TORONTO SENIORS HOUSING CORPORATION (TSHC)

Social Media Policy

Policy Owner: Engagement & Communications Team
Approval: Board of Directors
First Approved: May 18, 2022
Effective Date:
Policy Statement

The Social Media Policy guides the approval and use of social media for official Toronto Seniors Housing Corporation purposes to ensure such use is consistent with the corporation’s mission, vision and values while upholding all relevant policies, legislation and the protection of privacy.

Scope

This policy applies to all employees, and all consultants or independent contractors acting on behalf of Toronto Seniors Housing Corporation who are posting content to or sharing information on social media channels, including but not limited to social networks (including Twitter, Facebook, YouTube, LinkedIn, SnapChat, TikTok, Reddit, Instagram, Tumblr, etc.), blogs, and online communities.

This policy is not intended to limit the ability of Toronto Seniors Housing Corporation employees who, in their private capacity, use social media. However, as social media is a public activity, this policy also outlines considerations for employees using social media for personal purposes.

Values

Toronto Seniors Housing Corporation recognizes that social media are important channels for serving our tenants, engaging partners in building vibrant communities, and for telling the story of how our work benefits tenants and the city as a whole.

All corporate Toronto Seniors Housing Corporation social media use must adhere to practices consistent with the corporation’s mission, vision, and values.

Standards

Toronto Seniors Housing Corporation considers online and social media channels to be comparable to other communications and service delivery channels.

Definitions

Content owner: The employee assigned the responsibility of maintaining, monitoring, and moderating an official social media channel.

Official purposes: Sanctioned social media communications hosted in Toronto Seniors Housing Corporation’s name, including on behalf of any Toronto Seniors Housing Corporation program, in support of a business objective or strategic priority of the corporation, where the communication is part of an approved communications plan.

Private Information: Any information regarding an identifiable individual, which may include, but not be limited to, the individual’s background, race, ethnicity, nationality, age, religion, political views, home address, tenant file, criminal record, social status, education or medical history.

Social Media: Online technologies and practices that people use to share opinions, insights, experiences, and perspectives. Social media can take many different forms, including social networking sites (e.g., Facebook, LinkedIn), microblogging (e.g., Twitter), user- generated content (e.g., TikTok, Snapchat, YouTube, Flickr, Instagram), blogging (e.g., WordPress, Tumblr, Reddit), and online forums including comment sections on websites.

Policy Details

Approval Process

Employees must obtain written approval to use social media for all Toronto Seniors Housing Corporation business purposes. This includes using social media to engage in online interactions and manage a channel to support a Toronto Seniors Housing Corporation program or initiative.

Responsible Use of Social Media for Business Purposes

When using social media for business purposes, employees should conduct themselves in a professional manner and uphold Toronto Seniors Housing Corporation’s mission, vision, and values. In addition to the guidelines outlined in the Social Media Procedure, content owners must adhere to the following:

• Social media activities and interactions must uphold the mission, vision, and values of the corporation.
• While conducting Toronto Seniors Housing Corporation business, employees should only use approved social media accounts set up specifically for official purposes or approved for business
• Content owners must make every reasonable effort to respond to concerns or questions directed to social media account(s) for which they are responsible.
• Because records on external social media platforms are not within the control of Toronto Seniors Housing Corporation, content owners must refrain from any posts that disclose Toronto Seniors Housing Corporation tenant, employee or other stakeholder personal information, including but not limited to address, phone number, account number, and reference numbers for work orders or other database reports.
• Exchanges must be redirected to Toronto Seniors Housing Corporation phone and/or email support channels whenever personal information is involved or discussions involve more details than the channel can accommodate.
• Personal information, including photographs or videos of identifiable individuals, must not be shared without express consent of Toronto Seniors Housing Corporation and the individual in the photograph or video.
• Posts that provide information that is already public or that seek public input are not considered business records and are permissible uses of social media.
• As many social media channels present accessibility barriers, whenever possible content owners should refrain from using social media channels as the sole avenue for sharing information. Whenever possible, content owners should make their best efforts to use social media channels that comply with Accessibility
• Any and all media requests or issues of concern must be directed to the Communications and Engagement Team immediately, as per the Media and Issues Protocol.
• Employees must comply with the terms and conditions of use that have been established by the social media service Provider.

Personal Use of Social Media

Toronto Seniors Housing Corporation acknowledges that its employees, in their private capacity, may use social media to share information and communicate with friends, family, co-workers, and members of the public.

Employees of Toronto Seniors Housing Corporation are encouraged to engage through social media in a way that supports the mission, vision, and values of the corporation.

Employees should be aware that, due to their role with Toronto Seniors Housing Corporation, any personal activities on social media could impact the reputation of the organization and/or the interests of our tenants.

Employees are reminded that even though they are using social media for personal purposes, policies and protocols such as the Code of Conduct Policy, the Computer, Internet and Email Use Policy, the Media and Issues Protocol and related policies apply to activities on social media.

Considerations for employees who use social media for personal purposes are included in the Social Media Procedures.

Terms of Use

All Toronto Seniors Housing Corporation social media channels must post and abide by the Terms of Use, which are contained in the Social Media Procedure and posted on the corporation’s external website.

Compliance and Monitoring

Toronto Seniors Housing Corporation reserves the right to monitor content posted on social media channels and to modify or remove any content that it deems, in its sole discretion, to be in contravention of Toronto Seniors Housing Corporation’s policies or guidelines or relevant provincial and federal legislation, or that could be detrimental to the corporation’s mission, vision, and values.

Toronto Seniors Housing Corporation reserves the right to take appropriate action to any incident on social media or non-adherence to this policy, which could include:

• Issuing a correction, apology, or other response;
• Deleting a comment or post;
• Decommissioning a social media account;
• Disciplinary action up to and including dismissal, in accordance with the collective agreement where relevant;
• Pursuing legal action where appropriate;
• Revoking social media access rights for an employee or employee(s);
• Alerting senior management and/or the Board of Directors;
• Developing recommendations to prevent similar incidents from re-occuring.

Governing and Applicable Legislation

• Municipal Freedom of Information and Protection of Privacy Act
• Ontario Human Rights Code
• Canada Copyright Act

Related Policies and Procedures

• Employee Code of Conduct Policy
• Media and Issues Protocol
• Computer, Internet and Email Policy
• Workplace Violence and Workplace Harassment Policy
• Records Management Policy
• Social Media Procedure

Commencement and Review

Next Scheduled Review Date:

The proposed review period for this policy is every two years.

Toronto Seniors Housing Corporation (TSHC)

Elections Policy

Policy Sponsor: Director, Engagement, Partnerships, and Communications

Approver: Board of Directors

Initial Approval Date: May 18, 2022

Date of Last Revision, if applicable: N/A

Effective Date: June 1, 2022

Policy Statement

Toronto Seniors Housing Corporation (TSHC) is committed to working with tenants, candidates, political parties, and public officials at all three levels of government to facilitate elections and election activities on TSHC-managed property, in accordance with applicable legislation, by-laws, and TSHC policies.

During municipal, provincial, and federal election campaigns, TSHC will:

• ensure tenants’ personal information is kept private and confidential, in accordance with applicable legislation and internal protocols
• ensure that TSHC resources are not used to promote or give advantage to any candidate, political party or registered third party
• ensure that inquiries from candidates, political parties, or their agents are managed by the Communications Team
• support employee participation in political activities by granting unpaid leave to those seeking election

Policy Objectives

The objectives of this policy are to:

• outline TSHC’s responsibilities during elections
• outline how TSHC resources can and cannot be used during election campaigns, and which requests can and cannot be accommodated
• guide the conduct of TSHC’s employees and Board members during election campaigns in compliance with applicable legislation, by-laws and TSHC policies
• guide the conduct of TSHC’s employees and Board members seeking political office

Scope

The Elections Policy (Policy) governs election-related activities on TSHC-managed property and the actions of TSHC’s employees and Board members related to elections.

The Policy applies to:

• municipal (including school board), provincial or federal elections, or by-elections and to questions on the ballot
• all TSHC employees, Board members, and tenants, including those running for political office
• TSHC resources, including, but not limited to, employees, events, facilities, funds, information, and infrastructure

Definitions

Campaign/Campaigning: any activity by or on behalf of a candidate, political party, registered third party or in support or opposition to a question on a ballot, meant to elicit support during the election period. Campaigning does not include the appearance of elected officials, other candidates or registered third parties at an event in their personal capacity without the display of any signage or graphic which identifies the individual as a candidate or registered third party and without the solicitation of votes.

Campaign Materials: Any advertising or promotional materials intended to influence persons to vote for or against a candidate, political party, or a question on a ballot. Materials may include literature, banners, posters, pictures, buttons, clothing, etc. Election materials also include materials in all media, including websites or social media.

Elected Official: An individual elected to the House of Commons, the Legislative Assembly of Ontario, Toronto City Council, or a school board.

Election: An election or by-election at the municipal, provincial, or federal level, or the submission of a question on a ballot to the electors.

Election Officials: Employees of Elections Canada, Elections Ontario, Toronto Elections, or their agents.

Election Period: The official campaign period of an election.

• For municipal elections, the election period commences on May 1 of an election year and ends on election day.
• For provincial and federal elections, the election period commences the day that the election writ is issued and ends on election day.
• For by-elections, the election period commences when the by-election is called and ends on election day.
• For a question on a ballot, the election period commences when the respective level of government passes legislation or a by-law to put a question to the electorate. It ends on election day.

Employee: Includes management and exempt employees, contract-managed employees, and all members of TSHC bargaining units.

Leadership Team (LT): Team of senior leaders responsible for the strategic management of the corporate and operational functions of TSHC.

Official Election Materials: Any materials provided to voters by Elections Canada, Elections Ontario, Toronto Elections, or their agents to facilitate voting.

Personal Information: As defined in the Municipal Freedom of Information and Protection of Privacy Act, includes recorded information about an identifiable individual.

Political Office: The elected offices of municipal, provincial, or federal government.

Question on a Ballot: Any question submitted to electors by the municipal, provincial, or federal government.

Registered Third Party: In relation to a municipal election, an individual, corporation, or trade union that is registered with the City Clerk, in accordance with the Municipal Elections Act, section 88.6, whose purpose is to promote, support, or oppose a candidate for office, or an issue on a question on a ballot, and is not under the direction of a candidate.

Toronto Seniors Housing Corporation (TSHC) Resources: Including, but not limited to, employees, funds, events, facilities, information, and infrastructure, as defined below:

• “Election Day” means the day on which an election is held. This is the day most people go to vote.
• “Events” means events funded or organized by TSHC, including events that may be jointly organized with tenants, community organizations, and/or external sponsors.
• “Facilities” means common areas or grounds of any facility which is managed by TSHC.
• “Information” means any information in the custody and control of TSHC, including databases that may be the repository of names, contact information, business records, financial information, personal information, or other identifiers compiled and used by TSHC employees to carry out TSHC business. This information is considered TSHC property, and in most cases, it is not known to the public and may be confidential. It must not be used or disclosed without proper authorization, and in accordance with the Municipal Freedom of Information and Protection of Privacy Act.
• “Infrastructure” means any physical or technological systems and equipment that support the operation of TSHC, including, but not limited to, fleet vehicles, computer networks, telecommunications systems, wireless equipment, mobile phones, computer hardware, software and peripherals, internet, and intranet.

Roles and Responsibilities

• Communications Team: As policy owner, the Communications Team is responsible for the administration of this policy. All issues with respect to this policy and guidelines should be directed to the Communications Team.
• Department Leads: Department Leads are responsible for the application of this policy and guidelines to TSHC resources, facilities, and employees they manage.
• TSHC Employees: Employees are responsible for understanding and applying the Elections Policy and guidelines and for seeking clarification and advice from Department Leads if required.

Policy Content

The Elections Policy provides detailed information in the following areas:

• election activities on TSHC-managed property
• election signs
• protection of tenant privacy
• election-related inquiries
• use of TSHC resources during an election campaign
• workplace conduct during an election campaign
• employees seeking political office

Election Activities on TSHC-Managed Property

TSHC employees must ensure that:

• election officials, candidates, and their agents provide proper identification and display that identification to gain access to TSHC-managed property for election-related work
• election officials, candidates, and their agents have reasonable access to TSHC-managed property to perform their duties in accordance with the Residential Tenancies Act

TSHC employees will not:

• discard or tamper with official election materials (e.g., voter registration, voter identification cards, polling location information, etc.) delivered to tenants by election officials or their agents
• discard or tamper with campaign materials (e.g., pamphlets, flyers, letters, etc.) delivered to tenants by candidates, political parties, registered third parties or their agents

Election Signs

The City of Toronto’s Municipal Code provides rules and regulations regarding election signage that candidates must observe for any election in the City of Toronto.

• Signs cannot be illuminated or attached to trees.
• Signs cannot be placed between the curb and the sidewalk.
• Signs cannot interfere with the safe operation of vehicular traffic or with the safety of pedestrians.
• Signs cannot be located adjacent to a voting place.
• Signs may only be erected with the consent of the tenant.
• Signs may be higher than two meters above ground level provided they are displayed indoors. They cannot be attached to the outside of a balcony or terrace.
• No person is allowed to deface or willfully cause damage to a lawfully erected election sign.

Election signs may be erected on TSHC-managed property subject to compliance with the City’s rules and the following conditions:

• Tenants are permitted to post election signs anywhere considered to be within their personal unit. This includes fenced-off yards and ground-level fences attached to their unit.
• Tenants are not permitted to post election signs on their balconies.
• Election signs cannot be posted in common areas.

TSHC employees are required to remove election signs from common or prohibited areas, or signs that do not comply with City rules.

Protection of Tenant Privacy

TSHC is committed to protecting personal information consistent with the principles outlined in the Municipal Freedom of Information and Protection of Privacy Act and the Housing Services Act. TSHC employees must not provide tenant lists or other personal information about tenants to election officials, candidates, political parties, registered third parties, or their agents.

Election-Related Inquiries

• All election-related inquiries to employees or Board members from political parties, candidates, registered third parties, and/or their agents must immediately be directed to the Communications Team. Employees should also inform their managers of the inquiry.
• TSHC will share information with candidates, political parties, and/or their agents provided it contains no confidential information or personal information about tenants.
• Information that is provided by TSHC to one candidate or political party during an election period will be provided to all others, either by posting the information online or through other means.
• Requests made by a candidate, political party, or registered third party for a personal meeting or tour with an Officer, Board member, Leadership Team member or other TSHC employee during an official election period will not be accommodated.

Use of Toronto Seniors Housing Corporation (TSHC) Resources

• Elected officials may attend TSHC events and/or events held at TSHC facilities in their capacity as elected officials; however, they may not solicit votes, display election signs, or distribute campaign material.
• Candidates, representatives of political parties, and registered third parties may attend TSHC events and/or events held at TSHC-managed facilities as private citizens but may not campaign while in attendance. They may not solicit votes, display election signs, or distribute campaign material.
• Once the writ is issued for Provincial or Federal elections, Members of Parliament (MPs) and Members of Provincial Parliament (MPPs) are no longer elected officials and should not be invited to attend TSHC events in their capacity as elected officials.
• TSHC cannot make a contribution including money, goods, and services to any candidate, political party, or registered third party.
• TSHC resources cannot be used to promote one candidate, political party, or registered third party over another during an election period.
• TSHC supports tenant engagement in elections. To facilitate this engagement, all-candidates meetings may be held at TSHC-managed facilities, where practicable, provided that all registered candidates are invited to attend.
• After August 1 in a municipal election year, TSHC will not reference the name of members of City Council in:
  • advertising and other communications materials paid for or distributed by TSHC
  • event signage, including banners and posters
  • media releases issued by the Communications Team
• If it is necessary to reference a specific member of City Council or the Mayor in TSHC communications or media materials after August 1 in a municipal election year, the generic term “Councillor Ward XX” or “Mayor of Toronto” must be used.
• TSHC communications materials, including websites or domain names funded or administered by TSHC, and social media, blogs, or other new media created and managed by TSHC employees, whether for internal or public distribution, must not:
  • profile (name or photograph), refer to, and/or identify any individual as a candidate, or any individual or entity as registered third party, in any election
  • profile any slogan or symbol associated with a candidate, political party, or registered third party during the election period
  • advocate for or against a particular candidate, political party, or ballot question position during an election period
• Photographic or video materials created by TSHC employees or with TSHC resources cannot be used in any campaign materials.
• TSHC’s logo cannot be used in any campaign material.

Workplace Conduct During an Election Campaign

TSHC recognizes the right of employees to participate in political and election activities balanced against the corporation’s legitimate interest in both being and appearing to be non-partisan.

TSHC employees are not permitted to:

• use or allow the use of TSHC resources for campaign activities. TSHC resources include, but are not limited to, employee time, as well as events, facilities, funds, information, and infrastructure.
• engage in campaign activities during working hours. Working hours do not include vacation time or time on leaves of absence.
• display election campaign items at work.
• attend campaign events or undertake campaign activities while in TSHC clothing.
• solicit funds for a candidate from co-workers, either at work or outside of work.

The Chief Executive Officer of TSHC and members of the Leadership Team are not permitted to campaign for a candidate or political party before or during municipal, provincial, and federal elections.

Employees Seeking Political Office

TSHC employees seeking to run for political office must first declare a potential conflict in writing to their Department Lead and receive authorization prior to filing their candidacy. The employee must provide written notice to their manager at least two weeks in advance of their intention to take unpaid leave.

• For municipal elections, the leave must start the next working day after the employee files their candidacy.
• For provincial and federal elections, the leave must start the next working day after the employee receives the nomination.

Conflict of Interest

• Employees on an approved leave of absence from TSHC remain employees of the organization and are bound by all TSHC policies.
• While campaigning, employees on political leave must clearly state at all times that the views they express are personal views, and not those of TSHC.

Salary and Benefits

• Political leave is unpaid, and benefits can be continued at the employee’s expense.
• For management and exempt employees, continuous service and vacation entitlement are not affected by a leave without pay, where the leave is for twenty (20) business days or less.
• Bargaining unit employees are subject to the provisions in their existing collective agreement.

Election to Political Office

• An employee who is elected to political office within the geographical boundaries of the City of Toronto must resign from TSHC.
• An employee who is elected to political office outside of the geographical boundaries of the City of Toronto must resign from TSHC if the political office will interfere with their ability to perform their regular duties, as determined by their Department Lead.
• The resignation must take effect no more than two weeks after the election and prior to the commencement of the term of office.

Rehiring

• TSHC has no obligation to rehire employees who have resigned their position to take political office. Rehiring would be subject to TSHC’s hiring policies.

Board Members Seeking Political Office

TSHC Tenant Directors (Board members) seeking political office should refer to the rules set out in the Board of Directors Conflict of Interest Policy.

Related Legislation, Regulations, and TSHC Policies:

Legislation and Regulations

• Federal Elections Act
• Election Act
• Municipal Elections Act
• City of Toronto Municipal Code
• Residential Tenancies Act
• Housing Services Act
• Municipal Freedom of Information and Protection of Privacy Act
• Personal Information Protection and Electronic Documents Act

TSHC Policies and Procedures:

• Board of Directors Conflict of Interest Policy
• Board of Directors Code of Ethics and Conduct Policy
• Employee Code of Conduct Policy
• Employee Conflict of Interest Policy
• Guidelines for Elections Policy
• Media and Issues Protocol
• Voluntary Leave without Pay Policy

Amendments (Revision History):

N/A

Next Scheduled Review Date: 2027

This policy will be reviewed once every 5 years.

Policy Contact

Manager, Communications and External Affairs

Appendices

Guidelines for Elections Policy

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Translation and Interpretation

Summary of Policy

This policy sets out Toronto Seniors Housing Corporation (TSHC)’s commitments to communicate to tenants in multiple languages to enable tenant participation and promote tenant communication.

Introduction

TSHC recognizes that the City of Toronto is made up of many peoples and cultures. TSHC is committed to providing an inclusive housing environment in which all individuals are equally valued and fairly treated.

TSHC recognizes that many tenants communicate in a language other than English. In addition to English, there are at least 13 commonly used languages to communicate in our communities. The Housing Services Act requires TSHC to provide translation and interpretation services for the French language where requested. TSHC provides translation/interpretation at the building, community and cross organizational level for at least 12 languages in addition to English and French.

This policy has been adapted from TCHC Translation and Interpretation Policy.

Purpose

The purpose of this policy is to enable tenant participation; maximize tenant understanding of matters affecting tenancy and their daily lives as tenants; provide clear direction to Toronto Seniors Housing Corporation staff regarding translation and interpretation; provide direction to other tenant facing translation and interpretation needs.

The policy helps to meet the goal of providing an inclusive housing and working environment, which is a commitment made in Toronto Seniors Housing Corporation’s policy on Human Rights, Harassment and Fair Access.

This policy focuses on both translation of materials and interpretation services to tenants.

Application of Policy

This policy applies to:

• Rent Geared to Income and Market Rent Tenants;
• Direct and Contract Managed Communities;
• TSHC Contracts for service in which tenant engagement is required.

Definition

For the purposes of this policy, the following definitions have been taken from applicable legislation:

• Translation is changing one written language into another written language.
• Interpretation is changing the spoken word into another spoken language and is an interactive

Principles

Tenants require access to information that affects: 

• the status of their tenancy in Toronto Seniors Housing Corporation,
• their daily lives as tenants,
• their ability to participate in decision-making processes that ultimately can affect their

Policy statement

TSHC will use translation and interpretation services to promote tenant understanding and engagement to enable full participation for tenants in TSHC issues and activities.

Language Preference

TSHC will develop a methodology to collect and analyze the language of preference for TSHC tenants; Translation will be provided based on the identified needs of the target audience of the communication, which may include:

• The top languages of a building;
• Identified languages of a specific group, e.g. tenant representatives;
• Regional Managers will review the language preferences in the communities on a regular basis, at a minimum during the annual business planning process and share information with Communications team;
• When TSHC receives written communication in a language other than English, TSHC will have this communication translated and reply in the language of the tenant’s choice;
• TSHC will ensure that a translation and/or interpretation strategy is incorporated into each communication plan and community engagement activity undertaken;
• TSHC will provide advance notice of meetings to ensure tenants requiring or requesting translation and/or interpretation services are able to do so in advance;
• Regional Managers will ensure that strategies for translation and interpretation are developed to meet the identified language preferences of tenant representatives;
• TSHC will provide interpreters at tenant meetings and other events where tenants and/or staff have identified the need for interpreters;
• Toronto Seniors Housing Corporation recognizes its obligation to provide communications regarding housing services in the French language as requested.

Translation of written communication

TSHC will normally translate the following types of written communication:

• Invitations to participate in consultation sessions, tenant election activities, and building meetings;
• Newsletters, information     notices      and      other communication where the primary audience is tenants;
• Tenant Policies and Procedures;
• Tenant handbooks or similar information materials;
• Building signage in each building’s top languages (e•g•, laundry room instructions, fire exit procedures).

Toronto Seniors Housing Corporation will translate materials that affect tenants as described above. This includes, but is not limited to, materials such as:

• Contracts, Leases, Legal Notices,
• Strategic plans

TSHC and Tenant Responsibilities

• Tenants will provide as much notice as possible, in advance of a meeting, to advise TSHC that they are requesting translation and/or interpretation services OR that they no longer require the requested translation and/or interpretation
• TSHC will make use of international symbols and drawings to improve the communication with all language
• Documents on corporation-wide issues will be translated into the languages that are needed.
• Toronto Seniors Housing Corporation staff will provide interpreter services for meetings or telephone conversations with individual tenants where tenancy issues are being discussed. Staff will also arrange for interpreter services where tenants are using the corporation’s complaints procedure.

Standards

• TSHC will develop and communicate to stakeholders a set of standards to be applied to translation and interpretation services;
• TSHC will develop a pool of approved translators and interpreters and make it available to all

Policy Review

This policy, and the costs associated with its usage, will be reviewed as part of the annual planning process.

Applicable Legislation and Reference Documents

The following legislation and reference documents apply:

• Tenant Protection Act, 1997;
• Housing Services Act, 2011;
• TSHC Community Management Plan (CMP);
• TSHC Human Rights, Harassment and Fair Access

Approvals

Approved by the TSHC Board of Directors, May 18, 2022.

Policy Contact

Strategic Communications & Engagement

TORONTO SENIORS HOUSING CORPORATION (TSHC)

INVESTMENT POLICY

Policy Owner: Finance

Approval By: Board of Directors

First approved: May 18, 2022

Effective Date: June 1, 2022

Policy Statement

The purpose of this policy is to establish investment principles and guidelines that are appropriate for the purposes of meeting the various capital, financial and other obligations of Toronto Seniors Housing Corporation (TSHC).

Scope

This policy is applicable to TSHC personnel who have been vested with the power and responsibility to transact and invest funds on behalf of the organization. This policy applies to all investments decisions and transactions.

Content

Investment decisions will prudently balance liquidity, risk, growth, and yield and produce a total return that will preserve the real purchasing power of the principal invested.

Cash that is surplus to TSHC’s current requirements may be invested in:

1. Government of Ontario or Canada Treasury Bills
2. Government of Ontario or Canada Bonds
3. Guaranteed Investment Certificates (GIC) issued by a Canadian Chartered

The maximum investment term for excess “in year” operating cash shall be for the period of up to one (1) year.

All investment transactions require the joint written approval of the Chief Executive Officer (CEO) and the Director of Finance.

Responsibilities

The CEO or designate and the Director of Finance have joint authority for transacting and investing funds on behalf of TSHC. The CEO designation of authority is to be in writing to the Director of Finance. The Director of Finance cannot designate his or her authority. The Director of Finance shall prepare a schedule of investments for presentation quarterly to the Audit and Finance and Risk Committee.

Review

The policy shall be reviewed every two years or earlier if deemed necessary by the Director of Finance and amendments shall be presented to the Audit and Finance and Risk Committee for recommendation to the Board of Directors.

Change History:

TORONTO SENIORS HOUSING CORPORATION (TSHC)

PROCUREMENT POLICY

Policy Owner: Finance

Type: Board Policy

Approval By: Board of Directors

First approved: May 18, 2022

Effective Date:

Last Reviewed:

Policy Summary

This policy guides employees with respect to procurement of goods, services and construction. Toronto Seniors Housing Corporation’s (TSHC) Procurement business cycle is a shared service that Toronto Community Housing Corporation (TCHC) performs on the behalf of TSHC and therefore TSHC will use the procurement procedures in place at TCHC for all TSHC related procurements.

Policy Statement

This Procurement Policy will promote ethical, legal, efficient, effective, professional, and accountable sourcing strategies. Toronto Seniors Housing will use fair, open, and transparent processes to make procurement decisions based on a “value for money” criterion.

“Value for Money” means that the selection of goods, services and construction will be based on an optimal combination of relevant factors beyond the price by leveraging the aggregate spend to achieve economies of scale, where possible. This includes such factors as:

• total cost of acquisition
• quality and fit-for-purpose issues
• product or service lead time and delivery schedule
• vendor performance
• product or service support
• environmental and sustainability issues
• support and maintenance considerations
• end-of-life disposal
• other corporate objectives

Scope

This policy applies to all planning, acquisition and management of goods, services and construction by all officers, directors, employees, agents and designated representatives of Toronto Seniors Housing.

This policy must be read in conjunction with the Procurement Procedures, Procurement Protocols, and Financial Signing Authorities.

Exceptions

This policy does not apply to purchases of the following goods and services:

1. Sale or purchase of real property
2. Goods or services intended for resale to the public
3. Goods or services from other public sector bodies or non-profit organizations
4. Health care services, including services provided by medical doctors, dentists, nurses and pharmacists
5. Utilities, including hydro and electricity
6. Anything covered by the Employee Expense Policy or the Tenant Expense Policy.

Guiding Principles

Effective procurement is a critical support function for public institutions as they responsibly manage public funds. The objective of this policy is to ensure that Toronto Seniors Housing conducts procurement processes that conform to the following principles:

1. Compliance with all applicable laws, regulations, by-laws, policies and trade treaties
2. Consistency with other Toronto Seniors Housing policies and procedures
3. Open, fair, and transparent procurement that affords equal access to all qualified vendors
4. Reciprocal non-discrimination and geographic neutrality with respect to Ontario’s trading partners and avoidance of preferences for local vendors
5. Achieving best value for Toronto Seniors Housing for the expenditure of public funds through consideration of the full range of procurement formats and the adoption of commercially reasonable business practices
6. Achieving maximum benefit for the residents of Toronto Seniors Housing
7. Effective balance between accountability and transparency and efficiency
8. Adherence to the highest standards of ethical conduct

Policy Details

Notification of Procurement Opportunities

Notification of public procurement opportunities shall be listed by Toronto Community Housing on their website and appropriate tendering websites and other media on behalf of TSHC.

Award Information

Final award notifications for all public competitions will be posted online by TCHC.

Unsolicited Bids

Toronto Seniors Housing will not accept or consider unsolicited bids with a procurement value of $100,000 or greater. Unsolicited bids with a procurement value of less than $100,000 may be considered on a case-by-case basis with approval of the CEO, but Toronto Seniors Housing is under no obligation to consider or accept any unsolicited bid.

Conflicts of Interest

Toronto Seniors Housing must ensure that it effectively manages internal and external conflicts of interest. All conflicts must be declared in writing to TSHC Procurement who will then notify the TCHC Procurement Unit.

Internal Conflict of Interest

Toronto Seniors Housing must ensure that the management of all procurement projects is free from internal conflicts of interest.

All participants in the Procurement Project (including all procurement staff, all involved members of the TSHC Business Unit and all members of the evaluation team) must ensure that there are no undeclared internal conflicts of interest.

The Toronto Seniors Housing Board of Directors and staff must not have any direct or indirect involvement in any Procurement Project or decision outside of the required approvals and procurement roles set out in these procedures.

External Conflict of Interest

In addition to ensuring that there are not internal conflicts of interest, Procurement Projects must also be free of external conflicts of interest. All vendors must be required to declare, as part of their Bid in a procurement process, that there are no conflicts of interest, or they must provide details of any actual or apparent conflicts of interest. The TCHC Procurement Unit must ensure that all procurement templates include appropriate conflict of interest language and declarations.

Where a vendor is retained to participate in the development of a Solicitation Document or the specifications for inclusion in a Solicitation Document, that vendor must not be allowed to submit a Bid or directly or indirectly participate in the submission of any Bid in response to that Solicitation Document. While this restriction shall be deemed to apply to all Toronto Seniors Housing Procurement Projects, it must be disclosed in the initial procurement process by which the vendor is retained.

Procurement Record Keeping

Proper documentation must be maintained for all stages of the Procurement Project.

Access to Information

The maintenance, release and management of all procurement records must be in accordance with Toronto Seniors Housing’s Records Retention Policy. Toronto Seniors Housing is subject to the Municipal Freedom of Information and Access to Information

Act. TSHC Procurement and TSHC Business Units in co-operation with Toronto Community Housing will be responsible for any requests for access to procurement-related documents.

Confidentiality

Toronto Seniors Housing must ensure that Bidder and vendor information submitted in confidence as part of a Procurement Project is adequately protected. The TCHC Procurement Unit, TSHC Procurement and TSHC Business Units must ensure that all Bids and contracts are kept in a secure location and only accessible by those individuals directly involved with the Procurement Project.

Procurement Review and Audits

Toronto Seniors Housing shall conduct regular reviews and audits of its procurement activities, procedures and practices to ascertain compliance with this Policy.

Policy Review

The Procurement Policy will be reviewed by TSHC Procurement and the TCHC Strategic Procurement Unit and assessed once every two years to ensure its goals are being met.

The Procurement Procedures will be reviewed and assessed once a year to ensure the integrity of each process and that they are promoting the Procurement Policy objectives.

Toronto Seniors Housing Corporation (TSHC)
Accessibility Policy

Policy Sponsor: Director, Strategy and Business Management

Approver: Board of Directors

Initial Approval Date: May 17, 2022

Effective Date: June 1, 2022

Organizational Statement of Commitment

Toronto Seniors Housing Corporation (TSHC) is committed to providing an inclusive environment to tenants and employees with disabilities in accordance with the core principles of accommodation, dignity, independence, integration and equal opportunity outlined in the Human Rights Code, R.S.O. 1990, c.H.19 and the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c.11, and the complimentary legislation of the Employment Standards Act, 2000, S.O. 2000, c.41, the Ontario Building Code, O. Reg. 332/12, and the Integrated Accessibility Standards, O. Reg.191/11.

Policy Statement

Toronto Seniors Housing Corporation recognizes the need to identify and remove barriers faced by people with disabilities and will achieve greater accessibility by aligning with a culture that recognizes the dignity and worth of every individual.​

This policy provides an overview of all of Toronto Seniors Housing Corporation’s policies, plans and programs as they relate to accessibility. While components of this policy are intended to address the corporation’s compliance with legislation, Toronto Seniors Housing Corporation’s commitment to accessibility extends beyond legislative compliance. As Toronto Seniors Housing Corporation continues to achieve accessible social housing and employment, this policy requires Toronto Seniors Housing Corporation staff to incorporate best practices in accessibility through all aspects of its business. Toronto Seniors Housing Corporation will engage and consult with stakeholders, tenants, and employees with disabilities in the development of its accessibility policies, plans, and programs.

Definitions

​​Accessible formats: ​Formats that are an alternative to standard formats and are accessible to people with disabilities. Accessible formats may include, but are not limited to, large print, recorded audio and electronic formats, braille and other formats usable by persons with disabilities.

​Communication supports: Supports that individuals with disabilities may need to access information. These include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

Disability: From the Ontario Human Rights Code, R.S.O. 1990, c. H. 19:

• any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness;
• a condition of mental impairment or developmental disability;
• a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoke language;
• a mental disorder; or
• an injury or disability for which benefits were claimed or received under the Workplace Safety and Insurance Act, 1997, S.O. 1997, c. 16 sche. A, or Ontario Disability Support Program.

​In addition, the definition of disability under the Ontario Human Rights Code, R.S.O. 1990, c. H. 19, may include but is not limited to:

• Acquired Brain Injury
• Deaf, deafened, hard-of-hearing
• Low vision or blind
• Chronic health conditions (cancer, epilepsy, heart disease, etc.)

Accessibility Lead: The member of the leadership team who has been designated as the lead for this policy and all related accessibility initiatives.

Toronto Seniors Housing Corporation staff: All Toronto Seniors Housing Corporation employees, whether full or part-time, temporary or permanent, including secondees. ​

Volunteers: Any individual who works for or on behalf of Toronto Seniors Housing Corporation on an unpaid basis, or for nominal consideration, including, but not limited to, volunteers, tenant volunteers, interns, and students.

Scope

This policy applies to all Toronto Seniors Housing Corporation staff, volunteers, and third party contractors who interact with tenants or staff on behalf of Toronto Seniors Housing Corporation.

​Core Principles

In keeping with our values of respect, inclusion, accountability and innovation, Toronto Seniors Housing Corporation will implement this policy in accordance with the following principles:

Dignity

Tenants and staff are treated in a respectful manner.

Independence

Services, opportunities, programs, and facilities for persons with disabilities will support their independence while respecting their right to safety and personal privacy. Service delivery will consider the nature of the service and alternative accommodation that may be required.

Equity/Equality of Outcome

Tenants and staff with disabilities will be provided the same access to our programs, services, opportunities, and facilities as all other tenants and staff.

Integration

Tenants and staff with disabilities will fully benefit from the same programs, services, opportunities, and facilities, in the same places and in the same or similar way as all other tenants and staff. An emphasis on inclusion will focus on eliminating barriers for people with disabilities.

Governance and Legislation

Toronto Seniors Housing Corporation will meet or exceed the following legislative requirements:​

Accessibility for Ontarians with Disabilities Act, 2005 (AODA)

The AODA came into effect in 2005. It permits the Ontario government to establish Accessibility Standards to remove or prevent barriers for Ontarians with disabilities by 2025. For details on Toronto Seniors Housing Corporation’s compliance with the AODA and associated legislation refer to the relevant policies as listed in the Policy Details.

Employment Standards Act, 2000 (ESA)

The ESA sets out the minimum standards for working in Ontario and defines the rights and responsibilities of employees and employers. Toronto Seniors Housing Corporation is committed to complying with the standards outlined in the ESA as they relate to accessibility and accommodation on the basis of disability.

Ontario Human Rights Code (OHRC)

The OHRC was enacted in 1990 and ensures the rights of all people to be treated equally and without discrimination based on race, colour, gender identity, sex, sexual orientation, disability, creed and age. Toronto Seniors Housing Corporation is committed to upholding the OHRC in its entirety.

Integrated Accessibility Standards (IASR)

The IASR was enacted under the AODA in 2011, with phased implementation requirements commencing January 1, 2012 through to January 1, 2021.
​The IASR addresses three specific areas of relevance to Toronto Seniors Housing Corporation: accessible employment practices; accessible information and communication supports; and design of the built environment. Provisions that guide staff in complying with the IASR can be found in a number of policies, programs and standards and are noted in the Policy Details below.

