Safe Sport

The SCRC Safe Sport Manual

We have updated our Safe Sport information to make it more accessible to our public.

Click here to view our Safe Sport Manual as a PDF.

Definitions in our Manual

The terms defined below shall apply to all policies included in this St. Catharines Rowing Club Safe Sport Policy Manual.

“Affected Party” - Any Individual or entity, as determined by the Appeal Manager, who may be affected by a decision rendered under the Appeal Policy and who may have recourse to an appeal in their own right under the Appeal Policy.
“Appellant” – The Party appealing a decision pursuant to the Appeal Policy.
“Appeal Manager” – An individual appointed by RCA or a Provincial Rowing Association who may be any
staff member, committee member, volunteer, Director, or an independent third party, to oversee the administration of the Appeal Policy. The Appeal Manager’s responsibilities shall include those as described in the Appeal Policy.
“Athlete” – includes any Individual who is registered with St. Catharines Rowing Club for either recreational or competitive purposes.
“Board” – the Board of Directors of St. Catharines Rowing Club.
“Case Manager” – an independent individual appointed by RCA or a Provincial Rowing Association, as
applicable, to fulfill the responsibilities described in the Harassment, Discipline and Complaints Policy. In order to be appointed as a Case Manager, the individual must have relevant experience and skills to manage complaints and perform their duties, either as a legal practitioner or sport administrator.
“Complainant” – the Party making a complaint pursuant to the Harassment, Discipline and Complaints Policy and as referred to in Row Ontario’s Investigations Policy.
“Complaint Resolution Officer” – an individual appointed to handle the duties of the Complaint Resolution Officer as described in the Harassment, Discipline and Complaints Policy.
“Criminal Record Check (CRC)” – A search of the RCMP Canadian Police Information Centre (CPIC) system for adult convictions
“Days” – calendar days. For the purpose of calculating deadlines in this Safe Sport Policy Manual, days excludes weekends and public holidays, and the day of the act/decision is not counted as the first day of any deadline.
“Discrimination” – Differential treatment of an individual based on one or more prohibited grounds which include race, citizenship, national or ethnic origin, colour, religion, age, sex, sexual orientation, gender identity or expression, marital status, family status, genetic characteristics, or disability.
“Event” – An event sanctioned by RCA or a Rowing Organization, including St. Catharines Rowing Club, and which may include a social event.
“Harassment” – A vexatious comment (or comments) or conduct against an Individual or group, irrespective of whether the comment or conduct occurs in person or via any other media, including social media, which is known or ought to reasonably be known to be unwelcome. Types of behaviour that constitute harassment include, but are not limited to:
1. Written or verbal abuse, threats, or outbursts;
2. Persistent unwelcome remarks, jokes, comments, innuendo, or taunts;
3. Racial harassment, which is racial slurs, jokes, name calling, or insulting behaviour or terminology that reinforces stereotypes or discounts abilities because of racial or ethnic origin;
4. Leering or other suggestive or obscene gestures;
5. Condescending or patronizing behaviour which is intended to undermine self-esteem, diminish performance or adversely affect working conditions;
6. Practical jokes which endanger a person’s safety, or which may negatively affect performance;
7. Hazing, which is any form of conduct that exhibits any potentially humiliating, degrading, abusive, or dangerous activity, which does not contribute to any Individual’s positive development, but is required to be accepted as part of a team or group, regardless of the individual’s willingness to participate. This includes, but is not limited to, any activity, no matter how traditional or seemingly benign, that sets apart or alienates any teammate or group member based on class, number of years on the team or with the group, or ability;
8. Unwanted physical contact including, but not limited to, touching, petting, pinching, or kissing;
9. Deliberately excluding or socially isolating a person from a group or team;
10. Persistent sexual flirtations, advances, requests, or invitations;
11. Physical or sexual assault;
12. Behaviours such as those described above that are not directed towards a specific person or group but have the same effect of creating a negative or hostile environment; and
13. Retaliation or threats of retaliation against a person who Reports harassment to RCA or to a Rowing Organization.
“Independent Third Party” – the independent individual retained by RCA to receive complaints and to
fulfill the responsibilities outlined in the Harassment, Discipline and Complaints Policy and Investigations
Policy – Discrimination, Harassment and Maltreatment, as applicable.
“Individuals” – refers to all categories of members and/or registrants defined in the Bylaws of St.
Catharines Rowing Club, as well as all people employed by, contracted by, or engaged in activities with St. Catharines Rowing Club including, but not limited to, employees, contractors, athletes, coaches, umpires, officials, volunteers, managers, administrators, parents or guardians, spectators, committee members or directors or officers
“Maltreatment” – any volitional act by an Individual that results in harm or the potential for physical or psychological harm to another Individual, and includes any of the following behaviours or conduct:
1. Psychological Maltreatment: any pattern or single serious incident of deliberate conduct that has the potential to be harmful to the psychological well-being of an Individual. Psychological maltreatment is determined by the objective behaviour, and not whether harm is intended or results from the behaviour. It includes:
  1. Verbal Acts: verbally assaulting or attacking an Individual, including but not limited to unwarranted personal criticisms; body shaming; derogatory comments related to an Individual’s identity (e.g. race, gender identity or expression, ethnicity, Indigenous status, ability/disability); comments that are demeaning, humiliating, belittling, intimidating, insulting or threatening; the use of rumours or false statements about an Individual to diminish their reputation; using confidential sport and non-sport information inappropriately. Verbal maltreatment may also occur in online forms.
    1. Non-Assaultive Physical Acts (no physical contact): physically aggressive behaviours, including but not limited to throwing objects at or in the presence of others without striking another; hitting, striking or punching objects in the presence of others.
    2. Acts that Deny Attention or Support: acts that deny attention, lack of support or isolation including but not limited to ignoring psychological needs or socially isolating an Individual repeatedly or for an extended period of time; abandonment of an athlete as punishment for poor performance; arbitrarily or unreasonably denying feedback, training opportunities, support or attention for extended periods of time and/or asking others to do the same.
  2. Physical Maltreatment: any pattern or single serious incident of deliberate conduct that has the potential to be harmful to the physical well-being of an Individual. Physical maltreatment is determined by the objective behaviour, and not whether harm is intended or results from the behaviour. It includes, without limitation:
    1. Contact behaviours: including but not limited to deliberately punching, kicking, beating, biting, striking, strangling or slapping another; and deliberately hitting another with objects;
    2. Non-contact behaviours: including but not limited to isolating an Individual in a confined space; forcing an Individual to assume a painful stance or position for no athletic purpose (e.g., requiring an athlete to kneel on a hard surface); the use of exercise for the purposes of punishment; withholding, recommending against, or denying adequate hydration, nutrition, medical attention or sleep; denying access to a toilet; providing alcohol to an individual under the legal drinking age; providing illegal drugs or non- prescribed medications to an Individual; encouraging or knowingly permitting an athlete to return to training or on the water prematurely following any injury or after a concussion and without the clearance of a medical professional; encouraging an athlete to perform a skill for which they are known to not be developmentally ready.
  3. Sexual Maltreatment, including, but not limited to, any act targeting an Individual’s sexuality, gender identity or expression, that is committed, threatened or attempted against that person, and includes but is not limited to the Criminal Code Offences of sexual assault, sexual exploitation, sexual interference, invitation to sexual touching, indecent exposure, voyeurism and non- consensual distribution of sexual/intimate images. Sexual maltreatment also includes sexual harassment and stalking, cyber harassment, and cyber stalking of a sexual nature.
    1. Examples of Sexual Maltreatment include, but are not limited to:
      1. Any penetration of any part of a person’s body, however slight, with any object or body part by a person upon another person, including but not limited to:
        vaginal penetration by a penis, object, tongue, or finger; and
        anal penetration by a penis, object, tongue, or finger.
      2. Any intentional touching of a sexual nature of any part of a person’s body, however slight, with any object or body part by a person upon another person, including but not limited to:
        kissing;
        intentional touching of the breasts, buttocks, groin or genitals, whether clothed or unclothed, or intentionally touching of another with any of these body parts;
        any contact, no matter how slight, between the mouth of one person and the genitalia of another person, and
        making another touch themselves, the individual, or someone else with or on any of the body parts listed in 2).
        any intentional touching in a sexualized manner of the relationship, context or situation.
  4. Neglect: any pattern or a single serious incident of lack of reasonable care, inattention to an Individual’s needs, nurturing or well-being, or omissions in care. Neglect is determined by the objective behaviour but the behaviour must be evaluated with consideration given to the Individual’s needs and requirements, not whether harm is intended or results from the behaviour.
    1. Neglect, or acts of omission, include without limitation, not providing an athlete recovery time and/or treatment for a sport injury; not being aware of and not considering an Individual’s physical or intellectual disability; not considering supervision of an athlete during travel, training or competition; not considering the welfare of the athlete when prescribing dieting or other weight control methods (e.g., caliper tests); disregarding the use of prohibited substances or methods by an athlete; failure to ensure safety of equipment or environment; allowing an athlete to disregard sport rules, regulations, and standards, subjecting Individuals to the risk of Maltreatment.
  5. Grooming: includes, without limitation, deliberate conduct by an individual to sexualize a relationship with a minor, and which includes making inappropriate behaviour seem normal and gradually engaging in ‘boundary violations’ which have been professionally-identified to Canadian standards (e.g., a degrading remark, a sexual joke, sexualized physical contact; adult participants sharing rooms with a minor who is not an immediate family member; providing a massage or other purported therapeutic interventions with no specific training or expertise; private social media and text communications; sharing personal photographs; shared use of locker rooms; private meetings; private travel, and providing gifts).
