Staff Report #2
March 30, 2026
To All Commissioners
Re: 2025 Mutual Respect/Human Rights Summary
Recommendation
That the Commission:
- APPROVE the revised Human Rights and Diversity Policy (Anti-Harassment, Anti-Sexual Harassment and Anti-Discrimination) and Mutual Respect in the Workplace Policy as set out in Enclosure I; and
- The report be RECEIVED for information.
Background
The London Transit Commission’s policies on Human Rights and Diversity (Anti-Harassment, Anti-Sexual Harassment, and Anti-Discrimination) and Mutual Respect in the Workplace set out the Commission’s expectations for employees and members of the public who use London Transit services.
The respective policies and written procedures outline the complaint procedure, investigation, and decision-making process, and provide complainants with the opportunity to appeal decisions to a higher level of review. These policies continue to be reviewed with all current employees and are incorporated into the Onboarding Program for all new employees.
The Workplace Investigations Specialist model, implemented in late 2022, continues to centralize all workplace investigations. This approach has improved consistency, documentation standards, investigation timeliness, and clarity for employees bringing forward concerns. In 2025, all the Human Rights investigations resulted in conclusive findings.
Delivery of the updated Human Rights, Mutual Respect, and Diversity training program continued throughout 2025, with the remaining employees expected to complete it by early 2027.
Summaries of complaints and investigations related to the above-noted policies for 2023–2025 are set out below. Information is summarized at a level sufficient to protect the privacy and confidentiality of all parties. For context, in 2025, London Transit employed approximately 700 employees and carried approximately 17.8 million rides between the conventional and specialized services.
All alleged Human Rights complaints are investigated consistently in accordance with policy and associated procedures. Where bargaining unit employees file complaints, investigations are conducted jointly between the Workplace Investigations Specialist (WIS) and an ATU Local 741 Union Executive member appointed by the ATU President, in accordance with the Collective Agreement. Final investigation reports, including findings and recommendations, are subject to the Director’s agreement.
The following table summarizes all Human Rights complaints received in 2023 through 2025. The internal complaint column contains claims filed by London Transit employees, and the external complaint column contains those filed by members of the public.
Summary of Human Rights Complaints 2023-2025
| Year | Internal | External | Total |
| 2023 | 16 | 21 | 37 |
| 2024 | 18 | 22 | 40 |
| 2025 | 14 | 9 | 23 |
| Total | 48 | 52 | 100 |
| % Allocation | 48% | 52% |
Overall, the total number of Human Rights complaints decreased materially in 2025, with 23 complaints received.
Across the three-year reporting period (2023–2025), 48 complaints (48%) were filed internally by employees, and 52 complaints (52%) were filed externally by members of the public. Historically, external complaints have represented the majority of total complaints.
From 2023 to 2024, external complaints remained relatively consistent (21 and 22, respectively). In 2025, external complaints decreased to nine. Internal complaints also declined in 2025, falling from 18 to 14, which contributed to an overall decline in total complaints from 40 in 2024 to 23 in 2025.
In 2025, 14 complaints were filed internally and nine externally. This is the first year in the reporting period in which internal complaints exceeded external complaints. This shift reflects the significant reduction in external complaints rather than an increase in internal complaint volume. Historically, external complaints have generally arisen from customer service interactions involving operators. While the 2025 reduction cannot be attributed to a single initiative, it may reflect the cumulative impact of efforts to clarify behavioural expectations for both employees and the public.
The “Expect Respect” campaign has reinforced that respectful conduct is expected on buses and throughout the transit system for everyone, including employees. Communications focused on Human Rights principles, promoting mutual respect, and professional conduct. In addition, the rollout of the updated training program has better clarified expectations regarding communication and workplace behaviour. Although full implementation remains ongoing, clearer articulation and reinforcement of standards may be contributing to improved frontline interactions.
London Transit will continue to monitor complaint trends to assess whether the 2025 decrease represents a sustained improvement.
Regarding investigation outcomes over the three years, approximately 33% of complaints were found to violate the Human Rights and Diversity Policy (Anti-Harassment, Anti-Sexual Harassment, and Anti-Discrimination). Approximately 33% were determined to be unfounded under the Human Rights Policy, but resulted in corrective action under other London Transit policies or performance expectations. The remaining 34% were deemed unfounded, with no further action required.
These findings indicate that while a significant portion of complaints do not meet the threshold for a Human Rights policy violation, many nevertheless identify workplace or service-related conduct requiring intervention, coaching, or corrective action. The data reflects continued utilization of the complaint process and consistent application of investigative standards.
