Author’s Note: This article discusses allegations, complaints, disciplinary proceedings, criminal charges, human-rights findings, independent reviews, and criminal convictions. These are legally and factually different categories. A charge is not a conviction, an allegation is not proof, and a disciplinary finding is not the same as a criminal finding. The cases discussed below are included because they are part of the public record and illuminate broader questions concerning workplace culture, supervision, institutional accountability, and public trust.
Introduction
The Toronto Police Service (TPS) is Canada’s largest municipal police service and one of the most visible public institutions in the country. It exercises significant state authority in a city of extraordinary demographic, economic, and cultural diversity. Officers are entrusted with powers of arrest, detention, search, investigation, and use of force. With that authority comes an unusually high public expectation of professionalism, integrity, accountability, and lawful conduct.
The debate surrounding TPS, however, is not limited to individual instances of police misconduct. Over a period spanning many years, independent reviews, human-rights investigations, disciplinary proceedings, criminal prosecutions, governance documents, race-based data, and workplace assessments have raised recurring questions about organizational culture.
Those questions include whether employees feel safe reporting misconduct; whether complainants fear retaliation; whether internal investigations are sufficiently independent; whether racial and gender disparities are effectively addressed; whether supervisory authority can be abused; and whether the governance structure is capable of identifying systemic problems before they become entrenched.
A central feature of the public record is that the issues are not confined to one category of conduct. Workplace harassment, sexual misconduct, discrimination, use of force, racial profiling, accountability and public confidence appear in different proceedings and reports, often involving very different factual circumstances.
That does not mean that every allegation demonstrates a systemic problem. Nor does the existence of multiple disciplinary cases establish that the majority of officers engage in misconduct. It does mean, however, that the questions raised by independent bodies cannot simply be reduced to isolated individual failures.
The Deloitte workplace review, for example, reported that approximately 60% of respondents had experienced or witnessed harassment or discrimination during the preceding five years. Separately, the Ontario Human Rights Commission (OHRC) concluded after a multi-year inquiry that systemic anti-Black racism, racial profiling and racial discrimination affected interactions between Black people and TPS/TPSB.
The more important question, therefore, is not whether problems exist. It is whether the organization has created systems capable of identifying misconduct, protecting complainants, holding decision-makers accountable, and producing sustainable cultural change.
Why Organizational Culture Matters in Policing
Organizational culture refers to the values, expectations, informal practices and assumptions that shape how people behave within an institution.
In an ordinary workplace, culture can affect morale, productivity and employee retention. In a police service, the consequences can be broader because the institution is exercising public authority.
Policing organizations are also unusually hierarchical. A supervisor may influence an employee’s evaluation, assignments, training, specialized-unit access, overtime, promotion prospects or disciplinary exposure. That means an employee who wishes to report misconduct by a superior may be required to challenge a person or structure that has genuine influence over the employee’s career.
The issue therefore is not only whether formal complaint procedures exist.
It is whether employees trust those procedures.
This distinction is important. A policy may state that retaliation is prohibited, while an employee may nevertheless believe that reporting a supervisor will damage their career. An organization may have an internal investigative unit, while employees may still worry about confidentiality or institutional bias.
The Deloitte review identified precisely these types of concerns within TPS. Its executive summary describes the review as an examination of “deep-rooted aspects of the culture” and notes that cultural change is particularly complex in a large hierarchical organization.
The OHRC’s later inquiry likewise connected current TPS culture, gaps in policies and procedures, training and education, and weaknesses in accountability mechanisms to systemic anti-Black racism.
The implication is significant: organizational culture is not merely a human-resources issue. It can influence whether rules are followed, whether misconduct is reported, how complaints are investigated, and ultimately how the public perceives the legitimacy of the police institution.
The Deloitte Workplace Well-Being, Harassment and Discrimination Review
One of the most important recent examinations of internal TPS culture was Deloitte’s Workplace Well-Being, Harassment and Discrimination Review.
TPSB retained Deloitte in September 2019 to conduct the review. The project was delayed and its scope affected by a number of major events, including changes in leadership and the COVID-19 pandemic. Importantly, Deloitte’s report explicitly connected its work to a wider effort to make TPS more inclusive, diverse, equitable and healthy.
