- Purpose and Commitment
The Newfoundland and Labrador Arts Council (ArtsNL) is committed to providing respectful, fair, and accessible service to artists, arts organizations, and members of the public. ArtsNL values questions, feedback, and complaints, and uses them to improve programs and services.
While robust discussion and disagreement are expected, ArtsNL must also ensure a safe and respectful environment for staff, Council members, contractors, and all others who interact with ArtsNL. This policy explains the standards of behaviour expected in interactions with ArtsNL, and how ArtsNL may respond when behaviour becomes unreasonable.
This policy is about conduct only. It does not affect how ArtsNL assesses grant applications or handles access and privacy matters under the Access to Information and Protection of Privacy Act, 2015 (ATIPPA, 2015). Those matters are decided on their merits under the relevant legislation and policies.
- Scope and Related Policies
This policy applies to all interactions with ArtsNL staff, Council members, and contractors by:
- applicants and potential applicants.
- funding recipients.
- partners and collaborators.
- members of the public.
It applies to all channels, including:
- in-person visits and meetings.
- phone calls and voice messages.
- email and written correspondence.
- virtual meetings.
- events and public activities hosted or supported by ArtsNL.
- ArtsNL’s social media channels, website, and other online platforms.
This policy works alongside ArtsNL’s other policies, including the Netiquette Policy (for online and social media interactions).
Where there are any inconsistencies, applicable legislation and mandatory policies will prevail.
- Expectations of Respectful Behaviour
ArtsNL expects all individuals who interact with the organization to:
- treat ArtsNL staff, Council members, contractors, and other clients with courtesy and respect.
- communicate concerns and disagreements without aggression, abuse, or discrimination.
- allow staff to carry out their duties without interference or intimidation.
- provide information that is accurate and relevant to their request, application, or complaint.
- follow any reasonable instructions about how and when to contact ArtsNL.
ArtsNL is committed to treating all individuals with courtesy, respect, and professionalism, and to communicating decisions and processes in a clear and accessible way.
- What ArtsNL Considers Unreasonable or Unacceptable Behaviour
Most people who interact with ArtsNL do so respectfully. When behaviour becomes unreasonable, ArtsNL may need to place limits on contact to protect staff, ensure safety, and maintain fair access to services.
Unreasonable behaviour is conduct that, because of its nature, frequency, or severity, interferes with ArtsNL’s ability to provide services or creates health, safety, resource, or fairness concerns for staff, Council members, other clients, or the person themselves.
The examples below are not exhaustive. ArtsNL will consider the circumstances of each case before deciding that behaviour is unreasonable.
4.1 Excessive or Disruptive Contact
Behaviour may be unreasonable when it:
- involves very frequent or lengthy calls, emails, messages, or visits that consume disproportionate time or disrupt normal work.
- involves contacting multiple ArtsNL staff or Council members about the same issue to pressure for a different outcome.
- demands immediate responses or attention where that is not feasible or reasonable.
4.2 Excessive Persistence
Behaviour may be unreasonable when it:
- continues to pursue an issue that ArtsNL has already clearly addressed or closed, including after any available review processes are complete.
- repeatedly challenges decisions without providing any new information.
- attempts to reopen closed decisions outside established processes.
4.3 Aggressive, Abusive, or Discriminatory Behaviour
Behaviour may be unreasonable when it includes:
- shouting, persistently raising one’s voice, or using an aggressive or hostile tone.
- abusive, insulting, or derogatory language.
- discriminatory language or behaviour related to protected characteristics.
- direct or indirect threats, intimidation, or behaviour that makes others feel unsafe.
- personal attacks on staff, Council members, or other clients, including defamation or unsubstantiated allegations of misconduct.
4.4 Misleading or Obstructive Behaviour
Behaviour may be unreasonable when it:
- deliberately provides false, misleading, or selectively incomplete information that interferes with ArtsNL’s work.
- refuses, without reasonable explanation, to provide information needed to progress a matter.
- covertly records meetings or conversations in a way that undermines trust or creates safety concerns.
4.5 Interfering with ArtsNL Operations
Behaviour may be unreasonable when it:
- involves loitering, causing a disturbance, or otherwise disrupting ArtsNL offices, events, or activities.
- prevents staff from carrying out their duties or interferes with other people’s ability to access ArtsNL services.
- uses public escalation (for example, coordinated online campaigns or mass tagging) primarily to pressure staff in a way that interferes with fair and independent decision-making.
