1. Catulpa Community Supports Services (Catulpa) procurement function shall be performed in an open, fair and transparent manner where goods and services are procured in a competitive environment and where all transactions yield the optimal benefit to the agency.
2. Catulpa aspires to high ethical, legal, environmental, managerial and professional standards in the management of the resources entrusted to it following the Ontario Broader Public Sector Supply Chain Code of Ethics.
Catulpa works within a brokered services environment and contracts both frontline and back office services with a variety of network partners as such these contracts fall outside of this procurement scope in an understanding with the Central Regional Office of the Ministry of Children & Youth Services and Ministry of Community and Social Services.
- Personal Integrity and Professionalism All broader public sector (BPS) supply chain participants will act, and be seen to act, with integrity and professionalism. Honesty, care and due diligence must be integral to all supply chain activities within and between BPS organizations, suppliers and other stakeholders. Respect will be demonstrated for each other and for the environment. Confidential information will be safeguarded. Participants will not accept gifts and favours, provide preferential treatment, publicly endorse suppliers or products or engage in any other activity that would create, or appear to create, a conflict of interest.
- Accountability & Transparency Supply chain activities will be open and accountable. In particular, tendering, contracting and purchasing activities must be fair, transparent and conducted with a view to obtaining the best value for public money. All participants will ensure that scarce public sector resources are used in a responsible, efficient and effective manner.
- Compliance & Continuous Improvement All BPS supply chain participants will comply with this Code of Ethics and the laws of Canada and Ontario. Participants should continuously work to improve supply chain policies and procedures, to improve supply chain knowledge and skill levels, and to share leading practices.
Segregation of Duties
The following segregation of duties is in place to ensure goods and services are purchased in an efficient and cost effective manner and to establish internal control over the authorization of expenses.
- Designated Signing Authority Designated signing authorities appointed by the board are as follows, Executive Director, Director of Finance, Board Chair, Treasurer, and Vice Chair. Any changes to this roster of individuals can only be made by a motion of the Board.
- Requisition of goods and services Requests for goods and services can be requested throughout the organization and sent to the appropriate Director/Manager for approval within their respective scope of authority.
- Budgeting for the purchase of goods and services Budgets for purchase of goods and services are set annually by the Director of Finance in consultation with the Management Team and approved by the Board of Directors.
- Commitment to release orders to vendors All orders for goods and services are processed through the Director of Finance or delegate(s) and placed with the vendor.
- Receipt of goods and services Goods and services received are checked for accuracy and completeness against the packing slip by the administrative assistants, Local Team Facilitators or Specialty Team Facilitators then forwarded to the Director of Finance’s office.
- Payment approval for goods and services Financial signing authority rests with the Executive Director or delegated to specific Directors within the organization consistent with the Director’s accountability and that fall within the approved annual budget.
Contracts or Agreements
Based on the assumption of thorough vetting and within the approved annual budget, the following will apply:
1. The Following agreements must be signed by a least one designated signing authority
a. All contracts, lease and partner agency agreement renewals or amendments
b. Offer letters to independent service contractors, offers of employment or employment contracts.
c. All contracts, leases and partner agency agreements.
d. Annual bank operating agreements and renewals.
e. Government reporting
f. Bank Credit Card agreements
g. Supplier credit or purchase account agreements
2. Program training agreements up to $1,000 are signed by the appropriate Manager and reviewed with the Executive Director.
3. Acceptance of bequests and endowments are signed by the Executive Director and Board Chair.
4. Bank loans, notes or short term borrowing agreements are signed by the Executive Director and Board Chair.
5. Legal consultations: approval to consult with legal counsel occurs through discussion with the Executive Director.
6. Cheque Runs: every cheque run report is reviewed and signed by the Director of Finance.
7. The following areas fall under the Procurement Limits:
i. All consultant agreements
ii. Equipment purchases
iii. Supply contracts
Cheque Signing Authority
All cheques will be signed by two designated signing authorities; any cheques over $99,999 are signed by the Executive Director or Director of Finance and Board Chair or Treasurer.