The headline statistic received substantial media attention:
Approximately 60% of respondents reported experiencing or witnessing harassment or discrimination during the preceding five years.
The report identified recurring themes involving:
- gender-based discrimination;
- leadership conduct;
- mental-health stigma;
- diversity;
- differences between uniform and civilian members;
- workplace harassment and discrimination;
- and a lack of trust in the complaints process.
The reporting gap was particularly important. Of those who experienced or witnessed harassment or discrimination, less than half said they reported the incident.
That finding complicates any simple interpretation of complaint statistics. A low number of formal complaints cannot necessarily be interpreted as evidence that misconduct is rare. In an organization where employees are reluctant to report, the official complaint numbers may represent only a portion of actual experiences.
Why Employees Often Do Not Report Misconduct
Under-reporting is a major challenge in workplace accountability.
An employee may decide not to complain because of:
- fear of retaliation;
- fear of professional isolation;
- concern about confidentiality;
- concern about promotion or assignment prospects;
- distrust of investigators;
- concern that colleagues will regard the complainant as disloyal;
- or a belief that nothing meaningful will happen.
The problem can be magnified in policing because employees frequently work in small teams and rely heavily on supervisors and colleagues.
There is another important issue: the distinction between an employee not reporting an incident and an employee not regarding an incident as sufficiently serious to report.
The two should not be conflated.
The Deloitte findings nevertheless make clear that reporting confidence was a central issue within TPS.
This is one reason why workplace-culture assessments are valuable. They can reveal experiences that may never appear in disciplinary statistics.
Harassment, Retaliation, and Abuse of Authority
Workplace harassment is broader than sexual misconduct.
It can include:
- bullying;
- intimidation;
- humiliation;
- repeated derogatory conduct;
- exclusion;
- retaliation;
- misuse of supervisory authority;
- discriminatory treatment;
- and conduct that creates a poisoned or hostile workplace.
The role of authority matters greatly.
A supervisor who makes an inappropriate comment is not necessarily committing a crime. A supervisor who repeatedly uses rank to intimidate an employee, retaliates after a complaint, or threatens an employee may create much more serious legal and institutional consequences.
A particularly instructive TPS example comes from a case described in a later civilian review of police workplace harassment investigations.
According to the Civilian Review and Complaints Commission’s review of workplace harassment within the RCMP, a Toronto Police Service female constable in 2007 complained of nine incidents of sexual harassment by a male supervisor. The supervisor responded with four complaints against the constable, including allegations of insubordination. The internal investigator assigned to the harassment complaint had reportedly never previously investigated a workplace-harassment complaint and had received no specialized harassment-investigation training. The investigator did not find harassment, stating that independent evidence did not support the complainant’s allegations.
This particular example is important because it concerns not merely alleged harassment, but the quality and structure of the investigative response.
It raises a difficult institutional question:
What happens when the person complaining about harassment is investigated by an inexperienced process while the person accused of harassment is in a position of authority?
The RCMP’s civilian-review report used the example to underscore the need for properly trained harassment investigators.
Even though the case is historical, it is directly relevant to the broader question of whether institutional structures can unintentionally disadvantage complainants.
Sexual Harassment and Gender-Based Misconduct
Sexual harassment has repeatedly emerged as a subject of concern within policing organizations.
The problem is not limited to overt sexual propositions. It can include unwanted touching, sexualized remarks, circulation of sexualized images, abuse of authority, gender-based humiliation and unwanted advances.
The Toronto Police Service’s own Human Rights procedure confirms that the Service regards human-rights protections as applying to the workplace as well as policing services. It expressly recognizes protections against discrimination and harassment based on grounds including race, sex, sexual orientation, gender identity and gender expression.
The existence of such policies does not itself demonstrate whether workplace culture is effective. That has to be assessed against actual complaints, investigations and outcomes.
The record includes several cases that illustrate why.
Case Study: Heather McWilliam and the Human Rights Tribunal
One of the most important TPS workplace-harassment cases is McWilliam v. Toronto Police Services Board and Angelo Costa and TPA, 2020 HRTO 574.