  6. Interference with or Manipulation of Process
    1. An adult individual violates the Code of Conduct and Ethics by directly or indirectly interfering with a process instituted pursuant to the Code or the process of St. Catharines Rowing Club, RCA or Rowing Organization instituted pursuant to any other policy, including the policies found in the St. Catharines Rowing Club Safe Sport Policy Manual, by:
      1. falsifying, distorting, or misrepresenting information, the resolution process, or an outcome;
      2. destroying or concealing information;
      3. attempting to discourage an individual’s proper participation in or use of St. Catharines Rowing Club, RCA or another Rowing Organization’s processes;
      4. harassing or intimidating (verbally or physically) any person involved in St.
        Catharines Rowing Club, RCA or another Rowing Organization’s processes
        before, during, and/or following any proceedings;
      5. publicly disclosing an individual’s identifying information, without the
        individual’s agreement;
      6. failing to comply with any temporary or provisional measure or other final
        sanction;
      7. distributing or otherwise publicizing materials an individual gains access to
        during any investigation or hearing, except as required by law or as expressly
        permitted; or
      8. influencing or attempting to influence another individual to interfere with or
        manipulate the process.
  7. Retaliation: An individual shall not take an adverse action against any other individual for making a good faith report of possible maltreatment or for participating in any process found in RCA or a Rowing Organization’s policies, including those found in this St. Catharines Rowing Club Safe Sport Policy Manual. Retaliation includes threatening, intimidating, harassing, coercing or any other conduct that would discourage a reasonable person from engaging or participating in St. Catharines Rowing Club, RCA or another Rowing Organization’s processes. Retaliation after the conclusion of investigation and sanction processes is also prohibited. Retaliation may be present even where there is a finding that no maltreatment occurred and does not include good-faith actions lawfully pursued in response to a report of possible maltreatment.
  8. Aiding and abetting:
    1. any act taken with the purpose of facilitating, promoting, or encouraging the commission of maltreatment by an individual. Aiding and abetting also includes, without limitation, knowingly:
      1. allowing any person who has been suspended or is otherwise ineligible to be in any way associated with sport or to coach or instruct individuals;
      2. providing any coaching-related advice or service to an athlete who has been suspended or is otherwise ineligible; and
      3. allowing any individual to violate the terms of their suspension or any other sanctions imposed.
  9. Failure by an adult individual to report actual or suspected maltreatment of a minor. This obligation is ongoing and is not satisfied by making an initial report; instead, this obligation includes reporting to the Independent Third Party, on a timely basis, all relevant information that the adult individual is or becomes aware of, and requires making a direct report to the Independent Third Party. Any report shall include the personally identifying information of the potential minor complainant (to the extent known), and any such information learned at a later date.
  10. Failure to report inappropriate conduct: Any Individual who suspects or becomes aware of another individual’s inappropriate conduct, even if it is not defined as maltreatment, has a duty to report such inappropriate conduct to the Independent Third Party. Persons in Authority who become aware of another Individual’s inappropriate conduct have a responsibility for reporting the concern to the Independent Third Party.
  11. Intentionally filing a false allegation. An allegation is false if the events or conduct reported did not occur and the individual making the report knows that the events or conduct did not occur. An individual shall not be considered to have filed a false allegation in cases where the allegation cannot be substantiated by supporting evidence but was nevertheless filed in good faith.
“Minor” – any Individual who is under the age of eighteen (18) at the time when the alleged breach of St. Catharines Rowing Club, RCA or any other Rowing Organization’s policy has occurred. Adult individuals are responsible for knowing the age of a minor.
“Parties” – in the context of a complaint under the Harassment, Discipline and Complaints Policy, the complainant and respondent; in the context of an appeal under the Appeal Policy, the appellant, respondent and affected party (or parties).
“Person in Authority” – Any Individual who holds a position of authority within RCA or a Rowing Organization, including, but not limited to, coaches, umpires, officials, managers, support personnel, chaperones, committee members, and directors or officers. In addition to the responsibilities described for individuals in the Code of Conduct and Ethics, a person in authority shall be responsible for knowing what constitutes maltreatment.
“Power Imbalance” - A Power imbalance may exist where, based on the totality of the circumstances, an individual has supervisory, evaluative, a duty of care, or other authority over another Individual. A power imbalance may also exist between an athlete and other adults involved in sport in positions such as high-performance directors, sport specific health-care providers, sport science support staff, care or support persons, guides or pilots. Maltreatment occurs when this power is misused. Once a coach- athlete relationship is established, a power imbalance is presumed to exist throughout the coach-athlete relationship, regardless of age, and is presumed to continue for minor athletes after the coach-athlete relationship terminates or until the athlete reaches 25 years of age. A power imbalance may exist, but is not presumed, where an intimate relationship existed before the sport relationship commenced (e.g., a relationship between two spouses or life partners, or a sexual relationship between consenting adults that preceded the sport relationship).
“Reporting (or Report)” - The provision of information in writing by any person or an individual to a relevant independent authority (the Independent Third Party or position charged with receiving a report and determining next steps) regarding maltreatment. Reporting may occur through either: (i) the complainant (of any age) or the one who experienced the maltreatment, or (ii) a witness – someone who witnessed the maltreatment or otherwise knows or suspects maltreatment. In either case, the intention of reporting is to initiate an independent investigative process, which could result in disciplinary action being taken against the respondent.
“Respondent” – the party responding to a complaint or investigation; or, in the case of an appeal, the body or organization whose decision is being appealed, or the individual who was the subject of a decision that is being appealed.
“Rowing Organization” – an organization that provides programmes, facilities or events to Individuals participating in the sport of rowing on a local, regional or national level in Canada, and which includes Rowing Clubs,1 Special Associations and Provincial Rowing Associations.
“Sexual Harassment” – A vexatious comment (or comments) or conduct against an Individual 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 advance to the Individual and the person knows or ought reasonably to know that the solicitation or advance is unwelcome. Types of behaviour that constitute sexual harassment include, but are not limited to:
1. Sexist jokes;
2. Threats, punishment, or denial of a benefit for refusing a sexual advance;
3. Offering a benefit in exchange for a sexual favour;
4. Demanding hugs;
5. Bragging about sexual ability;
6. Leering (persistent sexual staring);
7. Sexual assault;
8. Display of sexually offensive material;
9. Distributing sexually explicit messages or attachments such as pictures or video files;
10. Sexually degrading words used to describe an individual;
11. Unwelcome inquiries into or comments about an individual’s gender identity or physical appearance;
12. Inquiries or comments about an individual’s sex life;
13. Persistent, unwanted attention after a consensual relationship ends;
14. Persistent unwelcome sexual flirtations, advances, comments or propositions; and
15. Persistent unwanted contact.
“Social Medium (Social Media)” – A form of electronic communication including websites for social networking and microblogging such as blogs, YouTube, Facebook, Instagram, Tumblr, Snapchat, Tik-Tok, and Twitter. Social Media is the plural of Social Medium representing all the platforms broadly.
“Vulnerable Individuals” – Includes children / youth (minors) and vulnerable adults (people who, because of age, disability or other circumstance, are in a position of dependence on others or are otherwise at a greater risk than the general population of being harmed by a person in authority);
“Vulnerable Sector Check (VSC)” – a detailed check that includes a search of the RCMP Canadian Police Information Centre (CPIC) system, local police information, and the Pardoned Sex Offender database
“Workplace” - Any place where events, business or work-related activities are conducted. Workplaces include but are not limited to, the office or facilities of St. Catharines Rowing Club, work-related social functions, work assignments outside offices, work-related travel, the training and competition environment (wherever located), and work-related conferences or training sessions
“Workplace Harassment” – Vexatious comment(s) or conduct against a worker in a workplace that is known or ought reasonably to be known to be unwelcome. Workplace harassment should not be confused with legitimate, reasonable management actions that are part of the normal work/training function, including measures to correct performance deficiencies, such as placing someone on a performance improvement plan, or imposing discipline for workplace infractions. Types of behaviour that constitute workplace harassment include, but are not limited to:
1. Bullying;
2. Workplace pranks, vandalism, bullying or hazing;
3. Repeated offensive or intimidating phone calls, text messages or emails;
4. Inappropriate sexual touching, advances, suggestions or requests;
5. Displaying or circulating offensive pictures, photographs or materials in printed or electronic form;
6. Psychological abuse;
7. Excluding or ignoring someone, including persistent exclusion of a person from work-
  related social gatherings;
8. Deliberately withholding information that would enable a person to do his or her job,
  perform or train;
9. Sabotaging someone else’s work or performance;
10. Gossiping or spreading malicious rumours;
11. Intimidating words or conduct (offensive jokes or innuendos); and
12. Words or actions which are known or should reasonably be known to be offensive, embarrassing, humiliating, or demeaning.
“Workplace Violence” – the use of or threat 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; or 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. Types of behaviour that constitute workplace violence include, but are not limited to:
- Verbal or written threats to attack;
- Sending or leaving threatening notes, text messages or emails;
- Physically threatening behaviour such as shaking a fist at someone, finger pointing, destroying
  property, or throwing objects;
- Wielding a weapon in a workplace;
- Hitting, pinching or unwanted touching which is not accidental;
- Dangerous or threatening horseplay;
- Physical restraint or confinement;
- Blatant or intentional disregard for the safety or well-being of others;
- Blocking normal movement or physical interference, with or without the use of equipment;
- Sexual violence; and
- Any attempt to engage in the type of conduct outlined above.

