioned. The finding of the brief situational review will be immediately reported to the Executive or Program Director. The final decision regarding calling the police will rest with the Director or the Executive Director upon receiving the 'situational review or assessment of possibility'.
APPROPRIATE RESPONSE/DISCIPLINARY ACTION:
After thorough investigations have been completed and if it is determined that a staff has been engaged in inappropriate misconduct, appropriate disciplinary action will be taken immediately. Using VITA's established procedures and to fulfill its obligations under the law which is to promote a workplace that is free from harassment and abuse, VITA will determine the appropriate actions to be taken which may rang from counselling to termination of employment.
If during the investigation it is determined that abuse has not occurred all documentation of the evidence shall be given to the Executive Director and no such documentation or allegations of abuse will be placed in the employees personnel file.
This policy will be reviewed annually by management.
Any employee who abuses a member (in accordance with the enclosed policy) WILL BE DISMISSED.
PURPOSE OF THE POLICY:
These Policies and Procedures on Sexuality have been developed in order to ensure the protection and the rights of our members and employees. These policies set out guidelines for all Vita Community Living Services and Mens Sana Families for Mental Health (VITA) staff supporting adults within our programmes. For the purpose of this policy, adults are defined as any person age 18 or older.
The purpose of this policy is to ensure a coherent and consistent approach is applied when dealing with adults who receive service and supporting their personal relationships and sexuality within the agency. It seeks to ensure a proper balance between an individual's rights, their physical and emotional safety, and the rights and responsibilities of others including VITA staff.
This policy aims to:
- Provide VITA staff with relevant information about rights and responsibilities when adults within our programmes develop personal relationships and explore their sexuality
- Give clear guidance on how VITA staff should respond in specific situations and what support you should receive from VITA
- Increase your confidence and competence in dealing with situations at work relating to relationships and sexuality
When this policy is used consistently by VITA staff, we expect that Adults within our programmes will be:
- Supported to achieve their rights to have relationships and explore their sexuality in a safe environment
- Able to access appropriate information and services about relationships and sexual health
- Treated with respect and dignity
Members' Parents/Guardians will be:
- Confident that good decisions are helping to keep their loved ones safe
- Clear that VITA staff are expected to support the rights of the person they care for
- Able to access information, advice and support about this policy
It is the expectation of VITA that all employees will read, understand and abide by the guidelines stated in this document.
Please raise any questions you may have in regards to this document immediately to the Executive Director, your Program Director or Human Resources department for clarification.
Upon completion of reading these Policies and Procedures, you will be asked to sign a form stating you have read, understand, and will abide by the guidelines stated in VITA's Sexuality Policy.
VITA recognizes the significance of intimate personal relationships and of sexual expression for all people. It is the policy of VITA to promote the rights of adults within our programmes to develop and enjoy the personal and/or sexual relationships of their choice.
These rights include:
- The right to have opportunities to love and be loved and to engage in consenting relationships, whether sexual or not
- The right to education and information about their own bodies
- The right to education and information about personal relationships and sexuality presented in a manner appropriate to their individual needs
- The right not to be sexually exploited
- The right to opportunities to develop legally acceptable relationships
- The right to information and help with contraception and the maintenance of sexual health, including the right to be included in all sexual screening programs
- The right to develop consenting intimate relationships, marry, enter into a civil partnership or cohabit and to receive support in maintaining such partnerships
- The right to have their sexual orientation respected
- The right to be treated with respect and dignity
- The right to information and advice about the responsibilities of parenthood, and support when deciding whether to become a parent or not
- The right to support during pregnancy and the subsequent upbringing of children (where their capacity to provide proper care can be demonstrated)
- Adults within our programmes have sexual feelings, needs and identities and have the right to privacy and sexual expression
When enabling people to exercise any of these rights, VITA recognize the need for planned, multi-disciplinary approaches, properly discussed and recorded.
Nothing in this policy shall be construed as removing any statutory rights or obligations.