The distribution of protected grounds has remained relatively stable over the reporting period, reflecting consistency in the types of claims raised. Allegations related to ancestry, colour, race, citizenship, ethnic origin, place of origin, and creed account for 67 (63%) of total allegations. These categories continue to represent the largest share of allegations and warrant sustained organizational focus.
Disability-related complaints account for 27 cases (25%). While disability remains the second most frequently cited ground overall, there has been a notable decrease in 2025 (six cases) compared to prior years (11 in 2023 and 10 in 2024). This downward trend may reflect improved awareness, accommodation practices, or early resolution efforts; however, continued monitoring remains appropriate.
Complaints relating to gender identity, gender expression, sexual orientation, and sex total 11 cases (10%).
While some complaints involve multiple protected grounds, there has been no significant shift in the categories of allegations raised. The data suggests consistency in the types of concerns raised, with race-related grounds remaining the most prevalent area requiring continued attention through policy reinforcement, training, and awareness initiatives.
Race-related matters require continued attention. Substantiated findings in 2025 confirm that certain violations involved race-related conduct in the workplace. Internal complaints filed against customers also include allegations of discriminatory conduct directed toward Operators. As frontline employees, Operators have the highest level of public interaction and are therefore more likely to encounter behaviour inconsistent with the Human Rights Code. To reinforce respectful conduct publicly, London Transit installed visible messaging on all buses articulating behavioural expectations for customers. The signage includes statements such as “Respect the Operator” and confirms that discrimination, harassment, and verbal or physical confrontations are not tolerated.
Recognizing these trends, London Transit engaged Senomi Solutions in 2025 to support continued efforts to strengthen workplace inclusion, respectful conduct, and leadership awareness. This work remains in its early phase. Facilitated employee engagement sessions are underway, and the consultant is identifying themes, communication gaps, and practical improvement opportunities. A summary of findings and recommended actions is anticipated to be available by the 4th quarter of 2026, at which time Human Resources will assess next steps and report back to the Commission as appropriate.
Collectively, these initiatives demonstrate London Transit’s commitment to proactively addressing race-related concerns, supporting frontline employees, and reinforcing a respectful and inclusive workplace culture.
It should be noted that the statistics reflected in this report represent complaints filed internally under London Transit’s Human Rights and Diversity Policy and investigated through the organization’s internal complaint process. These figures do not include applications filed externally with the Human Rights Tribunal of Ontario or any other adjudicative body.
Mutual Respect Complaint Process Summary
Mutual Respect investigations address a broad range of workplace matters, from interpersonal communication concerns to more serious allegations involving harassment, inappropriate conduct, or privacy-related issues. The WIS receives complaints and conducts the necessary investigations. Where a bargaining unit employee files a complaint, a joint investigation is conducted between the WIS and an ATU Local 741 Union Executive member appointed by the ATU President, in accordance with the Collective Agreement. The final investigation report, including findings and any recommendations, is subject to the Director’s agreement.
London Transit conducts an annual review of Mutual Respect complaints and related investigation outcomes to identify trends and determine whether targeted interventions are required.
The following table summarizes all Mutual Respect in the Workplace complaints received in 2023 through 2025.
Summary of Mutual Respect Complaints 2023-2025
| Year | Complaints |
| 2023 | 15 |
| 2024 | 19 |
| 2025 | 19 |
| Total | 53 |
Between 2023 and 2025, a total of 53 Mutual Respect complaints were received. Complaint volume increased from 15 in 2023 to 19 in 2024 and remained stable at 19 in 2025. Of the 19 Mutual Respect complaints received in 2025:
- 14 (74%) resulted in a finding that the Mutual Respect Policy had been violated;
- 2 resulted in other action being taken; and
- 3 required no further action.
Across the three-year reporting period, 49% of Mutual Respect complaints resulted in a violation finding, 9% resulted in other corrective action, and 42% were determined to be unfounded. While the overall volume of complaints has remained stable, the proportion of substantiated findings increased in 2025 compared to prior years. This suggests that a greater number of matters advancing to formal investigation met the policy threshold for violation.
In 2025, there was a noticeable emergence of cases in which both the respondent and the complainant were found to have engaged in conduct inconsistent with the Mutual Respect Policy. While these cases do not represent the majority of complaints, they reflect situations where workplace conflict involved reciprocal behaviour rather than a one-sided policy breach. This developing trend reinforces the importance of clearly communicating behavioural expectations across the organization. It also underscores the continued need for impartial investigations that assess all parties’ conduct against policy standards, regardless of who initiated the complaint. The investigative process remains grounded in objective evidence, consistent documentation, and the fair application of policy requirements.