Athlete Protection Policy

Purpose
This Athlete Protection Policy describe how Persons in Authority shall maintain a safe sport environment for all Athletes.

Interactions between Persons in Authority and Athletes – the ‘Rule of Two’
St. Catharines Rowing Club strongly recommends the ‘Rule of Two’ for all Persons in Authority who interact with Athletes, whether in person or remotely (i.e., in virtual settings). The Coaching Association of Canada describes the intention of the ‘Rule of Two’ as follows:

A coach must never be alone or out of sight with a minor athlete. Two NCCP trained or certified coaches should always be present with an athlete, especially a minor athlete, when in a potentially vulnerable situation such as in a locker room or meeting room. All one-on-one interactions between a coach and an athlete must take place within earshot and in view of a second coach except for medical emergencies. One of the coaches must also be of the same gender as the athlete. Should there be a circumstance where a second screened and NCCP trained or certified coach is not available, a screened volunteer, parent, or adult can be recruited.

St. Catharines Rowing Club recognizes that fully implementing the ‘Rule of Two’, as described above (and modified accordingly for Persons in Authority), in all circumstances, may not always be possible. Consequently, at a minimum, interactions between Persons in Authority and Athletes must respect the following:

The training and competition environments should be open to observation so that all interactions between Persons in Authority and Athletes are observable.
Private or one-on-one situations must be avoided unless they are open and observable by another adult or Athlete.
Persons in Authority shall not invite or have a Vulnerable Individual (or Vulnerable Individuals) in their home without the written permission and contemporaneous knowledge of the Vulnerable Individual's parent or guardian.
Vulnerable Individuals must not be in any situation where they are alone with a Person in Authority without another screened adult or Athlete present unless prior written permission is obtained from the Athlete’s parent or guardian

Practices and Events
As it relates to practices and/or competitions, the following shall be respected:

A Person in Authority should never be alone with a Vulnerable Individual prior to or following a
competition or practice unless the Person in Authority is the Athlete’s parent or guardian.
If the Vulnerable Individual is the first Athlete to arrive, the Athlete’s parent should remain until another Athlete or Person in Authority arrives.
If a Vulnerable Individual would potentially be alone with a Person in Authority following a competition
or practice, the Person in Authority should ask another Person in Authority (or a parent or guardian of another Athlete) to stay until all of the Athletes have been picked up. If an adult is unavailable, another Athlete, who is preferably not a Vulnerable Individual, should be present in order to avoid the Person in Authority being alone with a Vulnerable Individual.
Persons in Authority giving instructions, demonstrating skills, or facilitating drills or lessons to an individual Athlete should always do so within earshot and eyesight of another Person in Authority
If there is a concern with observing the Rule of Two, Persons in Authority and Athletes should take additional steps to achieve transparency and accountability in their interactions.

Communications
Communications between Persons in Authority and Athletes shall respect the following:

Group messages, group emails or team pages are to be used as the regular method of communication between Persons in Authority and Athletes.
Persons in Authority may only send personal texts, direct messages on Social Media or emails to
individual Athletes when necessary and only for communicating information related to team issues and activities (e.g., non-personal information). Any such texts, messages or emails shall be professional in tone and must be copied to another adult when the Athlete is a Vulnerable Individual.
No personal texts between Vulnerable Individuals and Persons in Authority may be sent; however, if this is necessary under Section 5(b), it shall include one other adult person on the message (preferably the Vulnerable Person’s parent(s)/guardian(s)).
Parents and guardians may request that their child not be contacted by a Person in Authority using any form of electronic communication and/or to request that certain information about their child may not be distributed in any form of electronic communications.
All communication between a Person in Authority and Athletes must be between the hours of 6:00am and 11:00pm unless extenuating circumstances justify otherwise (e.g., cancelling an early morning practice).
Communications concerning drugs or alcohol use (unless regarding its prohibition) is not permitted .
No sexually explicit language or imagery or sexually oriented conversation may be communicated by any medium.
Persons in Authority and Athletes are not permitted to offer or ask one another to keep a secret for
them.

Virtual Settings
The Rule of Two shall apply to all Minors in a virtual environment. Specifically:

For Athletes under the age of 16, where possible, a parent/guardian should be present during any virtual
session.
Two adult coaches should be present or one coach and one adult (parent, guardian, volunteer, club
administrator). One-on-one virtual sessions are prohibited.
Coaches shall be informed by St. Catharines Rowing Club, as applicable, of the expected standards of
conduct during virtual sessions.
Parents/guardians of Minors shall be informed by St. Catharines Rowing Club of the activities that will
take place during the virtual session, as well as the process of the virtual session.
Parents/guardians of Minors shall provide consent to the Minor participating in the virtual session, if
irregularly scheduled, or prior to the first session if the sessions will take place on a regular basis.
Communications during virtual sessions shall take place in an open and observable environment.
Sessions must be initiated in appropriate locations (i.e., not in personal or inappropriate locations such
as bedrooms).
Virtual sessions should be recorded whenever allowed by the technology being used.
Parents/guardians should debrief with Minors on a weekly basis regarding virtual sessions.

Travel
7. Any travel involving Persons in Authority and Athletes shall respect the following:

Teams or groups of Athlete shall always have at least two Persons in Authority with them.
For mixed gender teams or groups of Athletes, there will be one Person in Authority from each gender.
Screened parents or other volunteers will be available in situations when two Persons in Authority cannot be present.
No Person in Authority may drive a vehicle with an Athlete alone unless the Person in Authority is the Athlete’s parent or guardian.
A Person in Authority may not share a room or be alone in a hotel room with an Athlete unless the
Person in Authority is the Athlete’s parent or guardian.
Room or bed checks during overnight stays must be done by two Persons in Authority.
For overnight travel when Athletes must share a hotel room, roommates will be age-appropriate and, for Minors, shall be within two years of age of one another and of the same gender identity.