Throughout this document, the words "sexual relationship" and "sexuality" are intended to include heterosexual, gay, lesbian, bisexual, transsexual and transgender relationships and expressions of sexuality.
CONFIDENTIALITY & PRIVACY:
Adults with disabilities are entitled to confidentiality regarding all aspects of their relationships and sexuality, unless there is evidence of abuse or significant concern about the possibility of abuse. Information will not be shared without their consent, unless there are issues of personal safety. In that case, they must always be told that confidentiality cannot be maintained.
Personal and sexual relationships and individual expressions of sexuality require access to private space, which must be offered and respected. In residential establishments, public and private areas should be clearly identified. Day programs are, by definition, public places in their entirety.
SEXUALITY EDUCATION AND TRAINING:
- VITA abides by the principles that all adults with disabilities or with mental health needs and all staff working with them should be provided with education and training in all areas of sexuality.
- Individuals served by VITA who may require education in sexuality as identified by themselves, their families or primary support workers will be instructed, as needed and as specified in an Individual Service Plan. The technical and social dimensions of sexuality to be presented will be in keeping the organizational premises, values and principles.
- VITA will determine the need for and seek as appropriate the resources of other professional including a socio-sexual consultant, physician, and/or therapist to develop or provide instruction to individuals and staff requiring education on sexuality.
PROCEDURES: POLICY GUIDELINES
Standard(s): Beliefs and assumptions held by the Agency, which support the need, development and implementation of the policy.
Implementation: Action steps expected by the Agency, which support the maintenance of the policy.
1. Sexuality, Abuse and Education
Standard: All people have the option and right to obtain accurate, current and factual education regarding relationship and sexuality. The denial of sexual education to people with disabilities has contributed to abuse and misinterpretation of behaviour.
Implementation: VITA will provide classes, which address not only sexual relationships, but also relationships of all kinds. Subjects covered will include interpersonal skills - including but not limited to communication, decision-making, assertiveness, and refusal skills - sexual health and hygiene, and information related to sexuality and specific disabilities. Classes will also include education to help decrease the risk of victimization and abuse and reduce the risk of unwanted pregnancy and disease. Classes will work to increase the understanding of people with disabilities regarding pro-social and pro-sexual behaviour in order to educate them about actions that can be misinterpreted as behavior with a criminal intent. Additional resources and services will be accessed when necessary.
Standard: Any relationship, including a sexual relationship, must be consensual; that is, it must involve the willing participation of those in the relationship. A person's ability to understand the nature of sexual activity and the implications or consequences of that activity is a key component of consent. Due to the varying levels of cognitive ability, as well as the fact that people with disabilities have been denied sex education and have had few typical opportunities for a range of social and sexual activities, questions may arise concerning ability to give informed consent in social/sexual situations.
Implementation: VITA will address the issue of relationship consent through education and training within the curriculum to both people receiving and providing services. Additional resources and services will be accessed when necessary.
Implementation: VITA will address the issue of relationship consent through education and training within the curriculum to both people receiving and providing services. Additional resources and services will be accessed when necessary.
Standard: Pursuing relationships of choice is a basic human right.
Implementation: VITA will provide education through the curriculum and direct support for safe, legal and consensual relationships. Additional services and resources will be accessed when necessary.
4. Sexual Orientation
Standard: People have the right to be in consensual relationships of choice with those of the same or opposite gender. Although sexual orientation is often subject to divergent attitudes, all individuals need to be able to discover and express who they are free from external pressures, prejudices and discrimination. Regardless of orientation or gender, everyone has a right to intimacy within a consensual relationship.
Implementation: VITA will provide education through the curriculum and direct support for the expression of sexuality within a consensual relationship regardless of orientation. Additional resources and services will be accessed when necessary.
5. Masturbation and Self-Stimulation
Standard: Masturbation is a natural sexual exploration of one's own body that is acceptable when done in a safe, private place. An understanding of privacy, appropriateness, and gentleness is essential. Although people with disabilities are often misinformed about masturbation, and have been punished for practicing this form of sexual expression, everyone is entitled to an atmosphere of comfort and calm regarding this private sexual behaviour.
