Policy Statement

To foster a positive relationship with the community and its stakeholders, The Lighthouse is committed to maintaining a complaints policy that provides a fair, accessible and timely process for Complainants to submit Complaints concerning their interactions with The Lighthouse for review, investigation, resolution and determination.

Definitions

“Board Committee” means a committee of the Board of Directors of The Lighthouse.

“Board” or “Board of Directors” means the Board of Directors of The Lighthouse.

“Chair” means the Chair of the Board of Directors.

“Complaint” means a complaint submitted by a Complainant in accordance with this Policy for review and investigation by The Lighthouse concerning any aspect of The Lighthouse, including the policies and activities of The Lighthouse and the conduct of its Employees, Directors, volunteers and contractors.

“Complainant” means an individual who has had a direct interaction with The Lighthouse and has submitted a Complaint in accordance with this Policy.

“Decision” has the meaning set out in section 4(14).

“Director” means a director of The Lighthouse.

“Employee” means an employee of The Lighthouse.

“Executive Director” means the Executive Director of The Lighthouse.

“Frivolous and Vexatious” means a Complaint that has no merit in fact or law or was made without any reasonable ground.

“HR Policies” means The Lighthouse’s Human Resources Policies and Procedures.

“Investigation Committee” means the committee of directors appointed by the Chair in accordance with section 4(4) of this Policy.

“Investigator” means the external investigator appointed by the Chair or Executive Director in accordance with section 4(4) of this Policy.

“Policy” means this Complaints Policy.

“Respondent” means the individual who is the subject of a Complaint.

Roles and Responsibilities

• The Board of Directors shall be responsible for approving this Policy.
• The Executive Director shall be responsible for:

• developing, updating and submitting the Policy to the Board of Directors for approval;
• ensuring information on this Policy and how to file a Complaint is accessible on The Lighthouse website; and
• investigating and resolving Complaints as specified by this Policy.

(3)  The Chair will be responsible for investigating and resolving Complaints as specified by this Policy.

Complaints Process

• Complaints may be submitted to the Chair or Executive Director in writing. If the Complainant is incapable of submitting a Complaint in writing, the Complainant may submit their Complaint to the Chair or Executive Director, as applicable, verbally, in which case the Chair or Executive Director will document the Complaint.
• Within three (3) business days of receiving a Complaint, the Chair or Executive Director will notify the Complainant that the Complaint has been received and provide a copy of this Policy.
• The Chair will be responsible for investigating and resolving Complaints relating to the Executive Director, Directors, Board Committee members and the policies of the Board, while the Executive Director will be responsible for investigating and resolving Complaints relating to all other matters, including Complaints regarding volunteers and contractors of The Lighthouse.
• The Chair or Executive Director, as the case may be, may, when reasonably necessary, engage an external investigator (“Investigator“) or appoint a committee of up to three (3) Directors (“Investigation Committee“) to investigate and resolve any Complaint.
• Complaints and information included in the Complaints, including identifying information about the individuals involved, will be kept confidential and shall not be disclosed unless disclosure is necessary for the purposes of investigating or taking corrective action, allegations of criminal conduct are made or disclosure is otherwise required by law.
• Complaints may be dismissed summarily on written notice to the Complainant when the Complainant is not directly affected by or has no direct knowledge of the matters set out in the Complaint or when such matters are clearly frivolous and vexatious.
• If, after reviewing the Complaint and making further inquiries with the Complainant, it is determined that the Complaint can be resolved without an investigation, the matter may be resolved informally provided that the Complainant and Respondent, if any, agree with the resolution.
• Complaints concerning Employees will be addressed by The Lighthouse as an internal, matter in accordance with the HR Policies. Except for Complaints made by Employees regarding workplace harassment and workplace violence under section 4(9) of this Policy, the Complainant will not be entitled to receive disclosure of specific disciplinary measure that may have been taken against the Employees as a result of the Complaints.
• For Complaints made by Employees involving allegations of workplace harassment and workplace violence as described in the HR Policies:

• the Complaint will be submitted to the Executive Director provided that the Executive Director is not the alleged harasser or to the Chair if the Executive Director is the alleged harasser; and
• the Complainant and the alleged harasser will be informed in writing of the results of the investigation and of any corrective action that has been taken or will be taken as a result of the investigation.
• When a Complaint is made against a Respondent, the Respondent will be notified of the Complaint and provided with a copy or summary of the Complaint and a copy of this Policy.
• The Complainant and Respondent, if any, will be notified in writing of the decision to investigate or not to investigate a Complaint.
• The investigation will be carried out in an impartial manner with the goal of obtaining and assessing all available facts, information and evidence relevant to the allegations made in a Complaint.
• Prior to completing the investigation, the Chair, Executive Director, Investigator or Investigation Committee, as applicable, will provide the Complainant and Respondent with (a) a summary of their proposed findings and recommendations and (b) an adequate opportunity to respond.
• The Chair, Executive Director, Investigator or Investigation Committee, as the case may be, will strive to provide their decision (“Decision“) setting out their findings, recommendations and reasons within sixty (60) days after the Complaint was first submitted to the Chair or Executive Director. In the event that a Decision cannot be made within sixty (60) days, the Chair, Executive Director, Investigator or Investigation Committee, as applicable, will ensure that the Complainant and Respondent, if any, are updated on a regular basis on the status of the Complaint, and on not less than a monthly basis.
• The Decision shall be final.

Retention of Records and Reporting

• The Lighthouse will retain records relating to each Complaint for a minimum period of 7 years from the date of the Decision.
• Records relating to Complaints concerning Employees shall be retained by The Lighthouse in accordance with its internal human resources policies and practices.
• Subject to the confidentiality of the Complaints and information contained in the Complaints as set out in section 4(5) of this Policy, the Executive Director will report to the Board of the number of Complaints and status of those Complaints on an annual basis.

To submit a Complaint, please contact:

Anne Smith, Executive Director
asmith@lighthousegriefsupport.org
Business Phone (905) 337-2333 x 229
Cell (289) 772 8917

Date of Approval: March 2023