Locker Room / Changing Areas
The following shall apply to locker rooms, changing areas, regatta weigh-in area(s), and meeting rooms:

Interactions (i.e., conversation) between Persons in Authority and Athletes should not occur in any room where there is a reasonable expectation of privacy such as a locker room, regatta weigh-in area(s), restrooms or changing areas. A second adult should be present for any necessary interaction between an adult and an Athlete in any such room. The Rule of Two must be respected.
If Persons in Authority are not present in the locker room or changing area, or if they are not permitted to be present, they should still be available outside the locker room or changing area and be able to enter the room or area if required, including but not limited to team communications and/or emergency situations.

Photography / Video
Any photograph or video involving Athletes shall respect the following:

Photographs and video may only be taken in public view, must observe generally accepted standards of
decency, and be both appropriate for and in the best interest of the Athlete.
The use of recording devices of any kind in rooms where there is a reasonable expectation of privacy is
strictly prohibited.
Examples of photos that shall be edited or deleted include:
1. Images with misplaced apparel or where undergarments are showing
2. Suggestive or provocative poses
3. Embarrassing images
If any photographs or videos will be used on any form of public media, an Image Consent Form must be completed before any images are taken and used.

Physical Contact
10. It is recognized that some physical contact between Persons in Authority and Athletes may be necessary for various reasons including, but not limited to, teaching a skill or tending to an injury. Any physical contact shall respect the following:

Unless it is otherwise impossible because of serious injury or other justifiable circumstance, a Person in Authority must always clarify with an Athlete where and why any physical contact will occur prior to the contact occurring. The Person in Authority must make clear that he or she is requesting to touch the Athlete and not requiring physical contact.
Infrequent, non-intentional physical contact during a training session is permitted.
Hugs lasting longer than five seconds, cuddling, physical horseplay, and physical contact initiated by the Person in Authority is not permitted. It is recognized that some Athletes may initiate hugging or other physical contact with a Person in Authority for various reasons (e.g., such as crying or celebrating after a performance), but this physical contact may only occur in an open and observable environment.

Enforcement
Any alleged violations of this Athlete Protection Policy shall be addressed pursuant to St. Catharines Rowing Club’s Harassment, Discipline and Complaints Policy.

Privacy
The collection, use and disclosure of any personal information pursuant to this Policy is subject to St. Catharines Rowing Club’s Privacy Policy.

Code of Conduct

Harassment, Discipline and Complaints Policy

Purpose
Individuals are expected to fulfill certain responsibilities and obligations including, but not limited to, complying with the policies, Bylaws, rules and regulations of St. Catharines Rowing Club. Non-compliance may result in the imposition of sanctions pursuant to this Policy.

Application of this Policy

This Policy applies to all Individuals and any alleged breaches of the Code of Conduct and Ethics or any policy within the Safe Sport Policy Manual.
This Policy applies to matters that may arise during the business, activities, and events of St. Catharines Rowing Club including, but not limited to, competitions, on and off water training, evaluations (including time trials or any other form of testing), treatment or consultations (i.e., massage therapy), training camps, travel associated with St. Catharines Rowing Club activities, and any meetings.
This Policy also applies to individuals’ conduct outside of the business, activities, and events of St. Catharines Rowing Club when such conduct adversely affects St. Catharines Rowing Club’s relationships (and the work and sport environment) or is detrimental to the image and reputation of St. Catharines Rowing Club, or upon the acceptance of St. Catharines Rowing Club.
Without limiting the generality of the foregoing, this Policy applies to alleged breaches of the Code of Conduct and Ethics by individuals who have retired from the sport of rowing where any claim regarding a potential breach of the Code of Conduct and Ethics occurred when the individual was active in the sport. In addition, this Policy will apply to breaches of the Code of Conduct and Ethics that occurred when the individuals involved interacted due to their mutual involvement in the sport of rowing or, if the breach occurred outside of the sport environment, if the breach has a serious and detrimental impact on the individual(s).
If an Individual makes a complaint or reports an incident that occurred at a time during which a different St. Catharines Rowing Club policy was in force (i.e., Code of Conduct and Ethics, Harassment, Discipline and Complaints Policy), the matter will be governed by the substantive rules in the policy in force at the time that the incident occurred to determine whether an offense or breach of the policy has occurred, unless the panel hearing the matter determines that the principle of lex mitior applies to the circumstances of the case; however, for such cases, this Harassment, Discipline and Complaints Policy will apply retroactively, prior to its approval date, as it relates to procedural matters.
Applicability of this Policy will be determined by the Independent Third Party at their sole discretion and shall not be subject to appeal.
In the event that it is considered appropriate or necessary on the basis of the circumstances, immediate discipline or the imposition of an interim suspension or sanction may be applied by St. Catharines Rowing Club’s President (or designate), after which further discipline or sanctions may be applied according to this Policy. In any workplace related situations, any involved employee will be accommodated, if necessary, in a reassignment or similar accommodation. Any infractions occurring within competition will be dealt with by the procedures specific to the competition, if applicable. In such situations, disciplinary sanctions may be for the duration of the competition, training, activity, or event only.
In addition to being subject to disciplinary action pursuant to this Harassment, Discipline and Complaints Policy, an employee of St. Catharines Rowing Club who is a respondent to a report may also be subject to consequences in accordance with the employee’s employment agreement, if applicable, or St. Catharines Rowing Club’s Human Resources or other applicable policies. Violations may result in a warning, reprimand, restrictions, suspensions, or other disciplinary actions up to and including termination of employment.
St. Catharines Rowing Club will adhere to all disclosure and reporting responsibilities required by any government entity, local police force, or child protection agency.

Minors

Complaints may be brought for or against an individual who is a minor. Minors must have a parent/guardian or other adult serve as their representative during this process. If the minor’s representative is not their parent/guardian, the representative must have written permission to act in such a capacity from the minor’s parent/guardian.
Any individual who reports or brings a complaint involving known or suspected abuse, neglect, or maltreatment of a minor on behalf of the minor must report this to local child welfare services, the applicable provincial social service ministries or departments, or local police.
Communication from the Independent Third Party, Case Manager, Complaint Resolution Officer, or discipline panel, as applicable, must be directed to the minor’s representative, or parent/guardian until such a time as a representative is identified.
A minor is not required to attend an oral hearing, if held.

Reporting a Complaint
All complaints must be reported in writing by an individual (or individuals) to RCA’s identified Independent Third Party within fourteen (14) days of the occurrence of the incident. This timeline may be waived at the Independent Third Party’s sole discretion if they consider that there were extenuating circumstances that prevented the individual from reporting their complaint within fourteen (14) days of the occurrence of the incident.

A complainant who fears retribution or reprisal or who otherwise considers that their identity must remain confidential may report a complaint to the Independent Third Party and request that their identity be kept confidential. If the Independent Third Party considers that the complainant’s identity must remain confidential, the Independent Third Party may ask that the relevant Provincial Rowing Association take carriage of the complaint and act as the complainant as laid out below.
If the Independent Third Party considers that it is unnecessary to keep the complainant’s identity confidential, they shall inform the complainant, who may decide whether or not to pursue the reported complaint. However, the Independent Third Party may not reveal the identity of the complainant unless the complainant expressly informs them of their desire to pursue the complaint and has indicated, in writing, their approval to have their identity divulged.

Independent Third Party Responsibilities
As indicated in the Sport Dispute Resolution Centre of Canada’s Investigation Guidelines, a reported complaint shall not be characterized as vexatious if the evidence demonstrates that there was a reasonable basis for filing and pursuing it. For a complaint to be considered to have been made in bad faith, the Independent Third Party must consider that it was filed consciously for a dishonest purpose or due to the moral underhandedness of the complainant and that there was an intention to mislead.