Heather McWilliam, a TPS constable, brought a human-rights claim involving alleged workplace sexual harassment and discrimination.
The case was unusually significant because it was not merely an internal complaint. It ultimately generated a lengthy Human Rights Tribunal of Ontario decision after approximately five years of proceedings and 35 hearing days.
The Tribunal found that McWilliam had established that she experienced a poisoned work environment, sexual harassment, sexual assault and discrimination by superior-ranking officers employed by the Toronto Police Services Board.
The case attracted national attention and became an important reference point in discussions about women working in policing and other highly hierarchical workplaces.
Earlier reporting described allegations that, between 2008 and 2014, McWilliam experienced repeated sexualized conduct at 23 Division, including alleged distribution of photographs of female officers in bikinis and a supervisor allegedly telling her that he would spank her. Those were allegations advanced in the litigation; the later Tribunal decision established findings against the respondents.
Toronto City Council subsequently specifically directed the City Manager to report on the HRTO decision, its remedies and implementation. The fact that the case generated formal municipal follow-up is itself significant from a governance perspective.
McWilliam’s case is therefore more than an example of alleged misconduct. It demonstrates how a workplace complaint can move through:
internal complaint → human-rights litigation → adjudicated findings → institutional response.
It also illustrates why workplace culture cannot be evaluated solely through criminal convictions. Human-rights tribunals address discrimination and harassment through a different legal framework.
Case Study: Constable Usman Haroon
A more recent TPS disciplinary proceeding provides another concrete example.
In a 2025 disciplinary decision, Constable Usman Haroon pleaded guilty to discreditable conduct arising from unwanted physical contact with fellow constable Shauna Williams.
The agreed statement of facts stated that on November 21, 2015, Haroon was working with Williams. As she exited an elevator, he placed his hand on her buttocks. The interaction was captured on video. The Tribunal found him guilty of discreditable conduct.
The Tribunal imposed a six-month reduction in rank from First Class Constable to Second Class Constable, after which he could return to his prior classification. He was also ordered to attend the TPS Respectful Workplace Unit for training.
The case is particularly relevant because the prosecutor emphasized the concept of sexual autonomy and public trust. The decision recorded the prosecution’s submission that touching a fellow officer in a sexual manner without consent, particularly while on duty, was serious misconduct.
The case also contains an important detail that should not be overlooked: it was not Haroon’s first disciplinary finding involving a female co-worker. The decision records that he had previously been found guilty in a separate matter involving inappropriate touching of a female coworker.
The Tribunal therefore illustrates an issue that appears repeatedly in institutional accountability debates: how should an organization respond when conduct is repeated, even if each individual incident falls short of criminal prosecution?
Criminal Charges Against Toronto Police Officers
Disciplinary proceedings are only one part of accountability.
Where conduct potentially violates the Criminal Code, police officers can themselves become subjects of criminal investigation.
This is particularly significant in Toronto because TPS officers may be investigated by an organization outside their ordinary chain of command—the Special Investigations Unit—where its statutory mandate applies.
Several TPS cases demonstrate the range of possible outcomes.
Case Study: Constable Mandip Sandhu
In 2010, the SIU investigated allegations of a sexual nature involving Toronto Police Constable Mandip Sandhu.
The SIU charged Sandhu with sexual assault under section 271 of the Criminal Code.
The case proceeded to trial.
Sandhu was convicted and sentenced to 15 months’ imprisonment followed by two years of probation. His conviction and sentence were later upheld on appeal. The appellate court described the offence as involving “sexual violence and an egregious abuse of public trust and authority.”
This case is particularly relevant to the article’s discussion of supervisory and institutional power because the court did not treat the matter as an ordinary private sexual dispute. The judgment explicitly recognized the abuse of public trust and authority involved.
It is also an example of the distinction between workplace misconduct and criminal misconduct: the matter progressed beyond administrative discipline into criminal prosecution and conviction.
Case Study: Constable Conal Quinn
Constable Conal Quinn provides another significant case.
