Specialist Expertise

Bill C-65 Certified
Investigations.

Bill C-65 amended the Canada Labour Code to mandate independent workplace harassment and violence investigations for federally regulated employers. Roots Investigation Services is one of Calgary's few certified C-65 investigators with real-world federal experience.

What Is Bill C-65

Understanding Your Legal Obligations

Bill C-65 came into force in January 2021, amending Part II of the Canada Labour Code to extend workplace harassment and violence protections to all federally regulated workplaces.

The legislation requires employers to conduct a workplace assessment, implement a prevention plan, and establish a clear resolution process — including mandatory investigation by a qualified, neutral third party when a notice of occurrence is filed.

Non-compliance can result in inspections by Employment and Social Development Canada (ESDC), compliance orders, and significant legal and reputational risk. The obligation to investigate is not discretionary — it is a legal requirement.

As a certified C-65 investigator with hands-on experience at a major federally regulated airline — including a 120+ employee assessment across remote Nunavut communities — we understand these obligations from the inside out.

Who is federally regulated?

Airlines & aviation (Canadian North, WestJet, Air Canada)
Banks & federally regulated financial institutions
Telecommunications (Bell, Telus, Rogers, Shaw)
Inter-provincial pipelines (TC Energy, Enbridge)
Federal Crown corporations
Federal government departments & agencies
Canada Post & courier services
Rail & inter-provincial trucking
⚠️ Not sure if C-65 applies to you? Contact us for a free 15-minute compliance check. Operating under federal jurisdiction without a compliant prevention program in place is a significant legal exposure.
The Process

How a C-65 Investigation Works

Each step follows the requirements of the Workplace Harassment and Violence Prevention Regulations (SOR/2020-130).

01

Notice of Occurrence Filed

An employee files a notice of a workplace harassment or violence occurrence with the employer. This formally triggers the C-65 resolution process under the Canada Labour Code.

Regulatory Trigger
02

Negotiated Resolution Attempt

The parties first attempt to resolve the matter through a facilitated negotiated resolution. If unsuccessful or inappropriate, the matter proceeds to formal investigation.

Resolution Attempt
03

Appointment of Independent Investigator

The employer and the responding party jointly agree on a qualified independent investigator. Roots Investigation Services is appointed as the neutral third party.

Our Engagement Begins
04

Evidence Gathering & Interviews

Structured, procedurally fair interviews with all principal parties and witnesses. Document and records review conducted against applicable standards.

Investigation Phase
05

Investigation Report Delivered

A comprehensive written report with findings of fact, conclusions, and recommendations — delivered within regulatory timelines and provided to all parties as required.

Final Deliverable
06

Employer Action Plan

The employer implements corrective actions based on our recommendations. We provide advisory support to ensure the response is compliant and defensible.

Post-Investigation
Employer Obligations

What the Law Requires

Under the Canada Labour Code and the Workplace Harassment and Violence Prevention Regulations, federally regulated employers have specific, non-negotiable obligations.

📋

Workplace Assessment

A joint assessment to identify risk factors for harassment and violence, conducted in collaboration with the applicable workplace committee or representative.

🛡️

Prevention Plan

A written workplace harassment and violence prevention plan — implemented and reviewed at least every three years or after any occurrence.

📢

Notice Response

When a notice is received, employers must respond within prescribed timelines and offer the resolution options outlined in the Regulations.

🔍

Independent Investigation

If negotiated resolution fails or is inappropriate, a qualified, neutral third-party investigator must be jointly appointed to conduct a formal investigation.

📊

Annual Reporting

Employers must submit an annual report to the Minister on the number of occurrences, resolutions, and outstanding matters within their workplace.

🎓

Training

All employees — including managers and designated recipients — must receive training on the prevention plan and the employer's obligations under the Regulations.

FAQ

C-65 Questions Answered

Do we have to use an external investigator under C-65? +
In many cases, yes. Internal HR staff are often perceived — or actually are — biased, which can invalidate the process and expose the employer to serious legal risk. An independent external investigator provides the neutrality required by both the Regulations and sound legal practice.
What happens if we don't comply with Bill C-65? +
Non-compliance can result in ESDC health and safety officer inspections, compliance orders, and formal directions to your organisation. Beyond regulatory penalties, failure to properly investigate creates significant civil liability and damages employee trust — often irreparably.
How long does a C-65 investigation take? +
A straightforward investigation typically takes 4–6 weeks from appointment to report delivery. Complex matters involving multiple parties or large document volumes may take 8–12 weeks. We commit to regulatory deadlines from the outset and are transparent about timelines.
Does C-65 apply to our provincially regulated workplace? +
Bill C-65 applies exclusively to federally regulated workplaces operating under Part II of the Canada Labour Code. Provincially regulated workplaces fall under provincial OHS and human rights legislation. Contact us for a free eligibility check if you're unsure which regime applies.
What if the respondent is a senior leader? +
This is precisely where an independent investigator is most critical. Investigating allegations against senior leaders internally creates serious conflict-of-interest risks. Our independence means we treat every respondent — at any level — with the same procedural fairness and rigour.

Need a certified C-65 investigator now?

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