Toronto Seniors Housing Corporation tracks the implementation of the IASR in its multi-year Accessibility Plan. The plan is posted on Toronto Seniors Housing Corporation’s website and is made available in accessible formats upon request. The plan is updated on an ongoing basis and is fully reviewed every five years.

Ontario Building Code (OBC)

The OBC is a set of mandated building design and construction standards aimed at minimizing the risk to the health and safety of the occupants of a building and to provide for the barrier-free access to buildings. Toronto Seniors Housing Corporation follows the standards set out in the OBC in order to make sure that the design and construction of all new buildings, and changes and additions to existing buildings serve to increase accessibility for tenants and meet legislative requirements by 2025.

​Accessibility Focus Areas

Accessible Customer Service

Toronto Seniors Housing Corporation will develop best practices to provide accessible customer service in a respectful and transparent manner. The relevant policies and programs are summarized below and the details can be found in the documents themselves.

• Accessible Customer Service Policy: outlines our commitment to provide customer service that is inclusive, barrier free and meets the unique needs of persons with disabilities.
• Communication Standards/Accessible Formats and Communications Supports:outlines the standards that Toronto Seniors Housing Corporation follows in all communications to tenants. These standards include the Information and Communications Standards as outlined in the IASR.
• Human Rights, Harassment & Fair Access Policy:Includes proactive measures to eliminate harassment and discrimination in accommodation, employment, delivery of services, and in all other contract arrangements. It reflects the requirements of the OHRC and policies established by the City of Toronto.
• Self-Service Kiosk Standards:Toronto Seniors Housing Corporation will ensure accessibility for persons with disabilities when designing, procuring and acquiring self-service kiosks, as indicated in the IASR.
• Tenant Transfer Policy:formalizes Toronto Seniors Housing Corporation’s commitment to priority transfers of persons who have a medically documented need for accessible accommodation.
• Tenant Complaints Process:ensures that complaints are heard, the facts of the complaints are established, and where required, remedial actions are taken. The primary objective of this process is to outline a simple process which is accessible to all.

Accessible Homes

Toronto Seniors Housing Corporation will ensure that tenants with disabilities can live in units, buildings and communities that accommodate their needs. The relevant policies and programs are summarized here and the details can be found in the documents themselves.

• Accessibility in the Built Environment Policy:TSHC strives to treat all individuals in a manner that allows them to maintain their dignity and independence and is committed to providing an inclusive environment to tenants with disabilities as outlined in the Human Rights Code, the Accessibility for Ontarians with Disabilities Act, and the complimentary legislation of the Ontario Building Code, and the Integrated Accessibility Standards. As the buildings TSHC manages are owned by Toronto Community Housing Corporation (TCHC), TSHC uses the TCHC’s Build Standards to provide guidance as they apply to minor accessibility modifications that TSHC may make to tenants’ units. TSHC’s Accessibility Plan sets out TSHC’s policy on how we will achieve accessibility generally, as well as in the built environment.
• Accessibility Program: Capital Planning:TSHC participates in TCHC’s capital planning and implementation process for planned capital improvements.
• Accessibility Program: Tenant Request Unit Modifications:includes standards and a process for accessibility-related unit modifications based on tenant request and documented medical need.

Accessible Workplaces

Toronto Seniors Housing Corporation will ensure that employees with disabilities are accommodated in a respectful and transparent manner. The relevant policies and programs are summarized here and the details can be found in the documents themselves.

• Hiring Policy:Outlines Toronto Seniors Housing Corporation’s commitment to meeting its statutory obligations in the hiring process, and ensures that employment accommodation is provided to all candidates in accordance with the OHRC and the ESA.
• Human Rights, Harassment & Fair Access Policy:Includes proactive measures to eliminate harassment and discrimination in accommodation, employment, delivery of services, and in all other contract arrangements. It reflects the requirements of the OHRC and policies established by the City of Toronto.
• Individualized Workplace Emergency Response Information:Individualized workplace emergency response information will be prepared for employees with disabilities where the disability is such that the individualized information is necessary and Toronto Seniors Housing Corporation is aware of the need for accommodation due to the employee’s disability. This will be prepared as soon as practicable after Toronto Seniors Housing Corporation becomes aware of the need for accommodation due to the employee’s disability. A detailed process can be found as part of Toronto Seniors Housing Corporation’s Workplace Accommodation Policy.
• Workplace Accommodation Policy:Facilitates effective responses to accommodation issues that arise in the workplace and ensures Toronto Seniors Housing Corporation meets its duty to accommodate under the OHRC.

Supports for Policy Implementation

• Staff Training:Toronto Seniors Housing Corporation will ensure that accessibility training is provided to all employees and persons who participate in developing our policies.

The training will consist of requirements under the IASR; the parts of the OHRC that pertain to people with disabilities.

​The training will be appropriate to the duties of the person being trained and will be provided as soon as practicable. A record will be kept of the dates of the training and the number of individuals trained.

Toronto Seniors Housing Corporation will also provide training on an ongoing basis when changes are made to the policies and programs listed above, and to new employees as part of the on-boarding process.

• Tenant & Staff Engagement:Toronto Seniors Housing Corporation will consult and work with tenants with disabilities and stakeholders in the development of the above accessibility policies, plans, and programs. Toronto Seniors Housing Corporation will consult with appropriate stakeholders, which may include tenants with disabilities, tenant accessibility advocacy groups, experts in the field of accessibility, and Toronto Seniors Housing Corporation staff when undertaking formal reviews of this policy and any other Toronto Seniors Housing Corporation policies related to accessibility.
• Procuring Goods and Services:Toronto Seniors Housing Corporation’s Procurement Department shall incorporate accessibility criteria and features into its procurement process, procurement documents shall specify the desired accessibility standards to be met and the related submission requirements, except where it is not practical to do so. Where it is impractical to incorporate accessibility criteria and features into the procurement process, the Procurement Department will provide an explanation upon request. The Procurement Department will also ensure that all selected vendors, where applicable, comply with the AODA and its regulations when providing accessible goods and services to Toronto Seniors Housing Corporation.​

Compliance and Monitoring

Accessibility Reviews

All new or revised policies and procedures will be reviewed to ensure legislative compliance. When developing, revising and implementing Toronto Seniors Housing Corporation’s policies and strategies, authorized Toronto Seniors Housing Corporation staff will conduct an accessibility review. This review will consider and address accessibility, with a particular focus on reducing barriers faced by people with disabilities and ensuring the principles guiding this policy are upheld.

Reporting

The accessibility lead will report regularly to the leadership team. Accessibility is an integral component of Toronto Seniors Housing Corporation’s business, and metrics on accessibility improvements will be reported  regularly to the Toronto Seniors Housing Corporation Board of Directors and annually through the annual report.

Related Legislation, Regulations, and TSHC Policies:

• Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11
• Employment Standards Act, 2000, S.O. 2000, c. 41
• Human Rights Code, R.S.O. 1990, c. H. 19
• Integrated Accessibility Standards, O. Reg. 191/11
• ​Ontario Building Code, O. Reg. 332/12
• TSHC Accessible Customer Service Policy
• TSHC Hiring Policy
• TSHC Human Rights Policy – staff
• TSHC Human Rights, Harassment & Fair Access Policy – tenants
• TSHC Workplace Accommodation Policy

Amendments (Revision History):

NA

​Next Scheduled Review Date:

This policy will be reviewed once every five years.

Policy Contact

Director, Strategy and Business Management

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Parking Policy Statements For Tenants / Non-Tenants / Agencies and Contractors

1. Toronto Seniors Housing Corporation will only register and permit roadworthy vehicles that are properly licensed – has current license plates and validated by Ministry of Transportation, not including tractor trailers, boats, buses, cube vans, or where the Vehicle Weight or Reg. Gross Weight exceeds 3000 kg.
2. Currently Toronto Seniors Housing Corporation does not have the facilities to accommodate the charging of hybrid vehicles. Until such a time as technological advances make this possible, Toronto Seniors Housing Corporation will be unable to provide power sources for these vehicles.
3. All Tenants, Non-Tenants, and Commercial Tenants will be “assigned” a parking space(s) in underground garages, where applicable.
4. Tenants are permitted to register personal vehicle(s) which they drive for personal use.
5. Non-Tenant Parker can request to register multiple vehicles, up to a maximum of 2 vehicles, to share the use of one parking space. This option is only available in underground parking facilities and through TCH’s Commercial Business Unit.
6. All Toronto Seniors Housing Corporation affiliated organizations’ vehicles, that are marked and identified with a logo are permitted to park on Toronto Seniors Housing Corporation property(ies) 24 hours a day, 7 days a week.
7. “Vehicle On Duty” Signs are available for rent for placement on Agencies’ & Contractors’ vehicles dashboards that attend multiple Toronto Seniors Housing Corporation sites and have regular frequent business  activities  on  Toronto  Seniors  Housing Corporation property.
8. Other Agencies, Contractors, or individuals that do not have regular business activities or agreement with Toronto Seniors Housing Corporation are to be treated as visitors, and are to follow the Visitor Parking Procedure.
9. All persons who park in a visitor parking space at a Pay & Display parking location need to purchase Pay & Display ticket and adhere to the display instructions, including already registered contractors’, agencies’ and employees’ vehicles.
10. Visitor Parking Permits must be used by all persons who park in a visitor parking space at a non-Pay & Display location, and must be completed and displayed as per the conditions listed on the back of the permit. Permits can be obtained from the Regional office or Superintendent (as applicable), free of charge for up to a maximum of 9 permits per unit per month, or as set by Toronto Seniors Housing Corporation.
11. Commercial Tenants that request to have “designated” parking are required to pay the Non- Tenant Parking monthly rate plus cover the expense of required signage and installation fee as set by Toronto Seniors Housing The number of fobs or access cards to be given will be equal to the number of parking spaces paid for. Toronto Seniors Housing Corporation does not enforce any “designated” parking spaces.
12. Lost or stolen or non-returned Permits are subject to a replacement fee, set by Toronto Seniors Housing Corporation, based on Parking Permit type.
13. Toronto Community Housing Corporation on behalf of Toronto Seniors Housing Corporation has the authority to tag and tow vehicles parked on Toronto Seniors Housing Corporation property which are not authorized to do so at the owner’s expense.
14. Tenants or Non-Tenants who are in arrears in excess of one month rent will not be registered for any new Tenant or Non-Tenant parking permit until their outstanding account is addressed through payment or repayment agreement.

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Closed Circuit Television

Policy Owner

Approval

First Approved

Effective Date

Why Toronto Community Housing/Toronto Seniors Housing has this Policy:

Toronto Community Housing/Toronto Seniors Housing has decided that there may be the need for Closed Circuit Television (CCTV) systems in some of its buildings. CCTV may help provide Toronto Community Housing/Toronto Seniors Housing’s tenants, employees, visitors and properties with an increased perception of safety and security, along with other measures that the organization and the community may put in place. The use of CCTV in Toronto Community Housing/Toronto Seniors Housing communities may help to discourage people from committing crimes, and may help to identify people who commit crimes on Toronto Community Housing/Toronto Seniors Housing properties. Toronto Community Housing/Toronto Seniors Housing’s focus is to create safe, healthy communities and the use of CCTV equipment is one measure that may be used to assist with that goal.

Toronto Community Housing/Toronto Seniors Housing will keep control of and be responsible for the CCTV surveillance systems in its buildings. Toronto Community Housing/Toronto Seniors Housing recognizes that the use of CCTV systems must balance safety needs and a tenant’s reasonable expectation of privacy.

What does this Policy apply to?

This Policy applies to all surveillance systems, surveillance monitors and camera recording devices used for security purposes that have been or will be installed by Toronto Community Housing/Toronto Seniors Housing on its properties.

This Policy does not apply to the following CCTV surveillance systems: required by law or a court order or installed by third parties such as the police and commercial tenants.

What laws will Toronto Community Housing/Toronto Seniors Housing follow in using the CCTV system?

Toronto Community Housing/Toronto Seniors Housing will follow the applicable privacy sections of the Ontario Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) and will use the Information and Privacy Commissioner’s guidelines in its practices related to the collection, use, sharing, storage and disposal of any information received from CCTV systems.

How will Toronto Community Housing/Toronto Seniors Housing decide if a building needs CCTV?

Toronto Community Housing/Toronto Seniors Housing will balance an individual’s right to privacy and the need to ensure the safety and security of its communities. Toronto Community Housing/Toronto Seniors Housing will work with the community to determine whether a CCTV system is a tool that fits with the community’s safe and secure plan. The following factors may be considered as to whether to install a CCTV system in a particular community:

• What other ways of preventing crime have not worked, or what other ways of preventing crime are not possible;
• What reports or incidents of crime or significant safety concerns have been received by Toronto Community Housing/Toronto Seniors Housing;
• Consideration of how CCTV will affect people’s privacy, and any privacy issues raised by use of CCTV on its properties; and
• Consultations with people who are affected about whether Toronto Community Housing/Toronto Seniors Housing needs CCTV, including tenants, employees, and the Toronto Police Services.

Where will Toronto Community Housing/Toronto Seniors Housing place the CCTV System and Equipment?

CCTV Cameras

Toronto Community Housing/Toronto Seniors Housing may place CCTV cameras in public areas of Toronto Community Housing/Toronto Seniors Housing property. Toronto Community Housing/Toronto Seniors Housing will not place CCTV cameras anywhere that tenants, employees, and the public should reasonably expect privacy. For example, Toronto Community Housing/Toronto Seniors Housing will not place cameras directly in front of a tenant’s door, or in washrooms and change rooms.

CCTV Recording Equipment

Toronto Community Housing/Toronto Seniors Housing will make sure that access to the CCTV recording equipment is kept away from the public. The equipment will be in places that only a few people can get into, such as a locked room. Toronto Community Housing/Toronto Seniors Housing will also make sure that the only people who can access the CCTV cameras and other equipment are Community Housing Managers, contract Property Managers, Toronto Community Housing/Toronto Seniors Housing Community Safety Consultants, Toronto Community Housing/Toronto Seniors Housing Community Safety Officers, and any other Toronto Community Housing/Toronto Seniors Housing employee, contractor or representative with permission to do so.

Retention Period of a CCTV Record

The information recorded by the CCTV will be kept for a period of 3 days or such lesser period as permitted by the system. Toronto Community Housing/Toronto Seniors Housing may keep a record longer than the retention period only if it is identified prior to disposal as being needed as part of a criminal, safety or security investigation or for evidentiary purposes.

Storage, Record Identification and Logbook

All of the CCTV records that Toronto Community Housing/Toronto Seniors Housing stores will be kept in a locked room with the CCTV equipment. Stored CCTV records will be clearly labelled with the date as its identification. For Digital Video Recorders (DVRs) that store information directly on a hard drive, Toronto Community Housing/Toronto Seniors Housing will use the computer time and date stamp as the identification. For Video Cassette Recorders (VCRs) that store information on videotapes, a label will be affixed to the videotape with the date as its identification.

A logbook will be kept in the locked room where the CCTV system and recording equipment is stored. Those individuals approved to access the system, as identified under section 5 (B) above, must sign the logbook to show when they access the record, how they used it, and when and how it was destroyed. The logbook must include the name of the person who had permission to access the record.

Disposal

Toronto Community Housing/Toronto Seniors Housing will do everything reasonably possible to keep CCTV records safe, and to destroy records when they are no longer needed. Old recording storage devices will be destroyed according to the applicable disposal process to ensure that recorded personal information is erased prior to disposal, and cannot be retrieved or reconstructed. Depending on the type of recording and storage device, Toronto Community Housing/Toronto Seniors Housing will shred, burn or erase the record.

Restricted Access to CCTV system

Toronto Community Housing/Toronto Seniors Housing will make sure that only the individuals identified under section 5(B) above will have access to the CCTV records, and only those individuals will be allowed to authorize the removal of CCTV records out of storage.

Allowing the police to use the CCTV records

If the police need a CCTV record to help them investigate a crime, Toronto Community Housing/Toronto Seniors Housing will let them look at the record and take it with them. Toronto Community Housing/Toronto Seniors Housing will follow the rules set out in MFIPPA. Where appropriate, Toronto Community Housing/Toronto Seniors Housing may request the police to only use the CCTV record as evidence in a court proceeding. Before taking a record, police officers will be required to fill out a release form as provided in Appendix A.

Toronto Community Housing/Toronto Seniors Housing will ask the police to return or destroy the record when the police and courts are finished with it. Toronto Community Housing/Toronto Seniors Housing will keep these records for one year after their return or as required under MFIPPA, and then destroy it in line with the proper disposal method.

Who can ask to see what is recorded by CCTV?

Any person who has been recorded by a CCTV system has a right to see what the record shows if it is still stored by Toronto Community Housing/Toronto Seniors Housing. This right is guaranteed by the Ontario Municipal Freedom of Information and Protection of Privacy Act (MFIPPA).

Any person who wants to see a CCTV record must write to Toronto Community Housing/Toronto Seniors Housing’s Privacy Coordinator as soon as possible after the record was made. The person requesting the record must identify where and when the recording was captured. If a person asks to see a CCTV record, that person can only see images of himself/herself. As with all requests for records, Toronto Community Housing/Toronto Seniors Housing will make sure that any other person identified in the record are blocked out. As with all such requests a fee may be applicable. Requests for access to a record may be denied in certain circumstances as set out in MFIPPA and any other applicable law.

Telling the public about the CCTV system

To tell the public that Toronto Community Housing/Toronto Seniors Housing is using CCTV, Toronto Community Housing/Toronto Seniors Housing will post signs on any property that has CCTV.

The following information may be on the signs:

• That CCTV may be in use on the property;
• Which law allows Toronto Community Housing/Toronto Seniors Housing to make records of people;
• The purpose behind the use of CCTV; and
• The title, business address and telephone number of a person who can answer questions about CCTV.

What Toronto Community Housing/Toronto Seniors Housing employees need to know

Toronto Community Housing/Toronto Seniors Housing will communicate this policy to its employees and those representatives that manage Toronto Community Housing/Toronto Seniors Housing residential properties. Toronto Community Housing/Toronto Seniors Housing will also make sure that all employees who do anything related to the CCTV systems follow this policy and any related MFIPPA requirements.

What contracted service providers need to know

Any time Toronto Community Housing/Toronto Seniors Housing contracts with a service provider that may have a connection that relates to Toronto Community Housing/Toronto Seniors Housing’s CCTV system, Toronto Community Housing/Toronto Seniors Housing will tell the service provider that all records in its CCTV systems belong to Toronto Community Housing/Toronto Seniors Housing and must be handled according to this Policy. Where a service provider does not follow this Policy, Toronto Community Housing/Toronto Seniors Housing may consider that the service provider has breached its contract and may result in the termination of its contract with Toronto Community Housing/Toronto Seniors Housing.

What happens if CCTV information is accidentally made public?

If any information from a CCTV record is accidentally made public in breach of this Policy, Toronto Community Housing/Toronto Seniors Housing will deal with the problem quickly and effectively. Toronto Community Housing/Toronto Seniors Housing will:

• immediately report what happened to its Privacy Coordinator,
• try to get the record back,
• tell the person whose privacy has been violated,
• tell the Ontario Information and Privacy Commissioner, and
• investigate what happened.

Reviewing the CCTV system

Toronto Community Housing/Toronto Seniors Housing will review its CCTV equipment on a periodic basis to ensure that it complies with this Policy.

Reviewing this Policy

Toronto Community Housing/Toronto Seniors Housing will periodically review and update this Policy.

Toronto Seniors Housing Corporation has adopted this policy as of May 17, 2022 and is in effect for June 1,2022

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Privacy Policy

 Policy Statement

Toronto Seniors Housing Corporation is committed to protecting Personal Information consistent with the principles outlined in the Municipal Freedom of Information and Protection of Privacy Act (“MFIPPA”) and the Housing Services Act (“HSA”).

Toronto Seniors Housing Corporation is required to protect Personal Information from theft or loss and protect Personal Information in its possession from unauthorized collection, access, use or disclosure. Toronto Seniors Housing Corporation will obtain consent before or when it collects, uses or discloses Personal Information, except where collection, use, or disclosure is authorized or required by law.

In some cases, Toronto Seniors Housing Corporation may be required to follow the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and it will adhere to PIPEDA’s “fair information principles” when managing Personal Information. The fair information principles includes the following:

• Accountability: Toronto Seniors Housing Corporation is accountable for the protection of Personal Information within its custody or control.
• Identifying Purposes: When required, Toronto Seniors Housing Corporation will identify purposes for which it collects Personal Information at or before the time the information is collected.
• Consent: When required, Toronto Seniors Housing Corporation will obtain consent before, or when, it collects, uses or discloses Personal Information, except where collection, use or disclosure is authorized or required by law.
• Accuracy: Toronto Seniors Housing Corporation shall ensure that the Personal Information is accurate, complete and up-to-date as is necessary for the purposes for which it is to be
• Safeguards: Toronto Seniors Housing Corporation shall protect Personal Information by security safeguards appropriate to the sensitivity of the information.
• Openness: Toronto Seniors Housing Corporation shall make readily available to individuals specific information about its policies and practices relating to the management of Personal
• Individual Access: Upon request, an individual shall be informed of the existence, use and disclosure of their Personal Information and shall be given access to that An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
• Challenging Compliance: Any individual may challenge Toronto Seniors Housing Corporation’s compliance with the above principles in respect to their Personal Information.

Scope

The purpose of this Policy is to assert Toronto Seniors Housing Corporation’s obligation with respect to the protection of Personal Information collected, used, disclosed and disposed by Toronto Seniors Housing Corporation.

All employees and board members of Toronto Seniors Housing Corporation are responsible for the protection and management of Personal Information. Toronto Seniors Housing Corporation will enter into agreements to ensure that contract management companies and vendors also respect this Privacy Policy.

Values

Toronto Seniors Housing Corporation supports a climate and culture that protects and respects the privacy of an individual’s Personal Information.

Definitions

Collection: The collection of Personal Information from or about the individual to whom the information relates including unintended or unprompted receipt.

Delegated Head: Under MFIPPA, the Toronto Seniors Housing Corporation Board of Directors is deemed to be the head of the institution responsible for overseeing the administration of its obligations and for decisions made under MFIPPA. MFIPPA permits the delegation of the Head’s powers and duties to an officer of the institution.

Disclosure: The release of Personal Information by any method to anybody.

Disposal: The action taken with regards to Personal Information, including destruction, transfer to another entity or permanent preservation.

Personal Information: Has the same meaning as defined in MFIPPA and includes recorded information about an identifiable individual which is collected, used, or disclosed by Toronto Seniors Housing Corporation. For the application of this Policy, Personal Information may include but is not limited to:

1. the personal address, telephone number or email address of an individual;
2. any identifying number assigned to an individual which can lead to their identification (e.g., Social Insurance Number);
3. information relating to the race, national or ethnic origin, colour, religion, age, sex, sexual orientation or marital or family status of the individual;
4. financial information about an individual for the purposes of establishing Rent-Geared-to-Income assistance;
5. information about rent payment history;
6. credit and rental history reports; and
7. employee information, including resumes, salary and benefits, tenant or client complaints about the individual and personnel issues.

With regards to applicants and tenants, personal information may include income, credit history, subsidy, arrears, personal circumstances, health, conflicts between tenants, requests for transfers for personal reasons and any requests from tenants that are personal in nature. With regards to staff, personal information may include hiring, termination, disciplinary record, salary negotiations, tenant complaints and problems between staff members.

Privacy Breach: The improper or unauthorized creation, collection, use, disclosure, retention or disposal of Personal Information in Toronto Seniors Housing Corporation’s custody and control resulting in disclosure of, or access to, personal information by unauthorized parties.

Purpose: The purpose for which the information was obtained or compiled.

Record: Any record of information however recorded, whether in handwritten notes, printed form, on film, by electronic means or otherwise. Records include:

• correspondence, a memorandum, a book, a plan, a map, a drawing, a diagram, a pictorial or graphic work, a photograph, a film, a microfilm, a sound recording, a videotape, a machine- readable record, any other documentary material regardless of physical form or characteristics and any copy thereof; and
• subject to the regulations made under MFIPPA, any record that is capable of being produced from a machine-readable record under the control of Toronto Seniors Housing Corporation by means of computer hardware and software or any other information storage equipment and technical expertise normally used by Toronto Seniors Housing Corporation.

Policy Details Access

Every person has a right of access to a record or a part of a record in the custody or under the control of Toronto Seniors Housing Corporation and contract property management companies unless the record or part of the record falls within one of the exemptions under MFIPPA, or the request for access is frivolous or vexatious. Toronto Seniors Housing Corporation will administer all requests for access to records that are in the custody of Toronto Seniors Housing Corporation and contract property management companies. MFIPPA Request Forms are available to request access to a record.

Limiting Collection, Use, Disclosure and Retention

The collection, use and disclosure of Personal Information will be limited to that which is reasonable and necessary for the purposes outlined in this Policy and required by law. Personal Information will be retained only as long as necessary for the fulfillment of those purposes.

Collection, Use and Disclosure

Toronto Seniors Housing Corporation collects, uses and discloses Personal Information of its tenants, employees, directors and vendors to the extent necessary to perform its work.

Toronto Seniors Housing Corporation will ensure that Personal Information is collected, used and disclosed in accordance with legislation and in compliance with this Policy and other Toronto Seniors Housing Corporation policies.

Personal Information may be collected for purposes including but not limited to the following:

• to determine income and assets for rent calculation;
• to protect the health and safety of an individual;
• to approve tenancy and determine appropriate unit type and size; and
• to assist staff in determining what services and supports tenants may require.

Consent

Toronto Seniors Housing Corporation may collect, use and disclose Personal Information where the individual to whom the information relates has consented to the collection, use, and disclosure proposed by Toronto Seniors Housing Corporation.

Personal Information may be collected, used and disclosed without consent only if allowed by legislation. Permitted situations may include, but are not limited to, the following:

• the information is being collected, used or disclosed for a consistent purpose, meaning a purpose the person could have reasonably expected for such use or disclosure;
• disclosure to an institution or the Toronto Police Service or other law enforcement agencies in Canada to assist in a criminal investigation;
• disclosure to an officer, director, employee, consultant or agent of Toronto Seniors Housing Corporation who needs the Personal Information in the performance of their duties and if disclosure is necessary and proper in the discharge of Toronto Seniors Housing Corporation’s functions (e.g., Internal Audit to assist in an investigation into any breach of Toronto Seniors Housing Corporation’s policies);
• compelling circumstances affecting the health and safety of an individual (provided Toronto Seniors Housing Corporation notifies the person whose information it is); and
• compassionate

It is not necessary to have a signed consent to release information to collect a debt, for example to a collection agency, or for the Landlord and Tenant Board or Small Claims action.

Retention

Records containing Personal Information will be kept and disposed of according to the retention periods and disposition methods authorized in Toronto Seniors Housing Corporation’s Records Retention Schedule.

Privacy Breach

Should a Privacy Breach occur, Toronto Seniors Housing Corporation will act quickly and transparently to respond and will take appropriate measures to rectify the breach and avoid future incidents. Measures may include:

• stopping and containing the Privacy Breach;
• notifying affected individuals of the Privacy Breach;
• notifying the Information and Privacy Commissioner of Ontario; and
• conducting an internal investigation.

Responsibilities

Toronto Seniors Housing Corporation will:

• Promote a culture, and business practices, that make sure that information is shared and is accessible to the greatest extent possible, while respecting security and privacy requirements of Personal Information and other confidentiality
• Provide education to employees who are responsible for the protection of Personal Information under this Policy.
• Follow specific procedures established for disclosing Personal Information to a law enforcement agency in Canada.
• Investigate complaints and respond to individuals who file complaints regarding the collection, use and disclosure of Personal Information in accordance with legislated requirements.

Obligations of Employees

Compliance with this Policy is the obligation of every employee at Toronto Seniors Housing Corporation. In performing their duties and responsibilities for the organization, employees will come into contact with, or otherwise learn about, Personal Information.

Employees are expected to take all reasonable steps to protect Personal Information from unauthorized collection, use or disclosure. This includes safeguarding documents, tenant files, laptops, cell phones and company files that contain Personal Information that has been entrusted to the employee’s care, as well as steps to protect Personal Information when using computer systems and sending e-mail.

Employees are prohibited from trying to use or access Personal Information if it is not associated with their work. Employees also are prohibited from disclosing Personal Information if it is not associated with their work. For more information, please see the Code of Conduct and Conflict of Interest Policy.

Compliance and Monitoring

• The General Counsel and Corporate Secretary is the Delegated Head of Toronto Seniors Housing Corporation and is accountable for Toronto Seniors Housing Corporation’s compliance with this Policy.
• Employees who do not follow this Policy or the related sections of the Code of Conduct may be subject to discipline, up to and including dismissal for cause.
• Employees must also comply with any section of the Code of Conduct, which requires the protection of personal or confidential
• Toronto Seniors Housing Corporation will take reasonable steps to restrict access to Personal Information to those individuals who require access to Personal Information in order to perform their duties and where access is necessary for the administration of their business.
• Toronto Seniors Housing Corporation will take appropriate steps to ensure vendors and contractors comply with this Policy.

Governing and Applicable Legislation

• Municipal Freedom of Information and Protection of Privacy Act, 1990
• Personal Information Protection and Electronic Documents Act, 2000
• Housing Services Act, 2011

Related Policies and Procedures

• Code of Conduct
• Acceptable Use of Information Technology Policy
• Records Management Policy
• Records Retention Schedule
• CCTV Policy

Commencement and Review

TORONTO SENIORS HOUSING CORPORATION (TSHC)

INFORMATION BREACH POLICY

Policy Statement

Toronto Seniors Housing Corporation (Toronto Seniors Housing) collects and retains Confidential Information that must be properly managed to protect the privacy and security of the party whose information has been collected, including, but not limited to, tenants, employees and the corporation itself. If Confidential or Internal Information is lost, corrupted, accessed or disclosed without proper authorization, it can pose a high level of legal, reputational, financial and safety risks to Toronto Seniors Housing.

This Policy provides a framework within which employees of Toronto Seniors Housing are required to respond to an Information Breach, and sets out responsibilities within Toronto Seniors Housing and its employees for the reporting and handling of an attempted, actual or suspected Information Breach, in order to minimize its impact.

Scope

This Policy applies to any improper or unauthorized use, release, disclosure or disposal of Confidential or Internal Information in Toronto Seniors Housing’s custody and control, such as tenant, employee, third party or corporate information.

It covers both Information Breaches and Information Technology System Breaches.

Information Breaches can arise from cybersecurity attacks, as well as from the theft, loss, abuse, damage or unauthorized access to or disclosure of Toronto Seniors Housing information, whether the breach was intentional or inadvertent.

This Policy is applicable to all employees of Toronto Seniors Housing that have access to information in the custody or under the control of Toronto Seniors Housing and its Information Technology Systems. Toronto Seniors Housing will enter into agreements to ensure that contract management companies, vendors and third parties meet the relevant requirements of this Policy.

Values

Toronto Seniors Housing supports a climate and culture that protects both Confidential and Internal Information. Toronto Seniors Housing will implement this Policy in accordance with the following values:

Respect: All Toronto Seniors Housing employees will adhere to this Policy and will take appropriate measures to protect both Confidential and Internal Information to which they have access from an Information Breach in accordance with this Policy.

Accountability: Toronto Seniors Housing will designate Incident Response Leads within the Legal Services and Information Technology Services Divisions who will lead its response to an Information Breach.

Integrity: Toronto Seniors Housing employees will alert the organization of an Information Breach.

Definitions

Confidential Information: Information that is in the custody or control of Toronto Seniors Housing that is highly sensitive, protected from public disclosure and intended for use by a specified group of authorized users, such as Personal Information, and information related, generally, to Toronto Seniors Housing’s tenants, residents, contractors, employees, and members of the public that, if disclosed, may give rise to a significant risk of harm to both Toronto Seniors Housing and others.

Incident Response Lead: The employee within Toronto Seniors Housing’s Information Technology Services or Legal Services Division who is (depending on the nature of the breach) responsible for leading its response to an Information Breach.

Information Breach: The improper or unauthorized use, disclosure, release or disposal of either Confidential or Internal Information, resulting in the information being access by or disclosed to unauthorized parties. Examples of an Information Breach include, but are not limited to:

• an employee sending an email containing either Confidential or Internal Information to an unintended recipient in error;
• an individual (such as a tenant, vendor or other stakeholder) being mistakenly provided with or accessing either Confidential or Internal Information that they are not authorized to view;
• the removalof a tenant file from a Toronto Seniors Housing office resulting in the unauthorized disclosure of either the tenant’s Personal Information; or
• an Information Technology System Breach.

Information Technology System Breach: An Information Breach that occurs as a result of:

• unauthorized activity by parties internal and external to Toronto Seniors Housing;
• a technical vulnerability; or
• a combination of those or other causes; impacting Toronto Seniors Housing’s Information Technology Systems that results in the use, disclosure, release or disposal of either Confidential or Internal Information, resulting in the information being access by or disclosed to unauthorized parties of information systems or networks.

Internal Information: Information other than Confidential Information that is generally only available and intended for use by Toronto Seniors Housing employees and authorized third parties such as consultants and vendors. (e.g. Corporate policies, standards, and procedures unless they are intended for publication, general corporate internal announcements to staff, etc.), including but not limited to information related to Toronto Seniors Housing’s financial affairs, marketing plans, resources, proposed initiatives, and strategies, etc.

Personal Information: Has the same meaning as defined in Municipal Freedom of Informationand Protectionof Privacy Act, RSO 1990, c M.56, as amended, and includes recorded information about an identifiable individual which is collected, used, or disclosed by Toronto Seniors Housing. For the application of this Policy, Personal Information may include but is not limited to:

1. the personal address, telephone number or email address of an individual;
2. any identifying number, symbol or other particular assigned to an individual which can lead to their identification (e.g., Social Insurance Number or Tenant ID);
3. information relating to the race, national or ethnic origin, colour, religion, age, sex, sexual orientation or marital or family status of the individual;
4. financial information about an individual for the purposes of establishing Rent-Geared-to-Income assistance;
5. information about rent payment history; credit and rental history reports; and
6. employee information, including resumes, salary and benefits, tenant or client complaints about the individual and personnel issues.

With regards to applicants and tenants, Personal Information may include income, credit history, subsidy, arrears, utility consumption, personal circumstances, health information, information regarding conflicts between tenants, requests for transfers for personal reasons and any requests from tenants that are personal in nature. With regards to employees, Personal Information may include hiring, termination, disciplinary record, salary negotiations, tenant complaints and information regarding conflicts between employees or between employees and tenants.

Public Information: Information that is generally available to the public, with no special protection from disclosure required (e.g. a press release, a public request for proposals, external TSHC website content, and published reports).

Policy Details

Toronto Seniors Housing Responsibilities

Toronto Seniors Housing will:

• Promote a culture and implement business practices that support information security, cybersecurity and the prevention of Information Breaches.
• Provide education on information security to Incident Response Leads and employees who have access to or are responsible for either Confidential or Internal Information.
• Maintain appropriate administrative, physical and technical security safeguards to prevent the unauthorized access, use or disclosure of either Confidential or Internal Information.
• Maintain procedures and protocols to identify, contain, and recover from any Information Breaches that ensures there is a consistent and effective approach to the management of Information Breaches.

The General Counsel and Corporate Secretary will oversee Toronto Seniors Housing’s response to an Information Breach and will work with the Vice President, Information Technology Services and the Incident Response Leads to mitigate its impact.

Employee Responsibilities

In performing their duties and fulfilling their responsibilities, employees will learn information about Toronto Seniors Housing and its operations. This includes information in that is shared with the employee verbally and in writing, through formal documents, corporate files, e-mails, computers files, data records, etc. In most cases, this information is not generally known to the public. Examples include information related to our financial affairs, marketing plans, tenants, residents, resources, contractors, proposed initiatives, strategy, members of the public, employees, etc. This information is confidential and is Toronto Seniors Housing’s property.

Employees are required to take all reasonable steps to protect both Confidential and Internal Information from unauthorized use or disclosure. This includes safeguarding physical and electronic documents, laptops, and cell phones that have been entrusted to their care, as well as taking necessary steps to protect information when using computer systems and sending e-mail pursuant to the requirements of related policies, procedures or directives that have been issued by TSHC.

If an employee becomes aware of an Information Breach, he or she must immediately notify their manager, Division Head and the General Counsel and Corporate Secretary in accordance with the procedure set out in the Information Breach Procedure.

If an employee suspects that an Information Technology System Breach may have occurred, he or she must immediately notify their manager, Division Head and the Information Technology Service Desk. The Service Desk team will report the breach to the Incident Response Leads in accordance with the procedure set out in the Information Technology Security Incident Management Procedure.