In March 2021, TPS notified the SIU of an alleged sexual assault involving a woman. The SIU subsequently charged Quinn with sexual assault under section 271 and breach of trust by an official under section 122 of the Criminal Code.
According to the later court record, Quinn was on duty and in uniform when the incident occurred.
In 2023 he was convicted of sexual assault. In February 2024, the Ontario Superior Court sentenced him to four years in custody. The sentencing judge characterized the offence as a grave breach of trust involving misuse of Quinn’s position as a police officer.
The Ontario Court of Appeal subsequently dismissed Quinn’s appeal in 2025. The appellate decision addressed, among other matters, the application of evidence rules concerning sexual history and the trial judge’s treatment of abuse-of-authority considerations.
This case is especially important for the legal discussion in this article.
A supervisor-subordinate relationship or a relationship involving authority is not automatically criminal.
But Canadian law recognizes that abuse of a position of trust, power or authority can be relevant to the existence of legally valid consent. The Quinn prosecution provides a concrete example of how those principles can operate in a criminal case involving a police officer.
Case Study: Constable Bojan Antal
A more recent case demonstrates that these issues remain current.
In November 2025, TPS announced criminal charges against Constable Bojan Antal following a Professional Standards investigation.
The charges included:
- sexual assault;
- two counts of assault;
- breach of trust by a public officer;
- criminal harassment;
- intimidation;
- two counts of mischief;
- and three counts of uttering threats.
Public reporting later clarified that the allegations covered incidents extending from 2014 through 2025, but that the individual charges were not all tied to the same year. Antal was suspended with pay and scheduled to appear in court.
This case must be described carefully: the charges are allegations and are not convictions.
Nevertheless, the combination of alleged sexual assault, criminal harassment, intimidation and breach of trust demonstrates why public accountability mechanisms matter. It also illustrates that misconduct allegations involving officers can engage multiple areas of law at once.
Case Study: Constable Parsa Hazeri
The issue became even more current in June 2026.
The SIU announced that Toronto Police Constable Parsa Hazeri had been charged following an investigation involving allegations concerning a female youth.
The charges include:
- sexual assault;
- sexual interference;
- invitation to sexual touching;
- transmitting sexually explicit material to a person under 16;
- communicating with a person under 16 for the purpose of facilitating an offence;
- breach of trust;
- careless handling of a firearm.
The SIU stated that the alleged conduct occurred between September and December 2025.
Again, these are charges and remain allegations unless proven in court.
But the case demonstrates an important feature of modern policing accountability: when there are reasonable grounds to believe a police officer may have committed criminal offences within the SIU’s mandate, the officer can be investigated and charged through an independent civilian investigative body.
Case Study: Calvin Au and the Limits of “Off-Duty” Conduct
Not all police misconduct occurs while officers are acting in their official capacity.
In R. v. Au, the Ontario Superior Court dealt with an assault involving TPS Constable Calvin Au.
Au and another off-duty TPS officer went to Brampton to purchase an Apple Watch advertised on Kijiji. The watch turned out to be counterfeit. A confrontation followed, and Au pursued and took the seller, Chadd Facey, to the ground.
The court ultimately found Au guilty of the lesser offence of assault rather than assault causing bodily harm. In sentencing, the court concluded that excessive force had been used, although the conduct was not committed in Au’s capacity as a police officer. He received a suspended sentence and 12 months’ probation, together with ancillary orders including a weapons prohibition.
This case is relevant because it illustrates a broader principle: police officers remain subject to criminal law even when off duty.
It also demonstrates why institutional standards can be higher than ordinary workplace standards. Police officers retain their public identity and professional obligations even outside their regular shifts, although the legal analysis depends heavily on the facts.
The Ontario Human Rights Commission Inquiry
No serious examination of TPS culture can ignore the Ontario Human Rights Commission inquiry into anti-Black racism.
The inquiry began in 2017 and eventually became one of the most extensive external examinations of a Canadian police service undertaken by a human-rights body.
The OHRC examined:
- policing data;
- SIU materials;
- court and tribunal decisions;
- policies and procedures;
- training;
- accountability mechanisms;
- community experiences;
- and evidence from Black communities and officers.