The majority of Mutual Respect complaints (77% over the reporting period) originated within Operations, which is proportionate to the department’s staffing levels and the size of our frontline workforce. Given the operational environment and the frequency of interpersonal interaction within that department, this distribution is not unexpected. However, the higher percentage of cases in 2025 where investigations confirmed a policy violation supports continued emphasis on communication standards, supervisory awareness, and early conflict resolution within operational settings.
As previously discussed, London Transit introduced the Expect Respect initiative to reinforce respectful conduct within its organization. This internal campaign promotes employee-to-employee accountability and reciprocal standards of professional behaviour. The messaging emphasizes respect for oneself, colleagues, equipment, and the workplace, and reinforces that all employees share responsibility for maintaining a professional, respectful work environment. This initiative supports the Mutual Respect Policy by clearly articulating behavioural expectations and reinforcing that inappropriate conduct between employees will be addressed.
Investigation management remains strong, with 96% of Mutual Respect cases over the reporting period resulting in conclusive findings and minimal outstanding matters at year-end. This reflects consistent application of investigative standards and timely resolution of concerns.
Taken together, the data suggest that while complaint volume has stabilized, a greater proportion of complaints in 2025 were substantiated. Continued emphasis on respectful communication, visible leadership reinforcement, targeted supervisory development, and early intervention strategies will remain priorities in 2026.
This report will be summarized and shared with all employees through internal communication protocols.
Policy and Procedure Update
In the first quarter of 2026, Administration undertook a comprehensive review of its Human Rights and Diversity Policy (Anti-Harassment, Anti-Sexual Harassment, and Anti-Discrimination) and Mutual Respect in the Workplace Policy, and related Complaint Procedures, to ensure they reflect current legislation, best practices, and the needs of LTC as an organization. The revised policies are set out in Enclosure I for Commission approval. The related complaint procedures for these policies are set out in Enclosure II for information purposes, noting the procedures are not subject to Commission approval.
Key updates to the policies and related procedures as part of the recent review include:
- Legislative Compliance The definitions of Workplace Sexual Harassment and Workplace have been updated to reflect amendments to the Occupational Health and Safety Act under the Working for Workers Five Act, 2024 (Bill 190), which came into force on October 28, 2024. These amendments expressly extend protections to virtual harassment through information and communications technology and confirm that the OHSA applies to telework performed in a private residence. Training requirements have been updated accordingly.
- Policy Clarity – Plain-language guidance has been added to clarify which policy applies to a given situation. Conduct connected to a protected ground under the Ontario Human Rights Code is addressed under the Human Rights and Diversity Policy. Personal conduct directed at an individual, including bullying and intimidation, is addressed under the Mutual Respect in the Workplace Policy. This distinction has been made explicit in both policies to assist employees and managers in understanding and applying the correct process.
- Psychologically Safe Workplace – A new paragraph affirms LTC’s commitment not only to preventing harassment and discrimination, but to actively building a workplace where employees feel safe, valued, and supported. This section cross-references LTC’s Mental Health and Wellbeing Policy to reflect the interconnected nature of these programs.
- Employee Rights – A new section has been added confirming that nothing in these policies limits an employee’s right to file a direct application with the Human Rights Tribunal of Ontario.
- Complaint Procedure Strengthening – The complaint procedures have been restructured to improve readability. A standalone Duty to Investigate section confirms LTC’s obligation to act regardless of whether a formal complaint has been filed. A 90-day investigation commitment has been introduced, with written notice to the Complainant where the timeline will be exceeded.
- Cross-References – LTC’s Mental Health and Wellbeing Policy and Social Media Policy have been added as cross-references in the complaint procedures, reflecting the interconnected nature of these programs.
- Training – The employee refresher training cycle has been updated to a minimum of every four years, or sooner where warranted by a significant incident, legislative change, or at the direction of the Senior Management Team, reflecting the operational realities of delivering training across LTC’s workforce.
Next Steps
Following Commission approval, the revised policies and related complaint procedures will be updated and redistributed to all employees in accordance with LTC’s communication protocols. A targeted communication campaign will be developed to inform employees and other applicable parties of the key changes, reinforce expectations, and support awareness of the updated framework. Training materials will be reviewed and updated as required to reflect current policies and any legislative changes, and incorporated into both onboarding and the ongoing refresher training program. The policy revisions will also be incorporated into the existing training rollout, with all remaining employees expected to complete the updated program by mid-2027.
Enclosures
Recommended by:
Kristan Timmermans, Workplace Investigations Specialist
Joanne Galloway, Director of Human Resources
Concurred in by:
Kelly S. Paleczny, General Manager