Information Breach Standards

In the event of an actual or suspected Information Breach, Toronto Seniors Housing will, to the extent necessary in order to mitigate the impact of the Information Breach, undertake the following actions:

• Determine if an actual breach occurred and identify the type of information that was disclosed (i.e., Confidential Information, Internal Information or Public Information).
• Contain the incident to minimize impact (e.g. retrieving the information if possible, disconnecting devices affected or implicated by the Information Breach from the network, suspending access rights, quarantining any discovered malware).
• Investigate the cause of the Information Breach and depending on its nature, conduct any additional forensic analysis required to support any criminal or legal investigation as may be required.
• Conduct an assessment with relevant employees to determine the impact of the Information Breach and review the recovery actions required.
• Notify the affected stakeholders (e.g. employees, tenants, vendors) and if Personal Information may have been disclosed, notify the Information and Privacy Commissioner as necessary.
• Notify Toronto Seniors Housing employees and Directors, as appropriate.
• Conduct a post-incident analysis of the cause of the Information Breach, and identify lessons learned, preventative actions, and how to further improve Toronto Seniors Housing’s overall information security protocols.

Compliance and Monitoring

Compliance with this Policy will be assessed through various methods, including internal and external audits. Legal Services and Information Technology Services will monitor the volume and severity of Information Breaches and prepare an annual report of incidents to the Executive Leadership Team highlighting any actions that need to be taken to mitigate risk. At the direction of the President and CEO, the content of this annual report will be shared with the Toronto Seniors Housing Board of Directors through the Building Investment, Finance and Audit Committee.

Employees who do not follow this Policy or the related sections of the Privacy Policy and the Code of Conduct which require the protection of personal or confidential information may be subject to discipline, up to and including dismissal. Non-compliance with any provision of this Policy by employees or Toronto Seniors Housing affiliates may result in remedial action up to and including termination of any affiliate contract, and may result in possible civil, criminal, or regulatory action.

Toronto Seniors Housing will take appropriate steps to ensure vendors, contractors and third-parties comply with this Policy.

Governing and Applicable Legislation

• Municipal Freedom of Information and Protection of Privacy Act
• Personal Information Protection and Electronic Documents Act, 2000 

Related Policies and Procedures

Procedures Established pursuant to this Policy

• Information Breach Procedure
• Information Technology    Security    Incident    Management Procedure

Related Policies and Procedures

• Employee Code of Conduct
• Acceptable Use of Information and Technology
• Records Management Policy Enterprise Risk Management Policy
• Conflict of Interest Policy
• Privacy Policy

Commencement and Review

Next Scheduled Review Date:

Toronto Seniors Housing Corporation Multi-Year Accessibility Plan

(the “Accessibility Plan”)

(Ontario Regulation 191/11) of the Accessibility for Ontarians with Disabilities Act, 2005

Introduction

The Integrated Accessibility Standards Regulations (“IASR”) under the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”), require that Toronto Seniors Housing Corporation (TSHC) establish, implement, maintain, and document its accessibility policies and multi-year accessibility plan (the “Accessibility Plan”), which outlines TSHC’s strategy to prevent and remove barriers for persons with disabilities and to meet its requirements under the IASR.

The Accessibility Plan will be available in an accessible format upon request. The Accessibility Plan will be reviewed and updated, if applicable, at least once every five years.

Application

The Accessibility Plan applies to all employees, tenants, and clients of TSHC, and, where indicated, to any independent contractor representatives working for the company.

Our Commitment

In fulfilling our mission, TSHC strives to treat all individuals in a manner that allows them to maintain their dignity and independence. TSHC promotes integration and equal opportunity and is committed to meeting the needs of people with disabilities in a timely manner. We will seek to achieve this by preventing and removing barriers to accessibility and by meeting accessibility requirements under the AODA. This Accessibility Plan sets out TSHC’s policy on how we will achieve accessibility generally, as well as in employment, information and communications, and the design of public spaces (built environment).

Under the IASR, the following accessibility strategies set out the requirements that are applicable to TSHC:

• Workplace Emergency Response Information
• Training
• Information and Communication
• Employment
• Design of Public Spaces Standards

Accessibility Standards for Customer Service

TSHC is committed to compliance with the Accessibility Standards for Customer Service Regulation (O.Reg.429/07) under the AODA, which involves providing its services in ways that respect the dignity and independence of people with disabilities.

TSHC’s employees who are involved in providing customer service to its customers and the general public have been trained on TSHC’s Accessible Customer Service Policy, and all new employees hired to provide such services will receive such training as part of their orientation with the company.

Copies of TSHC’s Accessible Customer Service Policy will be made available to members of the public and third parties on request and is available on the TSHC website here.

Integrated Accessibility Standards Regulations (IASR)

The following sets out how TSHC is committed to complying with the IASR.

1. Workplace Emergency Response Information

Where TSHC is aware that an employee has a disability and that there is a need for accommodation, individualized workplace emergency response information will be provided to the employee as soon as practicable if such information is necessary given the nature of the employee’s disability.

Action Taken:

TSHC will be implementing the following measures to address Emergency Response for employees who have disabilities:

• individualized workplace emergency response information procedures will be developed for employees with disabilities where required.
• where employees disclose a disability and are being accommodated according to their disabilities, workplace emergency response information forms will be prepared where required.
• where required, TSHC provides assistance to specific disabled employees, with the disabled employees’ prior consent, to help them evacuate the workplace in case of an emergency or disaster. Plans for providing assistance will be set out in individualized emergency plans for the employees.
• individualized emergency plans will be communicated to the employees’ respective managers and safety personnel on an ‘as needed’ basis.
• on an ongoing and regular basis, and as per the applicable terms of the IASR, TSHC will review and assess general workplace emergency response procedures and individualized emergency plans to ensure accessibility issues are addressed.

Compliance Date: June 2022

2. Training

TSHC is committed to providing training on the requirements of the accessibility standards referred to in the IASR and on the Human Rights Code, as it pertains to persons with disabilities.

Planned Action:

In accordance with the IASR, TSHC will:

• determine and ensure that appropriate training on the requirements of the IASR and on the Human Rights Code as it pertains to persons with disabilities, is provided to all employees, independent contractor representatives, volunteers, third-party service providers who provide services related to products, services, and facilities on TSHC’s behalf, and persons participating in the development and approval of TSHC’s policies.
• ensure that the training is provided to persons referenced above as soon as practicable.
• keep and maintain a record of the training provided, including dates the training was provided and number of individuals to whom it was provided.
• ensure training is provided on any changes to TSHC’s policies on an ongoing basis.

Anticipated Compliance Date: March 2024

3. Information and Communication

TSHC is committed to making company information and communications accessible to persons with disabilities. TSHC will incorporate new accessibility requirements under the information and communication standards to ensure that its information and communications systems and platforms are accessible and are provided, upon request, in accessible formats that meet the needs of persons with disabilities.

a. Feedback, Accessible Formats, and Communication Supports

Planned Action:

In accordance with the IASR, TSHC will:

• ensure that existing and new processes for receiving and responding to feedback are accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports, upon request and in a timely manner.
• more broadly, as a general principle where accessible formats and communication supports for persons with disabilities are requested:
  • provide or arrange for the provision of such accessible formats and communication supports.
  • consult with the person making the request to determine the suitability of the accessible format or communication support.
  • provide or arrange for the provision of accessible formats and communication supports in a timely manner that takes into account the person’s accessibility needs due to disability, and at a cost no more than the regular cost charged to other persons.
• notify the public about the availability of accessible formats and communication supports.

Compliance Date: January 2023

b. Accessible Websites and Web Content

Planned Action:

In accordance with the IASR, TSHC recognizes its obligation to provide web content which conforms with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG 2.0) Level AA.

Any website hosted by TSHC shall meet the requirements set out in the IASR.

Compliance Date: September 2023

4. Employment

a. Recruitment

TSHC is committed to fair and accessible employment recruiting practices that attract and retain employees with disabilities. This includes providing accessibility at all stages of the employment cycle.

Planned Action:

In accordance with the IASR, TSHC will do the following:

(i) Recruitment General

TSHC will notify employees and the public of the availability of accommodation for applicants with disabilities in the recruitment process. This will include:

• review and, as necessary, modification of existing recruitment policies, procedures, and processes.
• specifying that accommodation is available for applicants with disabilities, on TSHC’s website and on job postings.

Anticipated Compliance: March 2024

(ii) Recruitment, Assessment, and Selection

TSHC will notify job applicants, when they are individually selected to participate in an assessment or selection process and inform them that accommodations are available upon request in relation to the materials or processes to be used in the assessment/selection process. This will include:

• review and, as necessary, modification of existing recruitment policies, procedures, and processes.
• inclusion of availability of accommodation notice as part of the script in the scheduling of an interview and/or assessment.
• consultation with the applicant and arrangement for provision of suitable accommodations in a manner that takes into account the applicant’s accessibility needs due to the disability where a selected applicant requests accommodation.

Compliance Date: June 2022

(iii) Notice to Successful Applicants

When making offers of employment, TSHC will notify the successful applicant of its policies for accommodating employees with disabilities. This will include:

• A review and, as necessary, modification of existing recruitment policies, procedures, and processes.
• inclusion of notification of TSHC’s policies on accommodating employees with disabilities in offer of employment letters.

Compliance Date: June 2022

b. Informing Employees of Supports and General Provision of Accessible Formats and Communications Supports

In accordance with the IASR, TSHC will inform all employees of policies that support employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee’s accessibility needs due to a disability.

This will include:

• informing current employees and new hires of TSHC’s policies supporting employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee’s needs due to disability.
• providing information as soon as practicable after the new employee begins employment, specifically in the orientation process.
• keeping employees up to date on changes to existing policies on job accommodations with respect to disabilities.
• where an employee with a disability so requests it, TSHC will provide or arrange for provision of suitable accessible formats and communications supports for:
  • information that is needed in order to perform the employee’s job.
  • information that is generally available to employees in the workplace.
• in meeting the obligations to provide the information that is set out above, TSHC will consult with the requesting employee in determining the suitability of an accessible format or communication support.

Compliance Date: June 2022

c. Documented Individual Accommodation Plans/Return to Work Process

TSHC will incorporate new accessibility requirements under the IASR to ensure that barriers in accommodation and return to work processes are eliminated and corporate policies surrounding accommodation and return to work are followed, where applicable.

Planned Action:

TSHC’s existing policies include steps that TSHC will take to accommodate employees with disabilities and to facilitate employees’ return to work after absence due to disability.

TSHC will review and assess the existing policies to ensure that they include a process for the development of documented individual accommodation plans for employees with disabilities, if such plans are required.

In accordance with the provisions of the IASR, TSHC will ensure that the process for the development of documented individual accommodation plans includes the following elements:

• information regarding the manner in which the employee requesting accommodation can participate in the development of the plan.
• information regarding the means by which the employee is assessed on an individual basis.
• information regarding the manner in which TSHC can request an evaluation by an outside medical or other expert, at TSHC’s expense, to assist TSHC in determining if and how accommodation can be achieved.
• steps to protect the privacy of the employee’s personal information.
• information regarding the frequency with which individual accommodation plans will be reviewed and updated and the manner in which this will be done.
• the reasons for a denial where an individual accommodation plan is denied.
• information regarding the means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs,
• the following will be included if individual accommodation plans are established:
  • any individualized workplace emergency response information that is required.
  • any information regarding accessible formats and communication supports that have been provided for or arranged, in order to provide the employee with:
    • information that is needed in order to perform the employee’s job.
    • information that is generally available to employees in the workplace.
• identify any other accommodation that is to be provided to the employee.

TSHC will ensure that the return-to-work process as set out in its existing policies outlines:

• the steps TSHC will take to facilitate the employee’s return to work after a disability-related absence.
• the development of a written individualized return to work plan for such employees.
• the use of individual accommodation plans, as discussed above, in the return-to-work process.

Compliance Date: June 2022

d. Performance Management, Career Development and Redeployment

TSHC will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans:

• when using its performance management process in respect of employees with disabilities.
• when providing career development and advancement to employees with disabilities.
• when redeploying employees with disabilities.

Planned Action:

In accordance with the IASR, TSHC will:

• review, assess and, as necessary, modify existing policies, procedures, and practices to ensure compliance with the IASR.
• take the accessibility needs of employees with disabilities and, as applicable, their individualized accommodation plans, into account when:
  • assessing performance
  • managing career development and advancement
  • redeployment is required
• review, assess and, as necessary, include in performance management workshops, accessibility criteria.
• take into account the accessibility needs of employees with disabilities when providing career development and advancement to its employees with disabilities, including notification of the ability to provide accommodations on internal job postings.
• take into account the accessibility needs of employees with disabilities when redeploying employees, including review and, as necessary, modification of the employee transfer checklist.

Compliance Date: June 2022

Integrated Accessibility Standards Regulations – Design of Public Spaces

While TSHC has no plans to engage in new construction or redevelopment which would be captured by the requirements of the IASR concerning the Design of Public Spaces, TSHC recognizes its obligations under the relevant sections of the Regulation and is committed to incorporating barrier-free design principles into any public spaces that are newly constructed and redeveloped on or after January 1, 2017.

Toronto Seniors Housing Corporation manages the Landlord and Tenant relationship.  All 83 of the TSHC-managed buildings are owned by the Toronto Community Housing Corporation.

Feedback:

For more information on this Accessibility Plan or for accessible formats of the Accessibility Plan, please contact:

Grant Coffey, Director of Strategy and Business Management

Email: Grant.Coffey@torontoseniorshousing.ca

Telephone: 416-981-4548

Plan version:  August 2024

Toronto Seniors Housing Corporation (TSHC)
Accessible Customer Service Policy

Policy Sponsor: Director, Strategy and Business Management

Approver: Board of Directors

Initial Approval Date: May 17, 2022

Effective Date: June 1, 2022

Policy Statement

Toronto Seniors Housing Corporation (TSHC) recognizes that accessibility for persons with disabilities is an important issue that needs to be addressed throughout our portfolio. Toronto Seniors Housing Corporation is committed to the principles of accommodation outlined in the Accessibility for Ontarians with Disabilities Act, 2005 (AODA), the Accessibility Standards for Customer Service, Ontario Regulation 429/07 (the Customer Service Standard), and the Ontario Human Rights Code. The Accessibility Standards for Customer Service, Ontario Regulation 429/07 (the Customer Service Standards) is an accessibility standard created under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).

Toronto Seniors Housing Corporation will continue to provide customer service for persons with disabilities in a manner that respects their dignity and independence while allowing them the same opportunity as any other customer to access and benefit from our services.

As additional standards identified in the AODA pass into regulation, this policy will be adjusted to include these new standards.

Policy Objectives

In fulfillment of its obligations under the Customer Service Standards and in keeping with its values, this policy outlines Toronto Seniors Housing Corporation’s commitment to provide customer service that is inclusive, barrier free and meets the unique needs of persons with disabilities.

The purpose of this policy is to lay out Toronto Seniors Housing Corporation’s commitment to providing accessible customer service. This policy sets out key customer service commitments in several areas relating to accessibility.

Guidelines will set out detailed procedures and protocols that guide Toronto Seniors Housing Corporation in applying this policy. The policy and Guidelines will inform tenants and the public of our commitment and will guide them in requesting accommodation in service and providing feedback about our services.

Scope

This policy applies to all persons who interact with tenants, members of the public or third parties on behalf of Toronto Seniors Housing Corporation, as an employee, contractor, volunteer, member of the Board of Directors or otherwise.

Key Values

Toronto Seniors Housing Corporation shall provide accessible customer service in accordance with the following key principles:

Dignity

Service is provided in a respectful manner consistent with the needs of the individual.

Independence

Services for persons with disabilities shall support their independence while respecting their right to safety and personal privacy. As such, service delivery shall consider the nature of the service and alternative accommodation that may be required.

Equity/Equality of Outcome

Customers with disabilities will be provided with the same opportunity to access our services as all other customers.

Integration

Customers with disabilities shall fully benefit from the same services, in the same place and in the same or similar way as all other customers.

Definitions

Under the Customer Service Standards (O.Reg. 429/07):

Assistive Device: A device used to assist persons with disabilities in carrying out activities of daily life or accessing the services provided by Toronto Seniors Housing Corporation including, but not limited to, wheelchairs, walkers, canes, note-taking devices, portable magnifiers, recording machines, personal oxygen tanks and devices for grasping.

Barrier: Anything that prevents a person with a disability from fully participating in all aspects of society because oftheir disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy a practice.

Disability: (a) any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co- ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device, (b) a condition of mental impairment or a developmental disability, (c) learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language, (d) mental disorder, or (e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Service Animal: An animal trained specifically to assist an individual with a disability, either where it is readily apparent that the animal is a service animal or where a letter has been provided by a doctor or nurse confirming that the person requires the animal for reasons related to a disability.

Support Person: Someone who accompanies a person with a disability and assists them with communication, mobility, personal care, medical needs or with access to goods or services.

Customer Service Commitments

Training

Toronto Seniors Housing Corporation will provide training to all Board Members, employees, volunteers and others who interact with the tenants, the public or other third parties on its behalf, and all those who are involved in the development and approvals of customer service policies and procedures. Training will include the following:

The purposes of the AODA; the requirements of the customer service standard; and any subsequent legislation.

Instruction on Toronto Seniors Housing Corporation’s policies, and procedures pertaining to the provision of goods and services to persons with disabilities, including the customer service standard.

How to interact and communicate with persons with various types of disabilities.

What to do if a person with a disability is having difficulty accessing Toronto Seniors Housing Corporation’s goods and services.

New staff will be trained upon their initial orientation. Following initial training, existing staff will receive training on a regular basis and when changes are made to these policies and procedures or regulations.

Service Animals

Toronto Seniors Housing Corporation is committed to welcoming persons with disabilities who are accompanied by a service animal on the parts of our premises that are open to the public.

If a service animal is excluded by law, Toronto Seniors Housing Corporation will suggest appropriate alternatives and provide assistance in order to ensure that the person is able to access, obtain, use or benefit from Toronto Seniors Housing Corporation’s services where possible.

Support Persons

Any person with a disability who is accompanied by a Support Person will be allowed to access any services provided by Toronto Seniors Housing Corporation with their Support Person. At no time will Toronto Seniors Housing Corporation prevent a person with a disability who is accompanied by a Support Person from having access to their Support Person.

Where there are barriers to access or attendance by a Support Person at sponsored meetings, consultations or events, Toronto Seniors Housing Corporation will seek to facilitate access so as to ensure the participation of persons with disabilities.

Assistive Devices

Persons with disabilities shall be permitted to obtain, use or benefit from goods or services through the use of their own assistive devices. Staff will be trained so as to be familiar with various assistive devices that may be used by customers with disabilities while accessing services.

In the event a person with a disability is hindered from accessing any goods or services offered, Toronto Seniors Housing Corporation will seek to accommodate the person by offering the use of another assistive device that is available or an alternative way of delivering the same service.

Toronto Seniors Housing Corporation will ensure that staff know how to use assistive devices available in their various locations for customers and inform customers of the assistive devices that are available.

Notice of Temporary Disruptions

Toronto Seniors Housing Corporation is aware that the operation of its services and facilities is important to its customers. However, temporary disruptions in services and facilities may occur.

Toronto Seniors Housing Corporation will provide its customers with notice of any disruption to its services, including information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if any, that may be available.

Notice of service disruptions will be provided as soon as staff is aware of the disruption, or in advance in the case of planned disruptions. Notice will be provided by a variety of methods, depending on the circumstances, and may include postings in conspicuous places at the affected premises, in other Toronto Seniors Housing Corporation facilities, on Toronto Seniors Housing Corporation’s website or by any other means that will ensure that the notice reaches those persons potentially affected by the temporary disruption in a manner that is accessible to them.

Feedback Policy

The goal of Toronto Seniors Housing Corporation is to meet and surpass expectations while providing services to customers with disabilities. Feedback on our services and whether expectations are being met are welcome and appreciated. Feedback may be provided by a person with a disability in the manner deemed most convenient to them, such as in person, by telephone, in writing, by email or otherwise. All feedback will be kept in strict confidence and used to improve customer service. In addition, the author of the feedback will be provided a response in the format requested (or the most appropriate format where no request was made) outlining actions taken. Where an individual is not satisfied with Toronto Seniors Housing Corporation’s response to their feedback, staff will direct their complaint to the appropriate individual to respond.

Related Legislation, Regulations, and TSHC Policies:

• Accessibility for Ontarians with Disabilities Act, 2005 (AODA)
• Accessibility Standards for Customer Service, Ontario Regulation 429/07
• Ontario Human Rights Code
• TSHC Human Rights and Harassment Policy – Tenants
• TSHC Accessibility Policy
• TSHC Multi-year Accessibility Plan
• TSHC Tenant Complaint Procedure
• TSHC Accessibility Customer Service Policy Guidelines (to be reviewed)

Amendments (Revision History):

NA

Next Scheduled Review Date: 2025

This policy will be reviewed once every 5 years.

Policy Contact

Director, Strategy and Business Management

Conflict of Interest Policy – Board of Directors

Policy Owner: Corporate Governance and Human Resources Committee

Approval: Board of Directors

First Approved:

Revision Approval:

Effective Date:

In this Document:

“Board” or “Board of Directors” means the board of directors of the Toronto Seniors Housing Corporation;

“CGHRC” means the Corporate Governance and Human Resources Committee of the Board;

“Director” or “Directors” means a director or directors of the Toronto Seniors Housing Corporation;

“Policy” means the Conflict of Interest Policy for the Board of Directors of the Toronto Housing Seniors Corporation;

“Stakeholders” include the tenants, suppliers, employees, the City of Toronto and other individuals, groups and entities that may from time to time interact with the Toronto Seniors Housing Corporation; and,

“TSHC” means the Toronto Seniors Housing Corporation.

Policy Statement

Promoting public confidence in the Toronto Seniors Housing Corporation is the responsibility of every Director. All Directors must understand that their individual decisions could have an impact on the TSHC’s success and reputation. It follows that in carrying out their duties, Directors are expected to promote the TSHC’s core values and to observe a high standard of honesty, integrity, accountability and ethics.

TSHC Stakeholders have placed their trust in the TSHC. The business decisions of the TSHC Board of Directors must therefore withstand rigorous scrutiny by TSHC Stakeholders. Directors shall act accordingly and shall avoid even the appearance of improper behaviour.

This Policy sets out the expectations placed on Directors related to conflicts of interest, including how to identify and resolve a conflict of interest. The TSHC wishes to establish clear standards to address real, potential and perceived conflicts of interest, to protect the integrity of the TSHC’s decision-making processes and to provide a means to identify and resolve such conflicts of interest in favour of the TSHC’s best interests.

Although this Policy does not address every issue that could possibly arise, it does set out basic expectations for the Directors and offers guiding principles to achieve these expectations whenever Directors interact with Stakeholders and other Directors.

Conflicts of interest can sometimes be subtle. Directors must therefore act as soon as a situation arises that raises any doubts whatsoever.

Should Directors have any questions or need any clarification about this Policy and its interpretation, they should consult with the Chair of the CGHRC .

Scope

This Policy applies to all members of the Board of Directors of the TSHC, as well as to non-Director members of any TSHC Committee or Subcommittee.

Key Definitions

“Conflict of Interest” means any situation in which a Director’s personal or business interests may compete or appear to compete with her or his duties as a Director of the TSHC, or may cause the Director to act contrary or appear to act contrary to, the best interests of the TSHC.

A conflict of interest can be one or more of the following types:

Actual Conflict: a conflict of interest that the Director has, or may have, at the present time;

Potential Conflict: any situation which may lead or have the potential to lead to a conflict of interest in the future; or,

Apparent Conflict: any situation which could reasonably be perceived as a conflict of interest by others, regardless as to whether or not there is an actual conflict of interest.

“Personal or Business Interest” includes any personal gain, benefit, privilege, or advancement that the Director, and/or the Director’s family, friends or business associates (past and present) may receive or expect to receive, whether monetary or non-monetary.

Policy Details

Directors shall not enter into any situation, arrangement or agreement (collectively referred to in this Policy as “matters and transactions”) that results or could result in a conflict of interest (actual, potential, or apparent) and Directors shall arrange their personal and business affairs to ensure that conflicts of interest are avoided.

Directors should consider any advantage that their position as TSHC Directors may give them, whether it be the power to influence decisions, their ability to use the organization’s resources or their access to information about the TSHC and others.

In deciding whether their actions could result in a conflict of interest, Directors are expected to consider how their actions will be seen by their colleagues on the Board or by Stakeholders including the general public.

In general, a Director shall not participate in decision-making with respect to a matter or transaction if that Director is in a conflict of interest position. Examples of conflicts of interests are (but are not limited to):

• Directors, or their family or friends, who transact business (funding or contractual arrangements) directly with the TSHC;
• Hiring a Director’s family member or personal friend;
• Directors who accept gifts, entertainment or other personal benefits from an existing or potential TSHC Stakeholder such as a supplier, tenant, or business This also includes family members of Directors who accept such benefits.
• Working for a supplier while continuing to be a Director of the TSHC;
• Directors who have a financial interest in a supplier or other Stakeholder;
• Directors who give preferential treatment to any person or entity in which the Director has a personal interest;
• Using confidential information to benefit the Director or his/her family or friends;
• Being involved with or employed by, an entity other than the TSHC if such involvement or employment would conflict with or detrimentally affect the Director’s performance of his or her duties as a TSHC Director;
• Directors who use the TSHC’s property, equipment or resources, other than for TSHC business; or,
• Directors who divert, directly or indirectly, to their own use an opportunity or advantage that belongs to the TSHC.

1. Financial and Business Transactions

Directors shall avoid financial transactions between themselves and the TSHC, between themselves and a third party, or between the TSHC and a third party that may adversely affect the performance of their duties as Directors or confer a personal or business advantage on them. This includes transactions involving entities in which a Director, his or her family member or friend, is a director, trustee, officer, committee member, or has a substantial financial interest through ownership or control.

Directors shall avoid investing, directly or indirectly, in any property managed by the TSHC. A Director shall use special caution to avoid purchases and sales of anyproperty that may be interpreted as attempting to profit from special knowledge of the TSHC’s operations, or other confidential information obtained by reason of the Director’s TSHC duties.

If a Director is, or seeks to be, a director, officer, or employee of a company (or if the Director has a financial interest in such company) that has business dealings with the TSHC, this could be a conflict of interest.

If a Director (or a family member, friend or business associate of the Director) has a financial interest in a company that has business dealings with the TSHC, and the Director is involved in any process related to a business transaction involving the TSHC , this could be a conflict of interest.

2. Gifts or Donations

Subject to the other provisions in this Policy, Directors shall not solicit or accept any fees, advances, gifts, money, personal discounts, donations, personal benefits, meals, tickets, personal loans or the like from a resident, tenant or any other person or entity that has, or might have, business dealings with the TSHC for the purposes of, or that may be perceived to be for the purposes of, influencing an act or decision of the Directors.

The exceptions are gifts of a nominal value, which do not influence or would not be perceived as influencing, the performance of the Director’s duties.

In determining “nominal value”, consideration should be given to if the gift could reasonably be seen as an attempt to influence a decision on any matter or transaction. In this regard, consideration should be given, in turn, to the circumstances, nature, and timing of the gift. For example, a Director should not accept:

• any meals;
• offers to make a donation to a charitable cause on the Director’s behalf; or
• an invitation to an event at the expense of another individual.

3. Personal Relationships

Directors should always maintain a professional relationship with their colleagues on the Board and with Stakeholders, i.e., individuals, groups and entities with whom the TSHC has dealings including (but not limited to) tenants, contractors, suppliers and vendors. However, the TSHC acknowledges that Directors may have personal relationships with individuals with whom the TSHC has dealings from time to time.

Tenant Directors of TSHC will have ongoing personal relationships with other tenants and with staff as residents of TSHC buildings which do not constitute conflict of interest except as specified in 7 (d) ii below.

Directors shall take all reasonable steps to manage these relationships so as to avoid conflict-of-interest situations (whether actual, potential, or apparent).

An example is if a Director were to have access to a TSHC-operated building and has direct contact with a friend or family member who is a tenant or resident in the building or has access to the information of friends or family because of their position as a TSHC Director, as this could result in a conflict of interest.

As another example, if a Director were to be involved in the TSHC hiring process for, or will supervise, family, friends, or business associates (past or current), this could give rise to a conflict of interest.

4. Handling of Complaints

The Board of Directors recognizes the value, commitment and support of Stakeholders and it follows that they should welcome Stakeholder comments, suggestions, and complaints provided by them and made in good faith with a view to improving the TSHC.

If a Director receives a Stakeholder complaint or comment, the following steps shall apply:

1. For complaints or comments about the operations or policies of the TSHC:
   1. The complaint shall be forwarded to a senior TSHC executive officer for appropriate handling and The Director may notify the complainant of such forwarding and the senior TSHC executive officer will inform the Director of the disposition of the complaint.
   2. Directors shall not communicate with TSHC staff for the purpose of influencing or interfering in the equal and fair administration of TSHC repairs, programs or operations;
2. For complaints or comments relating to the integrity of a TSHC staff member, the complaint shall be forwarded to a senior TSHC executive officer; and,
3. For complaints or comments relating to the integrity of a Director, the complaint shall be forwarded to the Board Chair.

5. Outside Activity

Reference is also made to paragraph 7 dealing with Reporting and Resolving a Conflict of Interest.

a) Other Board/Committee Positions

If a Director accepts a position on a board or committee of a commercial or non profit entity, timely disclosure of this involvement must be made to the TSHC, in order to assist the TSHC in preventing any conflicts of interest between the two entities. For example, accepting a board position with a TSHC supplier would be a conflict. Reference is made in this regard to paragraph 7 below as to how such matters should be reported.

b) Political Involvement and Charitable Activity

The TSHC respects a Director’s right to be involved in the political process and community activity, subject to the possible requirement of taking a leave of absence from the Board as outlined in paragraph 10 below. When a Director engages in political or civic affairs, the Director’s views and actions are his or her own, not those of the TSHC and any statements made by the Director must not be attributed to the TSHC.  Reference is made in this regard to paragraph 7 below as to how such matters should be reported.

6. Exclusivity and Business Opportunities

During the course of his or her tenure on the Board of Directors, a Director may come across business opportunities that have potential for exploitation. However, over the course of her or his tenure on the Board, these opportunities belong to the TSHC and not to the Director personally.

Any business opportunities of any kind whatsoever and howsoever arising and relating to the business of the TSHC that become known to the Director during his or her tenure on the Board shall be pursued for the benefit of the TSHC only.

7. Reporting and Resolving a Conflict of Interest

a. What should a Director with a conflict of interest do?

Reporting the Conflict. A Director shall make a timely and full disclosure of any actual, potential or apparent conflict of interest.

The Director shall report in writing the facts and circumstances of the matter or transaction to the Board Chair and the Director shall govern himself or herself in accordance with the instructions received from the Board Chair.

Refraining from participation. The Director shall not participate in any formal or informal discussion of, any decision or vote on, or any attempt to exert influence over the contract, relationship, person or organization with respect to which the conflict may relate. A Director in this case, though, may be counted to establish a quorum for meetings.

Recusal. The Director shall temporarily recuse himself or herself from meetings in order to allow the remaining members of the Board or a Committee of the Board to engage in a full discussion regarding the impugned matter or transaction.

Refraining from voting. If a vote is taken in respect of the impugned matter or transaction, such Director shall abstain from voting and the minutes of the Board or Committee meeting shall record this fact if it has occurred.

b. When must Directors disclose conflicts of interest?

When they join the Board of Directors, Directors shall submit a written statement (in paper or digital form) concerning conflicts of interest. The Directors shall disclose in such statement all conflicts of interest that they know about and the nature and extent of such conflicts of interest.

For conflicts of interest after that time, Directors shall disclose them no later than the first Board of Directors meeting following the moment where they realized they had a conflict of interest.

c. What information do Directors have to disclose?

Directors shall disclose the nature, value of and any relevant details of the conflict of interest.

d. Do these requirements apply to all Conflicts of Interest?

1. Subject to the following, the requirements outlined in this paragraph 7 apply whenever there is an actual, potential or apparent conflict of interest unless the matter or transaction giving rise to the conflict of interest is one with an “affiliate”.
   In the case of a matter or transaction with an affiliate, the reporting requirement for a conflict of interest that is outlined in this paragraph 7 continues to apply; however, the other requirements (namely, Refraining from Participation, Recusal and Refraining from Voting) do not apply to conflict-of-interest matters or transactions with an “affiliate”.¹ To satisfy the requirement for reporting in the case of a conflict of interest with an “affiliate”, a Director should declare their interest in the “affiliate” immediately and then annually thereafter, in writing, to the Board Chair.
2. TSHC, through its Shareholder Direction includes Directors who are tenants of In general, tenant Directors are not expected to declare their interests with other tenants and can participate in all discussions and voting at the TSHC Board meetings unless there is an item that is specific to the interests of the tenant Director, or friends or family who are tenants as outlined in paragraph 3. Director should declare their conflict of interest to the Board Chair.

8. Documentation of Conflicts

The minutes of any meeting at which a transaction or matter involving a conflict of interest or an appearance of a conflict of interest is considered shall reflect whether the Director (as the case may be) made disclosure, withdrew himself or herself from the consideration of the transaction or matter, recused him or herself from the meeting room itself and abstained from voting on the impugned transaction or matter.

9. Failure to Disclose a Conflict and Remedies

If any Director has reasonable cause to believe that a Director has failed to disclose a conflict of interest, the Director shall inform the Board Chair of the basis for such a belief. The Board Chair shall then afford such Director an opportunity to explain the reported, alleged failure to disclose. If the Board Chair determines, after hearing any response given and making such further investigation as may be warranted by the circumstances, that such Director has in fact failed to disclose a conflict of interest, the Board Chair shall take appropriate action, which may include a recommendation to the Board that the Board request the City of Toronto to remove such Director from the Board of Directors, as well as the reconsideration of whether the matter or transaction was in the best interests of and fair and reasonable to, the TSHC at the time it was undertaken.

10. Leave of Absence

Directors shall notify the Board Chair in order to request a leave of absence. By way of example, Directors must be on an approved leave of absence in order to:

1. Seek a provincial or federal candidacy nomination or participate as a candidate in a municipal, provincial or federal election campaign, where the nomination process or the candidacy may conflict with the interests of the TSHC or may adversely affect the performance of the Director’s duties;
2. Apply for a position with the TSHC; or,
3. Any other event that may conflict with the interests of the TSHC or may adversely affect the performance of the Director’s duties.

Compliance and Monitoring

Directors must comply with this Policy at all times. Directors should use proper judgment and act in the spirit of this Policy at all times.

Contravention of this Policy is a serious matter. Non-compliance includes failing to declare a conflict of interest in accordance with this Policy. In some cases, non- compliance can also lead to legal action by TSHC.

Governing and Applicable Legislation

• Business Corporations Act, S.O. 1990, c.B.16

Related Policies and Procedures

• Code of Conduct for Directors of the Board (Date)
• Code of Conduct (Date..)
• By-Law 1-2021

Commencement and Review

 ¹ The TSHC is a corporation organized under and subject to, the provisions in the Business Corporations Act of Ontario. Paragraph (c) of sub-section 132(5) of this legislation provides in part, that a director of a corporation who is party to a material contract or transaction with the corporation or who has a material interest in a material contract of transaction with the corporation shall not attend a meeting of directors during which the impugned contract or transaction is discussed and shall not vote on any resolution to approve the impugned contract or transaction unless the contract or transaction is one with an affiliate. For these purposes and as applied to the TSHC, “affiliate” refers to any City corporation or agency, including Toronto Community Housing Corporation (“TCHC).

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Director Education and Board Development Policy

Policy Summary

Members of the Board of Toronto Seniors Housing Corporation (TSHC), as fiduciaries, have both a duty of loyalty and good faith, and a duty of care, diligence and skill. A Board member’s conduct is measured against an objective standard that requires informed decision-making and the discharging of duties responsibly.

While it is expected that Board members will possess sufficient knowledge, experience and expertise at the time of their appointment to serve in such capacity, it is also recognized that they will not necessarily be experts in all disciplines, in all aspects of governance, or in all business area within TSHC. As such, education and learning is a key driver of continued Director and Board effectiveness and is an ongoing responsibility of individual Board members, the Board, Management and the Corporation.

The Director Education and Board Development Policy lays out the responsibilities and expectations of the Corporation, the Board and individual Board members with respect to developing the knowledge and abilities to govern effectively.

Policy Statement

TSHC’s Board of Directors and individual Board members are committed to director education and board development.

The Board will balance the important need for education with financial prudence as stewards of the Corporation.

Policy Purpose

The objective of the Director Education and Board Development Policy is to equip Board members to add value to the Corporation, provide effective oversight and fulfill their fiduciary responsibilities to the corporation.

To fulfill the objective, the policy sets out the responsibilities and expectations of the Corporation, the Board and individual Board members regarding:

• Orientation;
• Director Education;
• Board Development; and
• Administration and Reporting of Board-related education and development activities

Policy Scope

This policy applies to all current and new Board members and to the Board of directors in general.