Upon receipt of a reported complaint from an individual (or individuals), the Independent Third Party shall:
- determine whether the complaint falls within the jurisdiction of this Policy;
- if it can be accepted pursuant to procedures for reporting a complaint above; and
- whether it is either a frivolous or vexatious complaint, or if it has been made in bad faith.1
  If the reported complaint is not accepted by the Independent Third Party for any of the aforementioned reasons, the Independent Third Party shall inform the complainant and provide the reasons for which the complaint was not accepted. If the reported complaint is accepted by the Independent Third Party, the Independent Third Party shall proceed to make the determinations indicated below and notify the parties accordingly that the reported complaint has been accepted.
In cases where the Independent Third Party receives a complaint or report involving known or suspected abuse, neglect or maltreatment of a minor, they shall report this to local child welfare services, the applicable provincial or territorial social service ministries or departments, or local police. The Independent Third Party shall not be responsible for fulfilling the aforementioned obligation if the individual making the complaint or filing the report confirms in writing that they have already reported to any such authorities.
If a reported complaint has been accepted by the Independent Third Party, the Independent Third Party shall determine whether the reported incident has occurred within St. Catharines Rowing Club, Row Ontario or RCA’s business, activities or events. If the incident has occurred outside of the business, activities or events of any of these organizations, the Independent Third Party will determine which organization’s relationships are adversely affected or which organization’s image or reputation will be detrimentally affected by the incident, or if the breach has had a serious and detrimental impact on the individual(s).
St. Catharines Rowing Club will only handle reported complaints in relation to incidents that fall within their business, activities or events, or, if the incident has occurred outside of the business, activities or events of St. Catharines Rowing Club but will adversely affect its relationships or detrimentally affect its image or reputation, if the reported complaint alleges any of the incidents listed in Section 20 below. St. Catharines Rowing Club may inform the Independent Third Party that it is unwilling and/or unable to handle a reported complaint and the Independent Third Party will direct the complaint to be handled by Row Ontario. In these cases, Row Ontario will work with the member Organization to consider how best to address the costs associated with handling the complaint.
Any complaints involving incidents that fall within St. Catharines Rowing Club’s business, activities or events, or outside St. Catharines Rowing Club’s business, activities or events, but that adversely affect its relationships or detrimentally affect its image or reputation and that fall within Section 21 below will be handled by Row Ontario.
The Independent Third Party shall direct a reported complaint to be managed by the Complaint Resolution Officer of St. Catharines Rowing Club2 if the complainant alleges that any of the following incidents have occurred:
1. Disrespectful conduct or behaviour.
2. Minor acts of physical violence, unless the physical violence is between a person in authority and a
  vulnerable individual, in which case the matter will fall under Section 21 below.
3. Conduct contrary to the values of St. Catharines Rowing Club.
4. Non-compliance with St. Catharines Rowing Club’s policies, procedures, rules, or regulations.
5. Minor violations of the Code of Conduct and Ethics, Social Media Policy, Athlete Protection Policy or
  RCA’s Rules of Racing.
The Independent Third Party shall direct a reported complaint to be managed by the Case Manager appointed by the relevant Provincial Rowing Association or RCA if the complainant alleges that any of the following incidents have occurred:
1. Repeated incidents pursuant to Section 20.
2. Abusive, racist, or sexist comments, conduct or behaviour.
3. Any incident of hazing.
4. Behaviour that constitutes abuse, maltreatment, harassment, sexual harassment, or sexual
  misconduct.
5. Major incidents of physical violence (e.g., fighting, attacking).
6. Pranks, jokes, or other activities that endanger the safety of others.
7. Conduct that intentionally interferes with a competition or with any athlete’s preparation for a
  competition.
8. Conduct that intentionally damages St. Catharines Rowing Club’s image, credibility, or reputation.
9. Consistent disregard for St. Catharines Rowing Club’s bylaws, policies, rules, and regulations
10. Major or repeated violations of the Code of Conduct and Ethics, Social Media Policy, Athlete Protection
  Policy or RCA’s Rules of Racing.
11. Intentionally damaging St. Catharines Rowing Club’s property or improperly handling the
  organization’s monies.
12. Abusive use of alcohol or any other intoxicating substance, any use or possession of alcohol or any
  other intoxicating substance by minors, or use or possession of illicit drugs and narcotics.
13. A conviction for any Criminal Code offense.
In exceptional circumstances, the Independent Third Party may direct a reported complaint to be managed by RCA if St. Catharines Rowing Club or Row Ontario is otherwise unable to manage the complaint for valid and justifiable reasons, such as a conflict of interest or due to a lack of capacity.

RCA recognizes that, due to limited human or financial resources, Clubs may establish pools of Complaint Resolution Officers to handle cases under this Policy.

Notwithstanding any provision in this Policy, Row Ontario as the St. Catharines Rowing Club’s Provincial Rowing Association may, at their discretion, or upon request by the Independent Third Party, act as the complainant and initiate the complaint reporting process under the terms of this Policy for matters that fall within Section 21 above. In such cases, Row Ontario will identify an individual to represent the organization, unless Row Ontario is acting as the complainant.
Complainants that allege incidents that could be considered Workplace Violence or Workplace Harassment will be directed to submit that complaint pursuant to St. Catharines Rowing Club’s Workplace Violence and Workplace Harassment Policy.

Investigations
25. In exceptional circumstances, and only when the Independent Third Party considers that the conditions indicated in this section have been satisfied, the Independent Third Party may determine that a reported incident requires further investigation by an independent third-party investigator. Any such investigations will be conducted by the relevant Provincial Rowing Association or RCA, as applicable. The Independent Third Party will direct that an investigation be conducted:

Only if the reported incident falls within Section 21 above;
In accordance with and by an independent investigator appointed pursuant to the Row Ontario’s
Investigations Policy – Discrimination, Harassment and Maltreatment;
Where the Independent Third Party considers that there is a need for an independent assessment to
determine whether an allegation or, where there are several allegations which allegations, should be heard by a discipline panel pursuant to this Policy because they constitute a likely breach of the Code of Conduct and Ethics, the Social Media Policy, the Athlete Protection Policy, or any other relevant and applicable St. Catharines Rowing Club policy, or whether the allegations are frivolous, vexatious or made in bad faith; and
For the purpose of making non-binding recommendations to the Independent Third Party so that they may discharge their responsibilities pursuant to this Policy.
If the Independent Third Party considers that an independent investigation must be conducted for the reasons mentioned above, the investigation shall be conducted by RCA or Row Ontario before any disciplinary procedures are commenced pursuant to this Policy; however, when an investigation is conducted and where it is necessary in the circumstances, interim measures may be imposed in accordance with Section 6 above.
Upon receipt of the investigator’s report, the Independent Third Party shall determine whether the matter will proceed pursuant to Sections 37 and below and shall inform the Parties and RCA or Row Ontario (as applicable).
If the Independent Third Party does not consider that an independent investigation is necessary and the reported complaint has been accepted pursuant to Section 16, the matter shall proceed pursuant to Sections 37 and following below.

Complaint Handled by Complaints Resolution Officer
26. Following the Independent Third Party’s determination that the reported complaint or incident shall be managed by a Complaint Resolution Officer pursuant to Section 20 above, St. Catharines Rowing Club will appoint a Complaint Resolution Officer. The Complaint Resolution Officer appointed to handle a reported complaint or incident must be unbiased and not in a conflict of interest situation.

The Complaint Resolution Officer will ask the complainant and the respondent for either written or oral submissions regarding the reported complaint or incident. Both parties shall also have the right to submit to the Complaint Resolution Officer any relevant evidence, including, but not limited to witness statements, documentary evidence or evidence from other media (i.e., photos, screenshots, videos or other recordings).
Each party shall have the right to receive the other party’s submissions and evidence, including the complainant’s complaint. In the case of oral submissions, each party shall be present when such submissions are made.
Following receipt of the parties’ submissions, the Complaint Resolution Officer may convene the parties to a meeting, either in person or by way of video or teleconference in order to ask the parties questions and to allow the parties to ask questions of one another.
Following their review of the submissions and evidence related to the reported complaint or incident, the Complaint Resolution Officer shall determine if any of the incidents listed in Section 20 above have occurred and, if so, if one or more of the following sanctions should be applied:
1. Verbal or written reprimand;
2. Verbal or written apology;
3. Service or other contribution to St. Catharines Rowing Club;
4. Removal of certain privileges;
5. Suspension from certain teams, events, and/or activities;
6. Suspension from certain activities for a designated period;
7. Any other sanction considered appropriate for the offense;
8. Education or training opportunities.

If, after hearing the parties and reviewing their submissions, the Complaint Resolution Officer considers that none of the incidents listed in Section 20 above have occurred, they shall dismiss the reported complaint.

The Complaint Resolution Officer will inform the parties of their decision, in writing and with reasons. Any sanction imposed shall take effect upon the parties’ receipt of the decision. Should the circumstances require a decision to be rendered immediately or within a short timeline, the Complaint Resolution Officer may render a short, written decision, either orally or in writing, followed by a written reasoned decision.
Any decision rendered by the Complaint Resolution Officer shall be provided to and maintained in the records of St. Catharines Rowing Club, Row Ontario and RCA. Decisions will be kept confidential by the parties and the aforementioned organizations and shall be retained and discarded in accordance with the relevant and applicable privacy legislation.