Approval Authority Schedule
Catulpa has established the following competitive procurement thresholds in accordance with the Broader Public Sector (BPS) Procurement Directive:
Goods, Non-Consulting Services and Construction
Consulting Services and Construction
Competitive Procurement Thresholds
CATULPA will follow the mandatory requirements under the BPS Procurement Directive for open competitive procurement. Exceptions to open competitive procurement include the following:
Sole Sourcing Exemption
Where only one supplier is able to meet the requirements of procurement, CATULPA will conduct non-competitive procurement as identified in the circumstances listed below (also known as sole source situations):
- To ensure compatibility with existing products, to recognize exclusive rights, such as exclusive licenses, copyright and patent rights, or to maintain specialized products that must be maintained by the manufacturer or its representative;
- Where there is an absence of competition for technical reasons and the goods or services can be supplied only by a particular supplier and no alternative or substitute exists;
- For the procurement of goods or services the supply of which is controlled by a supplier that is a statutory monopoly;
- For work to be performed on or about a leased building or portions thereof that may be performed only by the lessor;
- For work to be performed on property by a contractor according to provisions of a warranty or guarantee held in respect of the property or the original work;
- For the purchase of goods under exceptionally advantageous circumstances such as bankruptcy or receivership, but not for routine purchases;
- For the procurement of original works of art;
- For the procurement of subscriptions to newspapers, magazines or other periodicals;
- For the procurement of real property.
All non-competitive and competitive procurement purchases are made within the following process:
1. Requests for purchase are generated by staff and approved by the Manager.
2. Goods received are matched to packing slips.
3. Invoices are initialed by appropriate Manager and forwarded to the Director of Finance’s office
4. Cheque requisitions are reviewed and approved by Director of Finance prior to the cheques being issued.
Monitoring Report Requirements
1. Annual listing of contracts awarded over $25,000, disclosing the supplier and the amount to be provided to the Audit & Finance Committee with 30 days of fiscal year-end.
2. Annual listing of any approvals for purchases/contracts outside of approved budget to be provided to the Audit & Finance Committee with 30 days of fiscal year-end.
Employee Expense Reimbursement
All approved business related expenses incurred by employees are submitted to the Finance Department for reimbursement on a monthly basis, on a completed and signed expense form.
Catulpa Community Support Services (Catulpa) is bound by the Broader Public Sector Expenses Directive issued by Management Board of Cabinet effective April 1, 2011 and is accountable for public funds used to reimburse travel, meal and hospitality expenses. All expenses reimbursed to employees, board members and consultants or contractors engaged by the organization must be in support of business objectives of Catulpa and comply with the policy and procedures outlined in this document.
The Executive Director has the authority to establish additional rules regarding expenses provided they are consistent with the rules set out in this policy and are necessary to meet specific operational needs. Any additional rules do not replace existing rules outlined in this policy.
Individuals making claims (claimants) are required to:
- Obtain all appropriate approvals before incurring expenses
- Submit original, itemized receipts with all claims
- Credit card and debit card payment notices are not considered original receipts, when it is not possible to submit the original itemized receipt a written explanation must accompany the documentation, the Executive Director or Director of Finance must approve the other documentation as being sufficient or complete
- Submit claims no later than 90 days after the date of which the expense was incurred
- If leaving employment with Catulpa, submit claims for expenses prior to the last day worked
Catulpa will maintain original receipts and records for verification and audit purposes.
Approval of Travel, Meal and Hospitality Expenses
Staff expenses for travel, meal and hospitality expenses will be approved by their reporting Manager. In the absence of the Manager or designate, expenses can be approved by the director of Finance or Executive Director and the Manager will be copied with the approval. Expenses reconciliations submitted by Friday for approval will processed and paid the following week.
Individuals approving expenses (approvers) are accountable for their decisions which must be:
- Subject to good judgement and knowledge of the situation
- Exercised in appropriate circumstances; and
- Comply with the principles and mandatory requirement set out in this Standards and Guidelines
When situations arise and discretion needs to be exercised, approvers should consider whether the request for discretion is:
- Able to stand up to scrutiny by the auditors and members of the public
- Properly explained and documented
- Fair and equitable
2. Travel Expenses
- Catulpa Staff are not required to obtain prior written approval for travel expenses within their assigned work area in Ontario unless otherwise directed by their Manager
- The travel must be necessary for the conduct of Catulpa services and only the additional kilometers traveled on a shortest distance basis between their meeting/destination and home office location
- Travel expenses outside of Ontario require prior approval from the Executive Director
- Least costs travel methods may include car rental or other means of travel. Managers will work with staff to manage travel costs
- Catulpa assumes no financial responsibility for the use of personal vehicles other than paying the current kilometric rate
- Reimbursement for necessary and reasonable parking and tolls for bridges, ferries and highways when driving for Catulpa purposes
- Catulpa does not reimburse for traffic or parking violations
- When planning any travel, business continuity must be considered when determining whether senior management or key individuals with specialized knowledge should travel together
- Hotel/airport shuttles should be used wherever possible
Employees who are required to use a vehicle in the performance of their duties or for work related travel must have a minimum of $1,000,000.00 dollars of liability insurance and must ensure they have the appropriate insurance coverage for their specific vehicle.