4.6 Context and Fairness
ArtsNL recognizes that people may feel strong emotions and may express frustration, disappointment, or distress. ArtsNL will take context into account, including disability, cultural factors, language, and personal circumstances, before determining that conduct is unreasonable, while still prioritizing safety and fair access for all.
- Principles Guiding ArtsNL’s Response
ArtsNL’s responses to unreasonable behaviour will:
- be limited to what is necessary to prevent or reduce the impact of the behaviour.
- be proportionate to the nature, frequency, and impact of the behaviour.
- be time-limited where appropriate and subject to review.
- be consistent with ArtsNL’s legal obligations, including work health and safety and ATIPPA, 2015.
- be documented and applied in a fair, consistent, and transparent way.
ArtsNL will always focus on observable behaviour and its impact.
- What Could Happen: Step-by-step Response
This section explains what ArtsNL may do when behaviour becomes unreasonable.
6.1 Step 1: Real-time Warning and Boundary Setting
When behaviour first becomes concerning, ArtsNL staff will normally:
- explain the behaviour that is causing concern.
- ask that the behaviour stop and outline what is needed to continue the interaction.
For example, staff may state that they are willing to continue the conversation, but will end it if shouting, abusive language, or other inappropriate behaviour continues.
If the behaviour stops, ArtsNL will continue to provide services as usual. The interaction may be noted for internal records.
In cases of very serious behaviour (such as threats or violence), ArtsNL may proceed directly to subsequent steps without prior warning.
6.2 Step 2: Written Notice
If concerning behaviour continues, or if the behaviour is serious enough, the Executive Director may send a written notice that:
- describes the behaviour of concern and when it occurred.
- explains why ArtsNL considers the behaviour unreasonable.
- sets out expectations for future contact.
- explains possible further steps if the behaviour continues.
This written notice is intended to give the person a clear opportunity to change their behaviour and to understand the potential consequences.
6.3 Step 3: Limits on Communication and Contact
If unreasonable behaviour continues after a written notice, ArtsNL may introduce specific limits on communication and contact. These may include:
- limiting how often the person may contact ArtsNL (e.g., one email or call on a specified day).
- limiting the methods of contact (e.g., requiring communication in writing only, or through a specific email address).
- assigning a single point of contact within ArtsNL for all communication.
- limiting discussion to certain topics (e.g., declining further discussion of matters already decided, unless new information is provided).
- requiring appointments for any calls or meetings.
- ending calls or meetings immediately if behaviour breaches this policy.
The person will be informed in writing of any limits, the reasons for them, and how long they will apply.
6.4 Step 4: Stronger Restrictions
For ongoing or serious unreasonable behaviour, ArtsNL may apply stronger restrictions, such as:
- limiting or stopping in-person meetings and allowing contact only by phone or in writing.
- declining to review or respond to further correspondence on a matter that has been fully addressed, except where a response is required by law.
- directing the person to stop contacting ArtsNL about a particular matter and instead use formal review, appeal, or legal channels if they wish to take the issue further.
Any such decision will reflect the minimum steps necessary to manage the behaviour and protect staff and services.
6.5 Step 5: Safety and Legal Measures
If behaviour involves threats, harassment, or safety risks, ArtsNL may:
- end the interaction immediately and require the person to leave the premises or event.
- involve law enforcement.
- seek legal advice about further measures.
These measures may be used at any stage if necessary to protect the health and safety of staff and others.
- Effect on Services and Decisions
Restrictions under this policy relate to contact and behaviour, not to the fair assessment of applications or to rights of access under ATIPPA, 2015.
Where legislation requires ArtsNL to accept, consider, or respond to certain requests or information, ArtsNL will do so, but may impose conditions on how communications occur as a means of managing unreasonable behaviour.
- Review of Restrictions
A person subject to restrictions under this policy may request that ArtsNL reconsider those restrictions. ArtsNL will review any request for reconsideration, and the final decision will be made by the Executive Director.
In reconsidering a restriction, ArtsNL may consider:
- the nature and impact of the behaviour.
- any changes in the person’s behaviour since the restriction was imposed.
- the time that has passed.
- any new information provided by the person.
- ongoing safety or resource concerns.
Restrictions may be changed or lifted where behaviour has improved or where circumstances warrant it. ArtsNL may also extend or adjust restrictions if behaviour continues to be unreasonable.
- Questions About This Policy
Questions about this policy or its application can be directed to:
Melanie Martin
Executive Director, ArtsNL
(709) 726-2212 ext. 5
melanie@artsnl.ca
Effective: September 14, 2026