Request for Reconsideration
33. If the Complaint Resolution Officer decides not to impose a sanction on the respondent, the complainant may request a reconsideration from the Complaint Resolution Officer by informing them in writing, within four days of receiving the decision, that they are not satisfied with the decision and explain why.

If the Complaint Resolution Officer imposes a sanction, the respondent may request, in writing, a reconsideration from the Complaint Resolution Officer by informing them, within seven (7) days of receiving the decision, that they are not satisfied with the decision. In their request for reconsideration, the respondent must indicate:
1. Why the sanction is inappropriate;
2. Any evidence to support the respondent’s position; and
3. What penalty or sanction (if any) would be appropriate.
Upon receiving a request for reconsideration, the Complaint Resolution Officer shall render a decision within seven (7) days explaining whether they have accepted the request for reconsideration and, if so, their new decision.
The Complaint Resolution Officer’s new decision may be appealed in accordance with the Appeal Policy; however, no party shall have a right to appeal unless they have exhausted their right to request a reconsideration.

Handled by Discipline Panel and Case Manager

If the RCA Independent Third Party determines that the reported complaint or incident should be handled by the relevant Provincial Rowing Association pursuant to Section 21 above, that Provincial Rowing Association shall appoint a Case Manager to fulfil the responsibilities listed in the Provincial Rowing Association’s Harassment, Discipline and Complaints Policy.
If the RCA Independent Third Party determines that the reported complaint or incident should be handled by RCA pursuant to Section 21 above, RCA shall appoint a Case Manager to fulfil the responsibilities listed in RCA’s Harassment, Discipline and Complaints Policy.
Following the Independent Third Party’s determination that the reported complaint or incident should be handled by the relevant Provincial Rowing Association or RCA (as applicable) pursuant to Section 21 above, the appointed Case Manager will have the responsibility to:
1. a) Propose the use of the Provincial Rowing Association’s Dispute Resolution Policy (if considered
  appropriate in the circumstances);
2. b) Appoint the discipline panel, if necessary;
3. c) Coordinate all administrative aspects and set timelines;
4. d) Provide administrative assistance and logistical support to the discipline panel as required, including
  providing the discipline panel with any information related to previously established infractions committed by the respondent(s) of the policies of St. Catharines Rowing Club, RCA, any Rowing Organization or any other sport organization that had authority over the respondent;
5. e) Provide any other service or support that may be necessary to ensure a fair and timely proceeding.

Procedures

The Case Manager will establish and adhere to timelines that ensure procedural fairness and that the matter is heard in a timely fashion.
If appropriate in the circumstances, the Case Manager will propose that the parties use the Dispute Resolution Policy with the objective of resolving the dispute. If applicable, and if the dispute is not resolved, or if the parties refuse to use the Dispute Resolution Policy, the Case Manager will appoint a discipline panel, which shall consist of a single Arbitrator, to hear the reported complaint. In extraordinary circumstances, and at the discretion of the Case Manager, a discipline panel of three persons may be appointed to hear the complaint. In this event, the Case Manager will appoint one of the discipline panel’s members to serve as the Chair.
The Case Manager, in cooperation with the discipline panel, will then decide the format under which the reported complaint will be heard. This decision may not be appealed.
The format of the hearing may be an oral in-person hearing, an oral hearing by telephone or other communication medium, a hearing based on a review of documentary evidence submitted in advance of the hearing, or a combination of these methods. The hearing will be governed by the procedures that the Case Manager and the discipline panel deem appropriate in the circumstances, provided that:
1. The discipline panel determines procedures and timelines, as well as a hearing duration, that is as expedient and cost-efficient as possible in order to ensure that costs to the parties and RCA and/or the Rowing Organization are reasonable.
2. The parties will be given appropriate notice of the day, time, and place of the hearing, in the case of an oral in-person hearing or an oral hearing by telephone or other communication medium.
3. Copies of any written documents which the parties wish to have the discipline panel consider will be provided to all parties, through the Case Manager, in advance of the hearing.
4. The parties may engage a representative, advisor, translator, transcription services, or legal counsel at their own expense.
5. The discipline panel may request that any other individual participate and give evidence at the hearing.
6. If not a party, St. Catharines Rowing Club shall be allowed to attend the hearing as an observer and will be provided with access to any documents submitted. With the permission of the discipline panel, St. Catharines Rowing Club may make submissions at the hearing or may provide the discipline panel with
  clarifying information that may be required for the panel to render its decision3
7. The discipline panel may allow as evidence at the hearing any oral evidence and document or item relevant to the subject matter of the reported complaint, but may exclude such evidence that is unduly repetitious, and shall place such weight on the evidence as it deems appropriate
8. Where a discipline panel composed of three members is appointed, the decision will be by a majority vote

If the respondent acknowledges the facts of the incident, the respondent may waive the hearing, in which case the discipline panel will determine the appropriate sanction. The discipline panel may still hold a hearing for the purpose of determining an appropriate sanction.
The hearing may proceed even if a party chooses not to participate in the hearing.
If a decision may affect another party to the extent that the other party would have recourse to a complaint or an appeal in their own right, that party will become an affected party to the complaint and will be bound by the decision.
In fulfilling its duties, the discipline panel may obtain independent advice.

The purpose of this provision is not to provide St. Catharines Rowing Club with the possibility to try to influence whether a sanction is imposed and, if so, the duration or nature of the sanction. Instead, this provision is intended to provide St. Catharines Rowing Club with the possibility to provide the discipline panel with clarifying information when the parties have sought a particular sanction against an individual, but they have misunderstood or misrepresented fundamental elements of the programming or membership structure (or other similar issues) and, if left unaddressed, could result in the discipline panel imposing a sanction that is unenforceable.

Decision

After hearing and/or reviewing the matter, the discipline panel will determine whether an infraction has occurred and, if so, the sanctions to be imposed. If the discipline panel considers that an infraction has not occurred, the reported complaint will be dismissed.
Within fourteen (14) days of the hearing’s conclusion, the discipline panel's written decision, with reasons, will be distributed to all parties, the Case Manager, to RCA, the complainant and respondent’s Club(s) and the complainant and respondent’s Provincial Rowing Association. In extraordinary circumstances, the discipline panel may first issue a verbal or summary decision soon after the hearing’s conclusion, with the full written decision to be issued before the end of the fourteen (14) day period.
Subject to the confidentiality provisions below, the discipline panel’s decision will be considered a matter of public record unless decided otherwise by the discipline panel. However, the parties may request that the discipline panel redact all or part of the decision. This decision shall be at the discipline panel’s sole discretion and may not be appealed.
If the discipline panel dismisses the reported complaint, its decision may only be published with the respondent’s consent. If the respondent does not provide such consent, the decision will be kept confidential by the parties, the Case Manager, RCA and the Rowing Organization (including the respondent’s Club) and shall be retained and discarded in accordance with the relevant and applicable privacy legislation.

Sanctions
The discipline panel may apply the following disciplinary sanctions, singularly or in combination:

Verbal or written reprimand
Verbal or written apology
Service or other contribution to St. Catharines Rowing Club
Removal of certain privileges
Suspension from certain teams, events, and/or activities
Payment of the cost of repairs for property damage
Suspension of funding from the organization or from other sources
Expulsion from St. Catharines Rowing Club
Any other sanction considered appropriate for the offense

Where the discipline panel imposes a sanction, its order shall include, at a minimum, the following details:

which party is responsible for the costs of implementing any sanction;
which organization is responsible for monitoring that the sanctioned individual respects the terms of the
sanction imposed against them;
if applicable, any reinstatement conditions that the sanctioned individual must satisfy and which
organization is responsible for ensuring that the conditions have been satisfied; and
any other guidance that will assist the parties to implement the panel’s decision. If necessary, a party – or the organization that is responsible for implementing or monitoring a sanction – may seek clarifications from the panel regarding the order so that it can be implemented or monitored appropriately.

The following sanctions are presumed to be fair and appropriate for the maltreatment listed below, although the respondent may rebut these presumptions:

Sexual maltreatment involving a minor shall carry a presumptive sanction of a lifetime suspension;
Sexual maltreatment, physical maltreatment with contact and maltreatment related to process shall carry a presumptive sanction of either a suspension or eligibility restrictions
While a respondent has pending charges or dispositions in violation of criminal law, the presumptive sanction shall be a period of suspension.