Policy Details

A. Board Orientation

TSHC and its Board believe that properly oriented Board members are more effective directors; that more effective directors make for more engaged and effective boards; and that more engaged and effective boards provide greater strategic value to the Corporation, its Shareholder, its Tenants, and to the Chief Executive Officer and Management.

As such, TSHC will design and maintain an in-depth orientation program for new Board members. The Board Chair, Chief Executive Officer (CEO) and Corporate Secretary will ensure that the orientation program is designed to provide baseline knowledge to enable:

• New Board members to actively contribute to the work of the Board in a timely manner; and
• Productive and effective boardroom participation and understanding of the TSHC and the industry and environment within which it operates.

TSHC and its Board believe that some aspects of orientation should be standardized to ensure consistency among Directors. However, to be most effective, the onboarding process should also be tailored to each new Board member. As such, TSHC will tailor the orientation program as appropriate and feasible for each new Board member, taking into account their unique mix of skills, experience, education, and knowledge.

TSHC and its Board believe that the orientation of new Board members should not be viewed simply as a single orientation meeting. Instead, orientation will deliver information over a period of time to minimize the likelihood of overload and maximize lasting impact.

At a minimum, the compulsory orientation program should:

• Provide each new Board member with an understanding of the formal governance structure, the constitution, the bylaws and other constating documents, the role of the Board, its supporting committees, and the expectations with respect to individual Board member performance;
• Build an understanding of the Corporation’s nature; its operations and working environment, including the Corporation’s programs and services and summary details of the Corporation’s principal assets, liabilities, major contracts and major stakeholders; the Corporation’s structure; the Corporation’s major risks and its risk management strategy; key performance indicators; operational or regulatory constraints; and requirements for reporting and public disclosure;
• Build a link with the individuals who make up the Corporation, including opportunities to meet and get to know fellow Board members, meetings with Senior Management and site visits to view the Corporation’s operations and meet employees and tenants;
• Build an understanding of the Corporation’s main relationships, including key government representatives who deal with the Corporation, and people served by the Corporation;
• Foster an understanding of the public housing sector and the environment in which TSHC conducts its business; and
• Provide a comprehensive set of written briefing materials that Board members may use as reference materials. These materials should include biographical and contact information for all board members and the executive team; the corporation’s governing Acts, regulations, by- laws;
• the Corporation’s governance policies; the current strategic plan; the current annual work-plan; the most recent annual and/or quarterly financial and accountability reports; an explanation of the Corporation’s key performance indicators; a summary of Board member’s and officer’s liability insurance and indemnity; details of any major litigation involving the Corporation; minutes of the last year’s Board meetings; details of Board committees and copies of the minutes from the last 3-6 meetings if a new Board member will be joining a specific committee; a schedule of dates for upcoming board meetings; and website references.

All new Board members are expected to receive orientation materials and attend an initial board orientation meeting within the first two months of appointment to the Board or a new Board being constituted. A second, follow-up session will be scheduled after several meetings have been held to round out the orientation process.

Individual board members may inform the Board Chair, Corporate Governance and Human Resources Committee Chair and/or the Corporate Secretary of additional information or education needs to supplement the compulsory orientation program received.

B. Director Education

TSHC and its Board believe in the professionalism of directors and recognize the importance of ongoing director education as a means of strengthening the effectiveness of individual Directors.

TSHC and its Board believe that each Board member is responsible for their ongoing director education and that the corporation should support Directors in their pursuit.

The Corporate Governance and Human Resources Committee and Corporate Secretary are available to make learning recommendations to Board members who believe they need to be better equipped in order to fulfill their responsibilities.

Ongoing director education includes both formal and informal learning opportunities.

Formal Director Education

TSHC and its Board recognize the value of formalized learning environments for Directors such as classroom-based and online courses.

As such, Board members are encouraged to seek out external formal learning opportunities. Because the Corporation recognizes that financial competency is a key skill for all Board members, Board members who do not have a strong financial background are encouraged to seek out opportunities for financial essentials training to develop a certain level of comfort and competence with financial statements and the financial discussions and decision- making relevant to the Board of Directors.

Board members, and particularly the Chair of the Board, who may not already possess a director post-nominal designation, are encouraged to obtain such from a recognized Canadian or international accrediting body.

The Corporate Secretary shall make Board members aware annually and from time to time about relevant courses and other external formal educational opportunities.

Informal Director Education TSHC and its Board recognize the value of informal learning achieved through such external sources as membership in relevant professional organizations, subscriptions to relevant journals and attendance at relevant seminars or conferences.

TSHC shall support in the most cost-effective arrangement, memberships for each director in an organization committed to corporate governance and director professionalism.

The Corporate Secretary shall make Board members aware annually and from time to time about relevant external informal learning opportunities.

The Corporate Secretary shall from time to time provide relevant governance articles, magazines, websites or book summaries accompanied by management commentary on the implications for TSHC as part of board and committee packages to enable self-study by board members.

C. Board Development

TSHC and its Board recognize the value of group learning. Team- based development is intended to improve the Board’s decision- making by providing equal information to all Board members on important subjects, enabling Board members to interact on key issues that can often be critical to pending decisions and reinforcing key issues the Board faces in the context of its role and responsibilities as a board.

TSHC will establish a board development program annually. In developing this program, the Corporate Governance and Human Resources Committee and the Corporate Secretary shall:

• Undertake a process of polling Board members as a means of identifying issues or topics for which Board members believe they need to update their skills and knowledge of the Corporation, its business and key executives and to address ongoing and emerging issues in the functional areas of the Board (i.e. corporate governance, audit, risk management, real estate and development, tenant services);
• Reflect upon key strategic directions of the Corporation, major decisions on the horizon, appropriate and significant risk management themes and the landscape within which TSHC operates; and
• Prioritize topics for focused education sessions at regular Board meetings, special meetings or retreats devoted to education, or other suitable

The Board development program will reflect the needs and interests of the Board by including:

• Regular presentations by Management and Staff to the Board and Committees to educate them and keep them informed of changes within TSHC and in the legal, regulatory and industry requirements and standards;
• Trips to various operating sites; and
• Drawing upon external resources where appropriate, including presentations by outside experts to the Board or committees on matters of particular importance or emerging significance.

Policy Administration

The Board will receive from the Corporate Governance and Human Resources Committee annual recommendations for budget allocations to support effective director education and board development.

Course, seminar and conference attendance is specifically discouraged where costs of attendance are high and/or extensive travel is required.

Research, fact-finding, study and related trips abroad are discouraged where there are more cost-effective means of gathering information and knowledge.

Course, seminar and conference attendance, and other educational costs by individual directors may be reimbursed from the Board education and development budget only as follows:

• Where the expenditure is pre- approved by the Chair of the Board or the Chair of the Corporate Governance and Human Resources Committee;
• Where the expenditure is directly related to organizational governance, board effectiveness, or the business and operations of the corporation;
• Where the board member seeking reimbursement provides a written report to the Governance, Risk and Human Resources Committee on the results of and their view on the value of the expenditure; and
• Where all requirements are met from the approved Board Reimbursement of Expense

Policy Compliance and Reporting

Board members shall annually report on their formal and informal director education activities to the Corporate Governance and Human Resources Committee.

The Corporate Governance and Human Resources Committee will provide the Board with an annual report setting out the educational and development activities completed by

Consistent with high standards of governance transparency and the objectives of the corporation’s shareholder to ensure highly qualified and effective board members, the Corporate Governance and Human Resources Committee will annually and publicly disclose the steps taken by the Board and its members to comply with this policy.

Related Policies and Procedures

• Board Reimbursement of Expense Policy
• Code of Conduct for Board of Directors
• Conflict of Interest for Board of Directors

Policy Commencement and Review

This policy takes effect on (insert date of Board approval of policy)

The Corporate Governance and Human Resources Committee will review this policy, including the orientation program annually.

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Board of Directors Meeting Procedures Policy

CGHRC meeting March 11, 2022

Revised by Michael Sherar – March 18, 2022

Approved by Board on March 31, 2022

Rules of Order

All points of order or procedure for which rules have not been provided in this policy will be decided by the Chair as far as is reasonably possible first, in accordance with the rules of parliamentary procedure as contained in the current edition of Robert’s Rules of Order.

Schedule of Regular Board Meetings

At the beginning of each calendar year, the Board will set a schedule of regular meetings for the year for the Board of Directors and for Committees of the Board.

Meetings are usually held at 423 Yonge St. in the 2nd floor boardroom with a regular start time of 8:30 a.m. Board members are encouraged to attend in person but can join by videoconference or telephone if in-person attendance is not possible.

When meetings of the Board of Directors or of a Committee of the Board cannot be held in person, the meeting may be held by means of conference, electronic or other communications facilities to permit all persons participating in the meeting to communicate with each other, simultaneously and instantaneously. Any director participating in such a meeting by such means is deem ed to be present at the meeting.

Directors will be notified ahead of time of any changes to the schedule, time and/or location of the meeting.

Cancellation and Rescheduling of Meetings

Meetings may be rescheduled or cancelled in the event there is not quorum or for any reason necessitating the meeting change. The Corporate Secretary, in consultation with the CEO and the Board Chair, may take appropriate steps to advise all Directors of the cancellation and/or rescheduling of meetings. Notice of change is also to be posted on the Toronto Seniors Housing Corporation website and in Operating Unit offices.

If a regularly scheduled meeting of the Board is cancelled without being rescheduled, the next regularly scheduled meeting cannot be cancelled without being rescheduled.

Special Meetings

The Board Chair or any two directors may convene a special meeting of the Board at any time by giving formal notice not less than 48 hours to all Directors before the time of the meeting. Notice must be delivered or sent electronically or other form of written transmission to each Director. Notice, along with any agenda material must indicate the time, place and matter to be dealt with.

Board Workshops

Throughout the year, orientation sessions, workshops or training sessions for the Board may be called. No formal business of the Board will be carried out at these sessions. These sessions will not be open to the public.

Attendance

• Members will notify the Secretary if they:
  1. will not be attending;
  2. will be arriving late for; or
  3. will be leaving early from any meeting of the Board or a committee.
• The Secretary will advise the Board of any Member who has been or will be absent from meetings of the Board for three consecutive months and advise the Board of the explanation provided by the Member, if any. The Board will then decide whether to authorize the Member’s absence by a Board resolution.
• The Board will notify City Council of a vacancy if any Member is absent from Board meetings for three consecutive months without authorization of the Board.

Quorum

1. The quorum for Board meetings is a majority of the
2. A meeting will be cancelled if:
   1. no quorum is present within thirty minutes after the time fixed for a meeting, or the continuation of a meeting after a recess; or
   2. if quorum is lost for thirty consecutive minutes.
3. If a meeting is cancelled due to lack of quorum:
   1. the Secretary will record the names of the Members present; and
   2. the meeting will be considered adjourned until the next scheduled meeting or until the Chair calls a special meeting.
4. If a quorum is not possible because of declared conflicts of interest the remaining Members will constitute a quorum provided that quorum is never less than two Members.

Chair of Meeting

The Chair of any meeting of the Board of Directors shall be the Board Chair. If the Board Chair is not available, the Vice-Chair, if available, will assume the Chair of the meeting. If neither the Board Chair nor the Vice-Chair are available, another director who is present at the meeting and selected by the directors who are present, may assume the Chair of the meeting.

Agendas and Minutes

The agenda and any other agenda material such as minutes and reports shall be delivered to members of the Board of Directors or members of the Committee of the Board no less than 24 hours before the meeting.

Toronto Seniors Housing Corporation has a standard practice of sending agenda materials out to directors one week prior to the meeting. Meeting notices are posted in tenant buildings and the agenda materials are posted on the TSHC website five days in advance of the meeting.

While the standard is to have all agenda items available in advance of the meeting, there are times where this is not always possible (e.g., items are not available or come up after the agenda has been issued). At the Board Chair’s discretion, reports may be tabled at the meeting.

• The Secretary will keep minutes of all Board and Committee
• The minutes will record:
  1. the place, time and date of the meeting;
  2. the name of the Chair, the Members present, and the Members absent;
  3. any correction to, and the adoption of, the minutes of the previous meeting;
  4. all resolutions;
  5. any declarations of a conflict of interest, including the Member’s name and the reason for the conflict of interest.

• Reference will be made in the minutes to an agenda item discussed in a closed meeting and the reason why the discussion was closed to the
• The minutes will record that a Motion was carried or defeated, with no count of the vote, unless the vote was For recorded votes, the Members’ name and corresponding vote will be recorded in the minutes after the Chair has announced the results.
• The minutes of the previous meeting will be considered at the next meeting and, after the minutes have received approval, or approval as amended, by the majority of the Members present, they will be signed by the Chair or the appropriate Committee chair.

Review of Agenda

Upon calling the meeting to order, the Board or Committee Chair will request directors to identify any conflicts of interest with any item on the agenda.

Declaration of Conflict of Interest

1. Members must observe the requirements of the Conflict of Interest Policy by declaring any conflict of interest they have, directly or indirectly, in any matter before the Board.
2. A Member must declare any conflict of interest at the beginning of the meeting, on arrival at the meeting, or if not present at the meeting, at the next meeting attended.
3. A Member who has declared a conflict of interest in a matter must not take part in the discussion, must not vote, and must not try to influence the voting, on the matter.
4. If the discussion takes place in a closed meeting, the Member must leave the room or by electronic means if attending by telephone or videoconference.
5. All declarations of conflict of interest are recorded in the public minutes. Declarations of conflict of interest made in public must also specify the general nature of the interest declared.

Voting on Motions

1. All matters will be decided by a majority vote of the Members
2. A Member must be present when the Motion is put in order to
3. All Members present when the motion is put to the vote must vote, unless prohibited by statute, in which case it shall be so Any Member who refuses to vote is deemed to have voted against the Motion except where prohibited from voting by statute.
4. The Chair or Acting Chair must vote with the other Members on all
5. Voting on all Motions will be by a show of
6. In the event of a tie vote the Motion is
7. A Motion to reconsider is required to reopen a matter once the result of the vote is announced.

Recorded Vote

1. The Chair will conduct a recorded vote if requested by any Member.
2. The request must be made immediately before or after the taking of the vote.
3. The Secretary will record the name and vote of every Member for the minutes and announce the results to the Chair.
4. Results of the vote, including the name and vote of every Member, will be announced by the Chair immediately after the recorded vote has taken place.

Public Proceedings

Public proceedings of the Board are open to members of the public. As such, the public are notified of all public meetings. Reports and other items which are part of the public proceedings and any debate and voting of such items are open to the public.

Conduct of Public at Meetings

• Members of the public will be courteous and will not engage in any action which disturbs the meeting.
• Members of the public will not:
  1. make any noise or disturbance that prevents Members from being able to participate in the meeting;
  2. address the Board without permission;
  3. use unparliamentary or offensive language; or
  4. display signs or placards.

• The Chair may exclude any person from the meeting for improper conduct.

“In Camera” and Closed Proceedings

“In camera” and closed proceedings (meetings that are not open to the public) may take place according to the Toronto Seniors Housing Corporation (TSHC) Board Meeting Closed Session Policy.

 Prior to the commencement of an “in camera” or closed meeting, a motion must be made to move “in camera” or to closed meeting. At the conclusion of the “in camera” or closed meeting, the Board Chair, if applicable, will announce the time of the resumption of the public meeting.

Public Presentation

Any person wishing to make a presentation to the Board regarding items for action or information on the agenda will be heard by the Board provided:

1. A request to make a presentation is made to the Secretary, in writing by 12:00 m. on the business day prior to the Board meeting.
2. Include the name, address, telephone number and electronic mail address of the person or organization wishing to address the Board;
3. Include an outline of the submission to be made, and any relevant documentation;
4. The Chair in consultation with the Secretary may waive the above requirements if, in the Chair’s opinion, there were extenuating circumstances or the presentation would no longer be relevant if made at another meeting.

The Board may hear a presentation about a matter not on the agenda with the approval of the Chair in consultation with the Any request to present to the Board on a matter not on the agenda must: 

1. pertain to matters within the Board’s jurisdiction;
2. be received prior to the Agenda Deadline;
3. be in writing and sent to the Secretary;
4. include the name, address, telephone number and electronic mail address of the person or organization wishing to address the Board;
5. include an outline of the submission to be made, and any relevant documentation.
6. The Chair and Secretary may agree to schedule the presentation on the agenda of the next Board meeting or another future meeting of the Board or a Committee of the The Chair and Secretary may refer matters of TSHC administration or operations to the CEO.

While it is preferred that deputants inform the Board Secretary of their intention to depute it is not a requirement, however stakeholders who wish to ensure that their concerns can be adequately addressed by Directors at the meeting may submit a written or alternate format* copy of their deputation at least 3 days ahead of the meeting in order to allow enough time for:

1. 1. the distribution of deputation materials to Board/Committee members for their review prior to the meeting
   2. information-gathering by the Board/Committee Chair and/or Board/Committee members
   3. briefing of Board/Committee members on the issues raised
   4. clarification of issues/concerns raised

Each presentation is limited to five minutes regardless of the number of items or matters a presenter wishes to speak to (excluding questions from Board Members). This time may be reduced or extended at the discretio n of the Chair.

Presentations from groups or organizations shall have no more than three speakers. The number of speakers does not affect the total time limit for a presentation.

1. Any person making a presentation to the Board shall
   1. only speak on the subject(s) for which they have received approval;
   2. obey the rules of procedure and any decision of the Chair;
   3. refrain from using offensive language;
   4. refrain from speaking disrespectfully of another person.
   5. Failure to abide by these rules is grounds for the Chair to conclude or curtail a presentation. If the Chair rules that the presentation is concluded, the person or persons appearing before the Board shall immediately withdraw.

Conduct of Members at Meetings

1. A Member will be courteous and will not engage in actions which disturb the meeting.
2. Members will inform the Chair each time they leave or re-enter the
3. A Member will not:
   1. use unparliamentary or offensive language;
   2. make any noise or disturbance that prevents Members from being able to participate in the meeting;
   3. interrupt another Member who is speaking, except to raise a Matter of Privilege or a Point of Order;
   4. disobey the rules of the Board, or disobey a decision of the Chair or the Board on questions of order, practice, or on the interpretation of the rules of the Board.
4. The Chair may exclude a Member from the meeting who has been given a warning but continues to disregard the Chair’s rulings by the following process:
5. 1. 1. the Chair shall without debate put the question, “Should the Member be ordered to leave his or her seat for the duration of the meeting?”
      2. If the Board votes in the affirmative, the Chair will order the Member to leave his or her seat for the duration of the meeting;
      3. If the Member apologizes, the Chair, with the approval of the Board, may permit him or her to resume his or her seat.

New Business from Board Members

A member who wishes to add new business to a meeting agenda brings a Main Motion before the Board and will provide the Board with notice as follows:

1. Notices of Motion by Board Members submitted before the Agenda Deadline must be in writing and in a form that the Secretary approves and be signed by the Board member moving it and the Board member who seconds it. No signatures are required for notices received via email, but the seconder’s name must be included in the correspondence and the seconder must be copied on the email.
2. Notice of Motion by Board Members after the Agenda Deadline, but before the Board meeting:
   1. must be in writing and in a form that the Secretary approves and be signed by the Board member moving it and the Board member who seconds No signatures are required for notices received via email, but the seconder’s name must be included in the correspondence and the seconder must be copied on the email;
   2. must relate to an Urgent Matter as determined by the Chair and the Secretary.
      If the Secretary and Chair do not agree that the Motion deals with an Urgent Matter, the Secretary will refer it to the next Board meeting and present a list of these Motions to the Board for information only.
      A Motion that fails to comply with the notice requirements in subsections (b) (i) and (ii) may be considered by the Board if a two-thirds majority of the Members present vote in favour of its introduction.
3. Motion without Notice during a Board meeting:
4. 1. a Member may make a Motion without notice during a meeting if it complies with the requirements outlined here
   2. the Chair reviews it in advance and the Chair agrees that it concerns an Urgent Matter and allows the Member to ask the Board’s permission to introduce the Motion without notice; and
   3. two thirds of all Board Members vote in favour of its introduction.

Communications

• Communications may be made in writing addressed to the Board, to the Chair or to the Secretary.
• Communications must:
• 1. pertain to matters over which the Board has jurisdiction;
  2. be in a legible hand-written or printed form;
  3. contain a name, address and/or telephone number, and an electronic mail address if delivered by electronic mail;
  4. contain a signature unless delivered by electronic mail;
  5. not contain offensive language.
• All communications, including personal information and opinions contained in a communication, that the Board receives about a matter on the agenda becomes part of the public record, unless the Secretary determines the disclosure of personal information would contravene the Municipal Freedom of Information and Protection of Privacy Act.
  Communications that form part of the public record are available to the Board and to the public and may be distributed prior to, or during, the Board or Committee meeting.
• Communications that the Board receives about a matter on the agenda may be provided to the Board if received by the Secretary by 12:00 p.m. on the business day prior to the Board meeting. The Chair in consultation with the Secretary may waive these requirements if, in the Chair’s opinion, there were extenuating circumstances.
• For communications about matters not on the agenda the Chair, with the recommendation of the Secretary may:
  1. put the communication before the Board,
  2. allow the CEO to consider the communication and to report to the Board, or to a Committee, in response to the communication; or
  3. allow the CEO to respond to the communication as the CEO deems appropriate

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Board of Directors Reimbursement Policy

Summary of Policy

This policy sets out the guidelines for directors of the Board to be reimbursed for reasoned expenses incurred in exercising their responsibilities as a director.

This policy is designed to be consistent and compliant with the Shareholder Direction from the City of Toronto to Toronto Seniors Housing Corporation, as well as the City of Toronto’s Expense and Travel Reimbursement Policy For City Agencies, Boards, Commissions and Corporations.

Introduction

It is expected that in the course of exercising duties, expenses may be incurred by members of the Board of Directors. Pursuant to Section 5.5 of the Shareholder Direction between the City of Toronto and the Toronto Seniors Housing Corporation (TSHC), TSHC will reimburse Directors for reasonable expenses.

 Policy Statement

TSHC will reimburse Board members for all reasonable expenses incurred in exercising their responsibilities as a Director. This policy will ensure that reimbursement is done in an accountable and transparent manner.

Application of Policy

This policy applies to:

• All expenses incurred by a director in performing their duties and responsibilities as a member of the Board and/or on behalf of the Board such as:
• Representing TSHC at conferences, gatherings, meetings;
• Being asked to undertake certain specified activities for the Board; and
• Participation in TSHC Corporate and Community events to which they have been formally asked to attend on behalf of THSC in their capacity as a Director.

Policy Guidelines

General Expenses Eligible for Reimbursement

A Director may be reimbursed for all Board- related activities, including such expenses as:

• Meals (related expenditures that are incurred in the course of conducting the business of the Board or where the Director is entertaining a guest of the Board);
• Parking when attending meetings and event for the express purpose of fulfilling duties or expectations as a Director of THSC; and
• Any other expenses resulting from activities that are appropriate to fulfilling their role as a Director of TSHC.

Conference Expenses Eligible for Reimbursement

All TSHC travel by a Director must be approved in advance. Directors who are authorized to attend conferences on behalf of TSHC shall be reimbursed for related expenses including:

Travel Expenses

• Travel costs must be based on economy fare rates, unless otherwise authorized by the Directors may not use travel agents who charge service fees.
• Directors who use a personal car must claim the current per kilometer rate, as determined from time to time by TSHC to be consistent with City of Toronto rates and practices.
• Board members who use their own vehicle instead of traveling by air will be reimbursed at the rate of economy class airfare or the current approved mileage rate, whichever is less, unless specific rationale and authorization has been given for reimbursement at a higher rate.
• Other allowable expenses include taxis, shuttles, local transportation and parking, related to their role at the conference as a representative of TSHC.
• Reimbursement for TTC costs will be provided whenever a board member is required and authorized to travel on board business.

Accommodation Expenses

• Eligible accommodation will be a single room at government rates, if available.

Meal Expenses

• Meals not covered with the conference fees will be reimbursed at actual cost or up to $65 Canadian funds and up to $65  .S. funds per day outside Canada.). No receipts are required. Where some or all meals are included in the conference / seminar, the per diem must be reduced accordingly.
• Alcohol charges will not be

Other Business Expenses

• Reasonable incidental and business expenses, including faxes, photocopies, courier charges, telephone calls, and mail services will be reimbursed when those expenses are in support of TSHC
• Incidental childcare expenses as a result of attending Board meetings or on authorized Board business may be reimbursed where the Board deems financial hardship would otherwise Receipts must be provided.

Submission of Expenses for Reimbursement

• All expenses must be reasonable and necessary to the business of the TSHC Board and must be within the budgetary parameters established by the Board of Directors.
• All expenses by Directors must be properly documented and retained in a format which may be reviewed by the Board, or a delegation thereof, from time to time.
• Acceptable proof of payment (e.g., receipts) must be submitted with any request for reimbursement.
• The acceptability of proof of payment will be determined by the Chief Executive Officer.
• Claim forms must be signed, both by the member making the claim and the Chair of the Board certifying that the expenses claimed were incurred in performance of the claimant’s TSHC duties and authorizing the claim, before submitting it to TSHC Staff for Another Board Member must sign the claim form for the Board Chair. (This can be submitted electronically and not necessarily in paper format).
• It is within the responsibility of the claimant to submit all expense claims for reimbursement within 30 days of the expenses being incurred.
• If TSHC is reimbursing the claimant for only a portion of an expense and the claimant requires the proof of payment to make another claim, the proof of payment will be returned to the claimant with the notation on it of the portion reimbursed by TSHC.

Accountability

• The Chief Executive Officer will determine acceptable forms of proof of payment.
• Expense claims must be signed by the claimant and countersigned by the Chief Executive Officer or designate certifying that the expenses claimed were incurred in performance of the claimant’s TSHC duties.
• TSHC will monitor expense claims to ensure that budgetary parameters established by the Board of Directors are not
• TSHC will report to the Chair on all expenses claimed on a yearly basis.
• The Board shall report annually to the Shareholder the total expenses paid to each Director using the protocols established by the City’s Chief Financial Officer & Treasurer.
• TSHC will retain all expense claim forms and submitted receipts which may be reviewed by the Board, or a delegation thereof, from time to time.

Policy Review

This policy will be reviewed as required.

Approvals

Approved by the TSHC Board of Directors, (insert date).

Policy Contact

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Board of Directors Code of Ethics and Conduct Policy (Approved)

I. INTRODUCTION

The Board of Directors (the “Board”, or individually, the “Director(s)”) of the Toronto Seniors Housing Corporation (the “Corporation” or “TSHC”) has adopted this Code of Ethics and Conduct (the “Code”) for itself, and for the boards of its subsidiaries. Tenants, city residents and the City of Toronto, as both service manager under the Housing Services Act, 2011, and as shareholder of the Corporation, are entitled to expect the highest standards of ethics and conduct from the Directors appointed to the Board. When these standards are not met, this policy sets out how deficiencies in conduct should be managed.

Scope

The Code applies to all members of the Board of Directors of TSHC and of all board members of subsidiary corporations of TSHC.

Guiding Principles

The following principles shall be adhered to in the governance of the Corporation:

• Directors shall serve and be seen to serve the Corporation honestly and in good faith with a view to the best interests of the Corporation in a conscientious and diligent manner; and
• Directors shall serve the interests of the Corporation by upholding both the letter and the spirit of all applicable federal and provincial legislation and regulations, the articles and by- laws of the Corporation, the Shareholder’s Direction and approved policies of the Board.
• The Board is expected to model and promote an inclusive culture, while ensuring the best interests of the Corporation are always served.

While the above principles govern Directors in the performance of their responsibilities, the Board shall also take into account the viewpoints of tenants, city residents, the service manager and shareholder in all of its deliberations and in the decisions it makes.

Requirements of Individual Directors

Directors must be familiar with and adhere to the requirements set out in the Code of Ethics and Conduct.

Directors have a responsibility to be familiar with any legislation or regulations that apply to their Directorship and to be able to recognize potential requirements.

Directors must exercise good judgment in applying the standards of conduct to any particular situation in the spirit intended.

Administration of the Code

The Corporate Governance and Human Resources Committee (the “CGHRC”) is responsible for the proper administration of this Code. The CGHRC Chair shall be responsible for applying the Code consistently and fairly to all Directors.

II. LEGAL STANDARDS OF CONDUCT

Statutory and Other Provisions Regulating Directors’ Conduct 

While many statutes impose specific requirements on directors of corporations, the principal statutes governing the activities of TSHC Directors are as follows:

• The Ontario Business Corporations Act;
• The Housing Services Act, 2011; and
• The Municipal Freedom of Information and Protection of Privacy Act.

The corporate documents that generally regulate the activities of the Directors of TSHC are:

• The Articles of Incorporation.
• By-law 1 as may be amended or replaced from time to time;
• This Code; and
• The general policies of the Corporation, with all necessary changes read thereto to be applicable to the Board of Directors, as may be amended from time to time.

Duty of Loyalty

 As part of their legal duty of loyalty, Directors must:

• Act honestly and in good faith with a view to the best interests of the Corporation:
• Maintain Board and corporate confidences; and,
• Act independently when carrying out their duties as Directors of TSHC.

Acting Honestly and in Good Faith

• Directors must be honest in dealing with other Directors and with the Corporation and must disclose all relevant information to the Board.

Maintaining Confidentiality

• Directors shall maintain, at all times, the confidentiality of all confidential information (unless it is required by law to disclose) and records of the Corporation and must not make use of or reveal such information or records, except in the course of performance of their duties or unless the documents or information become a matter of general public knowledge.
• Directors shall not use confidential information obtained through their association with the Corporation to further their private interests or the private interests of their friends or relatives (please refer to TSHC’s Conflict of Interest Policy for additional requirements and guidance on managing personal conflicts of interest while serving as a TSHC Board member).
• Directors shall comply with any and all Corporation policies and procedures that guide the storage, use and transmission of any information of the Corporation, including the use of computer data bases or email
• Directors shall treat all Closed Session Board discussions in the strictest of confidence so that the opportunity for the Board to deliberate matters serves as a “safe haven” for the benefit of their peers and the Corporation’s executive. As such, Directors shall not repeat any Closed Session discussions concerning the Corporation’s business and practices, or any discussions of a personal nature of their peers and the Corporation’s executive, in a public setting unless required by law.

Acting Independently

• Directors must promote the best interests of the Corporation through the exercise of their independent judgment, even if it requires them to disagree with the views of Management, other Directors, the Service Manager or the Shareholder.

Duty of Care

The legal duty of care requires Directors to exercise the care, diligence and skill that a reasonably prudent individual would exercise in comparable circumstances.

III. OTHER STANDARDS OF CONDUCT

Attendance and Participation

Membership on the Board of Directors requires that all Directors:

• Shall demonstrate their commitment to the Corporation by giving high priority to the Corporation’s business and their attendance at and participation in Board and Committee meetings.
• Shall be prepared to participate actively and as knowledgeably as possible at all Board and Committee meetings by familiarizing themselves in advance with the meeting’s agenda and background information with a view to making a productive contribution to the Board’s consideration of the issues and business addressed at the meetings.
• Shall focus on the discussions at hand and be prepared to deal with issues that may not be easily solvable.
• Shall be members of at least one Committee of the Board.
• Shall make best efforts to attend:
  • Strategic planning and orientation workshops;
  • Board development workshops;
  • Seminars and other educational events that enhance their skills as Board members; and
  • Other special events.

• Must notify the CGHRC Chair and Board Chair to request a leave of absence from the Board. Directors must be on an approved leave of absence to:
  • Participate as a candidate in a municipal election,
  • Apply for employment within TSHC

Respect for other Directors, management and others

Membership on the Board of Directors requires that all Directors:

• Shall express their opinions freely and always with the goals of flexibility and compromise whenever achievable.
• Shall work with, respect and remain open to the opinions and viewpoints of their peers and leave personal prejudices out of all Board and Committee discussions.
• Shall observe agreed-upon meeting protocol, displaying courteous and respectful conduct in all Board and Committee meetings toward each other and toward Staff.
• Shall uphold and model TSHC’s commitment to providing a safe and healthy work environment free from violence, threats of violence, discrimination, harassment, intimidation and any other misconduct for every TSHC employee, contractor, temporary employee, and other Directors.

Support of TSHC Executive

Membership on the Board of Directors requires that all Directors:

• Shall actively support the Corporation’s executives by providing overall direction, resources and time frames to achieve the identified vision and ends of the Corporation.
• Shall publicly support actions taken by the Corporation’s executives to implement programs and achieve the objectives contained in the Corporation’s plans and budgets as approved by the Board.
• Shall recognize the difference between the role of the Board to set policies and strategic objectives, and the role of the Staff to implement same.
• Shall not direct Staff in any way. The Board can request that additional work be undertaken with the concurrence of the Corporation’s President and Chief Executive Officer.

Media/Public Comment

Membership on the Board of Directors requires that all Directors:

• Shall not, in the context of the Corporation’s business and practices, make comments to the media or make themselves available for interviews by the media on behalf of the Corporation without prior approval and briefing by the Corporation’s executive. The President and CEO, along with the Board Chair when deemed appropriate, typically performs the role of spokesperson on behalf of the Corporation.
• Directors shall ensure that any comments attributed to them by or in the media or on social media is outside of the context of the Corporation’s business and practices. Any comments made to the media, or on social media in any context is to be solely in their personal capacity and not in their capacity as a Director of the Corporation.

TSHC Property

• Directors shall not misappropriate the Corporation’s assets for personal use.
• Directors are entrusted with the care, management and cost- effective use of the Corporation’s property and resources, including the use of the Corporation’s name, and should not make use of these resources for their own personal benefit or purposes.
• Directors shall ensure that all property assigned to them by the Corporation is maintained in good condition and shall be accountable for such property.

Political Participation

• Directors are encouraged to participate fully as private citizens in the democratic process at any level, including campaigning in elections and running for or holding public office, however, Directors engaging in such political activity shall take care to separate these activities from their association with the Corporation.
• Directors shall ensure that any views they express in the context of their political participation is clearly and unequivocally stated to be that of the Director’s personal views and not the views of the Corporation.

IV. MANAGING BREACHES OF THIS CODE

Management by Board Chair

All alleged breaches of this Code by a Director, regardless of where it is initiated, must be directed to the Board Chair provided that, where the Board Chair is the subject of the breach or alleged breach, it shall be managed by the Board Vice-Chair.

Informal Resolution

The Board Chair should, wherever possible and as appropriate, first seek to resolve all allegations of breaches by using an informal process.

A one-on-one meeting between the Board Chair and Director in question should be held. This one-on-one approach minimizes the need for the dissemination of sensitive personal and confidential information, minimizes impact on the Director’s reputation and will, in most cases, resolve the issue without recourse to a formal process.

Where the Board Chair has not been successful in resolving the matter through an informal resolution process, the Board Chair may strike an ad hoc committee (the “Conduct Committee”) that, once struck, is authorized by this Code to consider next steps. The members of the Conduct Committee shall be the Board Chair, the CGHRC Chair and Board Vice-Chair. Should the allegation or issue involve any of the foregoing persons, the other two shall designate an alternative Director to serve as a member of the Conduct Committee.

Investigation of Alleged Breach

Where deemed appropriate by the Conduct Committee, a decision may be made to conduct an internal investigation. An investigation must be conducted in a manner that ensures due process and confidentiality, and that respects the privacy of all persons involved to the greatest extent possible. Investigations can be a costly, potentially time-consuming and distracting process and a decision to launch an investigation should not be made lightly.

 The Conduct Committee shall:

• Conduct an initial review to determine whether the allegations have merit;
• Determine if the involvement of legal counsel or other experts is required;
• Determine if an individual is required to be relocated or recused, and issue a letter to the affected party;
• Determine the scope of the investigation;
• Determine who will conduct the investigation and how the investigation will proceed;
• Ensure complainant(s) and Director (s) in question are provided with due process, respect, confidentiality and privacy during any investigation, as appropriate;
• Implement the appropriate action(s) to resolve the situation; and
• Monitor the situation to ensure the resolution is maintained.

Committee-Level Discipline

The Conduct Committee shall be authorized to apply the following corrective measures and/or discipline without full Board involvement, as deemed appropriate by the Conduct Committee:

• A dismissal of the complaint;
• A warning to the offending Director and required corrective action;
• Offer the offending Director to resign without further action by the Conduct Committee.

Board-Level Discipline

If the Conduct Committee believes the matter is of such importance as to warrant the full Board involvement, or the Director in question refuses to accept the findings or direction of the Conduct Committee with respect to a particular matter, then the Conduct Committee shall refer the matter to the full Board for consideration. Disciplinary measures that can only be imposed by the Board are as follows:

• Contacting the City Manager of the Shareholder for the purposes of requesting the removing the Director in question as a Director of the Corporation; or
• Such other recommendation(s) as the Conduct Committee shall consider advisable having regard to the facts and the gravity of the violation(s) of the Code, as applicable.

