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Fleet Industries , [] O. Behaviour does not have to be directed at any one person to create a poisoned environment. The policies must be reviewed at least annually.

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Educators, employers, housing providers and other responsible parties need to know the potential links between sexual harassment and violence, and must reflect this knowledge in policies, programs and procedures. Air Canada, supra , note 10 at para.

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A person may also experience sexual harassment or a poisoned environment because they have a relationship with a racialized person. If they attempt to break traditional female gender roles, such as entering traditionally male occupations, they may be targeted for harassment as a means of dissuasion.

2. Identifying sexual harassment

A successful female real estate agent was criticized for being "aggressive," "a woman in a man's environment" and "much like a man. This approach was consistent with human rights case law pre-dating the amendments: National Money Mart Co.

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Behaviour does not have to be directed at any one person to create a poisoned environment. Inappropriate comment or conduct does not just poison the environment for the people targeted — it is offensive to everyone. Gender-based harassment can be carried out by men or women, and its target may be male or female.
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