Alberta’s Occupational Health and Safety Code requires every employer to have a harassment prevention plan. Most small and mid-sized organizations don’t have one, and one of the biggest misconceptions we see is the belief that workplace harassment begins when someone files a complaint. By the time a formal complaint lands on a leader’s desk, the actual problem has usually been developing for months, sometimes years. The complaint is rarely the beginning of the story. It’s the moment the story becomes impossible to ignore.
Organizations don’t wake up one day with a harassment problem. What they usually have is a culture problem, a leadership problem, or a conflict problem that was never addressed early, and eventually those issues show up wearing a different label. Alberta’s legal framework doesn’t leave room for a reactive posture. The obligations are specific, they’re codified in the OHS Code, and employers who haven’t built the required structure before a complaint is filed are operating at a disadvantage from day one.
What Is Workplace Harassment? The Definition Under Alberta Law
Workplace harassment is defined under Alberta’s Occupational Health and Safety Act as any single incident or repeated conduct that a person knows or reasonably ought to know would cause a worker to be humiliated or intimidated. The definition is broader than most employers expect. It includes conduct from supervisors, coworkers, clients, and customers. It covers written and electronic communications as well as in-person interactions, and it applies regardless of whether the person engaging in the conduct intended to cause harm.
Most leaders picture harassment as the extreme cases: yelling, threats, discrimination, sexual misconduct. Those situations exist, but many of the complaints we see are far more subtle. A manager who regularly humiliates people in meetings. A leader who dismisses one employee’s contributions while praising everyone else’s. A coworker who repeatedly excludes someone from information and conversations. A workplace where sarcasm has become a management style. Individually, these behaviours get dismissed as personality or friction. Collectively, they create a work environment people dread, built from a hundred smaller moments rather than one major incident. The legal test asks whether a reasonable person in the same circumstances would experience the conduct as humiliating or intimidating, regardless of what the person engaging in it believed was acceptable.
The Four Types of Workplace Harassment
Understanding the forms workplace harassment can take is the foundation for building policies that address the full range of conduct an employer may need to respond to.
Personal harassment involves conduct that demeans, belittles, or targets an individual in a way that creates a hostile work environment, without connecting to a legally protected characteristic. It is the most common form reported in small and mid-sized organizations and often the least clearly defined in employer policies. Discrimination-based harassment targets an individual because of a protected characteristic under Alberta’s Human Rights Act, including race, gender, sexual orientation, religion, age, and disability. It carries exposure under human rights legislation in addition to OHS obligations, and mishandling it can result in complaints before the Alberta Human Rights Commission.
Sexual harassment covers unwelcome sexual advances, requests for sexual favours, and any verbal or physical conduct of a sexual nature that affects employment conditions or creates a hostile environment. Both the human rights and OHS frameworks apply, and the consequences of mishandled complaints in this category are significant. Psychological harassment, sometimes called workplace bullying, involves repeated conduct designed to degrade, intimidate, or isolate someone, including the systematic undermining of a person’s professional reputation or relationships. It is among the hardest forms to identify and document, and among the most damaging to culture when left unaddressed.
A well-designed harassment prevention policy addresses all four categories explicitly, with enough specificity that employees and supervisors can recognize the conduct it exists to prevent.
The Warning Signs Nobody Recognized
When we talk to leaders after a complaint has been filed, they’re often shocked, and it isn’t because they’re bad leaders. They say things like “nobody ever told me there was an issue” or “this came out of nowhere.” When we dig deeper, a different picture usually emerges. The employee raised concerns informally. Coworkers noticed tension. A manager saw behaviour that made them uncomfortable and didn’t address it. People started avoiding meetings, turnover crept up, someone stopped participating the way they used to. The warning signs were there; the organization just didn’t recognize them as warning signs. Most harassment complaints don’t come out of nowhere. They come from somewhere that nobody paid enough attention to.