Employees who may be required to use a vehicle in the performance of their duties must:
- Retain and carry a valid driver’s license
- Carry proof from their insurance carrier confirming that they have $1,000,000.00 of liability insurance and the required coverage type for their specific vehicle
- Ensure that their vehicle is in good working order at all times
- Assume sole responsibility for their individual policy and payment of insurance premiums; and
- Assume full responsibility for the cost of fines resulting from traffic violations, parking tickets, theft, loss or damage to their vehicle etc. while driving on agency business
- Reimbursement will be made for accommodation when travelling outside of the Catulpa office areas for single accommodation in a standard room
- Penalties that are incurred for non-cancellation of guaranteed hotel reservations will be the claimant’s responsibility and will only be reimbursed in exceptional circumstances
- There will be no reimbursement for hotel suites, executive floors or concierge levels
- In the normal conduct of Catulpa’s business, reimbursement for overnight accommodation within your office area will neither be authorized nor approved
- Private stays with friends and family are acceptable, and a cash payment or gift may be provided to the friends or family. A maximum of $30 per night is allowed for accommodation including any meals with friends or family. Instead of a receipt, the claimant must submit a written explanation on the expense claim form describing the purpose of the trip, identifying the host and the number of days stayed. The $30 value may also be given in the form of a small gift in which case the claim for reimbursement must be accompanied by a receipt
- Alcohol will not be reimbursed as part of a travel or meal expense. There are no exceptions to this rule. If alcohol is ordered with a meal the claimant is required to request separate receipts for the meal and alcohol consumed. Only the receipt for the meal expense is eligible for reimbursement
- Reasonable and appropriate meal expenses may be reimbursed. Meal expenses incurred for Catulpa’s business purposes while the claimant is away from the office locations
- Meals for business meetings at a Catulpa office location are eligible for reimbursement if the meeting occurs over a meal period
- Original, itemized receipts are required and reimbursement must not exceed the actual amount spent on meals. Taxes and gratuities are included in the meal rates. Reimbursement is for restaurant/prepared food and for appropriate groceries, receipts must be provided
- Reimbursement will not be provided for meals consumed at home or included in the cost of transportation, accommodation, seminars or conferences
- Reimbursement for meal expenses incurred in Canada is subject to the maximum rates set out below.
These rates include taxes and gratuities
- Breakfast – Maximum Amount – $15.00
- Lunch – Maximum Amount – $20.00
- Dinner – Maximum Amount – $30.00
The rates are not an allowance. They are for individual meals – you must have eaten the meal to be able to submit a claim for reimbursement.
When more than one meal is claimed for any day, you may allocate the combined maximum rates between the meals. The maximum rate for the multiple meals becomes the total for the meals consumed, regardless of what you spend on each meal. It is not possible to claim a combined rate and not to have consumed that number of meals.
6. Other Kinds of Expenses
- Individuals requiring a cash Advance for the purposes of travel must complete a cheque requisition form at least two weeks in advance of the event. This form must be properly approved by the Manager and the Executive Director or Manager of Finance
- Individuals will not be reimbursed for personal or recreational items including pay per view movies and items from the mini-bar
- Reimbursement for reasonable gratuities for porter, hotel room services and taxis will be allowed. Claimants are required to keep a record of gratuities paid
Reasonable amounts for gratuities include:
- 10% – 15% on a restaurant meal
- 10% on a taxi fare
- $2 – $5 per night for hotel housekeeping for up to 2 nights, $10 maximum for a longer stay
- $2 – $5 per bag for a porter
Individuals are permitted to use company cell phones and mobile internet devices for business purposes when travelling within Canada, Alternative arrangements must be approved by your Manager and implemented through the Executive Assistant prior to you departure. Wherever possible, individuals are expected to use the lease expensive means of communication. When travelling on Catulpa business, reimbursement will be made for reasonable and necessary personal calls home for each night away.