Implementation: VITA will support safe and private opportunities for masturbation. Additional resources and services will be accessed when necessary.
6. Sexual Contact including Sexual Intercourse
Standard: Sexual contact and intercourse - defined as any physical contact between people that involves genital contact, or contact with breasts or buttocks, including oral, anal and vaginal sex - is a right of consenting adults regardless of sexual orientation, creed, color or disability. A sexually intimate relationship is recognized as an exciting and fulfilling time, and a significant developmental and lifestyle marker. With this experience comes the obligation to make responsible decisions.
Individuals should be fully informed and able to consent before they begin a sexual relationship. Unwanted pregnancy, disease and abuse are all legitimate concerns related to sexual contact. However, these risks should not automatically preclude individuals from experiencing sexual contact. Providing education and experience regarding sexuality and relationships will help those who have historically been denied access to both undertake responsible decisions.
Implementation: VITA will provide education and support through the curriculum to support healthy, consensual sexual contact. Additional resources and services will be accessed when necessary.
7. Pregnancy Prevention
Standard: For those who choose to engage in heterosexual behaviour, pregnancy prevention is a critical issue. Everyone has a right to choose to use birth control options as a way of preventing pregnancy. Implementation: VITA will provide education regarding the importance of pregnancy prevention, and support the birth control method of choice for individuals through accessing medical and/or family planning services.
Standard: The decision to become a parent and raise a child must be made with an understanding of the financial, emotional, and time commitments involved. The parent(s) should also be aware of the risks involved if these commitments are not met. However, having a disability does not necessarily mean that a person cannot be a responsible parent.
Implementation: VITA will provide education, counselling and support surrounding the decision of an individual woman with regard to pregnancy. Additional resources and services will be accessed as necessary. We will also provide similar information to any partner of the pregnant woman with regard to their role and responsibilities. VITA however, is not licensed to provide support to individuals under the age of 18.
9. Sexually Transmitted Infections and AIDS
Standard: All those who are sexually active are at risk for Sexually Transmitted Infection (STI) and have the right to education, information and resources to protect themselves.
Implementation: People with STI's - known diseases that can be transmitted through sexual contact and/or exchange of bodily fluids- and/or HIV will not be subject to any discrimination. VITA supports the use of condoms and dental dams as safe-sex practices. VITA will provide education within the curriculum. Additional resources and services will be accessed when necessary.
10. Co-Habitation/ Marriage/Union
Standard: Everyone has the right to have the opportunity for consensual live-in partnership with person of their choice. This is a significant developmental and lifestyle marker and one of the most important decisions a person can make.
Implementation: VITA will provide education through the curriculum regarding sexuality and relationships to help people undertake safe and healthy decisions regarding the long-term partnerships in their lives. Additional resources and services will be accessed if necessary.
Standard: A broad range of sexually explicit material is available. Therefore, adults may need assistance in accessing material that is enjoyable but does not present sexual violence or illegal activity.
Implementation: VITA will provide support to an adult requesting access to use and own any legal erotic materials if they are used responsibly and privately, and without the potential for criminal behaviour.
Standard: Pornography is considered illegal items, photographs, literature, or media that involves the depiction of sexual images or activities intended to promote violence, abuse or illegal actions, and will not be allowed on VITA property. Material depicting children or violence against women or others will be considered pornographic.
Implementation: Notwithstanding the right of self-determination of individuals, pornographic material will be removed from VITA property. Individuals will not be reimbursed for any pornographic material that is removed.
13. Abuse, Harassment and Exploitation
Standard: Everyone has a right to be free from abuse, coercion, exploitation and harassment. People with disabilities are recognized as one of the most victimized group in society, with those providing care the primary abusers. People with disabilities must be made aware of their rights to a safe place to live and to be supported by respectful VITA staff. They must also learn how to understand and report abuse.