We’ve also learned to be cautious when organizations describe themselves as one big family. Sometimes that’s true and it’s wonderful. Sometimes it means accountability has quietly disappeared. Families excuse things, protect people, avoid difficult conversations, and give long-tenured or high-performing individuals a pass. We’ve seen organizations tolerate years of inappropriate behaviour because the person involved was considered valuable or hard to replace. Everyone knew it was happening and nobody addressed it. When a complaint finally arrived, leadership acted surprised. The real surprise was that it took so long.
What Alberta’s OHS Code Requires Employers to Have in Place
Part 1 of the Alberta Occupational Health and Safety Code, as updated through Bill 30 (An Act to Protect the Health and Well-being of Working Albertans), requires employers to create and maintain a harassment prevention plan. The plan must include a definition of harassment consistent with the OHS Act, a statement of employee rights and employer responsibilities, a procedure for reporting and investigating complaints, and a process for informing affected workers of the investigation’s outcome.
The Code also requires that workers be informed of the plan and understand its contents. A policy filed in a binder that employees have never seen does not meet the standard; awareness and accessibility are part of the legal requirement. These obligations apply to all employers covered by the OHS Act regardless of size. There is no small business exemption.
It’s tempting to file all of this under compliance obligations, another policy and another training session. But the legislation is solving a practical business problem. It asks whether employees know how to raise concerns, whether managers know what to do when concerns are raised, whether a process exists, and whether the organization can demonstrate that concerns are taken seriously. Those are leadership questions as much as legal ones, and organizations that can’t answer them clearly are vulnerable long before a complaint is filed.
What a Compliant Harassment Prevention Plan Actually Includes
A plan that holds up to scrutiny contains components many organizations currently lack. The definitions must accurately reflect the legal standard under the OHS Act and, where relevant, the Human Rights Act, rather than a simplified summary that omits protected categories or softens the statutory language. A policy that defines harassment too narrowly leaves whole categories of conduct unaddressed.
The reporting procedure must be accessible and clearly communicated, and it must be designed so employees can raise concerns without going through the person they’re reporting about. This is a structural failure in many smaller organizations, where the only channel runs through a single senior leader or the subject of the complaint themselves. The investigation procedure is where most plans fall short in practice: a compliant process specifies timelines, defines roles, establishes confidentiality protections, sets a clear standard for assessing the complaint, includes outcome communication to both parties, and identifies when an internal investigation is appropriate versus when an independent external investigator should be engaged. Documentation standards, a consequence framework, and an explicit anti-retaliation provision complete the structure.
One caution from experience: the organizations that struggle most with harassment usually don’t have a policy problem. They have a leadership problem. Most already have a policy sitting in a handbook that someone signed during onboarding. Policies don’t create culture; people do. We’ve seen organizations with beautiful policies and terrible workplace behaviour, and organizations with fairly basic policies and exceptional cultures. The difference was leadership, not paperwork.
How to Prevent Workplace Harassment
Prevention is more than a policy document. It’s the combination of clear standards, regular communication, trained supervisors, and a culture where employees believe concerns will be taken seriously and handled fairly.
Supervisor training is the most direct prevention lever available. Supervisors who understand what harassment looks like in their specific workplace, including the subtler forms that erode an environment over time, can intervene early, and early intervention is less disruptive, less costly, and far less damaging than a full investigation after the fact. Regular communication reinforces the standard: employees who heard about harassment prevention once, during onboarding years ago, are poorly positioned to recognize conduct or report concerns. Organizations that build harassment awareness into regular leadership conversations and annual training make the standard normal rather than exceptional.
The healthiest organizations we work with aren’t the ones that never receive complaints. They’re the ones where concerns surface early, employees trust the process, managers know how to respond, and leaders don’t panic when issues arise. In unhealthy organizations, concerns stay underground until they explode. In healthy ones, they come to the surface while they’re still manageable. That is what prevention actually looks like: problems addressed before they become formal investigations, not the absence of problems.