Hospitality is the provision of food, beverage, accommodation, transportation and other amenities at public expense to individuals who are not engaged in work for the Catulpa. Functions involving only people who work for Catulpa are not considered hospitality functions.
With the approved of the Executive Director or Board Chair, Hospitality may be extended in an economical and consistent manner when it facilitates the business of the Catulpa and is considered desirable as a matter of courtesy or protocol.
Staff appreciation and recognition events and staff retirement events are examples of expenses that do not fit the definition of hospitality. Expenses for such events will be allowable under the condition that such events are conducted with due consideration for the prudent and responsible use of taxpayer dollars, and for government direction on accountability and transparency. Costs should be minimized where possible with due regard for the guests’ status, the size of the event and the intended business purpose.
For hospitality events where guests may include current or prospective vendors, care should be taken to avoid actual and perceived preferential treatment of any vendor.
Appropriate token gifts of appreciation, valued up to $30, may be offered in exchange for gifts of service or expertise to people who are not engaged in work for the Catulpa. Gifts valued over $30 must have prior approval of the Executive Director.
8. Expenses for Consultants and Other Contractors
Consultants and other contractors will not be reimbursed for any hospitality incidental or food expenses, including:
- Meals, snacks and beverages
- Laundry or dry cleaning
- Valet services
- Dependent care
- Home management
- Personal telephone calls
Chair, Vice Chair or Treasurer of the Board of Directors are responsible for:
- Approving expenses of the Executive Director in accordance with this policy
- Ensuring all employees and appointees are made aware of their responsibilities under this policy
- Ensuring this policy is applied and monitored appropriately
- Ensuring staff with delegated authority are able to effectively apply this directive
- Board Member expenses are to be approved by the Board Chair or designate
Executive Director is responsible for:
- Approving travel expenses for Managers and any expenses outside of Ontario
- Delegating approval authority to the appropriate levels
- Ensuring that all persons covered by this policy are aware of their responsibilities
- Provide written authorization for alcohol served at hospitality events
- Review Board Member expenses verifying alignment with the expense policy prior to submission to the Board Chair for approval
Director of Finance is responsible for:
- Ensuring the principles and rules of this policy are implemented and monitored, including implementing processes that support the policy
- Ensuring there is an appropriate records retention system and that documents including claims and approvals are maintained and stored
- Ensuring that claims are fully documented by ensuring regular spot checks
- Ensuring that the policy is maintained and updated as required, consistent with applicable government directives
Managers are responsible for:
- Carrying out any delegated authorities and assigned tasks in accordance with this policy
- Exercising managerial discretion judiciously
- Ensuring staff are aware of the requirements of this policy
- Seeking timely direction when there are questions of application
- Taking appropriate action in the case of non-compliance
Individuals are responsible for:
- Following the principles and rules set out in this policy
- Being aware of any conflict of interest rules that apply to their situation
- Being aware or relevant statutes, directives, policies and guidelines
The Perquisites Policy ensures that the Catulpa Community Support Services (the Agency) is in compliance with the Broader Public Service Accountability Act (BPS). Specifically, this policy will apply to Agency Board Members, Staff and Volunteers, providing direction on the management of perquisites.
A perquisite (or perk) refers to a privilege that is provided to an individual or to a group of individuals as a result of the their employment or volunteer status with the Agency and is not generally available to others.
Perquisites which are not permitted
The following perquisites are not permitted under any circumstance:
- Club memberships for personal recreation or socializing purposes, such as fitness clubs, golf clubs or social clubs
- Seasons tickets to cultural or sporting events
- Clothing allowances not related to health and safety or special job requirements
- Access to private health clinics i.e., medical services outside those provided by the provincial health care system or by the employer’s group insured benefit plans
- Professional advisory services for personal matters, such as tax or estate planning
Authority for Approval
Perquisites are allowable only in limited and exceptional circumstances where it is demonstrated to be a business related requirement for the effective performance of an individual’s job.
Approvals for these types of perquisites must be obtained by the Executive Director, or the Agency Board of Directors where the perquisites apply to the Executive Director.
Records of costs and approvals for perquisites will follow Catulpa Community Support Services Purchasing Policy.