Confidentiality, Protection of Privacy, And Due Process

All parties involved in addressing an alleged breach of this Code, including complainants, respondents, support persons, witnesses, management (including Directors and officers), union/association representatives, and investigators are expected to treat the matter as confidential.

During an investigation, identifying information about any individuals should not be disclosed unless disclosure is necessary for the purpose of investigation, taking corrective action, or as is otherwise required by law. Parties to a complaint must not advise anyone about the investigation, any involvement in the investigation and/or the contents of an investigation interview and/or report.

Every Director that is the subject of a complaint under this Code is entitled to due process as set out in the Code.

V. ENFORCING AND MAINTAINING THE CODE Initial Briefing and Disclosure

The Corporate Secretary shall brief and counsel new Directors on the

Code and its interpretation.

Before a Director begins his or her duties, the Corporate Secretary shall ask them to complete:

1. A formal acknowledgement that they have read and understand the Code and will comply with it in a form acceptable to the CGHRC Committee;

All completed forms shall be shared with the Board Chair for the Board Chair’s review and, as appropriate, action. Forms shall also be stored and maintained in accordance with TSHC’s document retention policy.

Annual Update to Disclosure Form

Once per calendar year, the Corporate Secretary will send a request to Directors to certify that they have read, understood and complied with the Code during the specified reporting period.

Post-Directorship/Departure Briefing

 The Corporate Secretary or Corporate Lawyer in conjunction with the Board Chair shall brief and counsel departing Directors on their post- Directorship obligations including, but not limited to, the obligation to adhere to the Code, to the extent applicable, after leaving office.

Questions of Interpretation

 During their tenure, Directors shall raise any questions relating to how the Code should be interpreted or applied with the CGHRC Chair. A Director who is unsure of whether a situation violates this Code should discuss the situation with the CGHRC Chair.

Decisions

 Any decision on behalf of TSHC with respect to the application or interpretation of the Code will be made by the CGHRC Chair in consultation with the Chair of the Board.

Where the matter relates to the Board Chair, the decision will be made by the CGHRC Chair in consultation with the Vice-Chair of the Board.

Where the matter relates to the CGHRC Chair, the decision will be made by the Board Chair and the Vice-Chair of the Board.

VI. REVIEWS AND AMENDMENTS

The CGHRC Committee shall review the Code at least once every three (3) years and recommend to the Board any appropriate changes.

Selection and Appointment Process for Board Committee Membership and Committee Chair

(Approved by TSHC Board on August 3, 2023)

Selection and Appointment Process for Committee Members

1. The Board Chair will invite Board members to indicate their preferences in being a member of the three Committees and express their interest in serving on more than one Committee.
2. The Board Chair, in consultation with the Vice-Chair, shall take into account members’ preferences, areas of expertise and experience, and bring forward a recommendation on the Committee composition to the Board for approval.
3. The Terms of Reference for each Committee will also be considered, wherein for example Committee size and criteria for specific Committee membership are also articulated:

• Audit, Finance and Risk Committee Terms of Reference
• Quality and Tenant Engagement Committee Terms of Reference
• Corporate Governance and Human Resources Committee Terms of Reference

Selection and Appointment Process for Committee Chair

1. The Board Chair will invite Board members to express their interest in the Committee Chair position for the Committee(s) they are members of.
2. The Board Chair will meet with each candidate to ascertain interest and understand their qualifications and relevant experience. The Board Chair may canvas members who are not pursuing Committee Chair positions to obtain input.
3. The Board Chair, in consultation with the Vice-Chair, will recommend a nominee for each Committee Chair position and bring forward the recommendations to the Board for approval.

In nominating a member of the Board to serve as a Committee Chair, the following qualities should be considered:

• Proven breadth and depth of leadership experience;
• Willingness to dedicate sufficient time to Committee affairs during their term;
• Ability to chair a meeting in a way that is sensitive to group and individual dynamics with excellent facilitation skills;
• Ability to act impartially and without bias;
• Readiness to hold all Committee members accountable for their performance;
• Solid understanding of effective governance principles;
• Demonstrated commitment to diversity and inclusion;
• Effective communication skills.

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Hiring Policy

Effective date: 19 April 2022

Approval by: Executive Leadership Team Approval Date: 19 April 2022

Policy Statement

Toronto Seniors Housing Corporation is committed to fair, equitable, and transparent hiring practices, and to employing qualified, high performing candidates who reflect the diversity of Toronto, our communities, and the organization’s core values.

Scope

 This policy applies to all internal and external hiring (full-time, part-time, casual, or seasonal) for Toronto Seniors Housing Corporation positions, including:

• vacancies in the management/exempt category;
• vacancies in the bargaining unit; and
• paid student placements.

Where this policy conflicts with the requirements of a collective agreement, the collective agreement will govern.

Values

Toronto Seniors Housing Corporation is committed to hiring practices from assessment to selection of candidates that:

• are fair, equitable, consistent, and transparent;
• meet statutory obligations, including the Ontario Human Rights Code, Employment Standards Act, Accessibility for Ontarians with Disabilities Act, Municipal Freedom of Information and Protection of Privacy Act (MFIPPA), and the Municipal Act;
• support the unique requirements of each community and business unit;
• are linked to business and operational needs;
• hire persons with the qualifications required by Toronto Seniors Housing Corporation for the corresponding job. Qualifications include but are not limited to education, training, skills, experience, and/or ability to perform the work satisfactorily;
• consider seniority in accordance with the collective agreement, where applicable; and
• support workforce diversity as per the Toronto Seniors Housing Corporation Diversity Policy.

Standards

Conflict of Interest

All employees involved in the hiring process must abide by the Toronto Seniors Housing Corporation Conflict of Interest Policy. If an employee is in or will be in a conflict of interest during the hiring process or upon hire of a candidate, the employee must immediately declare the conflict of interest. For more information, please see the Toronto Seniors Housing Corporation Conflict of Interest Policy.

As per the Code of Conduct, information gathered during the hiring process should be kept confidential and only shared with employees who need to know the information for purposes directly associated with their work (i.e. the Hiring Manager, employees who are on the interview panel, Recruiters involved in the hiring process for the particular job, etc.).

Confidentiality

All interview panel members must also maintain the confidentiality of the interview process. This means the identity of the interviewees, interviewee scores, the questions that are asked, the interview answer key, or the results of the interview(s) should be kept confidential and only shared with employees who need to know the information for purposes directly associated with their work (i.e. other panel members or the Hiring Manager).

Definitions

Vacancy: a position that has become available at Toronto Seniors Housing Corporation when:

• a permanent or temporary position becomes available and it is determined by Toronto Seniors Housing Corporation that the vacancy should be filled; or
• a temporary or permanent position is created and approved.

Acting Assignment: the temporary placement of an existing employee who occupies a base position and who is temporarily placed in an alternate position on a continuous basis for a period of 30 days or more. For more information see the Toronto Seniors Housing Corporation Acting Assignment Policy.

Advertisement(s): any vacancy that is advertised externally via the external careers pages, websites, and print media such as newspapers, journals, or trade publications.

Candidate: any individual, whether internal or external, who has applied for a vacancy and/or in response to a posting.

Collective Agreement(s): the most recent collective agreement between Toronto Seniors Housing Corporation and a union(s). 

Conflict of Interest: any situation in which an employee’s personal or business interests may compete or appear to compete with their duties as an employee of Toronto Seniors Housing Corporation or may cause the employee to act contrary or appear to act contrary to the best interests of Toronto Seniors Housing Corporation. A conflict of interest can be an actual conflict, a potential conflict, or an apparent conflict of interest as per the Conflict of Interest Policy.

Divisional Lead: the Vice-President (or other member of the Executive Leadership Team) responsible for a specific division within the organization.

Hiring Manager: an employee who has direct or indirect supervisory responsibilities to the new hire or rehire.

HR Connect: an electronic system used to manage the hiring process at Toronto Seniors Housing Corporation.

New Hire(s): all individuals being hired by Toronto Seniors Housing Corporation who are not or have not previously worked at Toronto Seniors Housing Corporation.

Permanent Position: a position where employment is for an indefinite period of time based on the operational needs of the organization.

Posting: refers to a vacancy that is advertised on Toronto Seniors
Housing Corporation’s internet/intranet and/or other external websites.

Recruiter: A member of Talent Acquisition team in the Human Resources division of Toronto Seniors Housing Corporation.

Rehire(s): refers to any individuals who previously worked at Toronto Seniors Housing Corporation prior to resigning, retiring, or being terminated.

Salary, Vacation or Benefits Exception: a situation that falls outside of the standards or past practice for Toronto Seniors Housing Corporation with regards to compensation, vacation, or benefits (this applies to management/exempt employees only).

Temporary Position: a fixed-term temporary position that is not an acting assignment, where employment is for a pre-determined period of time based on the operational needs of the organization. .

Union: refers to employees represented by any of the following: Canadian Union of Public Employees (CUPE) Local 79; Toronto Civic Employees Union Local 416; Ontario Public Service Employees Union Local 529; United Association of Plumbers and Steamfitters Local 46 (Plumbers and Steamfitters); International Brotherhood Electrical Workers Local 353; United Brotherhood of Carpenters and Joiners of America Local 27. Also referred to in this policy as a “bargaining unit.”

Policy Details

Pre-Posting Approval Phase

 All vacancies must be entered into HR Connect by the Hiring Manager to create the job requisition, which initiates the hiring process. All necessary approvals must be completed in HR Connect before the hiring process can proceed. Budgeted positions require the approval of the Divisional Lead and unbudgeted positions require additional levels of approvals as outlined in HR Connect. All new permanent positions must first be approved through the annual budgeting process.

A job description and job information questionnaire must be completed by the Hiring Manager for newly created temporary or permanent positions. The job must be evaluated before a job requisition can be created and before the hiring process can proceed.

The Recruiter will also work in consultation with the Hiring Manager to determine the appropriate recruitment strategy, which includes timelines for filling the vacancy, appropriate selection and assessment criteria, hiring panel composition, and methods for attracting qualified candidates.

Notices regarding new job requisitions will be provided to unions as required by the respective collective agreements.

Job requisitions that have been approved but have not been actioned within four (4) months will be cancelled. The Recruiter will notify the Hiring Manager in advance of cancelling the hiring process and will work with them to determine the best course of action. If the job was posted, candidates will be notified of the cancellation.

Posting of Positions

All vacancies must be posted internally on the Toronto Seniors Housing Corporation intranet careers page for a minimum of fourteen (14) calendar days. The vacancy may be advertised externally at the same time as the internal posting with no minimum posting requirement. Human Resources is responsible for and must approve all internal and external job postings or other job-related advertisements. 

The Human Resources division will be responsible for costs for job postings or other job-related advertisements at their discretion and as budget permits. The costs of any job advertisement requested by the hiring department that are not covered by Human Resources will be the responsibility of the department at their discretion. Any external advertisements must be approved by Human Resources before posting. Advertisements or postings for similar vacancies may be combined into one advertisement in order to make more efficient use of resources.

All temporary positions and management/exempt acting assignments will specify the following language in the job posting: “Please note: This temporary position may be extended or become permanent in order to meet business needs. If this occurs, the position may not be reposted”.

Exceptions to Posting Requirements

The HR Director, Talent Acquisition and Compensation may make exceptions to the fourteen (14) calendar day posting requirement:

• when it is required to place a qualified employee who many otherwise be displaced (e.g. due to a restructuring-related job elimination); and/or
• when the organization is obligated to accommodate an employee in accordance with relevant legislation.

In addition, exceptions to post positions may be made if the same role was recently filled no more than three (3) months since the time of the interviews for the initial competition, and where there are additional qualified candidates. Approval must be received by the Human Resources Director, Talent Acquisition and Compensation. In these cases, the job description for the roles must be the same.

Application Process

All candidates must create a profile and apply to vacancies through HR Connect. Candidates will be manually added to HR Connect as deemed necessary by the Recruiter and/or to satisfy Toronto Seniors Housing Corporation’s obligations under AODA or Ontario Human Rights Code.

Late resume submissions and unsolicited applications are not accepted. The Talent Acquisition team reserves the right to add candidates identified by approved recruitment sourcing techniques to the competition (i.e. candidates found through sourcing and networking). 

Eligibility

Former Toronto Seniors Housing Corporation employees may be considered for employment as per the procedures outlined in Re-Hiring Employees After Separation Policy.

Management and exempt employees cannot start another position until they have completed six (6) months in their current position.

 Employees who are members of CUPE Local 416 who have recently been hired or transferred into a new role at TSHC may not apply for another position unless the start date for this position is more than twelve (12) months after their start date.

Screening

Screening must be completed using objective selection criteria related to the minimum skills, experience, and qualifications required for the job as outlined in the applicable job description. The selection criteria must be consistent throughout competition for the position.

Once a job posting closes, the Recruiter screens all applications and identifies a shortlist of candidates. The screening results are to be documented in HR Connect.

 In order to recognize and retain our top talent, where experience is comparable, qualified internal candidates are given priority consideration over external candidates.

Interviewing

In compliance with the Ontario Human Rights Code, Toronto Seniors Housing Corporation is committed to conducting interviews that are evaluated on a consistent and objective scale.

 Interview guides, assessments, scoring and hiring panelists are to be approved by the Recruiter. In addition, the Recruiter may choose to participate in the interview process at their discretion (typically in cases where Hiring Managers are new to the organization or interview infrequently). All interview panelists are required to complete interview training offered by Human Resources prior to their participation in any interview.

Secondary selection methods such as presentations, assignments, practical/written tests, psychometric testing may also be used with the approval of the Recruiter.

 Interview notes are to be restricted to the assessment of the candidates’ qualifications. Completed interview guides must be returned to the Recruiter within five (5) days of scoring and will be retained by Human Resources for two (2) years after the date the successful candidate commences their position.

Candidate Selection and Job Offer

Candidate selection is based on an assessment of the candidate’s ability to perform the duties and responsibilities of the job as outlined in the applicable job description. In determining suitability for a position, Toronto Seniors Housing Corporation will consider factors such as the candidate’s education, experience, knowledge, abilities and where applicable, seniority or other relevant provisions within a collective agreement. Internal candidate selection for management and exempt positions also takes into consideration the candidates past performance at TSHC.

The Recruiter, in consultation with the Hiring Manager, will approve the selected candidate as well as any offer details, including appropriate compensation, benefits and start date.

Once the offer details are confirmed, the competition will then proceed to the final stages in accordance with the following guidelines:

1. Reference checks will be conducted in accordance with the Employment Reference Checking section of this policy. Reference checks must be conducted before any verbal offer is made. In limited cases, and only with the approval of the Head of People and Culture or designate, offers can be made conditional on a satisfactory reference check.
2. If required, the Hiring Manager must prepare a business rationale for any Salary, Vacation or Benefits Exception requests. Approval must be obtained by both the Divisional Lead and the Head of People and Culture or designate prior to any verbal or written offers being made to the candidate.
3. Verbal offers will be made by the Recruiter and will highlight the main terms of employment including compensation, benefits, and start date.
4. After the verbal offer is accepted, a written offer will be sent through HR Connect for e-signature by the successful candidate. Any verbal offers are subject to the final written offer, which will contain all terms and conditions of employment.
5. If required, Police Background or Criminal Record Checks must be conducted before the start of employment and any verbal or written offers should be conditional until they are completed.

Upon e-signature by the successful candidate, all other candidates will be notified that they were not the successful candidate in the competition. Internal candidates may request feedback from the Hiring Manager, Recruiter, or as otherwise set out in the collective agreement. 

For successful internal candidates, the Hiring Manager, the employee’s current Manager, and the candidate must arrange a mutually agreed upon transfer date. The Hiring Manager will advise the successful candidate prior to contacting their current manager to discuss the transfer date. The transfer date is to occur no later than six weeks after the employee has accepted the verbal offer, unless otherwise approved by the Head of People and Culture or designate. Vacancies created by a transferring employee will, wherever possible, be treated as priority.

Employment Reference Checking

Reference checks are an important and integral component of the hiring process. Toronto Seniors Housing Corporation ensures that the procedure for the collection and disclosure of reference information is practiced confidentially and consistently.

All new hires and rehires to Toronto Seniors Housing Corporation are required to have two (2) employment references completed before a verbal or written offer is made. The employment reference checks must meet the following criteria: be former direct supervisors, cover as much of the new hire or re-hire’s last five (5) years of work history as possible, and one reference must be from the candidate’s most recent employer.

In cases where the individual is a recent graduate and/or has less than one (1) year of work experience, other references or documentation may be accepted (i.e. non- supervisor references, recent performance appraisals, and teacher references). These decisions will be made on a case-by-case basis and with the approval of the Recruiter.

Internal candidates may be subject to an internal reference check as part of the hiring process, unless otherwise prohibited by the Collective Agreement. Where an internal reference check is required, the reference checks must be completed with any manager the employee has reported to in the last one (1) year period.

 Consent must be obtained from the candidate (internal or external) prior to any references being conducted. No other references will be contacted under any circumstances.

Reference checks may be completed by the Hiring Manager and/or the Recruiter. In either case, the Recruiter will review and approve any reference checks.

Records Retention and Auditing

The Recruiter is responsible for ensuring all applicable documentation in the recruitment process is retained onsite in the job requisition and candidate pages in HR Connect during active competition and for a minimum of two (2) years after.

Audits of the hiring process are completed quarterly to ensure that the requirements of the Hiring Policy, legislation, collective agreements, procedures and guidelines are met.

 A copy of the successful candidates resume, references and police record check (if applicable) will be kept on their personnel file.

New Hire and Rehire Documentation

All new hire and rehire documentation must be received from the successful candidate no later than the deadline provided by the Hiring Manager or Recruiter. If there are any delays in receiving the required documentation prior to the employment start date, Human Resources will notify the Hiring Manager and a new start state will be determined.

Age Requirements

Candidates must be legally entitled to work in Canada. Candidates for entry-level positions in the Active Living Unit and candidates for positions created as part of the work of the Economic Opportunities Unit must be at least 14 years of age.

Conversion of Temporary Positions or Acting Assignments to Permanent Positions

If an employee has been placed on an acting assignment or hired externally to fill a non- union position on a temporary basis, the employee will qualify to be placed permanently in the same job classification without further competition. See Acting Assignment Policy for more details.

Compliance and Monitoring

All hiring files are subject to periodic audits in order to ensure compliance to this policy. Complaints on this policy will be addressed by Recruitment through the Recruitment Complaints Process and grievance process, where applicable.

Governing and Applicable Legislation

• Municipal Act;
• Ontario Human Rights Code;
• Employment Standards Act;
• Occupational Health and Safety Act;
• Accessibility for Ontarians with Disabilities Act;
• Municipal Freedom of Information and Protection of Privacy Act.

Ontario Human Rights Code (OHRC)

Toronto Seniors Housing Corporation is committed to hiring and retaining a diverse workforce in accordance with the Toronto Seniors Housing

Corporation Diversity Policy. Toronto Seniors Housing Corporation is also committed to preventing discrimination in its hiring practices based on any prohibited grounds identified by the Ontario Human Rights Code.

Accessibility for Ontarians with Disabilities Act, 2005 (AODA)

Toronto Seniors Housing Corporation is committed to accessible hiring practices in accordance with its obligations under the Accessibility for Ontarians with Disabilities Act, 2005 and its regulations and the Toronto Seniors Housing Corporation Accessibility Policy. Should an employee require accommodation during the hiring process, they are encouraged to contact accessibility.hr@torontohousing.ca or 416-981-4119.

To improve accessibility in its hiring practices, Toronto Seniors Housing Corporation will also:

• include a notification in all job postings about the availability of accommodation in the hiring process for candidates with disabilities;
• inform candidates who are chosen to participate in an assessment or selection process that accommodations in relation to materials and processes are available upon request;
• consult with candidates requesting accommodation to determine a suitable accommodation that takes into account his/her accessibility needs;
• upon hire, inform successful candidates about Toronto Seniors Housing Corporation’s policies for accommodating and supporting employees with disabilities; and
• comply with all other requirements of the Accessibility for Ontarians with Disabilities Act, 2005 or company policy regarding accessibility.

For more information see Accessibility Policy and Accessible Customer Service Policy and Human Rights, Harassment and Fair Access Policy.

Employment Standards Act, 2000 (ESA)

Toronto Seniors Housing Corporation complies with the ESA as it relates to its hiring practices.

Municipal Freedom of Information and Protection of Privacy Act (MFIPPA)

Toronto Seniors Housing Corporation is committed to respecting privacy and protecting the personal information of employees and other candidates in accordance with MFIPPA. Toronto Seniors Housing Corporation also requests consent for reference information collected during the hiring process.

Related Policies and Procedures

• Accessibility Policy
• Accessible Customer Service Policy
• Acting Assignment Policy
• Applicable Collective
• Conflict of Interest Policy
• Human Rights, Harassment and Fair Access Policy
• Police Reference Check Policy (in draft)
• Re-Hiring Employees After Separation Policy
• Student Placement Policy (draft complete, pending approval)

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Health and Safety Policy Statement

Toronto Seniors Housing Corporation and its subsidiaries are committed to working together at all levels to create and maintain a healthy and safe work environment that addresses risks to the physical and mental wellness of all employees.

• The Board and the CEO shall ensure that appropriate resources are provided to create, manage and support a leading organization in health and safety.
• The CEO shall ensure that appropriate systems are in place to meet and strive to exceed applicable legislative requirements, and shall provide the Board with information to facilitate their monitoring of the company’s health and safety program.
• Managers and supervisory staff shall be responsible for compliance with the Occupational Health and Safety Act and related legislation, policies and guidelines within their area of This includes the ongoing education, instruction and training employees must receive about the potential hazards of the work.
• Employees have a corresponding obligation and duty to apply the training and instruction received to comply with health and safety policies for their own protection and the protection of others.
• All workers, including suppliers and contractors, must comply with applicable statutes and the company’s health and safety policies and guidelines of the organization.

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Code of Conduct

Effective date: 28 April 2022

Policy Owner: Human Resources

Approval by: Board of Directors

Approval Date: 28 April 2022

References: Conflict of Interest Policy

Acceptable Use of Information Technology Policy Fraud Prevention Policy

Social Media Policy

Records Management Policy Media and Issues Protocol

Workplace Violence and Harassment Policy

Policy Statement

Toronto Seniors Housing Corporation is committed to enhancing public confidence in what we do. In carrying out their duties and responsibilities, employees are expected to promote core values and observe the highest possible standards of professionalism and service.

The purpose of this Code is to identify the standards Toronto Seniors Housing Corporation expects from employees in all dealings with residents, commercial tenants (‘tenants’), co-workers, visitors, contractors, suppliers, vendors (and potential contractors, suppliers, and vendors), and other members of the public.

This Code shall be interpreted in a manner consistent with governing legislation, including but not limited to the Ontario Human Rights Code.

Scope

This Code applies to every employee and director of Toronto Seniors Housing Corporation. This Code also applies to volunteers, contractors, and vendors when they have regular dealings with residents, tenants, employees, and members of the public on behalf of Toronto Seniors Housing Corporation (the word ‘employee’ in this Code will be modified where necessary).

Any employee who is in a position to make or influence decisions of the organization, such as a senior leadership role, will be held to a higher standard under this Code.

This Code does not replace any policy, procedure, or directive unless specifically stated by Toronto Seniors Housing Corporation.

This Code is a companion to other policy, procedures, or directives that are in full force and effect at Toronto Seniors Housing Corporation.

Compliance with the Code

This Code cannot anticipate every possible situation. Employees shall use proper judgment and act in the spirit of this Code at all times. Employees are also expected to consult with their supervisor or a manager should they have any questions about this Code or need any clarification about what is expected of them.

Contravention of this Code can lead to serious consequences. For employees, non- compliance with this Code may lead to discipline, up to and including dismissal for cause. In the case of a contractor or vendor, non-compliance can lead to termination of their contract. In some cases, non-compliance can lead to legal action on the part of Toronto Seniors Housing Corporation.

Values

All Toronto Seniors Housing Corporation policies, procedures, and directives, including this Code, are based on our core values. The core values guide our decision-making and inform our behaviour in all dealings related to our work. Values for the new organization will be created during the strategic planning process later in 2022.

General Standards

While carrying out job duties, employees of Toronto Seniors Housing Corporation are expected to:

• Promote the best interests of Toronto Seniors Housing Corporation;
• Become familiar with and abide by all policies, procedures, and directives;
• Follow any legislation that applies to their work;
• Be accountable: if an issue comes your way, take ownership over the problem, try to deal with it as best as you can, and ask for help when needed;
• Follow lawful directions of management;
• Refrain from condoning acts which are against the law or contrary to company policy, procedures, or directives;
• Be at work (unless on vacation or an authorized leave);
• Strive for customer service excellence;
• Use a professional tone of voice when interacting with others;
• Show care, diligence, and attention to detail in their work;
• Treat everyone with whom they have dealings with respect; and
• Be as helpful, professional, and courteous as possible.

This list is not exhaustive of the standards expected by Toronto Seniors

Housing Corporation. Employees should also be mindful that Toronto Seniors Housing Corporation is a public sector employer and their actions, both during working hours and in their off-duty time, can affect the reputation of Toronto Seniors Housing Corporation within the community.

Policy Details

Interactions with Residents and the Public 

Residents, tenants, and other members of the public can form impressions of Toronto Seniors Housing Corporation based on their interactions with employees of the organization. An employee’s individual actions reflect on Toronto Seniors Housing Corporation as an organization. Employees of Toronto Seniors Housing Corporation must work together to build and maintain relationships within the organization and in the community.

Residents, tenants, and all others who contact Toronto Seniors Housing Corporation may depend on us for information and the services we provide. Residents, tenants, and members of the public deserve to be treated with dignity and respect. In all dealings with residents, tenants, or the public, employees are expected to be as professional, helpful, and courteous as possible. The issues being faced by residents are important, and we must demonstrate through our words and actions that we take these issues seriously.

Toronto Seniors Housing Corporation is committed to providing a safe work environment for employees and will not tolerate violence or harassment in accordance with the Occupational Health and Safety Act and the Workplace Violence and Harassment Policy. This includes when employees are interacting with residents, tenants, and the public on behalf of the company during their working hours.

Interactions with Colleagues

Toronto Seniors Housing Corporation is committed to fostering a workplace in which employees treat each other with courtesy, sensitivity, respect, and dignity. At Toronto Seniors Housing Corporation we must maintain professionalism in the workplace and try to be as helpful as possible in all dealings with each other. 

Employees are expected to work collegially and resolve conflicts with each other in a constructive and professional manner during their working hours. Harassment, discrimination, or bullying under the Human Rights Code, Occupational Health and Safety Act, or company policy, are strictly prohibited.

Employees are also expected to avoid behaviors which a reasonable person would find inappropriate in a professional and productive workplace. This includes, but is not limited to the following: profane language; name calling; behaviour which is unnecessarily disruptive or intimidating; threats, jokes, gestures, and statements which could be offensive to another person; statements or other actions designed to be harmful, hurtful, or demeaning to another person (or which could be reasonably perceived that way by another person); insulting or derogatory comments; unnecessary shouting; withdrawal of work, favouritism, or the unnecessary exclusion of others for an improper reason (ie. a non-work related reason or a reason that is not justified by law); and/or making up or circulating rumours which could be harmful or hurtful to another person.

Please note that legitimate management direction and performance reviews are generally not seen by Toronto Seniors Housing Corporation as improper conduct on the part of management. However, employees should seek assistance if they believe they are the victim of harassment, discrimination, or bullying under company policy or the law.

Toronto Seniors Housing Corporation Property

Toronto Seniors Housing Corporation owns, controls, leases, or operates facilities, materials, resources, and assets, which includes (but is not limited to) buildings, land, money, vehicles, phones, phone system, records, files, documentation, office equipment, cell phones, passcards, computers, computer tools and network, supplies, cheques, and equipment (‘Toronto Seniors Housing Corporation Property’).

Employees are expected to use Toronto Seniors Housing Corporation Property reasonably and responsibly and take all possible steps to protect such property from misuse, loss, or damage. This includes safeguarding property that has been entrusted to their care, such as cell phones, money, or company files. Deliberately causing damage to such property (or deliberately allowing someone else to cause damage) is prohibited.

Employees are also expected to use Toronto Seniors Housing Corporation Property lawfully, and only for a purpose directly associated with their job at Toronto Seniors Housing Corporation. For example, employees should not circulate any e-mail messages which could be offensive on the basis of a prohibited ground under the Human Rights Code, or use a fob/passcard to access areas for personal reasons which are not related to their work.

The exception to personal use is limited and occasional use of company computers, networks, internet, e-mail, and phones, as permitted by the Acceptable Use of Information Technology Policy (Please note: communications over Toronto Seniors Housing Corporation Property are not private and may be monitored by the company). For further information, please see the applicable policy and procedures.

Fraud and Theft

Employees are strictly prohibited from engaging in any type of fraud as defined in the Fraud Prevention Policy, or any action by an employee intended to conceal or avoid detection of activity prohibited by this policy. Employees are expected to immediately report, in writing and in accordance with company policy, instances of suspected fraud and any knowledge of activity which is prohibited by this clause. All confirmed incidents may be viewed as acts of a criminal nature and may be treated accordingly.

Property of Others

Employees are expected to respect and treat with care the property of other employees, residents, tenants, former residents, co-workers, guests, visitors, vendors, volunteers, contractors, and suppliers, which are brought onto the premises of Toronto Seniors Housing Corporation owned, controlled, leased, or operated buildings.

Employees cannot ask to borrow or use the property of a resident. Employees cannot borrow, use, or take the property of a resident after they move out or the resident disposes of the property, unless the employee is authorized as part of their job to do so. If the property of a visitor to a Toronto Seniors Housing Corporation building is left behind, the employee must tell their supervisor or manager and return the property.

Licenses and Professional Designations

When an employee is required to have a license or professional designation for their job, the employee must immediately report any loss or potential loss of that license or professional designation to their supervisor or manager. For example, employees who drive company vehicles as part of their job must immediately report any suspensions of that license to their supervisor or manager.

Alcohol and Drugs

It is strictly prohibited for an employee to be under the influence of alcohol or drugs during working hours. The exception is over the counter or physician-prescribed medication and drugs unless the use will risk the health and safety of the employee or any other person. An employee must disclose to their supervisor or a manager if they are under the influence of any alcohol or drugs during working hours (or expect to be under the influence during working hours in the case of over the counter or physician-prescribed medication and drugs) where there could be any risk to the health and safety of the employee or any other person.

If a situation covered by this clause is brought to the attention of an employee’s supervisor or manager, the employee’s supervisor or a manager (or other management) will review the circumstances and take the appropriate action. The appropriate action shall include reasonable accommodation as required by the Ontario Human Rights Code. Toronto Seniors Housing Corporation has the right to request reasonable information or documentation to support an accommodation under this clause.

Information about Toronto Seniors Housing Corporation

In performing their duties and responsibilities for the organization, employees will learn information about Toronto Seniors Housing Corporation and its operations. This includes information in verbal conversations and information in writing, formal documents, files, e- mails, computers, data records, etc. In most cases, this information is not known to the public. Examples include information related to our financial affairs, marketing plans, tenants, residents, resources, contractors, proposed initiatives, strategy, members of the public, employees, etc.

This information is confidential and is Toronto Seniors Housing Corporation’s property. Employees must take all reasonable steps to ensure this information is not used or disclosed without proper authorization, and in accordance with company policy and the Municipal Freedom of Information and Protection of Privacy Act.

This includes securing and safeguarding information which has been entrusted to the employee’s care, such as locking cabinets and securing documents when not in use. Employees must also be mindful of what information can be overheard in conversations or seen on their phone, both during working hours and when they are in public during their private time. Employees must not deliberately try to access such information when the information is not associated with their work. Employees are also expected not to use or disclose such information for their own personal gain or for any purpose that is not associated with their work (unless authorized by their division head or when required by law). For more information, please see the Acceptable Use of Information Technology Policy, Records Management Policy, and Conflict of Interest Policy.

These rules concerning using or disclosing information do not apply where the employee is reporting wrongdoing under company policy or participating in an internal investigation. Employees should use proper internal channels, rather than a public setting, to address any concerns they have about Toronto Seniors Housing Corporation.

For more information about how to report wrongdoing and the protections available to employees who report wrongdoing, please see the Fraud Prevention Policy.

Media Inquiries

Communications with the media must be conducted so that all information originates from a qualified, informed, and approved spokesperson of Toronto Seniors Housing Corporation. All media requests for interviews or information must be referred to the media relations team in the Strategic Communications Unit. For more information, please see the Media and Issues Protocol.

Relationships with Residents

Employees may not enter the home of a resident or tenant, unless authorized by law and/or without authorization from Toronto Seniors Housing Corporation, unless they are invited by the resident, the visit takes place outside of the employee’s working hours, and the visit does not otherwise violate this Code. Employees must also comply with the Conflict of Interest Policy.

Governing and Applicable Legislation

• Employment Standards Act
• Human Rights Code
• Occupational Health and Safety Act
• Municipal Freedom of Information and Protection of Privacy Act

TORONTO SENIORS HOUSING CORPORATION (TSHC)

WORKPLACE ACCOMMODATION POLICY

Policy Owner: CGHC Committee

Date Approved: 18 May, 2022

Type: Occupational Health and Safety Policy

Approved By: Board of Directors

Last Reviewed:

Effective Date: 1 June, 2022

I. TORONTO SENIORS HOUSING’S COMMITMENT

TSHC is committed to promoting and ensuring equality rights in the workplace by ensuring a work environment where persons are comfortable identifying their needs; and where needs are properly assessed with a view to identifying and implementing accommodation activity responsive to substantiated needs.

Successful accommodation is a shared responsibility. All members of the TSHC workplace have important roles and responsibilities if successful accommodation activity is to be achieved. This includes all levels of management, exempt staff, union staff, and bargaining agents.

II. PURPOSE AND APPLICATION

The purpose of this policy is to encourage and facilitate effective responses to accommodation issues that arise in the workplace; responses that enable persons to perform their workplace responsibilities effectively. Our ability to identify, properly assess and implement accommodation activity is dependent upon the support and input of all members of all staff. This policy outlines the roles and responsibilities of all participants and stakeholders in the accommodation process.

III. UNDERSTANDING THE DUTY TO ACCOMMODATE

There is a legal duty to accommodate the needs of employees and prospective employees who identify a conflict between their employment obligations and their individual needs based on designated grounds in the TSHC Human Rights Harassment Fair Access Policy and the Ontario Human Rights Code.

As an Employer TSHC is required to respond in a timely and effective manner to substantiated accommodation issues consistent with the scope of the duty to accommodate.

Qualifying needs that can trigger the duty to accommodate may relate to a disability, religious observance, sex, age, family status, same sex partnership status. TSHC will respond to any conflict that an employee experiences between an equality right need and a workplace expectation by identifying and implementing appropriate accommodation activity; subject to the undue hardship limit.

The duty to accommodate does not require TSHC to create a new workplace position nor does it guarantee any person continued employment. Once a person is accommodated, the person must perform competently in the workplace.

The duty to accommodate is limited to circumstances where it does not expose TSHC or any other necessary participant to undue hardship.

Defining Undue Hardship

Generally speaking, the following three factors will be of relevance to assessing undue hardship:

Cost,
Outside sources of funding, and
Health and safety

IV. DEFINING ACCOMMODATION

 Accommodation can require the modification of rules, policies, practices or expectations that result in discrimination against an employee based on an equality right ground where there is a conflict between such rules, requirements or expectations and an employee’s need. The duty to accommodate incorporates an obligation to adapt/adjust the workplace to facilitate the employee’s continuing participation in the activity of work and employment.

The adjustments to the workplace can include the following:

• Physical workplace: Redefine the workplace, modification to equipment, provision of special equipment, tools, etc.
• Scope of work: It can require the removal of duties, reassignment of duties, providing assistance or changing duties.
• Hours of work: Accommodation may require modification to the days of work, hours per day, shift times or shift schedule of an employee.
• Job expectations or requirements: Accommodation can require the relaxing of timekeeping and attendance expectations where needs attending equality right conflict with such expectations.

In summary, accommodation activity can involve changing or modifying rules, policies or expectations by incorporating alternative or modified arrangements that eliminate the discriminatory barrier for the employee.

V. MULTI-PARTY RESPONSIBILITIES

 Accommodation activity can impact a number of stakeholders with- in TSHC. As a result, the accommodation process is seen as a multi-party process in which the input and cooperation of all parties can be relevant or necessary for successful accommodation activity. The following summarizes the responsibilities of the various parties or stakeholders. Each of these parties is required to make their required contribution to successful accommodation activity.

1. Responsibilities of Person Seeking Accommodation (Accommodee)

(i) Communication Of The Need
Employees with an accommodation need are expected to inform their manager of any need that conflicts with his/her ability to provide regular attendance, perform regular duties or meet any other term and condition of the employment contract.
On matters of disability the employee is not required to reveal their disability; but is required to ensure that TSHC has access to the scope of   information required to assess and respond to accommodation needs attending the disability issue.