Daeco’s approach to harassment prevention includes developing the OHS-compliant prevention plan, delivering harassment awareness training for employees and supervisors, and designing an internal reporting process that employees will actually use. We also conduct harassment prevention assessments with Alberta employers, structured conversations with leadership and staff that identify where gaps exist before a complaint exposes them.
When a Complaint Is Filed: The Employer’s Investigation Obligation
When a harassment complaint is received, the employer’s obligation to investigate is triggered. Under the OHS Act, an employer who becomes aware of a complaint must investigate promptly and in a manner appropriate to the circumstances, and that phrase carries significant weight. A complaint alleging a pattern of harassment by a senior leader cannot be investigated by that leader’s peer or direct report. A complaint serious enough to engage human rights legislation may need an independent third party who can demonstrate neutrality. A complaint that is received and quietly set aside is the single greatest exposure point for an employer; inaction is not a neutral choice under Alberta law.
The most common mistake we see when a complaint arrives is leaders immediately trying to determine who’s right. The first question should be whether you have a process. Once leaders start picking sides before gathering information, the investigation is compromised and everyone loses trust in it: the complainant, the respondent, and the witnesses. The organization now has two problems, the issue itself and the process used to address it. The complaint is also usually not the biggest risk on the table. The bigger risk is what it reveals about whether concerns were addressed early, whether expectations were clear, whether managers were trained, and whether accountability exists. The complaint is the flashlight. The real issue is whatever the flashlight uncovers.
Daeco supports Alberta employers through workplace investigations when complaints are filed. Our role is to ensure the process is procedurally consistent, thoroughly documented, and designed to produce a conclusion that is defensible to the parties involved and, if the matter proceeds further, to an external reviewer or tribunal.
Frequently Asked Questions
What is workplace harassment under Alberta law?
Under Alberta’s Occupational Health and Safety Act, workplace harassment is any single incident or repeated conduct that a person knows or reasonably ought to know would cause a worker to be humiliated or intimidated. It includes conduct by supervisors, coworkers, clients, and customers, and applies to in-person and written or electronic communications.
What are the four types of workplace harassment?
The four main types are personal harassment (conduct that demeans or creates a hostile environment without connecting to a protected characteristic), discrimination-based harassment (conduct targeting a protected characteristic under Alberta’s Human Rights Act), sexual harassment (unwelcome conduct of a sexual nature affecting employment conditions), and psychological harassment (repeated conduct designed to degrade, intimidate, or isolate an individual).
Is a harassment prevention plan required in Alberta?
Yes. Alberta’s Occupational Health and Safety Code requires all employers covered by the OHS Act to have a harassment prevention plan. There is no exemption based on organization size.
What must an employer do when a harassment complaint is filed in Alberta?
An employer who becomes aware of a harassment complaint must investigate promptly and in a manner appropriate to the circumstances. The investigation must be impartial, documented, and result in an outcome communicated to both parties. Where internal investigation isn’t appropriate, an independent external investigator should be engaged.
A Note from the Founder
I’ve seen organizations receive a harassment complaint and treat it primarily as a legal risk to be managed rather than a situation requiring genuine process. That approach consistently produces worse outcomes for the complainant, the respondent, and the employer. The question I’d encourage every leader to sit with is this: if someone in your organization experienced harassment tomorrow, would they know exactly who to talk to, and would they trust the process enough to actually use it? Most organizations can answer the first question. Far fewer can confidently answer the second. Prevention is the right approach ethically, and it’s also the operationally sound one.
— Elizabeth Disman, Founder, Daeco HR Consulting
If your organization does not have a harassment prevention plan that meets Alberta’s OHS requirements, or if you have received a complaint and need support with the investigation process, book a consultation with Daeco HR Consulting. We work with employers across Edmonton, Alberta, and Western Canada to build harassment prevention programs that are compliant, practical, and actually used.