Reporting Allowable Perquisites Publicly
Should an allowable perquisite exist, a summary identifying the type of perquisite and value will be disclosed in conjunction with the public sector salary disclosure on an annual basis.
View the Perquisites Compliance Review 2018-19 here.
View the Perquisites Compliance Review 2017-2018 here.
Code of Ethics/Code of Conduct
Catulpa strives to have all staff, volunteers, students and consultants, working within the agency, to conduct themselves with a high degree of professional conduct.
Catulpa employees uphold the agency Code of Ethics as a significant moral obligation as part of their accountability.
- Employees maintain high standards of professional behaviour both within the agency and in the wider community.
- Employees protect and enhance the trust placed in the agency by its participants/persons served.
- Employees recognize the influence of their roles and will deliver services in such a way as to promote empowerment of person served.
- Employees assume responsibility for personal factors which could affect professional competencies.
- Employees maintain and develop professional competence through on-going education and training.
- Employees avoid dual relationships that could impair professional judgement or increase the risk of exploitation of person served. Dual relationships include but are not limited to business and close personal relationships.
- Employees are prohibited from engaging in sexual activity with any current person served/person served family member for whom they provide direct service.
- When persons served require complex service needs, employees are encouraged to draw on additional expertise within and outside the agency in order to meet person served needs.
- Employees protect the confidentiality of all professionally obtained information. Disclosures of any such information will occur only with the proper authorization from the person served or when legally or professionally obligated; e.g. suspicion of abuse.
- Employees inform participants/persons served of their rights when receiving services from this agency.
- Employees are expected to seek assistance for personal issues that are likely to impact work performance or clinical judgement.
Conflict of Interest
Catulpa has guidelines in place to avoid conflict of interest of its employees or members of their family in relation to the agency and the programs, services and supports offered by the agency.
- A conflict of interest is defined as a conflict between personal and/or business interests of an employee and/or their family and their responsibility as an employee.
- The agency shall not rent or donate space, services or equipment to any employee related to their income generating activity.
- No employee will promote their affiliation with the agency as a means of enhancing or soliciting business for their income generating activity.
- No employee will engage in income generating activities which would reflect unfavourably upon or bring discredit to the agency, its employees, persons served, directors or corporate members.
- If an employee is engaging in additional income generating activities, these must only be carried out outside of regular business hours.
- The agency shall not rent, lease, or in any way use or occupy a property or building that is owned in whole or in part by an employee in which an employee has a financial interest.
- Where there is a competition of demand between an employee’s responsibilities to the agency and their income generating activity, the employee’s first obligation will be to the agency.
- Family members are eligible for employment at Catulpa. Persons served are eligible for employment once service has been completed. Areas that may be considered an exception to this are time limited programs designed for skill building (e.g. CAPC Team Assistants)
- To avoid a “Conflict of Interest” Catulpa will not offer employment to:
- the spouse of a member of the Board of Directors;
- the direct relative of a member of the Board of Directors –child, parent, sibling.
- An employee’s spouse/partner or a direct family member will not be considered for employment within a program where a family member is employed but may be eligible for other agency positions.
- Any employee engaged or contemplating involvement in income generating activities directly related to the work of the agency –such as respite care provider, paid care giver, special services at home worker, skills development facilitator, or private practice (therapy, training, consultation) will request permission from the executive director in writing, to proceed. Safeguards will be created to protect the agency and the employee in a situation where a conflict of interest.
- Token gifts given to staff by persons served, or parents of persons served are not perceived to create a “conflict of interest” for purposes of this Standard and Guidelines statement.
- Managers will ensure their employees are aware of this Conflict of Interest Standard and Guideline and will forward in writing to the executive director for approval any issue that may be in conflict with Catulpa’s philosophy.
Catulpa promotes and encourages diversity in all aspects of the organization and within the communities we serve. Discrimination of any type, internally or externally, will not be tolerated.
The agency supports the Ontario Human Rights Code and prohibits actions that discriminate against people based on protected grounds and social areas.
Protected grounds are:
- Ancestry, colour, race
- Ethnic origin
- Place of origin
- Family status
- Marital status
- Record of Offences
- Sexual Orientation
- Gender identity or expression
- Receipt of public assistance
Protected social areas are:
- Accommodation (housing)
- Good, services and facilities
- Membership in unions, trade or professional associations
- Catulpa expects that all staff, volunteers, students and consultants working within the agency, will treat all others with dignity and respect. Individuals will experience a fair, safe, inclusive and nondiscriminatory work environment at all times. Discriminatory disparagement, harassment and/or violence of any kind will not be tolerated.