(ii) Provide necessary information, including functional capabilities or other professional opinions that will assist in completing successful Accommodation Assessments

Whenever a potential accommodation issue has been identified, the employee seeking accommodation is responsible for delivering all information relevant to the assessment of the accommodation issue. Employees seeking accommodation are expected to co- operate with requests for information that TSHC identifies as relevant to assessing or pursuing accommodation initiatives.

(iii) Participate in discussions about solutions

Employees seeking accommodation are expected to provide their cooperation and support to facilitate the successful identification and implementation of accommodation activity. TSHC’s ability to successfully address the employee’s accommodation needs will be limited by inadequate information or participation by the person with the need.

NOTE: An accommodee’s right to have their needs accommodated may be curtailed or terminated in circumstances where the accommodee fails to meet their obligations as outlined in (i), (ii) and (iii) above.

2. Management’s Responsibilities

(i) Secure Relevant Information

Management or human resources shall initiate the necessary steps to secure information, input or documentation relevant to assessing the accommodation need. Such initiatives may include but will not be limited to verbal and written communications to the accommodee and/or their health professional to secure functional information required for and relevant to the assessment of accommodation options.

(ii) Assessment

Management shall use the information secured relevant to the accommodation need to evaluate accommodation options with a view to identifying the most appropriate accommodation initiative. Additional input may be sought from Human Resources and or Human Rights and Equity Unit.

(iii) Consultation

Management shall consult with the relevant stakeholders; including but not limited to the accommodee and the bargaining agent, where relevant. Such consultation shall include a review of the accommodation options and recommendations determined by management and seeking relevant employee or bargaining agent input in connection with finalizing an accommodation initiative or assessing the feasibility of an accommodation initiative.

(iv) Determination of Accommodation Issues

Using information acquired through the necessary assessments and consultation, management shall determine if an accommodation initiative is feasible; and where it is, determine the appropriate accommodation initiative in the particular circumstances.

(v) Implementation

Management   shall   finalize   and   implement   an   appropriate accommodation initiative. Implementation shall include verbal and documented communications to the accommodee and bargaining agent with respect to the details of the accommodation initiative to be implemented. When the implementation of a particular accommodation initiative demands the direct participation of a co- worker, management shall pursue the relevant communications with the coworker to ensure they understand the support that is required of them.

(vi) Monitoring

Management shall monitor the accommodation initiative. The monitoring may include requests for updated information from employees and/or attending health professionals. The monitoring and updating of information will facilitate the Organization in responding to changing accommodation needs and/or identify when the accommodation need is exhausted.

3. Responsibilities of Bargaining Agents

Bargaining agents have important roles and responsibilities with respect to facilitating effective accommodation assessments and facilitating the implementation of appropriate accommodation activity. In connection with supporting accommodation processes and the implementation of accommodation, bargaining agents are expected to facilitate the delivery of necessary information, provide relevant input on accommodation options that is consistent with the scope of the duty to accommodate; support and facilitate the implementation of appropriate accommodation activity, encourage bargaining unit members to meet their obligations in terms of the duty to accommodate.

VI. CORPORATE RESPONSIBILITIES

Successful accommodation requires the support and commitment of everyone working in TSHC. All employees are expected to provide their assistance and support where required. All members of the workplace have an obligation to support the right to accommodation. Other employees may be required to assume some additional responsibilities or burdens in connection with accommodation activity.

VII. HUMAN RESOURCES’ RESPONSIBILITIES

• To manage the process of accommodation assessments, determinations and implementation of accommodation activity.
• To provide support to all relevant parties and understanding and making the necessary contributions to successful accommodation.
• To provide policy clarification and consultative support when requested by supervisors, managers or any stakeholder in the accommodation process.
• To maintain ongoing communication with employee and any internal and external stakeholders to ensure, on an ongoing basis, that reasonable steps are being pursued to address the employee’s needs and TSHC’s interests.
• To facilitate the provision of legal, procedural, functional, ergonomic and job modification assistance to successfully address accommodation issues.

VIII. RESPONSIBILITIES OF HEALTH PROFESSIONAL

The verification of accommodation issues and identification of appropriate accommodation initiatives is dependent upon relevant and timely input from attending medical practitioners. The treating health professional of an employee who is faced with an accommodation issue in the workplace shall provide their full cooperation and support by:

1. Responding in a complete and timely manner to any request for information initiated by TSHC.
2. Communicating to TSHC through the Human Resources Division in a timely manner any changes in the Employee’s condition that may alter the required scope, duration or nature of an accommodation initiative.

IX. SUMMARY OF PROCEDURES FOR RAISING ACCOMMODATION ISSUES

1. Identification of accommodation needs: Employees are to notify their supervisor/manager or human resources of any need for workplace accommodation in a clear and timely It is recognized that the supervisor/manager or human resources staff may identify and raise an accommodation issue in circumstances where an employee experiences a conflict in his/her ability to comply with a job responsibility or any condition of employment in circumstances where it appears that the conflict may attend an equality right status.
2. The supervisor/manager shall immediately review and assess the accommodation request/issue. In connection with such review, he/she shall request and receive any input, information or documentation required from any of the relevant stakeholders (i.e. the employee with the accommodation need, treating Health Professional, supervisor/manager, bargaining agent, Health & Safety Unit, Human Rights and Equity Unit, Labour Relations & Employee Services Unit).
3. An appropriate accommodation plan shall be developed as promptly as possible with the input of the relevant internal and external stakeholders.
4. The accommodation initiative or plan shall be implemented immediately or as agreed to by the employee, management and bargaining agent where applicable.
5. If for any reason the stakeholders are unable to agree on a resolution, the Labour Relations and Employee Services Unit, and the Human Rights and Equity Unit in conjunction with the relevant supervisors/managers and in consultation with the employee and bargaining agent where relevant, will review the proposed accommodation plan with a view to making a final determination as to whether the plan or initiative is appropriate accommodation or would represent an undue hardship.

OUR MUTUAL COMMITMENT TO SUCCESSFUL ACCOMMODATION: SUCCESSFUL ACCOMMODATION REQUIRES THE COOPERATION, INPUT AND SUPPORT OF ALL RELEVANT STAKEHOLDERS (i.e. supervisors, managers, senior management, accommodee, co- workers, attending physicians, bargaining agents). SUCCESSFUL ACCOMMODATION DEPENDS UPON ALL PARTIES PROVIDING THE REQUIRED INPUT AND THEIR FULL SUPPORT AND COOPERATION IN CONNECTION WITH ACCOMMODATION ASSESSMENTS AND THE IMPLEMENTATION OF ACCOMMODATION ACTIVITY.

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Whistleblower Policy

Policy owner:

Date Approved:

Type:

Approved By:

Last Reviewed:

Policy Statement

Toronto Seniors Housing Corporation (TSHC) is committed to promoting integrity, ethics, accountability, and transparency in everything we do. TSHC recognizes it is in the best interests of the Corporation to maintain and enhance public confidence by encouraging the reporting of wrongdoing taking place within TSHC to designated individuals at the organization.

The purpose of this policy is to provide guidelines for reporting wrongdoing and to provide reasonable protection from reprisal for those persons who, in good faith and with reasonable belief, report wrongdoing in accordance with this policy.

Scope

This policy applies to all employees of TSHC, whether they work on a full-time or part-time basis. This policy also applies to members of the Board of Directors of TSHC as set out in this policy. This policy provides reasonable protection from reprisal for all employees and Directors of TSHC, who in good faith report wrongdoing under this policy.

Tenants of TSHC are also encouraged to report wrongdoing and are provided reasonable protection from reprisal in accordance with this policy.

This policy covers matters that are in the public interest and for which there are no existing processes for reporting and investigation. For example, corporate policy and/or the collective agreement (if applicable) are generally available to address individual complaints by employees of workplace discrimination or harassment. These complaints will not be seen as wrongdoing under this policy in the ordinary course. The exception is fraud which employees can report under this policy, but which may be investigated or addressed in accordance with the Fraud Prevention Policy.

Values

All TSHC policies, including this policy, are based on THSC’s core values of respect, accountability, community collaboration, integrity and accessibility for persons with disabilities.

TSHC expects employees to use proper judgment and act in a way that reflects these core values and corporate policy. Employees should also support the high standards expected of a corporation established to deliver seniors’ social housing in the City of Toronto. TSHC is also committed to maintaining an environment where people can raise concerns about improper behavior without fear of reprisal. The effectiveness of these commitments and TSHC’s policies, procedures, and directives are dependent on persons being able to report suspected cases of wrongdoing without fear of reprisal for doing so.

Definitions

• Director: Any individual member of the TSHC Board of
• Wrongdoing: Refers collectively to any serious act (or failure to act) that is covered by this policy and which:
  • Constitutes fraud or waste as defined under this policy.
  • Is a   violation of   TSHC policies, procedures, or directives.
  • Risks the health or safety of residents, employees, or visitors to THSC sites.
  • Is unlawful under any municipal, provincial or federals laws.
  • Knowingly directs or counsels another person to engage in such acts.
  • Is designed or intended to conceal conduct prohibited under this policy.

• Fraud: Any dishonest act that results in actual loss or risk of loss, deception, misappropriation of resources or the manipulation of data to the advantage or disadvantage of a person or Fraud includes any misuse, or attempt to misuse:
• one’s position in the company; and/or,
• a THSC asset for personal gain or purposes unrelated to company business.
  Fraud includes corruption which is defined as the offering, giving or soliciting, or accepting of an inducement or reward that may improperly influence the action of a person or entity.
  For more information, including examples of Fraud or Corruption, please see the Fraud Prevention Policy.

• Reprisal: Actions taken against another person as a direct result or in retaliation for making a report under this policy, being suspected of making a report under this policy, or participating in an investigation under this policy. Reprisal includes harassment, discrimination, intimidation, dismissal, suspension, demotion, discipline, termination, suspension, coercion, discipline, imposition of another penalty, or, in the case of an employee, any other action which adversely affects their working conditions. Reprisal includes a threat to take any such actions and knowingly directing or counselling of another person to engage in reprisal.

• Waste: Any other gross mismanagement, theft, falsification, misappropriation, or misuse of TSHC facilities, resources, and/or assets, either deliberate or by negligence, which is not covered under the Fraud Prevention
• Whistleblower: An employee, Director, or tenant who, in good faith and with reasonable belief that wrongdoing has occurred, makes a report under this policy.

Policy Details

Reporting Wrongdoing

Any employee who suspects or has knowledge of any occurrence of Fraud, shall immediately notify his/her manager or the General Counsel and Corporate Secretary, or report to the ethics hotline. An employee who suspects or has knowledge of any other type of wrongdoing will immediately notify his/her manager or report to the ethics hotline. A tenant who suspects or has knowledge of wrongdoing shall notify the General Counsel and Corporate Secretary. If the occurrence involves the General Counsel and Corporate Secretary, the employee or tenant shall notify the Chief Executive Officer.

Any Director who suspects or has knowledge of any occurrence of Fraud or any other type of wrongdoing shall immediately notify the Board Chair who will consult with the General Counsel and Corporate Secretary on the appropriate actions to take. If the occurrence involves the Board Chair, the Director shall report the occurrence to the Chair of GHRC who will consult with the General Counsel and Corporate Secretary on the appropriate actions to take.

Implementation

An employee who believes they are the subject of a Reprisal will notify the Vice- President of Human Resources immediately. Where a manager or supervisor is informed of, or becomes aware of, a reprisal, the manager or supervisor will notify the Director of Human Resources immediately. If the complaint involves the Director of Human Resources or a Director of the organization, the reprisal should be reported to the Chief Executive Officer.

Any allegation of a reprisal will be reviewed and may be the subject of a formal investigation. TSHC will determine who will lead the investigation, and the divisions/persons to be consulted, based on the subject matter at issue.

Investigations may be conducted by an external investigator if necessary and at the discretion of TSHC.

The Director of Human Resources will determine what, if any steps are appropriate to stop, reverse, or remedy a reprisal. For complaints involving the Vice- President of Human Resources, the President Chief Executive Officer will determine what, if any steps are appropriate to stop, reverse, or remedy a reprisal. For complaints involving a Director, the Chief Executive Officer in consultation with the Board Chair (or Vice-Chair if the complaint is against the Chair) will determine what, if any steps are appropriate to stop, reverse, or remedy a reprisal.

 Once the TSHC has provided an assurance of confidentiality to a whistleblower, the individual’s identity cannot be revealed without the individual’s consent.

With respect to TSHC’s commitment to provide reasonable protection for whistleblowers, this will include:

• Making all reasonable efforts to protect the identities of whistleblowers by not sharing a whistleblower’s identity, or information that could reasonably be expected to reveal the whistleblower’s identity, with others, including a law enforcement agency without the whistleblower’s explicit consent.
• Respecting the decision of the whistleblower as to how much personal information will be provided; and,
• Adhering to Canada’s Criminal Code which means TSHC cannot dismiss, suspend, demote, discipline, harass, or otherwise disadvantage whistleblowers, or deny you a benefit of employment when the information provided was given in good faith and that reasonably believed to be true and accurate.

Compliance and Monitoring

TSHC will not tolerate wrongdoing or reprisals against anyone who reports wrongdoing, and all employees have a duty to report suspected wrongdoing. No employee or Director will take any action in reprisal against a Whistleblower for making, or being suspected of making, a report of wrongdoing under this policy. No employee or Director will take any action in reprisal against any person who participates in an investigation under this policy.

An employee who is found to have engaged in reprisal prohibited by this policy shall be the subject of discipline, up to and including dismissal for cause.

Reprisal by a Director shall be treated in the same manner as a violation of the Code of Conduct for Directors. Conduct prohibited by this policy which is contrary to legislation, including that of a criminal nature, may be addressed or reported accordingly.

An employee who knowingly makes a false or misleading report under this policy, or who knowingly makes a false or misleading statement in an investigation under this policy, may be the subject of discipline, up to and including dismissal for cause.

Employees and other persons are expected to co-operate fully in an investigation under this policy. Employees who are contacted by the media regarding an investigation under this policy must refer all inquiries to the media relations team in the Strategic Communications Unit. Please see the Media and Issues Protocol.

Governing and Applicable Legislation

• Employment Standards Act
• Ontario Human Rights Code
• Occupational Health and Safety Act
• Criminal Code

Related Policies and Procedures

• Conflict of Interest Policy
• Code of Conduct
• Fraud Prevention Policy
• Board of Directors Reimbursement Policy
• Finance Policies

Commencement and Review

Next Scheduled Review Date:

Toronto Seniors Housing Corporation (TSHC)
Workplace Harassment Policy

Policy Sponsor: Director, People and Culture

Approver: Leadership Team

Initial Approval Date: May 18, 2022

Date of Last Revision, if applicable: February 7, 2024

Effective Date: February 7, 2024

Policy Statement

The Toronto Seniors Housing Corporation (TSHC) Workplace Harassment Policy outlines a transparent and consistent approach to be followed when a workplace harassment complaint is received.

Policy Objective(s)

Toronto Seniors Housing Corporation is committed to providing a work environment free of harassment in which all workers are treated with respect and dignity. In accordance with the Occupational Health and Safety Act, workplace harassment will not be tolerated from any person including tenants, other workers, supervisors, and members of the public.

Scope

This policy is in effect at all Toronto Seniors Housing Corporation Workplaces. Workers, contractors, tenants, visitors, volunteers, and persons engaged in business with Toronto Seniors Housing Corporation are expected to uphold this Policy.

Definitions

Workplace Harassment: engaging in a course of vexatious comment or conduct against a worker in a workplace that is known or ought reasonably to be known to be unwelcome.

Reasonable action taken by the employer or supervisor relating to the management and direction of workers or the workplace is not workplace harassment.

Workplace sexual harassment:

• engaging in a course of vexatious comment or conduct against a worker in a workplace because of sex, sexual orientation, gender identity or gender expression, where the course of comment or conduct is known or ought reasonably to be known to be unwelcome, or
• making a sexual solicitation or advance where the person making the solicitation or advance is in a position to confer, grant or deny a benefit or advancement to the worker and the person knows or ought reasonably to know that the solicitation or advance is unwelcome.

Roles and Responsibilities

Workers: are encouraged to report any incidents of workplace harassment  to the appropriate person. Workers may file a formal complaint of harassment in writing to People and Culture. If the complaint involves a member of the People and Culture team, the complaint should be directed to the Director, People and Culture or the Chief Executive Officer. If the complaint involves the Director, People and Culture the complaint should be directed to the Chief Executive Officer.

Management: will investigate and deal with all complaints of incidents of workplace harassment in a fair, respectful, and timely manner. Information provided about an incident or about a complaint will not be disclosed except as necessary to protect workers, to investigate the complaint or incident, to take corrective action, or otherwise as required by law.

Workers, contractors, tenants, visitors, volunteers, and persons engaged in business with Toronto Seniors Housing Corporation are expected to adhere to this policy and will be held responsible by the employer for not following. Workers are not to be penalized or disciplined for reporting an incident or for participating in an investigation involving workplace harassment.

If a worker needs further assistance, he or she may contact their union representative, Joint Health and Safety Committee representative, People and Culture Business Partner, or Employee and Family Assistance Program Provider.

Violation of this policy will result in appropriate remedial action, legal action, or disciplinary action up to and including immediate termination of employment for cause. In the case of a contractor or vendor, non-compliance can lead to termination of their contract.

Related Legislation, Regulations, and TSHC Policies:

• Occupational Health and Safety Act
• Ontario Human Rights Code
• Workplace Safety and Insurance Act
• Criminal Code of Canada
• Workplace Harassment Program (HSW1820)
• Workplace Violence Policy (HSW1800)
• Accident/Incident Reporting Procedure (HSW1500)
• Workplace Violence and Harassment Prevention and Crisis Resource Manual (HSW1806)
• Code of Conduct (Employees)
• Human Rights Policy (Staff)
• Human Rights Policy : Procedure for Staff Complaints
• Human Rights, Harassment, and Fair Access Policy – Tenants
• Tenant Representative Code of Conduct
• Accessibility Policy

Amendments (Revision History):

Initial policy approved by Corporate Governance and Human Resources Committee on May 18, 2022.

Policy reviewed on February 6, 2024 with the following revisions, approved by Leadership Team on February 6, 2024:

• Revision 1 – update of position titles and People and Culture department name.

Next Scheduled Review Date: February 1, 2025

This policy will be reviewed annually, or as often as necessary, to ensure it remains effective.

Policy Contact

Director, People and Culture

Toronto Seniors Housing Corporation (TSHC)
Workplace Violence Policy

Policy Sponsor: Director, People and Culture

Approver: Leadership Team

Initial Approval Date: May 18, 2022

Date of Last Revision, if applicable: February 7, 2024

Effective Date: February 7, 2024

Policy Statement

The Toronto Seniors Housing Corporation (TSHC) Workplace Violence Policy outlines a transparent and consistent approach to be followed when a workplace violence situation occurs.

Violence in the workplace is unacceptable from anyone. This policy is in effect at all Toronto Seniors Housing Corporation workplaces and applies to workers, contractors, tenants, visitors, volunteers, and persons engaged in business with Toronto Seniors Housing Corporation. Everyone is expected to uphold this policy and to work together to prevent workplace violence.

Policy Objective(s)

Toronto Seniors Housing Corporation is committed to providing a safe work environment and is ultimately responsible for workplace safety. In accordance with the Occupational Health and Safety Act workplace violence will not be tolerated. TSHC will take whatever steps are reasonable to protect our workers from workplace violence from all sources.

Scope

This policy is in effect at all Toronto Seniors Housing Corporation Workplaces. Workers, contractors, tenants, visitors, volunteers, and persons engaged in business with Toronto Seniors Housing Corporation are expected to uphold this Policy.

There is a workplace violence program that implements this policy. It includes measures and procedures to protect workers from workplace violence, a means of summoning immediate assistance and a process for workers to report incidents or raise concerns. The Program also includes measures for addressing domestic violence in the workplace and for communicating known risks of violence to workers.

Toronto Seniors Housing Corporation, as the employer, will ensure this policy and the supporting program are implemented and maintained. All workers and supervisors will receive appropriate information and instruction on the contents of the policy and program.

Definitions

Workplace violence means:

• The exercise of physical force by a person against a worker, in a workplace, that causes or could cause physical injury to the worker.
• An attempt to exercise physical force against a worker, in a workplace, that could cause physical injury to the worker.
• A statement or behaviour that it is reasonable for a worker to interpret as a threat to exercise physical force against the worker, in a workplace, that could cause physical injury to the worker.

Roles and Responsibilities

All workers, tenants, visitors and contractors are expected to refrain from violence or threats against workers of Toronto Seniors Housing Corporation and will adhere to this policy and supporting program.

Management: Management is responsible for ensuring that measures and procedures are followed by workers and that workers have the information they need to protect themselves.

Management pledges to investigate and deal with all incidents and complaints of workplace violence in a fair and timely manner, respecting the privacy of all concerned as much as possible. Reporting and investigation of workplace violence incidents must be conducted in accordance with Accident/Incident Reporting Procedure HSW1500.

Workers:  All workers are encouraged to raise any concerns about workplace violence and to report any violent incidents or threats to their supervisor.

Compliance and Monitoring

Violation of this Policy will result in appropriate remedial action, legal action, or disciplinary action up to and including immediate termination of employment for cause. In the case of a contractor or vendor, non-compliance can lead to termination of their contract.

Toronto Seniors Housing Corporation prohibits reprisals against persons who, in good faith, report incidents of workplace violence or who act as witnesses during investigations. Management will take all reasonable and practical measures to prevent reprisals or threats of reprisal.

Related Legislation, Regulations, and TSHC Policies:

• Occupational Health and Safety Act
• Workplace Safety and Insurance Act
• Criminal Code of Canada
• Workplace Violence Program (HSW1820)
• Accident/Incident Reporting Procedure (HSW1500)
• Workplace Violence and Harassment Prevention and Crisis Resource Manual (HSW1806)
• Code of Conduct (Employees)
• Tenant Representative Code of Conduct
• Working Alone Policy (HSW1801)
• Workplace Violence Risk Assessment and Control Evaluation Procedure (HSW1803)

Amendments (Revision History):

Initial policy approved by Corporate Governance and Human Resources Committee on May 18, 2022.

Policy reviewed on February 6, 2024 with the following revisions, approved by Leadership Team on February 6, 2024:

• Revision 1 – update of position titles and People and Culture department name.

Next Scheduled Review Date: February 1, 2025

This policy will be reviewed annually or as often as necessary to ensure that it remains effective.

Policy Contact

Director, People and Culture

Toronto Seniors Housing Corporation (TSHC)
Community Activities Fund Policy

Policy Sponsor: Director, Engagement, Partnership and Communications

Approver: Board of Directors

Initial Approval Date: December 8, 2023

Effective Date: April 1, 2024

Policy Statement

The Community Activities Fund Policy outlines how funds for tenant-led initiatives are allocated by the Toronto Seniors Housing Corporation (TSHC), with appropriate controls in place for oversight and accountability.

This Policy:

• Supports tenant-led activities and events within their communities.
• Specifies the criteria for initiatives that are eligible for funding.
• Outlines the standards that initiatives must meet to qualify for funding.

Scope

This Policy applies to all tenant communities and staff of TSHC. It outlines the activities that can be financially supported and explains the process of funding activities for tenants.

Out of Scope

This Policy does not apply to:

• Tenant expenses related to private events.
• Projects and events that are part of Community Programs and Partnerships’ tenant engagement work (e.g., refreshments for building meetings).
• Events that are exclusively faith-based.
• Events exclusively for members of a tenant association.

Implementing this policy should not only meet the requirements listed in the policy but also adhere to the corporation’s values of respect, inclusion, accountability, and innovation.

TSHC Values

• Respect – Our culture is built on respect, trust, and open, honest communication among tenants, staff, and service providers. We respect each tenant’s independence and privacy. We will assist tenants to find the services and supports they prefer.
• Inclusion – Quality of life for seniors is enhanced by living in vibrant and diverse communities. We strive for inclusion and equity.
• Accountability – We are accountable to our tenants, our shareholder (the City of Toronto), and the public. We are committed to transparency. We are clear on our goals. We set targets and report our results. We demonstrate integrity and responsible use of our resources.
• Innovation – We are creative, innovative, adaptive, and flexible to meet the needs of our current and future tenants. We are a catalyst for positive change, energizing communities and partners to join us to achieve our mandate.

Definitions

• Building: A structure that is designed and constructed to provide living spaces for individuals or families to use as their home.
• CAF (Community Activities Fund) Coordination Table: Members of this group will include Regional Managers, the Manager of Community Programs and Partnerships, and the Community Programs and Partnerships Clerk. The group will ensure that funds are managed and distributed equitably and timely across all buildings based on applications from all regions.
• Community Activities Fund (CAF): Funds set aside by TSHC for events or activities to bring tenants together and purchase supplies and smaller equipment that can be enjoyed in shared spaces.
• Community: Tenants belonging to a TSHC building or adjacent TSHC developments.
• Community Services Coordinators (CSCs): The Community Services Coordinator is a frontline member of the Community Programs and Partnerships team. They assist in developing and managing programs and partnerships, community and tenant engagement, and support TSHC’s efforts to build strong and vibrant communities.
• Event(s): A one-time or re-occurring activity that is open to all tenants within a given community.
• Larger Equipment: A tangible long-term asset that benefits the broader tenant community (e.g., exercise machines and recreational equipment such as pool tables). Equipment must have a minimum lifespan of two years and come at a price of $1,500 or more.
• Quarter: A quarter (calendar) is a calendar that breaks the year into four parts. Each part is three months. It helps to remember important dates and plan events. It is used to plan budgets and goals and manage time. For example, the year’s first quarter includes January, February, and March. The second quarter includes April, May, and June. The third quarter includes July, August, and September. The fourth quarter includes October, November, and December.
• Smaller Equipment: Materials, items, supplies, or equipment needed to implement community programs or activities.
• Tenant: A person who holds a residential lease agreement with Toronto Seniors Housing Corporation or a Toronto Seniors Housing Corporation-approved sub-landlord and lives in a Toronto Seniors Housing Corporation building.

Standards

• Community Activities Fund (CAF) initiatives must be identified at the building’s priority-setting meeting each year.
• The Community Services Coordinators (CSCs) are required to support an Annual Building Planning Process with tenants including priority-setting meetings at buildings at the beginning and where required throughout the year to help tenants throughout the CAF application.
• All equipment purchased through CAF is the property of TSHC.
• All events that are funded by the CAF budget must be accessible to all tenants in a given building/community.
• All tenants (over 15,000) will have an opportunity to participate in the decision-making process for activities, events, and equipment through the Annual Building Planning Process, to be within the CAF funds allocated to each building.

Community Activities Fund (CAF)

The Community Activities Fund Policy outlines how funds for tenant-led initiatives are allocated by the Toronto Seniors Housing Corporation. Every year, funding will be allocated to each building based on its size. All tenants will be encouraged to participate in a building meeting to set priorities. With staff support, tenants will decide on the events, activities, and equipment they want to have at their building for the coming year. Applicants must submit a form to TSHC to proceed with an event. If funds are still available mid-year (July), the Community Programs and Partnerships team will inform tenants of surpluses. All tenants in the buildings will be able to apply for extra funding if they are available. The deadline for submitting applications to use the remaining funds for the year is September 30.

Eligibility Criteria for CAF

TSHC tenants can request funds for initiatives that foster community development. Such initiatives include tenant-led activities and events that enhance tenant participation in their communities.

At the start of the year, the Community Services Coordinators (CSCs) will host an annual building meeting as part of the Annual Building Planning Process. Building tenants will be encouraged to gather and discuss the events, activities, and equipment they would like to have in their building for the upcoming year. Once priorities are set, the CSCs will work with the tenants present at the meeting to complete the application forms. Adjustments may be required throughout the year; CSCs will work with local volunteers to understand those, noting that volunteers will need to ensure that all tenants have had an opportunity to have input into the additional or new choices. Additional meetings with tenants will be undertaken as well if required.

Applications should be submitted for the current calendar year based on the submission deadlines listed in the Procedures document. Tenants must submit their applications no later than one month before the event or before the quarterly submission deadline, whichever comes first, as per the Procedures document. For example, if a tenant plans to organize an activity on April 15, they will need to submit the application before March 15 of the calendar year. All funding is managed annually. Funding for next year’s events will come from that year’s CAF allocation for each building. Tenants will need to work with their local CSCs. If there is a tenant volunteer or volunteers in a building, they should be made aware of the application.

Eligible Expenses through CAF Funding

• Smaller equipment that supports social recreational programming and enhancing community (e.g., gaming supplies, craft supplies)
• Food/refreshments for community events and re-occurring community gatherings (e.g., monthly social tea, BBQs)
• Event-related supplies (e.g., cutlery, trolleys or serving platters)
• Audio-visual supplies and smaller equipment for recreational room activities (e.g., microphone, projector)
• Tools and gardening supplies (for products related to food supply)
• Decorative items and seasonal décor
• Recreational smaller equipment (e.g., mahjong tables, foosball tables, and ping pong tables)

Ineligible Expenses through CAF Funding

• Alcohol or gifts
• Supplies or equipment which are for private use
• Items that are not accessible to the wider community (e.g., video game consoles)
• Duplicating items which can be provided by partner agencies or TSHC staff (e.g., mop, bucket, vacuum cleaner)
• Gardening products (e.g., soil, seeds, and plants for ornamental gardens as Operations will be funding these based on approved annual budgets)
• Costs to maintain activities beyond the funding term
• Items for events outside the building premises
• Larger equipment that exceeds $1500 and has a life span of two years or more (e.g. pool table, larger exercise equipment/treadmill which can be funded through the Operations team)

Allocation and Oversight for CAF

The CAF Coordination Group oversees the global budget for use of CAF funds. As such they are responsible for ensuring that funds are well managed and provided in a timely manner to all buildings based on applications from all regions. This administrative table approves all CAF requests to ensure Procurement and Finance and the Community Activities Fund policies are being followed.

Equity Impact Statement

Toronto Seniors Housing Corporation is committed to providing an inclusive living environment free of discrimination and harassment consistent with principles outlined in the Ontario Human Rights Code, and the Accessibility for Ontarians with Disabilities Act.

The Community Activities Fund is there to help tenant communities meet their unique equity needs, taking into account their diverse linguistic and cultural backgrounds. Tenants may use these funds for language or cultural events but must invite all building tenants to participate. If food is served at a CAF event, organizers must provide options that cater to various cultural dietary restrictions.

Conflict of Interest

A conflict of interest occurs when personal or business interests affect a tenant’s ability to fairly and objectively represent the best interests of all tenants. The interest may benefit the tenant, family, friends, or a business enterprise with which the tenant is associated.
Tenants:

• Should avoid using paid services from friends or family members.
• Must use a trusted, reputable vendor.
• Must not use Toronto Seniors Housing Corporation materials or facilities for personal gain. For example, renting out Toronto Seniors Housing Corporation office space or equipment or using Toronto Seniors Housing Corporation office space for own business or commercial activities is not allowed. (Personal gain also means gains for a family member or a friend).

Other

• For TSHC to fund events organized through CAF, all events must be fully accessible to tenants. Tenants cannot charge an additional fee for the event.
• Gratuities (tips) for any vendor must be included within the event budget and cannot exceed 15 per cent of the total invoice.

Compliance and Monitoring

The Community Programs and Partnerships team at TSHC will maintain clear and transparent records of all applications, decisions, delivery of goods, and reconciliation of funds for the projects.

The CAF Coordination Group will ensure that the funding spent on approved CAF requests follows TSHC’s policies, procedures, and guidelines and the building’s priorities.

The Finance team will review the annual reconciliation and will conduct random audits of the submissions to confirm compliance with this Policy. The CAF Coordination Group will provide the Finance Department with quarterly reporting on CAF submissions.

Related Legislation, Regulations, and TSHC Policies:

• TSHC Expense Reimbursement Policy
• TSHC Human Rights, Harassment and Fair Access Policy – Tenants
• TSHC Tenant Representative Code of Conduct
• TSHC Non-Residential Use of Space for Tenants and Tenant-Led Groups Policy

Amendments (Revision History):

Initial policy approved by Board of Directors on December 8, 2023, effective April 1, 2024.

This Policy replaces the former Tenant Funds Distribution Policy to be retired on April 1, 2024, and the Distribution of Tenant Council Funds Policy to be retired on December 31, 2023.

Next Scheduled Review Date: December 2026

This policy will be reviewed once every three (3) years.

Policy Contact

Manager, Community Programs and Partnerships

Appendices

Community Activities Fund Procedure

Toronto Seniors Housing Corporation (TSHC)
Eviction Prevention Policy for Non-payment of Rent (Arrears)

Policy Sponsor: Director, Operations

Approver: Board of Directors

Initial Approval Date: April 28, 2022

Effective Date: June 1, 2022

Policy Statement

This is a policy on eviction prevention related to the non-payment of rent. Tenants are responsible for paying their full rent on the first of every month and reporting changes in income or household composition so that their rent is calculated properly.

Toronto Seniors Housing Corporation is committed to working with tenants so that they meet these responsibilities and, wherever possible, prevent tenants from losing their housing.

Toronto Seniors Housing Corporation will work with tenants and external supports or service agencies where possible, to keep tenants housed and to ensure that rent is paid and eviction is the very last resort.

The policy is established within the context of the Shareholder Direction from the City of Toronto, the Housing Services Act, 2012 and the Residential Tenancies Act 2006.

Policy Objective

The purpose of the policy is to ensure rent is collected as required and to evict as few tenants as possible for not paying their rent.

Scope

This policy applies to:

• the non-payment of rent;
• all residential tenants in TSHC managed buildings, including rent-geared-to-income (RGI), affordable housing and market tenants.

Out of Scope

Tenants can be evicted for other reasons. These are described in a separate policy: TSHC Evictions for Cause Policy.

Values

Toronto Seniors Housing Corporation is committed to supporting successful tenancies and ensuring that tenants meet their rental responsibilities. We will:

• recognize tenants as responsible and able participants in maintaining their own tenancy and paying their rent;
• work with tenants to try to identify solutions, recognizing that tenants sometimes face barriers to maintaining their tenancy through lack of support or access to services;
• ensure all procedures regarding tenancies at risk are fair, open and equitable (procedural fairness);
• recognize the right of each individual to be treated fairly, with respect and without discrimination;
• collect rent on time, because lost revenue means there is less money for building maintenance and other services for all tenants.

Standards

• Tenants must pay their rent each month. Eviction prevention cannot be an incentive not to pay rent on time and in full.
• Staff are required to make a minimum of three (3) documented attempts to make personal contact with the tenant or one successful contact before filing an Application to Evict a Tenant for Non-payment of Rent and to Collect Rent the Tenant Owes (L1) at the Landlord and Tenant Board.
• At least one reasonable and accessible opportunity for a face- to-face meeting must be given to the tenant during the eviction process.
• Efforts and results of communications with tenants during the eviction process will be documented.
• Clear information on how rent is calculated and rental account status will be made available to tenants.
• A fair and transparent process will be available to tenants for review of RGI decisions and calculations, by a person or a panel independent from the original decision maker.
• Notices to evict will include information on the supports available to tenants to help them pay their rent, including information about local legal clinics.
• Tenants will be informed of the services offered at the Landlord and Tenant Board including mediation, duty counsel and interpretation services if applicable.
• Tenants who are evicted by the Sheriff will be informed of services offered by external organizations to assist them in finding other accommodation and support.

Policy Details

Many people living in Toronto Seniors Housing Corporation have nowhere else to go for secure, permanent housing. At times, some tenants will have trouble paying rent. Toronto Seniors Housing Corporation recognizes this and tries to prevent tenants from losing their housing because of unpaid rent.

The primary strategy for eviction prevention is effective rent collection. Efforts to collect rent and to support tenants facing eviction will continue after an order to evict has been issued by the Landlord and Tenant Board and up to the point where the unit is being re-rented.

Eviction Prevention Strategies

Staff have the flexibility and discretion to choose appropriate strategies for different situations.

Rent Collection

• Focus on collecting the rent on time.
• Provide a range of flexible rent payment options.
• Inform tenants about steps to take if they are unable to pay rent, and offer to help tenants develop plans for staying housed.
• Negotiate reasonable repayment agreements that best fits the tenant’s circumstances.
• Explain that tenants are required to indicate changes in income and household composition promptly so that rent calculation is based on the most up to date information.

Education

• Educate tenants about their rights and responsibilities and about the Eviction Prevention Policy at lease signing, at regular intervals, and when they are having trouble paying their rent.
• Train staff in eviction prevention strategies when they are hired and at regular intervals.

Communication

• Communicate directly with tenants at key stages before issues escalate, and document all attempts to communicate.
• Communicate in a timely fashion and in plain, clear, respectful language.
• Ensure documents related to eviction prevention adhere to our standards of translation and interpretation. Make staff available to talk to tenants in confidence about their situation.