Implementation: VITA will provide education and support through the curriculum to you and to VITA staff to address potential abuse, harassment and exploitation. Additional resources and services will be accessed if necessary.
14. Staff-Individual Contact/Boundaries
Standard: Touch and informal conversation may be easily misinterpreted by the people directly involved and/or observers. Understanding physical and emotional boundaries helps to ensure that people will develop and maintain effective relationships. This understanding also helps people recognize potentially unsafe contact and avoid behavior that may be misinterpreted.
Implementation: People providing services will model socially acceptable touch and speech in every situation. Sexual contact between those providing and those receiving services is prohibited at all times. VITA will provide education and support through curriculum. Additional resources and service will be accessed if necessary.
Standard: Everyone is entitled to privacy regarding their body and their personal space. This is critical to their mental and emotional well-being; and for understanding and maintaining safe and healthy distance from others.
Implementation: VITA will provide education within the curriculum and direct staff support to ensure privacy.
16. Designated VITA Staff
Standard: Everyone should have someone to communicate with when there is a need who is trusted, safe, informed and concerned; and who is compelled to provide effective problem-solving support. This is especially important for people with disabilities who often do not have natural supports to fill this role.
Implementation: VITA will train Designated Staff at each team to provide accurate information and support related to general areas of relationship and sexuality. Access to Designated Staff will also reduce the risk of sharing private and personal information with people with whom they are unfamiliar. Designated Staff will provide support limited to their scope of knowledge and will refer the individual to seek additional resources and services as needed.
17. Sexual Self-Advocacy
Standard: Everyone has the right to advocate for themselves in areas that impact their lives. Relationships and intimacy are two critical areas in which people have the right to speak for themselves to get their needs met.
Implementation: VITA will support an individual's right and need to speak for themselves concerning these subjects in any situation. Education will be provided through the curriculum; support will be provided through VITA and direct service staff. Additional resources and services will be accessed if necessary.
Standard: Guardianship may be necessary when a person cannot make safe, responsible decisions on their own. Effective guardianship involves the participation of the person to the highest degree possible when decisions are being made about the person's life or well being.
Implementation: VITA supports people in securing competent and responsive guardians to help them make informed decisions if this becomes necessary to ensure the health and safety of the individual.
This policy will be reviewed annually by management.
Vita Community Living Services and Mens Sana Families for Mental Health (VITA) will abide by the Broader Public Sector Perquisites Directive issued by the Government of Ontario’s Management Board of Cabinet under the authority of the Broader Public Sector Accountability Act, 2010, (Part IV.1: Perquisites).
The purpose of this policy it to set out the rules on perquisites through public funding. The directive provides for accountability and transparency, and to ensure that government funds are used prudently and responsibly. This policy applies to all employees, board members, consultants, contractors, vendors, students and volunteers.
The term “Perquisite” or “perks”, means a privilege that is provided to an individual or to a group of individuals that provides a personal benefit, and is not generally available to others. A perquisite is not a business-related requirement.
PROCEDURES:The following perquisites are not allowable under any circumstances:
- Club memberships for personal recreation or socializing, such as fitness clubs, golf clubs, or social clubs.
- Seasons tickets to cultural or sporting events.
- Clothing allowances not related to health and safety or special job requirements.
- Access to private health clinics, such as medical services outside those provided by the provincial health care system or by the agency’s benefits plans.
- Professional advisory services for personal matters, such as tax or estate planning.
The privileges mentioned above cannot be provided by any means, including:
- An offer of employment letter, as a promise of a benefit.
- An employment contract.
- A reimbursement of an expense.
The following perquisites are not considered perquisites in this policy:
- Insured benefits.
- Items generally available on a non-discriminatory basis for all or most employees, e.g. Employee Assistance Plans, Pension Plans, etc.
- Health and Safety requirements, e.g. work boots, etc.
- Employment accommodations made for human rights and/or accessibility considerations, e.g. special work stations, modified work hours, etc.
- Expenses covered under VITA’s Policy #2.23 “Vacation and Travel with Member’s Policy”.