When determining an appropriate sanction in cases of maltreatment, the discipline panel may consider the following factors:

The nature and duration of the respondent’s relationship with the complainant, including whether there is a power imbalance;
The respondent’s prior history and any pattern of inappropriate behaviour or maltreatment;
The ages of the individuals involved;
Whether the respondent poses an ongoing and/or potential threat to the safety of others;
The respondent’s voluntary admission of the offense(s), acceptance of responsibility for the
maltreatment and/or cooperation in the investigation and disciplinary process;
Real or perceived impact of the incident on the complainant, St. Catharines Rowing Club or the
rowing community;
Circumstances specific to the respondent being sanctioned (i.e., lack of appropriate knowledge
or training regarding the requirements in St. Catharines Rowing Club’s policies, addiction, illness,
disability);
Whether, given the facts and circumstances that have been established, continued participation
in the sport community is appropriate;
A respondent who is in a position of trust, intimate contact or high-impact decision-making may
face more serious sanctions;
Other mitigating or aggravating circumstances.

Any single factor, if severe enough, may be sufficient to justify the sanction(s) imposed. A combination of several factors may justify elevated or combined sanctions.

When imposing sanctions under this Policy, the discipline panel may take into account any previously established infractions committed by the respondent(s) of the disciplinary policies of RCA, any Rowing Organization or any other sport organization that had authority over the respondent.
Unless the discipline panel decides otherwise, any disciplinary sanctions will begin immediately, notwithstanding an appeal. Failure to comply with a sanction as determined by the Discipline Panel will result in an automatic suspension from participation in the activities of St. Catharines Rowing Club until such time as compliance occurs.
Records of all decisions will be maintained by Row Ontario. Row Ontario will submit all records to RCA and to the relevant club. Such records shall be retained and discarded in accordance with the relevant and applicable privacy legislation.

Appeals
The decision of the discipline panel may be appealed in accordance with Row Ontario’s Appeal Policy.

Suspension Pending a Hearing
St. Catharines Rowing Club (or Row Ontario for matters that it is handling) may determine that an alleged incident is of such seriousness as to warrant suspension of an individual pending completion of an investigation, criminal process, the hearing, or a decision of the discipline panel.

Criminal Convictions
An individual’s conviction for a Criminal Code offense will be deemed an infraction under this Policy and may, if justified by the seriousness of the criminal conviction, result in a suspension from the sport of rowing at all levels in Canada.
Confidentiality

The Harassment, Discipline and Complaints process is confidential and involves only St. Catharines Rowing Club (President and relevant staff as determined by the President), the Provincial Rowing Association(s) of the complainant(s) and respondent(s), the parties, the Case Manager, the Complaint Resolution Officer, the discipline panel, and any independent advisors to the discipline panel. Once initiated and until a decision is rendered, none of the parties will disclose confidential information relating to the discipline or reported complaint to any person not involved in the proceedings.
Any failure to respect the aforementioned confidentiality requirement may result in further sanctions or discipline by the Complaint Resolution Officer or discipline panel (as applicable) against the party(ies) in breach.

Timelines
If the circumstances of the reported complaint are such that adhering to the timelines outlined by this Policy will not allow a timely resolution to the complaint, the discipline panel may direct that these timelines be revised.

Records and Distribution of Decisions
Other individuals or organizations, including but not limited to, national sport organizations, Provincial/Territorial sport organizations, local sport organizations, etc., may be advised by St. Catharines Rowing Club of any decisions rendered in accordance with this Policy.

Privacy

The collection, use and disclosure of any personal information pursuant to this Policy is subject to St. Catharines Rowing Club’s Privacy Policy.
St. Catharines Rowing Club or any of its delegates pursuant to this Policy (i.e., Independent Third Party, Complaints Resolution Officer), shall comply with St. Catharines Rowing Club’s Privacy Policy in the performance of their services under this Policy.

Appeal Policy

Social Media Policy

Preamble
St. Catharines Rowing Club is aware that Individual interaction and communication occurs frequently on Social Media. St. Catharines Rowing Club cautions individuals that any conduct falling short of the standard of behaviour required by this Social Media Policy and the Code of Conduct and Ethics may be subject to the disciplinary sanctions identified within the Harassment, Discipline and Complaints Policy.

Application of this Policy
This Policy applies to all individuals and St. Catharines Rowing Club.

Conduct and Behaviour
For the avoidance of doubt, the following Social Media conduct may be subject to disciplinary action in accordance with the Harassment, Discipline and Complaints Policy:

Posting a disrespectful, hateful, harmful, disparaging, insulting, or otherwise negative comment on a social medium that is directed at an individual, at St. Catharines Rowing Club, RCA, at other Rowing Organizations, or at other individuals connected with St. Catharines Rowing Club, RCA or other Rowing Organizations
Posting a picture, altered picture, or video on a social medium that is harmful, disrespectful, insulting, or otherwise offensive, and that is directed at an individual, at [St. Catharines Rowing Club, RCA, at another Rowing Organization, or at other individuals connected with St. Catharines Rowing Club, RCA or other Rowing Organization.
Creating or contributing to a Facebook group, webpage, Instagram account, Twitter feed, blog, or online forum devoted solely or in part to promoting negative or disparaging remarks or commentary about St. Catharines Rowing Club, RCA or other Rowing Organizations, their stakeholders, or their reputation
Inappropriate personal or sexual relationships over a social medium between individuals who have a power imbalance in their interactions, such as between athletes and coaches, Directors and Officers, committee members and staff, umpires, officials and athletes, etc.
Any instance of cyber-bullying or cyber-harassment between one individual and another individual, where incidents of cyber-bullying and cyber-harassment can include but are not limited to the following conduct on any social medium, via text-message, or via email: regular insults, negative comments, vexatious or unwelcome behaviour, pranks or jokes, threats, posing as another person, spreading rumours or lies, or other harmful behaviour.
All conduct and behaviour occurring on Social Media may be Reported pursuant to the Harassment, Discipline and Complaints Policy.

Individuals’ Responsibilities

Individuals acknowledge that their social media activity may be viewable and viewed by anyone, including St. Catharines Rowing Club, RCA, other Rowing Organizations or other individuals.
If St. Catharines Rowing Club, RCA or another Rowing Organization unofficially engages with an individual in social media (such as by retweeting a tweet or sharing a photo on Facebook) the individual may, at any time, ask St. Catharines Rowing Club, RCA or the Rowing Organization to cease this engagement.
When using social media, an individual must model appropriate behaviour befitting the individual’s role and status in connection with St. Catharines Rowing Club, RCA or a Rowing Organization.
Removing content from social media after it has been posted (either publicly or privately) does not excuse the individual from being subject to the Harassment, Discipline and Complaints Policy.
An individual who believes that another individual’s social media activity is inappropriate or may violate the policies and procedures of St. Catharines Rowing Club should report the matter in the manner outlined by the Harassment, Discipline and Complaints Policy.

Privacy
The collection, use and disclosure of any personal information pursuant to this Policy is subject to St. Catharines Rowing Club’s Privacy Policy.

Screening Policy

Preamble
Rowing Canada Aviron (RCA) and Rowing Organizations understand that screening personnel and volunteers is a vital part of providing a safe sporting environment and has become a common practice amongst sport organizations that provide programs and services to the Canadian sport community, and specifically within rowing clubs and associations.

Application of this Policy
This Policy applies to all individuals whose position with St. Catharines Rowing Club is one of trust or authority which may relate to, at a minimum, finances, supervision, or vulnerable individuals.

Not all individuals associated with St. Catharines Rowing Club will be required to obtain a criminal record check or submit screening documents because not all positions pose a risk of harm to St. Catharines Rowing Club, RCA, Rowing Organizations, or participants. Individuals will be subject to the screening requirements described in the Screening Requirements Matrix found in Appendix A of this Policy and shall comply with the screening application requirements as detailed therein. Regardless of previous involvement with St. Catharines Rowing Club, should an individual look to take on a new role at any time that falls in a different category within Appendix A, they will be required to ensure St. Catharines Rowing Club is provided with any new screening documents associated with that new role. For any information on how to obtain a Police Record Check, please consult the Row Ontario Safe Sport webpage.