- All discrimination complaints will be dealt with in strict confidence subject to the agency’s obligation to conduct a thorough investigation. The investigation will be conducted in a timely and effective manner. All witnesses, if any, will be interviewed. Following the completion of the investigation, the complainant will be personally advised of the findings and the conclusions which have been reached. Unionized employees may have a Union Representative present.
- Employees who are not satisfied with any aspect of the investigation, may raise concerns directly with the executive director. Employees also have the right to file a formal complaint with the Ontario Human Rights Commission, or take legal action.
- Catulpa staff, students and volunteers will be provided regular training opportunities to proactively support inclusiveness within the workplace.
- Catulpa programs, standards and guidelines, decisions and actions will be written and implemented in recognition of the need for inclusiveness, accommodation, safety, and acceptance of all individuals within our workplace and community.
- Catulpa will ensure there is a valid reason for collection and use of personal information, including that of gender, gender identity or gender expression. Anyone can have their name or sex designation changed on agency identity documents and other records if desired. When the above information is collected, the reasons for collection will be shared.
- For acts of discrimination by individuals outside of this organization, (persons served, participants, and /or their family members) the employee will alert their manager and/or the manager of human resources. Action will be taken to resolve the issue, including possible re-assignment, temporary or permanent withdrawal of services or legal action.
Relationship With Participants, Persons Served and Families
Catulpa Community Support Services strives to have all staff, volunteers, students and consultants, working within the agency, to conduct themselves with a high degree of professional conduct.
All staff or volunteers by virtue of their position in the helping relationship, their specialized knowledge or influence, are in a position of power over participants/persons served and their families. This position must be respected and never abused.
Participants/persons served must be able to trust those with whom they interact professionally. Hence, situations which could lead to non-professional and/or harmful interacting must be avoided.
Note: Any relationship which staff or volunteers have with participants/persons served and families must be helpful and professional in nature.
Examples of situations which staff/volunteers will avoid may include but are not limited to the following
- Entering into a relationship to meet one’s personal needs such as social support, companionship or financial support, rather than meeting the needs of the person served/family. [Examples include: borrowing money, accepting money for services rendered or taking participants/persons served home for the weekend, socializing beyond the boundaries of the person served relationship.
- Initiating or encouraging or engaging in sexual intercourse or other forms of physical sexual contact (consensual or otherwise) with a person served or family member.
- Being appointed power of attorney for personal care and/or property for a person served/family of the agency. If power of attorney was given to staff or volunteer before the person served relationship was established, the staff or volunteer must declare this relationship to the manager of the agency responsible for the agency’s program. It is then expected that the manager will see that appropriate checks and balances are in place to protect all parties.
- Unacceptable relationships, suspected or known, must be reported to a senior staff member. These situations are to be treated seriously and investigated immediately.
- Misuse of any professional relationship that crosses the boundaries as mentioned above will be subject to disciplinary measures up to and including dismissal. The disciplinary response will vary in relation to the seriousness of the infraction.
Workplace Harassment and Violence
Catulpa believes that every employee and volunteer has the right to equal treatment and respect, and to be free of harassment and/or violence within the workplace.
Any harassment and/or violent behaviour by the employer or employee, volunteer or participants/persons served will not be tolerated by Catulpa Community Support Services.
- Harassment and/or violence can take the form of physical contact or non-physical behaviours and can include, but is not limited to:
- Threatening behaviour; shaking fists, destroying property or throwing
- Verbal or written threats, and any expression of an intent to inflict
- Any behaviour that demeans, excludes, embarrasses, humiliates, annoys, alarms or verbally abuses a person and that is known or would be expected to be unwelcome. This includes words, gestures, intimidation, bullying, or other inappropriate actions and may be sexual or non-sexual in
- Verbal abuse such as swearing, insults or condescending
- Physical attacks such as hitting, shoving, pushing or kicking
- Vexatious comments and conduct that is known or ought reasonably to be known to be unwelcome.
- Leering, grabbing, sexual innuendos, propositions for dates or sexual favours.
- Inappropriate comments with respect to personal appearance or smell