Approval and recording process on perquisites:
- Perquisites must be business-related requirements for the effective performance of an individual’s job.
- A perquisite requires approval by the Executive Director, a Board Member or designate.
- The approval and recording of perquisites are recorded, stored and subject to verification and audit.
- Perquisites will only be allowable in limited and exceptional circumstances where it is demonstrated to be a business-related requirement for the effective performance of an individual’s job.
Summary information on perquisites (if any) will be included in a report which will be referenced on VITA’s Web Site.
This policy will be reviewed annually by management.
Vita Community Living Services and Mens Sana Families for Mental Health (VITA) will abide by the Broader Public Sector Expenses Directive issued by the Government of Ontario’s Management Board of Cabinet under the authority of the Broader Public Sector Accountability Act, 2010, (Part IV – Expense Claims: Allowable Expenses).
The purpose of this policy it to set out the rules where expenses are reimbursed through public funding for travel, meals and hospitality. The directive provides for accountability and transparency, and to ensure that government funds are used prudently and responsibly. This policy applies to all employees, board members, consultants, contractors, vendors, students and volunteers.
VITA will reimburse preauthorized costs incurred by employees, board members, consultants, contractors, vendors, students and volunteers while conducting official business or travel for the agency and when appropriate documentation is provided.
The following rules will apply to all individuals outlined in this policy.
Accountability, Approval and Recording Process on Expenses:
a. All employee expense claims for reimbursement must be pre-authorized and pre-approved by a Director or designate.
b. Approvers are accountable for their decisions, which will include:
i. Good judgment and knowledge of the situation.
ii. Exercised in appropriate circumstances.
iii. Comply with the principles and mandatory requirements set out in this directive and the expenses rules.
c. All original, itemized receipts of expenses incurred must be submitted along with the completed and approved expense claim form to the Finance Department.
d. Any overpayments made to the employee in error must be repaid back to the agency.
e. Any overpayments made to the employee in error must be repaid back to the agency.
f. All paid expense claims will be maintained by the Finance Department for verification and audit purposes for a minimum of 7 years.
g. All employee expense claim reimbursements will be made in a manual cheque format signed and approved by the Executive Director.
h. Under no circumstances will expense reimbursement payments be made through payroll deposit.
i. A Board member authorized by the Board to so do will approve the reimbursements of the expenses of the Executive Director.
j. All approvers are prohibited from approving their own expenses.
k. Approvers will only approve expenses that are necessarily incurred in the performance of organization business and only for claims that include all appropriate documentation.
l. This policy will be posted on VITA’s Website and accessible to the public.
a. All travel within Ontario requires prior approval from a Director or designate.
b. Travel outside Ontario, but within Canada, must be approved by both, the Director responsible for the budget being used to fund the travel in order to enable an employee to visit another service provider or to attend training or a conference, and the Executive Director.
c. All International travel (outside Canada) must be pre-approved by the Executive Director.
d. Reimbursement of meal cost must not include the reimbursement for any costs associated with alcoholic beverages, and alcohol must not be consumed when employees are on duty except as explicitly approved by the Executive Director or designate.
e. When attending a conference, workshop, training session, seminar etc. VITA will not reimburse any meal expenses.
f. VITA employees who are supporting members on an outing to create a dining experience for the supported individuals, will be reimbursed for meal expenses as outlined below:
i. Breakfast - $7.50
ii. Snacks/coffee - $3.50
iii. Lunch - $11.00
iv. Dinner - $18.00*
g. It is VITA’s policy to ensure that all member outings per program are monitored as well as the frequency of the outings, the destinations chosen and the staff supporting the members.
