Abitibi River Forest Management Inc.
Harassment and Discrimination Policy

September 17, 2025


1. Purpose:

Abitibi River Forest Management Inc. (ARFMI) is committed to a work environment that is free from harassment or discrimination and supportive of the productivity, dignity and self-esteem of every individual. ARFMI complies with the requirements of the Ontario Human Rights Code, and will provide all individuals with equal access to employment opportunities and benefits.


2. Policy:

This Policy reinforces the fact that any form of harassment or discrimination is unacceptable and will not be tolerated. Any ARFMI Board Member or any shareholder representative engaged in the business of ARFMI, including meetings, who is found to have harassed or discriminated against another person will be subject to:

(a) the case of a Board Member, sanctions at the discretion of the Board of Directors, up to and including a motion for removal from the Board of Directors of ARFMI; or
(b) in the case of a shareholder representative, prohibition from further involvement with ARFMI, at the discretion of the Board.

This Policy outlines a complaint and investigation process for all Board Members and shareholder representatives who feel that they have been a victim of harassment or discrimination by any other employee, Board Member or shareholder representative.

Anyone behaving in a manner that contravenes the harassment or discrimination policy during a meeting being carried out to discuss the business of ARFMI will be asked to stand down. Should they continue to behave in an inappropriate manner, they will be asked to leave the meeting. Further discipline measures will be considered at the discretion of the ARFMI Board of Directors.


3. Definitions:

Harassment or discrimination means any unwelcome or objectionable conduct or comment relating to race, colour, ancestry, place of origin, political belief, religion, sex, sexual orientation, marital status, family status, physical or mental disability, age, or conviction of an offence unrelated to the person’s employment.

Conduct need not always be repeated or persistent to constitute harassment or discrimination. In some circumstances a single incident will suffice. Examples of illegal harassment could include but are not limited to:

a. remarks, questions, jokes, innuendo or taunting, which is unwelcome or offensive b. verbal abuse and threats
c. leering, staring or making gestures
d. display of pornographic, racist or other materials in the form of derogatory or demeaning pictures, graffiti, cartoons or sayings, which are offensive to members of a particular group
e. intimidation, physical threat or actual physical assault
f. unwanted physical contact such as touching, patting, pinching, hugging
g. sexual advances with actual or implied work related consequences
h. persistent sexual advances when it is known or ought to be known that such advances are unwelcome
i. the granting or withholding of any benefit or opportunity on the basis, in whole or in part, of one of the above personal characteristics.

Sexual Harassment is defined as unwelcome sexual attention such as sexual advances, requests for sexual favours or other verbal or physical behavior of a sexual nature that:

a. has the purpose or effect of creating an intimidating, hostile, or offensive work environment
b. has the purpose or effect of undermining work performance, work relationships or productivity

Harassment can occur even though there is no intent to harass. It is the effect of the behavior on the victim which determines whether harassment has occurred.

Finally, illegal harassment or discrimination includes any form of retaliation towards an individual because that person has made a complaint under this Policy.


4. Confidentiality:

All persons associated with a complaint of harassment must recognize the serious nature of such complaints and respect the sensitivity and confidentiality involved. ARFMI will maintain confidentiality with respect to those involved or the circumstances related to the complaint to the extent possible in light of ARFMI’s obligation to investigate and take action on the complaint.


5. Responsibilities:

ARFMI will:

a. investigate complaints in a discreet and expeditious manner and determine the appropriate response;
b. provide all parties to a complaint with a full and fair opportunity to be heard;
c. advise the complainant of the final disposition of the complaint.

All ARFMI Board Members and shareholder representatives have a responsibility to prevent and discourage harassment. These responsibilities include:

a. modeling appropriate behaviour;
b. encouraging Board Member and shareholder representatives to report harassment if it occurs and immediately inform ARFMI of any complaints received;
c. immediately report to the President or Secretary of the ARFMI Board of Directors any information or knowledge of conduct which may infringe this Policy;
d. endeavor to make Board Members or shareholder representatives aware of the Policy and encourage them to follow it.
e. Challenging anyone who is behaving in an inappropriate manner at an ARFMI Meeting.


6. Procedures:

Employees, Board Members and volunteers must have a clear understanding of what constitutes harassment and what their responsibilities are in regards to harassment. These responsibilities include:

a. knowing and following ARFMI’s policies and procedures
b. modeling appropriate behavior
c. telling the alleged harasser, where they feel able to do so, that their behavior is inappropriate. Employees, Board Members and volunteers, as the case may be, are encouraged to promptly make their discomfort and disapproval known to the alleged harasser. It is of great assistance to advise the alleged harasser that his/her conduct is unwelcome. Without clearly stating objections, some forms of conduct may be construed by the alleged harasser as acceptable.


7. Informal Complaint Resolution:

If the perceived harassment persists, or if director or shareholder representative is uncomfortable confronting the alleged harasser directly, the individual should inform the President or a Secretary of ARFMI.

That executive member may then discuss the allegation with the complainant and respondent with a view to reaching a solution. Discussions with witnesses may also occur. This process provides an opportunity to resolve relatively straightforward complaints in an expeditious manner.

If a resolution acceptable to both complainant and respondent is agreed upon, the issue will proceed no further. If no resolution is achieved the complainant may ask for formal complaint resolution.


8. Formal Complaint Resolution:

The formal complaint resolution procedure is:

a. the complainant shall prepare and maintain a written record of dates, times, nature of the behavior and witnesses (if any) and forward their written complaint to the designated ARFMI representative.
b. the designated ARFMI representative receiving the complaint will meet with the complainant and respondent separately to review the complaint and explain the investigation procedures.
c. the designated ARFMI representative will investigate the allegations, including interviewing any witnesses, and will determine whether the conduct constitutes harassment or discrimination as defined in the Policy.
d. The results of the investigation will be reported to the appropriate ARFMI officials, who will determine what steps shall be taken in response to the investigation.
e. any discipline or other sanction arising from the resolution of the complaint will be administered in accordance with this policy.
f. no Board Member or shareholder representative will be disciplined or otherwise suffer detrimental effects in the workplace as a result of making a good faith complaint under this Policy. However, the making of frivolous or vexatious complaints may be subject to:
i. in the case of a Board Member, sanction or removal by the Board of Directors; ii. in the case of a shareholder representative, a prohibition on further involvement with ARFMI.


9. Alternative Resolution:

Where a complaint is filed with an external body (i.e. Human Rights Commission or Police) internal procedures may be held in abeyance pending the disposition of the external complaint. However, it is strongly encouraged that there be serious attempts made to pursue resolution amongst the parties directly involved, through the process provided for under this Policy. This Policy is intended to facilitate early and fair resolution.


IT IS FURTHER RESOLVED:

That the Directors and Shareholders of the Corporation will review this Code of Conduct and Conflict of Interest Policy each year in preparation for the final quarterly meeting and that any proposed changes will be tabled at the last quarterly meeting of the year where the Policy will be annually re-endorsed by the Directors of the Corporation through a formal resolution.

THE FOREGOING RESOLUTIONS are hereby consented to by the Directors of the Corporation.