Screening Committee

The implementation of this Policy is the responsibility of a Screening Committee appointed by St. Catharines Rowing Club for all screening applications received pursuant to this Policy. The Screening Committee will possess the requisite skills, knowledge, and abilities to accurately assess screening documents and to render decisions under this Policy.
The Screening Committee will carry out its duties in accordance with the terms of this Policy.
The Screening Committee is responsible for reviewing all documents submitted with a screening application and based on the review, making decisions regarding the related appropriateness of individuals filling positions within St. Catharines Rowing Club. In carrying out its duties, the Screening Committee may consult with independent experts including Row Ontario’s Screening Committee, lawyers, police, risk management consultants, volunteer screening specialists, or any other person, provided that all documents are maintained strictly confidential.

Screening Requirements

A Screening Requirements Matrix is provided as Appendix A. All individuals must comply with the requirements detailed therein when first engaged by St. Catharines Rowing Club and shall respect the renewal requirements indicated below. Upon this policy becoming effective all current Individuals will be reviewed, and any gaps in St. Catharines Rowing Club’s screening records will be addressed within a six- month period.
If an individual subsequently receives a charge, conviction for, or is found guilty of an offense they will report this circumstance immediately to St. Catharines Rowing Club. Additionally, the individual will inform the relevant organization of any changes in their circumstance that would alter their original responses in their Screening Disclosure Form as part of their original Screening Disclosure Form agreement.
If St. Catharines Rowing Club learns that an individual has provided false, inaccurate, or misleading information, the individual will immediately be removed from their position and may be subject to further discipline in accordance with the Harassment, Discipline and Complaints Policy. For any individual employed by St. Catharines Rowing Club, providing false or inaccurate information is considered willful misconduct and disobedience that is not trivial which has not been condoned by St. Catharines Rowing Club and may result in termination without notice.

Procedure

Individuals must submit the screening documents indicated in Appendix A, according to the category in which they fall, as designated by the President (or designate) to the Screening Committee. Note for the sake of this policy, current is defined as within six months of the date of submission. For those individuals requiring Vulnerable Sector Checks, St. Catharines Rowing Club will provide a letter to be able to access a Vulnerable Sector Check for the position sought as required. Any information submitted shall be subject to St. Catharines Rowing Club’s Privacy Policy, as applicable, will only be viewed on a need-to-know basis, and will be protected in accordance with the relevant and applicable privacy legislation.
All positions are conditional on both the completion of the indicated screening activities in Appendix A as well as an acceptance of the results of those activities. An individual who refuses or fails to provide the necessary screening documents, or makes an incomplete application, will be ineligible for the position sought. The individual will be informed by the Screening Committee that their application and/or position will not proceed until such time as the screening documents are submitted.
St. Catharines Rowing Club understands that there may be delays in receiving the results of Police Record Check. At its discretion, St. Catharines Rowing Club may permit the individual to participate in the role during the delay, provided that the individual demonstrates that they have initiated the Police Record Check process. This permission may be withdrawn at any time and for any reason.
St. Catharines Rowing Club recognizes that different information will be available depending on the type of screening document that the individual has submitted. For example, some reports may show details of a specific offense, or not, and/or others may be returned with specific information or simply a notification indicating ‘cleared’ or ‘not cleared’. The Screening Committee will use its expertise and discretion when making decisions based on the screening documents that have been submitted.
The Screening Committee will review all screening documents for all Level 1 and Level 2 candidates, including supporting documents and shall make a decision as indicated below. For Level 3 screening applications, the Screening Committee will only review cases where the individual has made a declaration in their declaration form that may impact whether they can participate in the desired position.
Following the review of any Level 1 and Level 2 screening applications, the Screening Committee will decide whether:
- The individual has passed screening and may participate in the desired position;
- The individual has passed screening and may participate in the desired position with conditions; c) The individual has not passed screening and may not participate in the desired position; or
- More information is required from the individual.
In making its decision, and where relevant, the Screening Committee will consider all the relevant information from all documents including the type of offense, date of offense, and relevance of the offense to the position sought.
The Screening Committee must decide that an individual has not passed screening if the screening documentation reveals any of the following:
1. If imposed in the last three years:
  1. Any offense involving conduct against public morals
  2. Any offense for trafficking and/or possession of drugs and/or narcotics
  3. Any offense involving the use of a motor vehicle (including speeding tickets for excessive speeding), including, but not limited to, impaired driving (unless the individual’s role does not involve driving)
2. If imposed in the last ten years:
  1. Any crime of violence including but not limited to, all forms of assault
  2. Any offense involving a minor or minors
  3. Any offense involving theft or fraud
  4. If imposed at any time:
3. An individual’s conviction for any of the following Criminal Code offenses:
  1. Any offense of physical or psychological violence
  2. Any crime of violence including but not limited to, all forms of assault
  3. Any offense involving trafficking of illegal drugs
  4. Any offense involving the possession, distribution, or sale of any child-related pornography
  5. Any sexual offense

Conditions and Monitoring
Excluding the incidents above which, if revealed, would cause the individual to not pass screening, the Screening Committee may determine that incidents revealed on an individual’s screening documents may allow the individual to pass the screening process and participate in a desired position with conditions imposed. The Screening Committee may apply and remove conditions at its discretion and will determine the means by which adherence to conditions may be monitored.

Young People
When screening minors, St. Catharines Rowing Club will:

Not require the minor to obtain Police Record Check; and
In lieu of obtaining a Police Record Check, require the minor to submit up to two (2) additional
references.

Notwithstanding the above, St. Catharines Rowing Club may ask a minor to obtain a Police Record Check if the organization suspects the minor has an adult conviction and therefore has a criminal record. In these circumstances, the organization will be clear in its request that it is not asking for the minor’s youth record. St. Catharines Rowing Club understands that they may not request to see a minor’s youth record.

Renewal
Unless the Screening Committee determines, on a case-by-case basis, to modify the submission requirements, individuals who are required to submit a Police Record Check, Screening Disclosure Form, or Screening Renewal Form, are required to submit the documents as follows:

A Criminal Record and Judicial Matters Check every three years
A Screening Disclosure Form every three years
A Screening Renewal Form every year
A Vulnerable Sector Check once

The Screening Committee may request that an individual provide any of the above documents at any time. Such request will be in writing and reasons will be provided for the request.

Records
All records will be maintained in a confidential manner and will not be disclosed to others except as required by law, or for use in legal, quasi-legal, or disciplinary proceedings. This includes protecting all records in accordance with the relevant and applicable privacy legislation.

The records kept as part of the screening process include but are not limited to:

Documentation that an individual’s Criminal Record Check was seen
An individual’s Screening Disclosure Form (for a period of three years)
An individual’s Screening Renewal Form (for a period of one year)
Records of any conditions attached to an individual’s registration by the Screening Committee
Records of any discipline applied to any individual by RCA, by a Rowing Organization, or by another sport
organization

Privacy
The collection, use and disclosure of any personal information pursuant to this Policy is subject to St. Catharines Rowing Club’s Privacy Policy.

St. Catharines Rowing Club, or any of its delegates pursuant to this Policy (i.e., Screening Committee), shall comply with St. Catharines Rowing Club’s Privacy Policy in the performance of their services under this

Appendix A Screening Requirement Matrix

This interactive manual, as well as the PDF version, is reviewed annually. The Safe Sport Manual was approved by our Board of Directors on March 1, 2022 and will be updated again on March 1, 2025.

Additional Safe Sport Resources to Review:

The following is a narrated slide show that has the purpose of explaining our Safe Sport expectations at the St. Catharines Rowing Club. The video will explain:

Safe Sport Background
Key Roles in Safe Sport
the Safe Sport Policy Manual
the Safe Sport Policies/ Procedures
Additional Information that you can access.

Slides and Transcriptions from Video

The Rule of Two

Safe Sport - Rule of Two

The Rule of Two is a leading practice to ensure a safe sport environment for all.
The goal of the Rule of Two is to ensure all interactions and communications are open, observable, and justifiable. When following the Rule of Two, two responsible adults (a coach, parent, or screened volunteer) are present with a participant. There may be exceptions in emergency situations.

The SCRC Safe Sport Manual

We have updated our Safe Sport information to make it more accessible to our public.

Additional Safe Sport Resources to Review:

The Rule of Two

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The SCRC Safe Sport Manual

We have updated our Safe Sport information to make it more accessible to our public.

Additional Safe Sport Resources to Review:

The Rule of Two

SIGNATURE

PLATINUM

GOLD

SILVER

BRONZE​

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