Personal Vehicle Mileage Expensesa. Employees eligible to use their personal vehicle on approved agency business shall complete an Expense Claim Form, have their immediate Director approve and submit to the Finance Department at the end of each month end period.
b. All mileage expenses will be reimbursed at the rate approved by the Executive Director, which is subject to change over time.
c. VITA will not reimburse mileage expenses to and from work.
d. If VITA employees use their personal vehicles in the course of work duty, the employee’s first and last travel destinations will not be reimbursed, as these mileages are considered to and from work mileage calculations. However, if an employee makes multiple travel destinations during the course of their work duties for example travels from one VITA program to another etc, the mileage accrued throughout the day minus the first and last travel destinations will be reimbursed.
e. VITA will not reimburse expenses associated with repairs or damages to personal vehicles, oil changes, routine maintenance, traffic violations, parking tickets, personal automobile insurance etc., during travel or while on duty.
f. At the discretion of the Executive Director or designate, an employee may be reimbursed for expenses incurred for road, ferry, or bridge tolls if there was no reasonable alternative route that an employee could have taken or there was a need to get from one location to another in the shortest time possible.
g. Employee may incur parking fee when using their personal vehicles in the course of work. VITA will reimburse the parking fee only if an explanation of the parking is provided on the Expense Claim Form, along with the original parking receipt attached and approved by a Director or designate.
h. In order to be eligible for mileage expense reimbursement as outlined in this policy, an employee must complete an Expense Claim Form and clearly indicate the number of kilometers traveled, the destination(s), and the purpose for the travel. Incomplete Expense Claim Forms will not be processed.
Employees may request a cash advance from the Finance Department in order to pay for expenses in advance of purchasing them. All cash advances must be accompanied with a PO (Purchase Order) and must be pre-approved by a Director or Executive Director. Itemized original receipts of expenses must be submitted to the Finance Department to clear the cash advance. In the event that the cash advance is not reconciled with the Finance Department within (10) business days, the outstanding cash advance payment made to the employee will be deducted from payroll.
“Hospitality” is defined as the provision of food, beverages (including alcoholic beverages), accommodation, transportation, or other amenities at public expense to persons who are not engaged in work for VITA where there is benefit to VITA for such hospitality.
a. VITA will ensure that hospitality is provided in an economical, consistent and appropriate manner that facilitates the agency’s business or is desirable as a matter of courtesy.
b. Hospitality may be extended to cover the expenses of professionals coming to VITA from a distance, to cover the expenses of guests visiting VITA in an official capacity, to cover the cost of hosting conferences and interagency functions and to facilitate interactions with or reward volunteers, donors and business partners (business partners from either public or private sector).
c. VITA will ensure that hospitality expenditures are kept modest and will be consistent with the status of the guest(s), the number of persons attending, and the business purpose to be achieved.
d. All hospitality expenses will be recorded, documented and maintained in the Finance Department for a minimum of 7 years.
e. VITA will ensure to record and document the information pertaining to the purpose of the hospitality, the form of hospitality, the cost, name and location of the establishment, number of attendees, names of the individuals entertained and their titles/company name, and the name of the member of VITA management approving the expenditures.
f. Only under the discretion and approval of the Executive Director will alcoholic beverages be provided.
g. VITA will ensure that whenever alcohol is provided, it will be provided in a responsible manner, e.g. food will be severed when alcohol is available and that taxi chits will be made available.
Expenses for Consultants and Other Contractors
VITA will abide to the Broader Public Sector Expenses Directive issued by the Government of Ontario’s Management Board of Cabinet, and ensure that the following expenses for consultants and other contractors are not reimbursed under any circumstances:
- Meals, snacks and beverages.
- Laundry or dry cleaning.
- Valet services.
- Dependant care.
- Home management.
- Personal telephone calls.
VITA will ensure that consultants and other contractor’s reimbursements for allowable expenses can be claimed and reimbursed only when the contract specifically provides for it.
VITA’s Expense Claim & Mileage Form.Read Less
VITA is committed to sustaining a positive relationship with our members and their substitute decision makers. VITA encourages open communication with all levels of the organization. VITA also recognizes that our organization and our staff, as well as our members and their family are expected to treat all persons with dignity and respect. Discriminatory, hateful, derogatory or hurtful language towards anyone employed, contracted or supported by VITA will not be tolerated. VITA reserves the right to limit the access of any family member who in our opinion poses a threat or difficult working environment to our staff as a result of their conduct or actions.