Early Intervention

• Identify households that appear to be vulnerable or at a higher risk of eviction, during our interactions with tenants (e.g. unit inspections, annual rent review process).
• Monitor households that appear to be vulnerable or at a higher risk of eviction and respond accordingly.
• Intervene early when rent payment is late to help prevent tenants from falling further into arrears.

Partnerships and Referrals

• Develop partnerships with organizations that can provide supports to tenants.
• Inform tenants about, and connect them to, external organizations and community agencies that can help them maintain a successful tenancy.

Compliance and Monitoring

To ensure compliance:

• Toronto Seniors Housing Corporation will verify compliance on every file that proceeds to the Landlord and Tenant Board and will conduct random audits.
• Operational performance related to the range of eviction prevention strategies and rent collection practices will be monitored and gaps will be identified for further action.
• Eviction prevention performance reports will be submitted to the Board quarterly.

Related Legislation, Regulations, and TSHC Policies

• Residential Tenancies Act
• Housing Services Act
• Municipal Freedom of Information and Protection of Privacy Act
• Ontario Human Rights Code
• TSHC Human Rights, Harassment & Fair Access Policy – Tenants

Amendments (Revision History):

Initial policy approved by Board of Directors on April 28, 2022, effective June 1, 2022.

Next Scheduled Review Date: 2025

This policy will be reviewed once every three years.

Policy Contact

Manager, Business Operations and Compliance

Appendices

Arrears Collection Process

Toronto Seniors Housing Corporation (TSHC)
Evictions for Cause Policy

Policy Sponsor: Director, Operations

Approver: Board of Directors

Initial Approval Date: April 28, 2022

Effective Date: June 1, 2022

Policy Statement

Toronto Seniors Housing Corporation is committed to promoting successful tenancies while making sure that tenants can live together in strong, safe, and healthy communities.

The Eviction for Cause Policy outlines Toronto Seniors Housing Corporation’s approach and guides decision-making when individual behaviours impact others in Toronto Seniors Housing Corporation communities and are grounds for eviction for cause under the Residential Tenancies Act, 2006 (the RTA).

In implementing this policy, Toronto Seniors Housing Corporation is committed to making sure that individual rights under the Ontario Human Rights Code (the “Code”) are upheld, and that all tenants can live together in strong, safe, and healthy communities.

Toronto Seniors Housing Corporation will manage all tenancies in accordance with:

• The RTA;
• The Ontario Human Rights Code;
• Terms of the tenancy agreement (the “Lease”); and
• Toronto Seniors Housing Corporation policies, procedures, standards and protocols including but not limited to:
  • Human Rights, Harassment and Fair Access Policy – Tenants;
  • The established tenant complaint process.

While Toronto Seniors Housing Corporation recognizes the gravity and impact of eviction, it is prepared to pursue eviction when the legal grounds for eviction exist and the problem cannot be resolved in the interest of the community without pursuing eviction.

Policy Objective

The goal of the policy is to promote successful tenancies while maintaining safe and harmonious communities.

As a landlord, Toronto Seniors Housing Corporation is responsible for ensuring the maintenance and repair of buildings it manages is completed, and does not interfere with the rights of tenants as defined by the RTA.

The policy outlines principles and standards Toronto Seniors Housing Corporation will use to deal with actions and behaviours that result in tenants not complying with their responsibilities, interfere with the rights of other tenants or the landlord, or undermine community safety.

Scope

This policy applies to all residential tenants directly managed by Toronto Seniors Housing Corporation, including rent-geared-to-income (RGI), affordable housing and market tenants. It also applies to occupants, visitors, and guests insofar as tenants are responsible for the conduct of all occupants, guests, and visitors who they invite onto the residential complex^[1].

The policy is concerned with behaviours that could lead to eviction under the RTA and applies to the following stipulated causes for eviction:

• substantial interference with reasonable enjoyment or with other rights, interests or privileges;
• damage to property;
• impairment of safety;
• fraud and misrepresentation of income;
• illegal sublet unauthorized occupancy;
• ending the tenancy and/or relocation for demolition, conversion, repairs or sale of the property;
• illegal acts.

Out of Scope

This policy does not apply to the following:

• arrears; or
• ceasing to qualify for social housing.

Definitions

Guests: Persons who require temporary accommodation with a tenant (guests do sleep in the tenant’s unit but only for a maximum of 30 days within any 12-month period unless under the special circumstances as defined by the Visitor and Guest Policy and approved by TSHC). Guests are not part of the tenant’s household. Guests maintain a home address outside the tenant’s unit.

Occupants: For Rent-Geared-to-Income (RGI) tenancies, an occupant is a person who is a declared member of an RGI household, who has been added to the household with Toronto Seniors Housing Corporation’s consent, but who has not signed a lease with Toronto Seniors Housing Corporation.

For market rent tenancies, an occupant is a person who has been added to a market household, with Toronto Seniors Housing Corporation’s consent, but has not signed the lease, or an undeclared person who is living in a market rent unit together with the tenant.

Occupants have no right to live in the tenant’s unit once the tenant moves out.

Tenants: Persons who have signed a lease and have all tenant rights and responsibilities related to the tenancy.

Visitors: Persons who visit a tenant and do not require temporary accommodation with the tenant.

Visitors are not part of the tenant’s household. Visitors maintain a home address outside the tenant’s unit.

Values

Toronto Seniors Housing Corporation, its staff and tenants are committed to promoting successful tenancies while maintaining harmonious, safe, healthy and livable communities.

In making decisions about evictions for cause, we will:

• recognize the right of each individual to be treated fairly, with respect and without discrimination. Toronto Seniors Housing Corporation will not accept harassment or discrimination towards any tenant, or employee;
• recognize tenants as responsible and able participants in maintaining their own successful tenancy and healthy communities;
• recognize that some tenants may face barriers in maintaining a successful tenancy as the result of vulnerabilities, including but not limited to mental health issues, or disabilities. We will abide by our duty to accommodate under the Ontario Human Rights Code;
• make decisions based on what we believe to be reliable information; full and fair consideration of complaints; objective assessment of the facts; and, judgment of what will best solve the issue for the community.

Standards

Toronto Seniors Housing Corporation will:

1. use sufficient, relevant and objective facts to support decisions in the eviction process;
2. discuss the situation with the tenant prior to making an application to evict with the Landlord and Tenant Board. Sometimes it is not reasonably possible or appropriate to meet with the tenant. In these cases, clear documentation of the circumstances is required;
3. issue only the appropriate notices of termination, which clearly describe for the tenant the conduct and legal grounds that justify the notice;
4. inform tenants of the services offered through legal aid clinics as well as the need for translation services upon Toronto Seniors Housing Corporation issuing a Notice to Terminate a Tenancy; and,
5. ensure that, where an order to terminate a tenancy has been issued by the Landlord and Tenant Board, tenants are sent information on supports that may be available to them including information about shelters.

Toronto Seniors Housing Corporation will not pursue evictions for complaints or incidents that occurred more than three (3) years earlier unless there are extremely compelling reasons to do so such as:

• the incident is part of a pattern of behaviour that continues to impact the community;
• similar or related incidents have occurred since the original incident;
• Toronto Seniors Housing Corporation was not aware of the incident and it has the potential to seriously impact the community; or,
• other reasons set out in the procedures.

 Policy Details

Toronto Seniors Housing Corporation handles incidents that could lead to eviction in a balanced manner, taking into consideration the specific fact situation; a tenant’s individual circumstances; Toronto Seniors Housing Corporation’s responsibilities to all tenants and staff; and, Toronto Seniors Housing Corporation’s responsibility to respect human rights, procedural fairness and transparency.

A Balanced Approach

Apply a balanced approach to maintaining harmonious healthy communities as well as individual tenancies – the key consideration is what will best solve the problem for the community.

Use a problem-solving approach, including alternative resolution methods, giving the tenant an opportunity to correct the problem and negotiating agreements where appropriate.

Facilitate separate third party support services when a tenant faces barriers or difficulties maintaining their own successful tenancy and healthy communities.

Fair Review and Resolution

Toronto Seniors Housing Corporation will ensure that complaints are addressed and investigated in a consistent, fair and timely manner to reduce escalation.

When a tenant does not abide by the terms of the lease, and/or the RTA, Toronto Seniors Housing Corporation will provide and communicate clear, enforceable and progressive consequences that reflect the severity and persistence of the behaviour.

Circumstances Warranting Eviction

While Toronto Seniors Housing Corporation recognizes the seriousness of eviction and the impact it can have on some tenants for whom Toronto Seniors Housing Corporation is the only source of secure permanent housing, we will pursue eviction when:

• despite all efforts to resolve the problem, the actions of a tenant, household, pet, guest or occupant continue to negatively impact tenants, staff or the community, and the circumstances constitute grounds for eviction under the RTA;
• eviction may be pursued immediately in very serious situations, generally involving serious impairment of safety or serious criminal activity.

Compliance and Monitoring

Toronto Seniors Housing Corporation will:

• develop and maintain procedures to assist staff in interpreting and applying this policy;
• ensure clear documentation practices are in place;
• monitor the effectiveness of this policy in responding to and reducing incidents and behaviours that negatively impact the health of communities; and,
• provide quarterly reports to the Board on eviction rates.

Related Legislation, Regulations, and TSHC Policies:

• Residential Tenancies Act, 2006
• Housing Services Act, 2012
• Municipal Freedom of Information and Protection of Privacy Act
• Ontario Human Rights Code
• TSHC Guide to Contacting Tenants, Documentation and Record Keeping
• TSHC Human Rights, Harassment and Fair Access Policy – Tenants
• TSHC Tenant Complaint Process
• TSHC Visitor and Guest Policy

Amendments (Revision History):

Initial policy approved by Board of Directors on April 28, 2022, effective June 1, 2022.

Next Scheduled Review Date: 2025

This policy will be reviewed once every three years.

Policy Contact

Manager, Business Operations and Compliance

Appendices

• TSHC Evictions for Cause Procedures (under review)

^[1] The tenant is also responsible for the conduct of any visitor or guest that an occupant of their unit has invited onto the residential complex.

Toronto Seniors Housing Corporation (TSHC)
Visitor and Guest Policy

Policy Sponsor: Director, Operations

Approver: Board of Directors

Initial Approval Date: April 28, 2022

Effective Date: June 1, 2022

Policy Statement

This policy explains the way Toronto Seniors Housing Corporation will manage visitors and guests of all Toronto Seniors Housing Corporation tenants. Tenants may have visitors or guests in their homes. Toronto Seniors Housing Corporation and other social housing providers know that from time to time tenants may have guests who stay with them in their homes for a number of days at a time. These might include out-of-town guests, or persons who tenants have personal relationships with and are not part of their households.

 A tenant may have a guest in their home for a maximum of 30 days, in total, within a 12-month period. The 30 days may be consecutive or non-consecutive days and applies to any one individual that stays in the tenant’s unit. In special cases, as defined below, guests may stay in a unit longer than 30 days.

Tenants are responsible for the actions and behaviours of anyone that they invite onto the residential complex including their visitors and guests.

This policy defines Toronto Seniors Housing Corporation’s practice for dealing with visitors and guests. It supports Toronto Seniors Housing Corporation’s commitment to equitable and quality service and meets legislative requirements.

Policy Objectives

The purpose of this policy is to make sure that all tenants understand their responsibilities related to visitors and guests, and for Toronto Seniors Housing Corporation to meet the following objectives:

• explain when a person is considered a visitor or a guest;
• explain when a market rent household is required to inform Toronto Seniors Housing Corporation of changes to their household composition as required by this policy;
• explain when a rent-geared-to-income household is required to inform Toronto Seniors Housing Corporation of changes to their household composition as required by this policy;
• establish the maximum length of time tenants can have guests;
• establish exceptions to the maximum permitted time for guests;
• balance the tenant’s right to use their home and Toronto Seniors Housing Corporation’s requirement to assess household eligibility for housing;
• make sure that subsidies are based on the true household income, including anyone who moves into the unit;
• help to make sure that subsidies are available to households that qualify; and
• ensure that residential units are not improperly transferred or

Scope

This policy applies residents in Toronto Seniors Housing Corporation households.

Out of Scope

Live-in caregivers are not covered by the scope of this policy. If a member of a household requires a live-in caregiver, the tenant must make the request in writing to have the live-in caregiver stay in their unit through their Regional office.

Definitions

Guests: Persons who require temporary accommodation with a tenant (guests do sleep in the tenant’s unit, but only for a maximum of 30 days within any 12-month period unless they are a special case as defined below). Guests are not part of the tenant’s household. Guests maintain a home address outside the tenant’s unit.

Live-in caregivers: Persons who provide support services needed because of a household member’s disability or medical condition. They are not considered tenants, visitors or guests.

Occupants: For rent-geared-to-income tenancies, an occupant is a person who is a declared member of a rent-geared-to-income household, who has been added to the household with Toronto Seniors Housing Corporation’s consent, but who has not signed a lease with Toronto Seniors Housing Corporation. For market rent tenancies, an occupant is a person who has been added to a market household, with Toronto Seniors Housing Corporation’s consent, but has not signed the lease, or an undeclared person who is living in a market rent unit together with the tenant.

Occupants have no right to live in the tenant’s unit once the tenant moves out.

Tenants: Persons who have signed a lease and have all tenant rights and responsibilities related to the tenancy [1].

Toronto Seniors Housing Corporation staff: This includes, but is not limited to, all Toronto Seniors Housing Staff.

Unauthorized occupants: Any person who is not a tenant, occupant, visitor, guest, or live-in caregiver as defined by this policy. An unauthorized occupant has no lawful authority to be at a Toronto Seniors Housing Corporation residential complex and has no rights to the rental unit in question.

Visitors: Persons who visit a tenant and do not require temporary accommodation with the tenant (visitors do not sleep in the tenant’s unit). Visitors are not part of the tenant’s household. Visitors maintain a home address outside the tenant’s unit.

Roles and Responsibilities

Toronto Seniors Housing Corporation staff are responsible for:

• investigating cases where tenants appear to have guests staying with them for more than 30

Tenants are responsible for:

• the actions and behaviours of their occupants, visitors and guests;
• telling their guests and visitors that they may be asked to prove that they have a home address outside of the unit they are visiting;
• reporting a person that they wish to add to their household composition as outlined in the Addition to Household Composition Directive; and
• complying with this

Policy Content

Visitors

Visitors may come to the unit as often as the tenant invites them. Frequent visitors may be asked to prove that they have a home address outside of the unit they are visiting. Tenants are responsible for telling all visitors about this rule.

Guests

Tenants may have a guest stay in their unit for a maximum of 30 days in total, within a 12-month period and are encouraged to report to Toronto Seniors Housing Corporation all persons staying in the unit for safety and emergency purposes.

Guest who stays longer than 30 days – special cases

If Toronto Seniors Housing Corporation staff receive information that a person has been staying in a tenant’s unit longer than 30 days, Toronto Seniors Housing Corporation staff will investigate and request documentation from the tenant explaining the reason for the stay and information about how long the person is staying to ensure that the person qualifies as a special case guest.

Special cases where a guest may stay longer than 30 days might include, but are not limited to:

• an accommodation-related issue as defined in Toronto Seniors Housing Corporation’s Human Rights, Harassment and Fair Access Policy – Tenants and the Ontario Human Rights Code, such as the need for someone to provide short-term supportive care to a person with a disability as prescribed by a qualified licensed healthcare professional; or
• the guest lives outside the country and has travel documents to prove their planned return date and leaves on that

Additional detail about special cases is provided in the Visitor and Guest Policy Guideline.

Limitations to stays longer than 30 days

In all cases other than the special cases outline above, Toronto Seniors Housing Corporation will decline to allow the person to stay with the tenant.

Toronto Seniors Housing Corporation staff may determine a situation is not a special case and a guest is not allowed to stay longer than 30 days for the following reasons including, but not limited to:

• the tenant does not provide appropriate documentation as outlined in the Visitor and Guest Policy Guideline to explain why the guest needs to stay longer than 30 days;
• the guest does not intend to leave at the end of the agreed-to term;
• staff or tenants have complained about the guest’s behaviour, and Toronto Seniors Housing Corporation is satisfied the complaints are well founded; and
• the guest(s)’ stay would result in non-compliance with Occupancy Standards under the Toronto Municipal Code Property Standard [2].

Any person located in a residential unit who is not a tenant, occupant, visitor, guest, or live-in caregiver as defined by this policy is an unauthorized occupant and has no lawful right to be on the premises.

Unreported stay

If a person remains longer than 30 days in breach of this policy, Toronto Seniors Housing Corporation may pursue any legal rights available to it including, but not limited to:

• possible termination of subsidy if it is a rent-geared-to-income household due to failure to notify the landlord of changes in household composition as required by the Housing Services Act, 2011;
• enforcement of any rights available to Toronto Seniors Housing Corporation under the Trespass to Property Act against the unauthorized occupant; and
• any action against the tenancy available to Toronto Seniors Housing Corporation.

If a rent-geared-to-income household loses their subsidy, they will have to pay the market rent for the unit and will no longer qualify for a rent-geared-to-income subsidy. The tenant has the right to request a review of decisions related to their continued eligibility for rental subsidy.

Rights to unit

If the tenant moves out of the unit, all other persons in the unit must also leave. Any occupant, guest, visitor, live-in caregiver, unauthorized occupant, or anyone else found in the unit after the tenant moves out will be:

• ineligible for receipt of the household’s rent-geared-to-income subsidy; and
• identified as

Toronto Seniors Housing Corporation will reclaim the unit.

Market rent households

A market rent tenant:

• may allow a guest to stay in their rental unit. The market rent tenant may not, however, assign or sublet all or any part of the unit [3]
• is required by their lease to report any changes in household composition within 30 days of the change;
• may request to add another tenant to their unit and sign a new lease;
• should report all persons living in the unit even if the tenant does not wish to add the proposed person to their lease as a tenant. It is essential for safety and emergency purposes that Toronto Seniors Housing Corporation knows who lives in its units. Occupants do not have any legal rights or entitlements to a tenant’s

Compliance and Monitoring

The Regional Manager, or designate, will monitor compliance with the policy on an ongoing basis by reviewing a random sampling of tenant files.

Frequency of incidents involving unauthorized occupants will be monitored via reports to the fraud and waste hotline and complaints entered into the HoMES system.

Related Legislation, Regulations, and TSHC Policies:

• Housing Services Act, 2011
• Municipal Freedom of Information and Protection of Privacy Act, 1990
• City of Toronto Occupancy Standards
• Ontario Human Rights Code
• Residential Tenancies Act, 2006
• Trespass to Property Act, 1990
• TSHC Addition to Household Composition Directive
• TSHC Human Rights, Harassment and Fair Access Policy – Tenants
• TSHC Evictions for Cause Policy
• TSHC Tenant Charter

Amendments (Revision History):

Initial policy approved by Board of Directors on April 28, 2022, effective June 1, 2022.

Next Scheduled Review Date: 2027

This policy will be reviewed once every five years.

Policy Contact

Manager, Business Operations and Compliance

Appendices

• Visitor and Guest Policy Agreement

[1] In certain circumstances, as defined by the Residential Tenancies Act, the spouse of a tenant may become a tenant when the tenant dies or vacates the unit. This provision does not apply to some or all of Toronto Seniors Housing Corporation’s rental units. Anyone faced with this situation must speak with their Regional Manager.

[2] CHAPTER 629-25, Occupancy Standards, Toronto Municipal Code Property Standard:

“The maximum number of persons living in a habitable room shall not exceed one person for each nine square metres (96.8 sq. ft.) of habitable room floor area.”

“The minimum floor area of a room used by two or more persons for sleeping shall be four square metres (43 sq. ft.) for each person using the room.”

http://www.toronto.ca/legdocs/municode/1184_629.pdf

[3] Toronto Seniors Housing Corporation reserves the right to take any legal action available against a tenant who has illegally sublet or assigned their tenancy, and reserves the right to take legal action in relation to unauthorized occupancy of a rental unit.

[4] Toronto Seniors Housing Corporation reserves the right to refuse to enter into any tenancy in accordance with its normal leasing practices.

Toronto Seniors Housing Corporation (TSHC)
Relocation Policy

Policy Sponsor: Director, Operations

Approver: Board of Directors

Initial Approval Date: April 28, 2022

Effective Date: June 1, 2022

Policy Statement

Toronto Seniors Housing Corporation (TSHC) is committed to promoting healthy communities and quality of life for tenants. Toronto Seniors Housing Corporation recognizes that relocation may cause hardships for those directly affected and the community.

The purpose of the policy is to minimize the adverse effects of relocation on tenants facing displacement from a TSHC unit, with a goal of tenants being able to continue their life in a Relocation Unit with minimal disruption. This policy provides the framework to govern the relocation of households.

Scope

This policy applies to all residential tenants directly managed by Toronto Seniors Housing Corporation, including rent-geared-to-income, affordable, and market tenants that are required to move out of their units because TSHC needs possession of their unit for any of the following reasons:

• revitalization;
• renovation;
• permanent unit closures;
• emergency situations;
• accessibility upgrades; and
• any other reason that Toronto Seniors Housing Corporation requires a household to transfer from one Toronto Seniors Housing Corporation unit to another.

The Relocation Policy will cover all situations where Toronto Seniors Housing Corporation initiates relocating a current Toronto Seniors Housing Corporation household to a different Toronto Seniors Housing Corporation unit, except in instances of a fire in a unit or building. Reasons for relocation will be limited to the categories defined within the Relocation Policy and in compliance with relevant legislation.

Out of Scope

Tenant-initiated requests for transfer are addressed in Toronto Seniors Housing Corporation’s Tenant Transfer Policy.

Definitions

Accessibility Upgrades: Where a tenant’s unit is undergoing planned accessibility upgrades to accommodate their accessibility needs and it is not possible for them to remain in the unit while the work is taking place.

Emergency Situations: Where an emergency takes place in a unit or building (such as flood, emergency roof repairs, etc.) and occupying the unit would pose an immediate risk to tenants’ health or life safety, and major unplanned rehabilitation is required in the unit or building.

Large-Scale Renovation: Major planned repairs to a unit or building where a household’s unit must be vacant in order for the work to take place.

Permanent Relocation: Where a tenant is required to relocate from their unit and will not return to the same unit.

Permanent Unit Closure: Where units or buildings have deteriorated into a critical state of repair and must be closed because they are no longer safe for tenants to live in, where a building is repurposed for another use, or any other reason that requires a unit be closed.

Relocation Agreement: A written contract between tenants and Toronto Seniors Housing Corporation, which outlines the rights and obligations of both parties during the relocation process.

Relocation Unit: The unit a household is moved to when they must be relocated from their current unit.

Revitalization: The large-scale demolition and rebuild of multiple Toronto Seniors Housing Corporation-managed buildings in one community to elevate the housing conditions and circumstances for tenants.

Right to Return: Tenants who are moved due to revitalization have the right to return to a new unit in a revitalized community, subject to eligibility rules in the Relocation Agreement it signs with Toronto Seniors Housing Corporation.

Temporary Relocation: A temporary move between Toronto Seniors Housing Corporation units initiated by Toronto Seniors Housing Corporation where the household must return to their original unit.

Temporary Shelter Agreement: A written agreement between a household and Toronto Seniors Housing Corporation that outlines the rights and obligations of both parties during a temporary relocation. This only applies to relocation due to accessibility upgrades.

Tenancy in Good Standing: A household is in good standing if:

• none of the members of the household owe money to Toronto Seniors Housing Corporation in relation to a current or former tenancy or if any member of the household does owe money, they have entered into a repayment agreement with Toronto Seniors Housing Corporation and are in compliance with that agreement;
• Toronto Seniors Housing Corporation is not currently taking legal action against the household for any reason; and
• the Landlord and Tenant Board has not ordered termination of the tenancy.

Tenant Relocation Assistance Implementation Plan (TRAIP): A document that sets out the steps that Toronto Seniors Housing Corporation will take to support tenants to relocate units and what tenants can expect from Toronto Seniors Housing Corporation during the moving process such as notice periods, any financial assistance, and other supports to assist with moving.

Standards

Standards Applied to All Relocations

Toronto Seniors Housing Corporation may initiate the relocation of a household for any of the reasons listed above. In all instances, the following standards apply:

• Households may only relocate to a unit for which they are eligible under the Housing Services Act, the City of Toronto’s Occupancy Standards, and any other applicable rules and regulations.
• Toronto Seniors Housing Corporation may choose not to relocate a household if its tenancy is not in good standing.
• Toronto Seniors Housing Corporation will make reasonable efforts to assist each household to address any outstanding tenancy issues and ensure their tenancy is in good standing before relocation.
• Toronto Seniors Housing Corporation will work with community partners and will assist in connecting tenants with community partners and services, where needed.
• The relocation process cannot be used to split rent-geared-to-income tenancies. The rent-geared-to-income household is entitled to relocate to one unit in accordance with the City of Toronto’s Occupancy Standards.
• Toronto Seniors Housing Corporation staff will work with tenants on the selection of a relocation unit for which the household is eligible.
• Toronto Seniors Housing Corporation will provide moving assistance subject to the requirements in any applicable agreements (e.g. a Tenant Relocation Assistance Implementation Plan) and the household qualifying for moving assistance.
• For rent-geared-to-income tenants, rent will continue to be based on income. For all other tenants, rents may change as a result of relocation both in the relocation unit and the unit to which tenants return after the relocation.
• The relocation process will follow the rules in the Residential Tenancies Act and any other applicable rules and regulations.
• Households may waive the right to return, if applicable, and remain in their relocation unit, except in instances of relocation due to accessibility upgrades.

Note: If a unit or building is sold, the household may or may not be required to relocate. The decision to relocate a household will be based on the terms in the Agreement of Purchase and Sale signed with the new owners.

Standards Applied to Relocations due to Permanent Unit Closures or Revitalization

In instances of permanent unit closures or revitalization, the following standards apply:

• An official notice will be issued to each household in writing prior to relocation. Notification will be provided according to the timelines set out in any governing agreements and legislation.
• Toronto Seniors Housing Corporation may be required to develop a Tenant Relocation Assistance Implementation Plan for specific buildings or communities as part of the City of Toronto’s approval process. Where these plans are in place, they will take precedent over the standards in this policy.
• The order in which households will be offered a relocation unit will be established through a random selection draw.
• If a household does not choose a relocation unit by the deadline provided by Toronto Seniors Housing Corporation, Toronto Seniors Housing Corporation may begin the process for terminating the household’s tenancy.
• Once an offer is accepted for a relocation unit, the household must sign a new lease for the relocation unit and an Agreement to Terminate the Tenancy for their existing unit.
• Tenants who are moved due to revitalization have the right to return to a new unit in a revitalized community, subject to eligibility rules in the Relocation Agreement it signs with Toronto Seniors Housing Corporation.
• A household will only receive one offer of a revitalization unit. Once the household has exercised its right to return to a revitalization unit, it is not entitled to transfer to a different revitalization unit, even if the household’s family composition has changed after moving.
• Households may defer their right to return for a later opportunity, if allowed by the applicable Tenant Relocation Assistance Implementation Plan, and any other applicable agreements or plans.
• If a household terminates its tenancy with Toronto Seniors Housing Corporation at any point during the relocation process, it may no longer be eligible to return to the revitalized community subject to the terms of its Relocation Agreement.

Standards Applied to Relocations due to Large-Scale Renovations

In instances of large-scale renovations, the following standards apply:

• Once an offer is accepted for a relocation unit, the household will sign a new lease for that unit and an Agreement to Terminate the Tenancy for its existing unit.
• After the renovation is completed, the household has right of first refusal to return to the renovated unit as long as it gives Toronto Seniors Housing Corporation written notice it will be exercising that right before relocating and complies with any other conditions in the relocation agreement it signs with Toronto Seniors Housing Corporation.
• If a rent-geared-to-income household will be overhoused in the renovated unit at the time when it exercises its right of first refusal and returns to the unit, the household will not be eligible for moving assistance for the move from its relocation unit to the renovated unit.

Standards Applied to Relocations due to Emergency Situations

In instances of emergency situations, the following standards apply:

• Once an offer is accepted for a relocation unit, the household will sign a new lease for that unit and an Agreement to Terminate the Tenancy for their existing unit.
• After the repairs are completed, the household has right of first refusal to return to its previous unit as long as it gives Toronto Seniors Housing Corporation written notice it will be exercising that right before relocating.

Note: Where there is a fire in a unit, refer to the Resident Relocation – Fire Response Procedure.

Standards Applied to Relocations due to Accessibility Upgrades

In instances of accessibility upgrades, the following standards apply:

• Households who are relocated must sign a Temporary Shelter Agreement for their relocation unit.
• Households must return to their original unit after accessibility upgrades are complete.
• Rent-geared-to-income households that temporarily relocate outside of Toronto Seniors Housing Corporation while accessibility upgrades take place in their unit will not lose their rent-geared-to-income subsidy, provided they return to their unit once the work is complete. Where a household can stay with family or friends outside of Toronto Seniors Housing Corporation, this option will be pursued first.

Compliance and Monitoring

The Regional Manager in each Region is responsible for having a process in place to monitor staff compliance with this policy.

Related Legislation, Regulations, and TSHC Policies:

• Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11
• City of Toronto Occupancy Standards
• City of Toronto Property Standards Bylaw
• Housing Services Act
• Ontario Human Rights Code
• Residential Tenancies Act
• TSHC Accessibility Policy
• TSHC Evictions for Cause Policy
• TSHC Eviction Prevention Policy for Non-payment of Rent (Arrears)
• TSHC Human Rights, Harassment and Fair Access Policy – Tenants
• TSHC Tenant Complaints Process
• TSHC Tenant Charter
• TSHC Tenant Transfer Policy
• TSHC Translation and Interpretation Policy
• TCHC-TSHC Emergency Response Plan

Amendments (Revision History):

Initial policy approved by Board of Directors on April 28, 2022, effective June 1, 2022.

Next Scheduled Review Date:

This policy will be reviewed once every five years.

Policy Contact

Manager, Business Operations and Compliance

Appendices

• Relocation Procedure (in development)

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Human Rights, Harassment and Fair Access Policy – Tenants

Policy Owner:

Approval:

First Approved:

Current Approval:

Effective Date:

Policy Statement

Toronto Seniors Housing Corporation is committed to providing an inclusive living environment free of discrimination and harassment consistent with the principles outlined in the Ontario Human Rights Code (“Code”), and the Accessibility for Ontarians with Disabilities Act (“AODA”).

Toronto Seniors Housing Corporation will not tolerate, ignore or condone any form of discrimination, harassment or hate activity on Toronto Seniors Housing Corporation property. Under the Code, everyone has a right to be free from harassment and discrimination and a right to equal treatment and Toronto Seniors Housing Corporation supports delivering service that respects dignity, self-worth and the human rights of every person.

Scope

The purpose of this policy is to set out:

• The protections given to applicants and tenants related to discrimination in accommodation, contracts, services, or facilities;
• The protections given to applicants and tenants related to harassment based on a protected ground; and
• The expectations of Toronto Seniors Housing Corporation related to hate activity on Toronto Seniors Housing Corporation property.

Definitions

Accommodation: An individualized process to improve equality and remove barriers experienced by a person or groups related to a prohibited ground, to the point of undue hardship1. The accommodation process is a shared responsibility. Everyone involved including the person asking for an accommodation, should work together, exchange information, and look for accommodation solutions together. For more information, please see the Request for Accommodation section of this policy.

Applicant – An Applicant who has applied to live in a unit that is owned or operated by or on behalf of Toronto Seniors Housing Corporation.

Disability: A disability is defined in the Code as:

1. any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device,
2. a condition of mental impairment or a developmental disability,
3. a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,

1 The Code prescribes only three considerations when assessing whether an accommodation would cause undue hardship: cost, outside sources of funding, if any and health and safety requirements, if any.

1. a mental disorder, or
2. an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Discrimination: A practice or behaviour that treats people unequally or creates a distinction based on a prohibited ground under the Code resulting in an obligation, burden, barrier by perpetuating prejudice or stereotyping. Discrimination may result from the effect of applying general rules to everyone, because it has a discriminatory or unequal effect on a particular person or group based on a prohibited ground (see Prohibited Grounds definition). Systemic Discrimination a specific type of discrimination characterized by patterns of behaviour, policies or practices structure or culture of the organization.

Harassment: A course of unwanted comment(s) or conduct related to a prohibited ground that is known or ought reasonably to be known to be unwelcome. Harassment may result from one incident or a series of incidents.

Hate Activity: Acts committed to deliberately intimidate, harm, harass, use physical force against, or threaten a person on the sole basis that they belong to a group identified by a prohibited ground. Hate activity can be a form of discrimination and a criminal offence under the Criminal Code of Canada.

Prohibited Grounds: The Code forbids discrimination or harassment based on the following personal characteristics in occupancy of accommodation, contracts, and services: age, ancestry, citizenship, colour, creed, disability, ethnic origin, family status, gender identity, gender expression, marital status, place of origin, race, sex (including pregnancy and breast-feeding), receipt of public assistance, and sexual orientation.

Social areas: The Code ensures that every person can enjoy freedom from harassment and discrimination in five areas, called social areas. The three that apply to this policy are: Occupancy of Accommodation, Contracts and Services and Facilities.

Tenant: For the purpose of this policy, the term “tenant” includes all individuals living lawfully in a Toronto Seniors Housing Corporation household.

Both Tenants and Occupants are defined by Toronto Seniors Housing Corporation’s Addition to Household Composition Directive and Visitor and Guest Policy.

Policy Details

Toronto Seniors Housing Corporation is committed to fostering an environment that respects human rights and will advance this standard. The types of prohibited grounds can vary based on the social areas.

Housing or Occupancy

All tenants have a right to equal treatment with respect to occupancy of accommodation (housing) without discrimination by Toronto Seniors Housing Corporation, because of the following prohibited grounds or any combination of these grounds.

• race
• ancestry
• place of origin
• citizenship
• creed or religion
• gender identity
• gender expression
• receipt of public assistance
• age2
• disability
• colour
• ethnic origin
• sexual orientation
• sex (including pregnancy and breastfeeding)
• marital status
• family status
• association with anyone who has protections under this policy
• any other prohibited ground(s) that may be amended under the Code

Services and Facilities

All tenants have a right to equal treatment with respect to Toronto Seniors Housing Corporation services, and the use of Toronto Seniors Housing Corporation’s facilities, without discrimination or harassment, on any of the following prohibited grounds.

• race
• ancestry
• place of origin
• citizenship
• creed or religion
• gender identity
• gender expression
• colour
• ethnic origin
• sexual orientation
• sex (including pregnancy and breastfeeding)
• marital status
• family status
• age
• disability
• level of literacy*
• association with anyone who has protections under this policy
• any other prohibited ground(s) that may be amended under the Code

*While level of literacy is not a prohibited ground under the Code, in the interests of promoting inclusivity Toronto Seniors Housing Corporation will, wherever possible, communicate with tenants in a manner which is accessible to them.

2 Accommodation of person under eighteen – Every sixteen- or seventeen-year-old person who has withdrawn from parental control has a right to equal treatment with respect to occupancy of and contracting for accommodation without discrimination because the person is less than eighteen years old.

Contracts

Every person having legal capacity has a right to contract on equal terms without discrimination or harassment because of the following prohibited grounds or any combination of these grounds.

• race
• ancestry
• place of origin
• citizenship
• creed or religion
• gender identity
• gender expression
• age
• disability
• colour
• ethnic origin
• sexual orientation
• sex (including pregnancy and breastfeeding)
• marital status
• family status
• association with anyone who has protections under this policy
• any other prohibited ground(s) that may be amended under the Code

Hate Activity

Toronto Seniors Housing Corporation does not tolerate hate activity on Toronto Seniors Housing Corporation property and such behavior is grounds for a complaint under this policy.

Tenants are expected not to engage in hate activity and are expected not to promote, condone, or otherwise encourage hate activity by their guests or visitors on Toronto Seniors Housing Corporation property. Hate Activity can include but is not limited to acts of violence, verbal slurs accompanied by a threat, vandalism of the person’s property, and/or messaging designed to spread hate activity.

Filing a Complaint

Toronto Seniors Housing Corporation will respond to any complaints under the policy, providing the complaint is made within 12 months of the alleged discrimination or harassment incident. Complaints may be accepted after 12 months after the incident, at the discretion of Toronto Seniors Housing Corporation.

Please refer to the Human Rights, Harassment, and Fair Access Procedure for Tenant Complaints (“Procedure”) for further detail about Toronto Seniors Housing Corporation’s complaints process.

Reprisal

Toronto Seniors Housing Corporation forbids taking action against a person who has made a complaint of discrimination or harassment in good faith under this policy or is participating in an investigation under this policy. Reprisal includes harassment, discrimination, intimidation or imposition of another penalty, or any other action which harms their living conditions. Reprisal includes a threat to take action or knowingly advising another person to engage in reprisal.