The formal complaint procedure is intended to ensure that all complaints are handled fairly, promptly, consistently and, wherever possible, resolved to the complainant's satisfaction. The purpose of this policy is also to ensure that the complainant and respondent will not be victimized or discriminated against for taking part in the complaint procedure process as outlined in this policy.
VITA’s responsibility is to:
Acknowledge the formal complaint in writing.
Respond within a stated period of time as stated in this policy.
Deal reasonably and sensitively with the complaint.
Take immediate and appropriate action.
A complainant's responsibility is to:
Raise concerns promptly and directly with a VITA direct care staff first.
Explain the problem as clearly and as fully as possible, including any action taken to date.
Allow VITA a reasonable time to deal with the matter as stated in this policy.
Recognize that some circumstances may be beyond VITA’s control.
All members and families have the right to appeal against any action or decision made in the provision of services and supports. We encourage all families and members to speak directly to staff involved in their support plan to resolve all issues. Should issues not be resolved with the direct care staff, VITA has established the following process in regards to handling and resolving complaints.
Step 1: (Discussion with the Program Supervisor)
The member or family is to discuss the complaint with the specific program supervisor. The resolution will be documented by the supervisor and a copy provided to both the member or substitute decision maker and to the Director of Programs.
Step 2: (Discussion with the Program Director)
Should the issue remain unresolved, the member or family should contact the Director of Programs. Ideally bring their complaint in writing if possible.
If a phone call or email does not resolve the situation a meeting involving as appropriate, the staff, supervisor and Director of Programs along with the member or their substitute decision maker will be scheduled. Such meetings must occur no later than 1 month following the initial complaint.
Step 3: (Discussion with the Executive Director)
If the complaint remains unresolved, the member or substitute decision maker may request a meeting with the Executive Director. Ideally, the member or substitute decision maker will provide in writing the reason for their complaint prior to the meeting. The member or substitute decision maker will contact the Executive Assistant to provide the reason for the meeting and to schedule a date to discuss the matter.
If a phone call or email does not resolve the situation a meeting involving the Executive Director along with other employees as appropriate, the member or their substitute decision maker will be scheduled. Such meetings must occur no later than 1 month following the initial complaint submitted to the Executive Director.
Based on the nature of the resolution, the meeting will be documented and resolution of the complaint forwarded in writing to the member or their substitute decision maker.
Step 4: (Board of Directors)
All operational matters are the responsibility of the Executive Director. Should the member or the substitute decision maker have a complaint regarding the actions of the Executive Director that are in violations of the agency policies or are not operational in nature, a formal complaint can be made to the Board of Directors.
The member or substitute decision maker must prepare a written document outlining the nature of the complaint specific to the Executive Director and non operational matters. The letter should be addressed to the President of the Board. The Board of Directors will review the correspondence and if satisfied that the decision and actions taken by management and the Executive Director were within their responsibilities and operational in nature, the matter will not be further reviewed by the Board and considered final.
At the sole discretion of the Board, they may choose to meet with the complainant to review the matter further. Should the matter not be operational the Executive Assistant will arrange for a meeting between the complainant and Board representation as the Board determines appropriate.
Correspondence to the Board should be addressed VITA Board President and sent to 4301 Weston Rd., Toronto, ON. M9L 2Y3.
Step 5: (Government and funding bodies)
Families and substitute decision makers not satisfied with the resolution provided by the organization have the right to complain or take their action beyond the organization such as to government and funding bodies (Ministry of Community and Social Services).
At the request of any member or substitute decision maker, the contact information for ministry staff will be provided.
Except in exceptional circumstances, every attempt will be made to ensure that both the complainant and VITA maintain confidentiality. However, the circumstances giving rise to the complaint may be such that it may not be possible to maintain confidentiality. Should this be the case, the situation will be explained to the complainant.
VITA’s Senior Management team and the Board of Directors will conduct an evaluation of this policy on an annual basis.