Responsibilities

Toronto Seniors Housing Corporation will:

• Develop and maintain procedures and/or guidelines for investigating and addressing any complaints that may arise under this policy.
• Provide education to employees on this policy to make sure they are aware of the conduct which is prohibited under this policy.
• Create awareness where needed to make sure that all tenants have knowledge about their rights and responsibilities under this
• Promptly respond to and take appropriate actions when a complaint is made under this policy in accordance with the
• Address tenant complaints according to the
• Provide support to staff to address tenant complaints according to the Procedure.
• Collaborate with staff from Human Resources on human rights and diversity initiatives and provide additional resources or support when needed.
• Provide awareness and education to
• Facilitate requests by tenants for accommodations as
• Monitor the effectiveness of this policy through regular reporting on equity, diversity and human rights initiatives to the City of Toronto

The Human Resources will:

• Address or investigate complaints made against employees according to the applicable procedure, with the support a where
• Make sure employees comply with any obligations they may have under this policy or the Code.

Compliance and Monitoring

Toronto Seniors Housing Corporation employees may not engage in discrimination, harassment or hate activity under this policy. Violation of this policy can lead to discipline up to and including termination for cause.

Vendors or contractors, are responsible for following any provision of their contract related to discrimination or harassment on Toronto Seniors Housing Corporation property. Violation of this policy can lead to termination of their contract or any other consequence set out in their contract with Toronto Seniors Housing Corporation.

Tenants are also expected to follow this policy, which includes refraining from harassment, discrimination, or hate activity against other tenants, Toronto Seniors Housing Corporation employees, vendors or contractors on Toronto Seniors Housing Corporation property. Tenants are also responsible for making sure that their

guests or visitors follow this policy while on Toronto Seniors Housing Corporation property. Violation of this policy can lead to legal or other action by Toronto Seniors Housing Corporation.

Governing and Applicable Legislation

• Ontario Human Rights Code
• Accessibility for Ontarians with Disabilities Act
• Criminal Code of Canada
• Occupational Health and Safety Act
• Residential Tenancies Act

Related Policies and Procedures

• Human Rights, Harassment and Fair Access Procedure for Tenant Complaints
• Human Rights, Harassment, and Fair Access Complaint Procedure (Staff)
• Accessibility Policy
• Employee Code of Conduct
• Tenant Representative Code of Conduct
• Tenant Charter

Commencement and Review 

Next Scheduled Review Date:

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Tenant Complaint Procedure

TSHC Human Rights, Harassment and Fair Access Policy

Tenant Complaint Procedure related to Human Rights 

Policy Owner

Approval

First Approved

Effective Date

This Complaint Procedure covers the following topics:

• Purpose of Complaint procedure
• Scope of Complaints Procedure
• Definition of terms
• How the Complaints Procedure Works
• Step 1 Identify the problem
• Step 2 Gather evidence
• Step 3 Attempt resolution
• Step 4 File formal (written) complaint
• Step 5 Mediation
• Step 6 Investigation of a formal complaint
• Step 7 TSHC management decision
• Step 8 Remedies and Restoration Actions
• Miscellaneous Matters
• Confidentiality and Non-Disclosure
• Who can Complain and Anonymity
• Resources and Representatives
• Time limit for Complaints
• Disclosure of Investigation Results and Final decision
• Completion of Complaint Resolution Process
• Participation and Accommodation
• No Retaliation

Human Rights, Discrimination, Harassment and Fair Access Policy

TSHC will not tolerate, ignore, or condone any form of discrimination, harassment or barrier to services. All employees, contractors, agents, tenants, Board Directors, volunteers and appointees who serve on committees established by TSHC are bound by this policy in their dealings with TSHC. They have a duty to actively promote and support human rights, to remove barriers to equality and to refrain from harassment and discrimination. TSHC is committed to promoting a climate of understanding and mutual respect where each member of TSHC community is able to derive benefits and to participate fully to the development and well being of the community.

Purpose of Human Rights Complaints Procedure for Tenants

• This complaints procedure explains how a tenant can make a complaint related to a Human Rights issue.
• This procedure also explains what TSHC will do to try to resolve a complaint. TSHC believes that the main purpose of resolving complaints is not to punish people for their actions but to achieve respectful relations, though in some circumstances, a warning to cease certain conduct might be appropriate or it might be necessary for TSHC to terminate its relationship with that individual or cease a particular practice. This complaint procedure implements TSHC’s internal Human Rights, Harassment and Fair Access Policy meets its legal obligations related to the following:

1. Ontario Human Rights Code
2. Tenant Protection Act
3. Social Housing Reform Act

Scope of Complaints Procedure

This policy and supporting procedures covers all TSHC employees including full or part-time, permanent or non-permanent, management or non-management staff. All employees, contractors, agents, tenants, Board Directors, volunteers and appointees who serve on committees established by TSHC are bound by this policy in their dealings with TSHC.

Anyone who is a direct tenant of TSHC, or who is an occupant of a unit leased by a supportive housing provider from TSHC may rely on this procedure for both formal (written) and informal (written or verbal) complaints. A complaint that is processed through this procedure is an “internal” complaint as it will be investigated and resolved by TSHC management or external consultants hired by TSHC.

Definition of Terms

• agent: a person who is authorized by another to act for him or her; one authorized to transact business for his or her principal; TSHC employees who regularly have contact with tenants may be considered agents of TSHC in certain circumstances
• accessible format: various formats to effect communication e.g. large print, Braille, audio and video tape recording
• allegations: this refers to the actions of a person or the adverse effects of a policy that forms the basis of a complaint; they are called “allegations” because they have not been proved
• complainant: the person(s) or group making a complaint
• contractor: contractor includes independent consultants, persons who have entered a business agreement with the Toronto Seniors Housing Corporation to supply goods or perform work, including professional services, and includes employees of the contractors who work on site at TSHC to perform a contract; agencies that have entered into an agreement with TSHC to provide services to tenants and/or occupants are also included in the term “contractor”
• discrimination: any practice or behaviour, whether intentional or not, that has a negative effect on an individual or group based on a prohibited ground e.g. disability, sex, race, and sexual orientation. A decision to deny a benefit that relies on any of these grounds, unrelated to a person’s abilities, is prohibited. Discrimination may arise as a result of differential treatment or it may result from the unequal effect of applying general rules to everyone. In either case, if the effect of the behaviour or practice on the individual is to deny or limit access to housing accommodation, goods, services, facilities, employment, or contracts available to others, it is
• duty to accommodate: whenever applying a general rule has an adverse effect on an individual because of he or she belongs to a group that is identifiable by a prohibited ground, TSHC has a duty to accommodate the individual. TSHC must re-examine the general rule to minimize or eliminate the adverse In some instances, different approaches or an accommodation may be required to achieve equal access to goods, services and opportunities within TSHC. Accommodation could be an adjustment of TSHC rules to eliminate unequal effects, short of causing undue hardship to TSHC.
• employee: unionized or non-unionized, permanent or non- permanent, management or non-management staff who receive pay for working with TSHC
• external complaint: a complaint filed with a body outside TSHC g. Ontario Human Rights Commission, Ontario Rental Housing Tribunal
• ground: the basis for a decision or action. In TSHC’s policy, prohibited grounds of discrimination include race, ancestry, place of origin, colour, ethnic origin, citizenship, creed or religion, sex, sexual orientation, same-sex partnership status, gender identity, age (over 16), marital status, family status, receipt of public assistance, record of offences, political affiliation, disability or English-language proficiency.
• harassment: any comment or conduct that a person knows or ought to know would be unwelcome. Harassment may result from one incident or a series of incidents. Examples of harassment include offensive and embarrassing comments, derogatory remarks, threats, inappropriate jokes, innuendoes and teasing; insulting gestures; practical jokes that result in embarrassment; electronic or physical display of pin-ups, pornography, demeaning or sexually explicit materials; actions that invade privacy; spreading rumours that damage a person’s reputation; threats to disclose that someone is gay or lesbian; physical or verbal attacks on people who are gay or lesbian; refusing to work with person(s) or a group of persons because of their race, sexual orientation etc; condescending or patronizing behaviour; abuse of authority; unwelcome touching; physical assault or sexual assault.
• internal complaint: a complaint that is processed using this procedure for resolution by TSHC management or external consultants hired by TSHC
• investigator: may be a neutral TSHC manager or external consultant who is appointed or hired to investigate a complaint
• mediator: may be a TSHC manager or other trained TSHC staff who acts as a neutral facilitator, or he or she may be an outside consultant who is appointed to facilitate discussion and problem- solving between a complainant and a respondent
• occupant: a member of a household who live in a unit that is leased by a supportive housing provider from TSHC
• party or parties: may refer to the complainant and/or the respondent or both
• representative: a complainant or respondent can ask someone to be a personal advocate or advisor to help them go through the complaints process
• resources: refers to TSHC staff (e.g. Tenant Service Administrators, Seniors Services Coordinators, Community Service Coordinators, Tenant Representatives, Senior Housing Managers), translators/ interpreters and community agencies that provide services to tenants
• respondent: person(s) or group against whom the complaint is made; the respondent may be another tenant, a guest, a contractor, an employee of TSHC; if the complaint is about a policy or practice in TSHC, the respondent may be a manager of a building managed on behalf of TSHC
• retaliate: take action or initiate a proceeding against a person who has made or supported a complaint; cast accusation back upon a person
• systemic discrimination: refers to discrimination that may occur when a policy or practice has a disproportionate negative effect on a particular group of persons who are identified by a prohibited ground. These policies and practices may appear neutral but in fact, may result in barriers and reduced access to opportunities for members of different racial, cultural or other groups identified by a prohibited ground of discrimination
• tenant: includes all individuals in a household who are included in a signed tenancy agreement with TSHC; also includes an applicant who has applied to live in a unit that is managed by TSHC
• work unit: Seniors Housing Units and other discrete teams of employees at the corporate and service offices of TSHC who report directly to a manager who in turn reports to a General Manager
• workplace: all locations where business or social activities of TSHC are including off site locations (e.g. employee’s home is “workplace related” if unwelcome phone calls or visits are made by a tenant or co-worker).

How the Complaints Procedure Works

This procedure requires the full co-operation of the complainant and the respondent to be truly effective. It is an “internal” complaint procedure and is entirely voluntary.

 TSHC requires that managers and external consultants carry out the steps below in a timely manner.

Step 1. Identify the Problem Complaint about individuals

The complainant should:

• Describe in detail the actions or behaviour of the person(s) who is the source of the If there were several incidents, the complainant should describe each one separately.
• The complainant should identify to the Seniors Housing Manager, verbally or in writing:
  • when the action took place
  • where it happened
  • who the complainant believes caused the problem
  • the details of what happened – the speech or behaviour that the complainant believes is discrimination, harassment or unfair treatment
  • any witnesses
• If the complainant wants the complaint to be handled informally through facilitated discussion, the complaint can be made verbally or in writing.
• If the complainant wants the complaint to be formally investigated by TSHC, he or she should prepare, sign and date a written complaint.

 If the complaint relates directly to the conduct of the Seniors Housing Manger, the complaint should be filed with the Office of the Chief Executive Officer of TSHC

Complaint about a TSHC policy or practice

If the complaint is about a practice or policy of TSHC, the complainant should:

• identify the policy or practice that she or he believes is causing
• Identify how the policy affected the complainant
• prepare, sign and date a written complaint
• give the written complaint to his or her Seniors Housing Manager (SHM).

If the complainant requires assistance to write the complaint, the SHM will facilitate the process of putting the complaint in writing.

 Step 2. Gather the evidence

• Complainants should get the names of witnesses and gather as much evidence as possible to support their complaint about another person’s actions. For example, they should collect any physical evidence such as documents, voice mail messages, or other relevant items.
• If the complaint relates to TSHC practice or policy, the complainant should attach any related documents to the complaint. For example, if the person did not get a benefit or a service, the person should attach:

1. copies of notices or advertisements about a service or benefit being available
2. their application for the service or benefit
3. if there is no notice or advertisement, identify or explain which TSHC policy/practice they believe caused the adverse effects
4. the date of any meetings with staff about the service or benefit
5. names of staff
6. any notes from meetings or phone conversations
7. a letter of rejection or refusal
8. the details of the adverse effect(s) of a policy or practice based on a prohibited ground of discrimination
9. any information given to the complainant by TSHC staff about how to appeal the rejection or refusal.

Step 3. Attempt resolution informally between affected individuals

• As a general rule, TSHC urges individuals to first try to resolve their complaints among They can talk to or write to the person who has caused the problem or they can talk to the Seniors Housing Manager to get ideas on how to resolve the problem.
• Complainants and respondents can ask for help in resolving the complaint informally. There is a list of people they can ask for help (see Resources in the definition section).
• The information that is gathered at Steps 1 and 2 above should be shared so that all participants have a good understanding of the issues to assist in brainstorming about solutions. If a solution is reached at this stage, with the assistance of a Seniors Housing Manager or other resource, the matter can be closed.

 Step 4. Filing a formal complaint against an individual or a TSHC policy/practice

• A formal complaint requires the same details as outlined in Step 1 above except that the complaint must be in writing, signed and dated.
• If a complaint is being treated formally, a copy of the written complaint will be given to the respondent.
• The respondent will have the chance to respond to the allegations in the Any complainant who files a formal complaint must be prepared to have his or her name disclosed to the respondent. Only in rare cases, it may be appropriate to not disclose the name of the complainant to the respondent.

Step 5: Mediation

• If a written complaint has been filed and the complainant and respondent are both willing to try to resolve the matter through a mediator, TSHC will facilitate the selection of a mediator to assist the parties. Parties agree on the choice of the mediator. The mediator may be a TSHC staff member or an external person. If the parties cannot agree, a mediator will not be used and the matter will proceed to investigation.
• As in Step 3, the parties should share information with each other and the mediator to facilitate a frank discussion of the issues between With all parties’ agreement to mediation, a mediator may be able to assist with resolving the problem through discussion and avoid going through a formal investigation
• If mediation is successful, an agreement should be put in writing and should be signed by the parties. The agreement will provide a clear record of the terms each party has agreed to . Each party will be given a signed copy of the agreement that is to be treated as confidential between the parties involved.
• All discussions during the mediation process are to remain
• Settlement discussions are “without ” This means that if a settlement is not reached, each party can take a different position in any future investigations.
• If the complaint proceeds to investigation, neither party is allowed to talk to the investigator about the content of the discussions at mediation.

 Step 6: Investigation of a formal complaint

If a complaint has not been resolved either informally (Step 3) or with the help of a mediator (Step 4), TSHC may carry out a formal investigation.

• The investigator will be chosen by TSHC and will be a neutral person with no prior involvement with the parties or the
• Investigation involves interview(s) of the parties and their witnesses and a comprehensive and impartial review of all the relevant information to determine if there has been discrimination or harassment.
• The investigator may speak directly to TSHC employees, examine relevant documents, and enter any work location that is relevant to the complaint provided notice is given to TSHC management. The investigator can review confidential TSHC documents and enter areas that are normally restricted to investigate the TSHC employees cannot unreasonably withhold permission for these actions.

 The investigator requires full the co-operation of tenants and staff who are parties or witnesses for a thorough investigation.

Steps in the investigation include:

• meeting(s) with the complainant at the beginning of the investigation to establish the scope of the complaint and review details that support the allegations in the complaint
• meeting(s) with the respondent to provide him or her with the details of the complaint and a summary of all the supporting facts
• getting information from the respondent for a full response to the allegations
• informing the complainant of any counter-allegations made by the respondent to give the complainant a chance to respond to these new allegations
• providing opportunities for each party to answer to allegations and counter-allegations that arise during the investigation

At the conclusion of the investigation, the investigator will prepare a written report to the manager that includes evidence, findings, reasoning (analysis), recommendations or a plan of action. The investigator will protect or conceal the identities of witnesses to the greatest extent possible in the body of his or her report. If a complaint is upheld, TSHC management makes the decision on the restorative action to be taken.

 Step 7: Decision

• In the event that a complaint is found to have grounds, the investigator will make recommendations on restorative action to the Seniors Housing Manager. In most instances, the local Seniors Housing Manager will make the decision about restorative actions based on the investigator’s recommendations with input from the Solutions when requested by the manager
• A recommendation that may have corporate-wide impact must be referred to senior management
• If the complaint involves the Seniors Housing Manager as a respondent, or if the Seniors Housing Manager has not resolved the investigation in a timely manner, the Chief Executive Officer or delegate will make the decision on restorative action.
• TSHC’s decision is final. No further appeal is possible within TSHC. Parties may decide to pursue external If a party believes that this dispute resolution process has not been followed, he or she may discuss the matter with the manager who was responsible for conducting the investigation or overseeing the work of an external investigator. If the party is still not satisfied, he or she can pursue other recourse, if any, outside of TSHC.

Step 8: Remedies and Restorative Actions

If a complaint of harassment or discrimination is proven, TSHC can take action to correct the problem. Based on the findings and recommendations of an investigator, TSHC may:

• change a policy or practice
• compensate a complainant to put them in the position he or she would have achieved if there had been no discrimination or harassment
• initiate training programs or refresher training
• direct individuals to obtain counseling
• initiate discipline of employees or legal action against a tenant, agent or contractor where necessary

MISCELLANEOUS MATTERS

Confidentiality & Non-disclosure

• Everyone involved in a complaint must keep the allegations confidential. This permits the parties an opportunity to be frank and open so that a positive resolution can be facilitated.
• Every attempt will be made to fully disclose all relevant documents and information to all the Frank disclosure is only possible if all parties keep the matter confidential. There are limits however, if the information relates to health, personnel or other personal information that deserves privacy protection and/or falls under privacy protection legislation.

 Any breach in confidentiality will be treated seriously by TSHC.

Who can Complain & Anonymity

• Only individuals who are directly affected by the alleged discrimination, harassment or unfair treatment can file a complaint. If the person who is directly affected is cognitively impaired, his or her legal substitute decision-maker may file a complaint on his or her behalf.
• Witnesses cannot file complaints for someone However, they may be able to file their own complaints regarding a “poisonous” environment if the actions or behaviours they witnessed are extreme and/or persistent.
• Any member of TSHC’s community who is covered by this policy can file a complaint of systemic discrimination to challenge a TSHC policy or practice.
• TSHC will not process a complaint unless the identity of the complainant(s) is In rare cases, it may be appropriate to not reveal the identity of the complainant to the respondent where personal safety may be compromised.

Resources & Representative

Human Right Complaints are received in a general mailbox, triaged by Solutions and forwarded to the General Manager of Toronto Seniors Housing for investigation and resolution of the matter.

TSHC is available to assist unit managers on matters of Human Rights within the TSHC but will not necessarily be involved in the resolution of every complaint under the policy.

Tenants can get advice and help if they have a complaint and want to do something about it from the Seniors Housing Manager, a Community Service Coordinator, or other staff who work closely with tenants, a trusted tenant, or any other advocate they choose e.g. Legal Aid Clinic. The respondent can also request help from these resource persons to prepare a response to the complaint.

Any of the above TSHC staff will:

• advise the complainant or respondent on TSHC policies and procedures
• assist with the writing of the complaint or the response (the same person cannot help both parties to the dispute)
• provide an interpreter or translated materials or use accessible format (e.g. large print) to facilitate communication
• Both complainants and respondents have the right to have an advisor or representative of their choice. This person can come with them to meetings and generally give them support and advice. The advisor or representative should not have a conflict of interest and must keep the information about the complaint confidential.

Time Limit for Complaints

• A person has 6 months to file an internal complaint under this policy after the alleged discrimination, harassment or unfair treatment took place. TSHC may make exceptions to this deadline if there are special circumstances. Time lapses beyond 6 months generally make it more difficult to conduct a thorough and fair investigation for all parties involved. Often witnesses are no longer available, documentation may be unavailable and recall of details of the incident may be limited.
• The time limit to file an external complaint with the Human Rights Commission is also 6 months after the alleged incident took place. TSHC cannot guarantee that it will resolve an internal complaint before the expiry of this time limit. A complainant who submits a complaint to TSHC for investigation and decision-making can still complain to the Ontario Human Rights Commission or the Ontario Rental Housing Tribunal provided that the complainant acts within the deadlines established by those bodies.

Disclosure of investigation recommendations & final decision At the end of an investigation into a formal complaint, the investigator will provide a written report of his or her findings, conclusions and recommendations to the General Manager of Senior’s

Housing . The unit manager or the delegate of the Chief Executive Officer will communicate TSHC’s final decision to the parties in writing and will also be responsible for providing a written summary of the investigator’s recommendations.

Timing of completion of complaint resolution process Formal complaints should be resolved within 90 days, except for cases that have been referred to an agency outside TSHC for mediation or investigation. Informal complaints should generally be resolved within 30 days after the issue is raised with a Seniors Housing Manager.

From time to time, there may be delays because of situations outside the control of the responsible Manager (e.g. witnesses’ unavailability) In this case, the Manager will write to the parties to explain the reasons for the delay. The Manager will also estimate how much time will be needed to resolve the complaint.

Participation & Accommodation

All TSHC staff who are involved with processing a complaint must make sure all parties can participate fully. For example, they may need to meet in the evenings or weekends or at a location that is wheelchair accessible. Or, they may need to arrange for an interpreter or translated materials or make documents available in accessible formats.

No Retaliation

TSHC’s Human Rights, Harassment and Fair Access Policy prohibits any punitive action against individuals who pursue their rights under this policy. This protects individuals who:

• make a complaint that he or she reasonably and honestly believed to be true
• take part as a witness in an investigation
• are associated with either the complainant, the respondent or a witness during the procedure

 TSHC may take corrective measures against any tenant, employee, agent or contractor who retaliates against a complainant. A counter-claim by a respondent may or may not be treated as retaliation.

Toronto Seniors Housing Corporation (TSHC)
Absences from rent-geared-to-income units Guidelines

Guidelines Sponsor: Director, Operations

Approver: Board of Directors

Initial Approval Date: April 28, 2022

Effective Date: June 1, 2022

For a household paying rent-geared-to-income, the City of Toronto’s guideline for social housing sets 90 days as the maximum number of days that all members of the household can be “absent” or not living in their unit while continuing to receive a rent-geared-to-income subsidy. However, there are some exceptions to this rule.

This rule only applies if all members of your household are away at the same time.

Short absences of up to seven days in a row or less are not counted toward the 90-day limit within a 12-month period.

If all members of a household are away for more than 90 days in a row or more than 90 days within a 12-month period, and have not informed Toronto Seniors Housing Corporation, they could lose their rent-geared-to-income (RGI) subsidy. Informing Toronto Seniors Housing Corporation of any absence longer than 90 days will also help us to address safety and repair needs while a tenant is away.

Please tell us if you are in hospital, in rehabilitation, awaiting trial or have documentation to support another valid reason for being away from your unit longer than 90 days.

Learn more by reviewing the City of Toronto Absence from Unit from City Guideline 2013-9 https://www.toronto.ca/community-people/community-partners/social-housingproviders/rent-geared-to-income-administration/

Next Scheduled Review Date: 2027

This policy will be reviewed once every five years.

Guidelines Contact

Manager, Business Operations and Compliance

Appendices

City of Toronto Absence from Unit from City Guideline 2013-9

Who does the guideline apply to?

The guideline applies to tenants who live in a rent-geared-to-income (RGI) unit.

What is the guideline?

The guideline 2013-9 Local Eligibility Rule – Absence from Unit states the maximum number of days that all members of a household can be “absent” or not living in their unit and continue to receive a rent-geared-to-income (RGI) subsidy is 90 days. It also outlines the exceptions to this rule.

The maximum number of days that a household can be away from their unit is 90 days in a row or 90 days within a 12-month period.

This rule only applies if all members of your household are away at the same time. If at least one member of your household will be living in your unit during your absence, this rule does not apply. A member of your household is anyone listed on your Lease Agreement with Toronto Seniors Housing Corporation.

Short absences of up to seven days in a row or less are not counted toward the 90-day limit within a 12-month period.

Will I be eligible for RGI assistance if I am away for more than 90 days?

You will not be eligible for RGI assistance if you are away for more than 90 days unless you have given notice to Toronto Seniors Housing Corporation in writing of the reason you are away and the reason meets one of the exceptions as stated in the City’s guideline.

If you plan to be away for more than 90 days, call the Tenant Support Centre at 416-945-0800, email: support@torontoseniorshousing.ca or visit your Regional Office.

What happens if I lose my subsidy?

If you lose your subsidy, you will not lose your unit, but you will have to pay market rent.

What if I am the only member of my household and I have a medical condition that requires me to stay in hospital or be away from my unit?

If you are the only member of your household and have a medical condition that makes it necessary for you to be away from your unit for 90 days in a row or longer to receive treatment, call the Tenant Support Centre at 416-945-0800, email: support@torontoseniorshousing.ca or visit your Regional Office so we can help you keep your subsidy.

What happens if another member of my household (anyone listed on the Lease Agreement with Toronto Seniors Housing Corporation) has a medical condition and I have to be away from my unit to take care of them?

If all members of your household will be away due to this reason, call the Tenant Support Centre at 416-945-0800, email: support@torontohousing.ca or visit your Regional Office so we can help you keep your subsidy.

Will I be able to keep my subsidy if I am being held in jail while awaiting trial?

Yes. If a household has one member, and the member is absent because they are being held in jail while awaiting trial, they will not be considered absent from the unit. Paperwork/proof of the reason for absence must be provided to your Tenant Services Administrator. However, rent must also be paid while you are away.

What if the condition of my bail does not allow me to live in my unit for 90 days or longer?

If a household has one member, and a bail condition of release prevents the member from living in the unit, the household will not be considered absent from the unit. Paperwork/proof of the reason for absence must be provided to the Tenant Services Administrator. However, rent must be paid while you are away.

Will I lose my unit if I am convicted of a crime and serving a sentence?

If a household has one member, and the member has been convicted of criminal offence, the household will be considered absent from the unit for more than 90 days if the jail time served is greater than 90 days.

Note: Being convicted of a criminal offence does not make someone ineligible for RGI subsidy, unless the conviction is for RGI fraud or misrepresentation.

Someone who is convicted and serves a sentence leading to an absence of 90 days or more will lose their subsidy but not their unit and will have to pay market rent.

What are my options if I lose my RGI subsidy?

You can request a review of your eligibility for RGI subsidy by completing a Request for Review Form:

• in person at your Regional Office;
• by email to support@torontoseniorshousing.ca;
• by phone with a Tenant Services Administrator;
• by mail or fax.

Note: Requests for review must be made within 30 calendar days (plus five mailing days, if the request is mailed by the tenant) after the notice of decision has been given to the household by Toronto Seniors Housing Corporation. When you have completed your form, submit it to:

Toronto Seniors Housing Corporation

Attention: Review Body
423 Yonge St., 2nd Floor, Toronto, ON M5B 1T2

Toronto Seniors Housing Corporation (TSHC)
Addition to Family Composition Directive

Directive Sponsor: Director, Operations

Approver: Leadership Team

Initial Approval Date: May 17, 2022

Effective Date: June 1, 2022

Introduction

Toronto Seniors Housing Corporation (TSHC) recognizes that tenants may request that additional person(s) be added to their household composition from time to time due to changes in circumstances.

The Addition to Household Composition Directive will provide the framework to govern the standard practice and procedure in reviewing these requests, while supporting Toronto Seniors Housing Corporation’s commitment to equitable quality services and adhering to legal requirements as set out in the applicable legislation.

Directive Statement

TSHC is committed to a fair and equitable approval process for assessing tenants’ requests to add members to their household composition.

Application of Directive

This directive applies to all Toronto Seniors Housing Corporation Rent-Geared-to-Income (RGI) and Market Rent households who wish to add new member(s) to their household composition.

Directive Guidelines General Principle

Addition to Household Composition requests should generally be used to reunite families, however, doing so cannot create an underhoused situation that is in breach of the Occupancy Standards set out in the Toronto Municipal Code, Property Standards section.

Household refers to the people who live in a housing unit. Household can refer to one person who lives alone, or to a group of people who live together in a unit.

Rent-Geared-to-Income Households

Households may allow guests to stay with them for up to 30 days, in a twelve-month period, without asking for permission from Toronto Seniors Housing Corporation.

Households must report any guest who wishes to stay longer than 30 days, in a twelve-month period, as per Toronto Seniors Housing Corporation’s Visitor and Guest Policy.

Households requesting person(s) to be added as a Tenant (Leaseholder) or as an Occupant:

• To have guest(s) either become a tenant of an RGI unit or be added as an occupant of an RGI unit, the current tenant(s) must submit a completed Addition to Household Composition Request Form to Toronto Seniors Housing Corporation within 30 days of household composition change.
• The person(s) to be added and existing household members must be willing to provide the information, documentation and authorization necessary to determine whether they are eligible for RGI subsidy.

Limitations

Toronto Seniors Housing Corporation may decline to add an individual to an RGI Household if:

• The person(s) to be added does not meet basic eligibility criteria set out in social housing legislation.
• The addition(s) to the household would result in noncompliance with the Occupancy Standards set out in the Toronto Municipal Code, Property Standards.
• The existing household or the person(s) to be added has an outstanding balance with a social housing provider in Ontario, does not have a repayment agreement and/or is not up to date with repayments.
• The person(s) to be added was evicted from Toronto Seniors Housing Corporation for a non-arrears related issue in the last two (2) years or has been given a trespass notice and is no longer allowed on the property.

Important Note

• As per the current social housing legislation and Toronto Seniors Housing Corporation’s Visitor and Guest Policy, Addition to Household Composition requests must be submitted to Toronto Seniors Housing Corporation within 30 days of a change to the household composition as a result of a guest intending to reside in the RGI unit.
• The Household may become ineligible for RGI subsidy if new and/or existing members of the household do not meet the basic eligibility criteria set out in the social housing legislation.
• Households must not use Addition to Household Composition requests to assist any person to bypass the centralized waiting list or to assign^[1] or sublet^[2] the tenancy to another person.
• Toronto Seniors Housing Corporation may proceed with an application to the Landlord and Tenant Board or Court for an eviction if the addition of new a member was for the purpose of assigning the tenancy to another person.
• All applicable penalties as prescribed under the social housing legislation apply to any person who inappropriately helps another person obtain RGI subsidy.

Decision on Request

Toronto Seniors Housing Corporation will inform the household in writing of whether the addition to household composition request is approved or denied.

Approved

If the request is approved:

• A new lease agreement must be signed by all household members who are 59 or older.
• The rent will be recalculated based on the new total household income.
• The new member(s) will be deemed to be adequately housed and will be removed from the centralized waiting list where applicable, with the exception of new member(s) added to a rooming house household.

Denied

If the request is denied:

The household may appeal to the Regional Manager in writing.

If the person(s) to be added is not eligible for RGI subsidy, but the household continues to allow the person(s) to live in the unit, Toronto Seniors Housing Corporation will begin the Loss of Eligibility process and provide the household with 90 days written notice.

Market Rent Households

A Tenant is a leaseholder that has a contractual relationship with Toronto Seniors Housing Corporation. The Tenant(s) has sole responsibility for the rent, the unit, and is responsible for the actions of all non-tenants whom they permit to be on the Leased Premises.

An Occupant is a non-leaseholder adult who resides in a unit, but has not signed a lease with Toronto Seniors Housing Corporation. An Occupant does not have a contractual relationship with Toronto Seniors Housing Corporation, and has no legal rights, entitlements, or responsibilities to the Leased Premises.

A Market Rent Tenant may allow an Occupant(s) to reside in their rental unit. The Market Rent tenant may not, however, assign or sublet all or any part of the Leased Premises.

A Market Rent Tenant is required by their lease to report any changes in household composition within the same month the change occurs.

A Market Rent Tenant may request to add another Tenant to their unit and sign a new lease. It is up to the current Market Tenant to apply and not the proposed new tenant.

Reporting Occupants

Even where a Market Rent Tenant does not wish to add an Occupant as an additional Leaseholder, it is important that the Tenant reports all persons living with them in their unit. It is essential for safety and emergency purposes that TSHC knows who is living in its units.

Where a Tenant has reported that an Occupant resides in their unit, the Occupant may be entitled to apply for parking at the same rate that the Tenant pays for parking, provided other set of key requirements are met.

Household requesting person(s) to be added as a Tenant (Leaseholder)

• To have a person(s) become an additional Leaseholder, the original Market Tenant must submit a completed Addition to Household Composition Request Form.
• The person(s) to be added must be willing to provide the information, documentation and authorization necessary to determine whether they are eligible to be added to a Market Rent household.

Limitations

Toronto Seniors Housing Corporation may decline to sign a new lease to add an individual as an additional Tenant to a Market Rent household if:

• The person(s) to be added has no legal status in Canada as prescribed by Citizenship and Immigration Canada (i.e. legal status in Canada includes, but is not limited to, having a student visa, work permit, citizenship, permanent residency, being a refugee, etc.).
• The addition(s) to the household would result in noncompliance with the Occupancy Standards set out in the Toronto Municipal Code, Property Standards section.
• The person(s) to be added has an outstanding balance from a current or former tenancy with Toronto Seniors Housing Corporation or Toronto Community Housing Corporation.
• The person(s) to be added was evicted from Toronto Seniors Housing Corporation or Toronto Community Housing Corporation through an order of the Landlord and Tenant Board based on an illegal act (commonly referred to as an “N6”) in the last five (5) years.

Important Note

Toronto Seniors Housing Corporation will not sign a new lease to add an individual as an additional Tenant if either:

• The existing household has an outstanding balance with TSHC; or
• There is an active legal proceeding against the existing household for any arrears or non-arrears issue.

Decision on Request

Toronto Seniors Housing Corporation will inform the household in writing of whether the addition to household composition request is approved or denied.

Approved

If the request is approved to add new member(s) as Market Tenants (Leaseholders):

• A new lease agreement must be signed by all Tenant(s) of the household (existing and new).

If the request is to add a new member as an Occupant and not a Leaseholder, then:

• A new lease agreement is not required, but the Market Tenant may choose to sign a new lease with the new Occupant(s) listed in the “Occupants” section of the lease.
• The Occupant(s) shall have no rights or responsibilities to the unit.
• The existing Tenant(s) continues to be solely responsible for the rent, maintains all legal rights and responsibilities in relation to the unit, and is responsible for Occupant(s)’ actions on the leased premises.
• The Occupant(s) do not have any right to remain in the unit after the Market Tenant(s) (Leaseholder) moves out.

Denied

If the request is denied:

• The household may appeal to the Regional Manager in writing.

Accountability

• The Tenant Engagement and Services Supervisor will monitor application of this directive on an on-going basis.
• Random sampling reviews will be conducted on an annual basis by the Business Operations and Compliance Team.

Related Legislation, Regulations, and TSHC Policies:

• Housing Services Act, 2011
• Municipal Freedom of Information and Protection of Privacy Act
• Occupancy Standards of the Toronto Municipal Code, Property Standards section – Bylaw
• Ontario Human Rights Code
• Residential Tenancies Act, 2006
• TSHC Visitor and Guest Policy
• TSHC Human Rights, Harassment and Fair Access Policy – Tenants
• TSHC Market Rent Tenancy Agreement
• TSHC Rent-Geared-To-Income Tenancy Agreement

Amendments (Revision History):

Directive reviewed on May 17, 2022 by Board of Directions, effective June 1, 2022.

Next Scheduled Review Date: 2027

This policy will be reviewed once every five years.

Directive Contact

Manager, Business Operations and Compliance

^[1] When a Tenant(s) transfers their rights to occupy the rental unit and legal interests to someone else, and the Tenant(s) does not intend to return to the rental unit.

^[2] When a Tenant(s) moves out of the rental unit, lets another person live there for a period of time, but returns to live in the unit before the tenancy ends.

TORONTO SENIORS HOUSING CORPORATION (TSHC)

Unit Condition Follow-up Process

Policy Owner

Approval

First Approved

Effective Date

Toronto Seniors Housing inspects tenant units every year. This is important work. It’s our chance to make sure the units are livable and in a good state of repair. 

Common issues

During annual unit inspections, we find other problems such as:

• excessive clutter
• fire safety violations
• pests
• cleanliness/health hazards concerns

 Sometimes, families, caseworkers, neighbours or staff performing other duties report or flag unit conditions.

How we help

Toronto Seniors Housing staff have been trained on how to support residents with units that have these problems. There are four stages for staff to follow:

• Stage 1: Staff make note of units with concerns.
• Stage 2: Staff inform residents about concerns with their unit.
• Stage 3: Staff support residents to develop a plan to improve their unit.
• Stage 4: Follow-up/resolution. Staff visit unit to ensure the plan is working and the unit condition is maintained.

 This helps staff:

• decide how to respond to urgent problems
• prioritize cases
• work with the City and other external partners
• work with residents towards realistic progress
• use the legal process when working with residents to keep them housed

Review Toronto Seniors Housing policy on evictions for cause.

Toronto Seniors Housing Corporation has adopted this policy as of May 17, 2022 and is in effect for June 1,2022