The final report, From Impact to Action, was released in 2023.
The OHRC concluded that systemic anti-Black racism, racial profiling and systemic racial discrimination affected Black people’s interactions with TPS and TPSB. It identified gaps in policies and procedures relating to stops and searches, charges and arrests, use of force, anti-racism training, and monitoring and accountability.
The Commission produced 107 recommendations.
That number is significant because it demonstrates the inquiry was not recommending a single policy adjustment. It identified a broad range of structural measures involving governance, training, data, oversight, supervision and accountability.
A Collective Impact
The OHRC’s work was not a single report.
One important earlier publication was A Collective Impact, an interim report examining racial profiling and racial discrimination of Black people by TPS.
The OHRC’s process involved community consultations and other evidence-gathering methods. According to the Commission’s later account, approximately 130 Black community members across Toronto participated in consultations associated with the inquiry.
The significance of this approach is methodological.
The inquiry did not rely solely on police statistics. It also considered lived experience.
That is relevant because statistical disparity and personal experience answer different questions.
Statistics can demonstrate patterns.
Community testimony can illuminate how those patterns are experienced.
A serious institutional assessment benefits from both.
A Disparate Impact
In 2020, the OHRC released A Disparate Impact, another major interim report.
The report analyzed race-based policing data and examined disparities affecting Black people.
The Commission concluded that Black people were more likely to be arrested and charged and disproportionately represented in police use-of-force incidents.
The report’s significance was that the Commission was attempting to move the discussion from anecdotal allegations to empirical evidence.
The methodology and interpretation of race-based policing statistics naturally attracted debate. Statistical correlation does not automatically establish the cause of a disparity. Enforcement decisions can be affected by many variables.
Nevertheless, the OHRC concluded that the patterns it identified were consistent with systemic racial discrimination and anti-Black bias.
From Impact to Action
The final OHRC report went further.
The Commission concluded that current TPS culture, combined with deficiencies in policies, procedures, training and accountability mechanisms, contributed to systemic anti-Black racism.
The OHRC specifically emphasized that reform cannot necessarily be accomplished through training alone.
It raised the possibility that where a system itself creates recurring harmful outcomes, structural change may be required.
The report therefore recommended changes affecting:
- stops and searches;
- charges and arrests;
- use of force;
- data collection;
- training;
- governance;
- monitoring;
- accountability;
- and community engagement.
The OHRC has continued to monitor implementation and has stated that sustainable change remains a work in progress.
Key Recommendations
Among the recommendations were measures intended to improve:
- race-based data collection;
- transparency;
- accountability;
- training;
- supervision;
- monitoring of charges;
- equity analysis;
- anti-racial-profiling policies;
- use-of-force oversight.
The recommendations are important because they demonstrate that the OHRC did not regard the issue simply as one of individual officers behaving badly.
Its framework addressed organizational structures and decision-making.
That distinction is central to the broader concept of systemic reform.
TPS Race-Based Data Findings
TPS has itself developed race-based data collection initiatives.
Its publicly available materials report disparities in use-of-force incidents.
According to TPS:
- Black people were approximately 1.6 times overrepresented in reported use-of-force incidents compared with their presence in enforcement actions.
- East/Southeast Asian people were approximately 1.2 times overrepresented.
- Middle Eastern people were approximately 1.2 times overrepresented.
- Latino people were approximately 1.5 times overrepresented.
TPS also reports that Black, South Asian and East/Southeast Asian people were more likely than White people to experience higher levels of force across use-of-force incidents.
TPS notes that differences remained after considering certain factors such as weapons, calls for service resulting in enforcement action, and frequency of recent involvement in enforcement interactions.
These findings should not be treated as proof that every use-of-force incident involving a racialized person is discriminatory.
They do, however, establish a measurable disparity that requires explanation, monitoring and policy evaluation.
Governance and the Toronto Police Service Board
The Toronto Police Service Board occupies a central position in this system.
The Board’s responsibilities include:
- strategic governance;
- policy;
- budget approval;
- appointment and oversight of the Chief;
- institutional accountability.
The Board does not ordinarily direct individual criminal investigations.
Its role is instead to establish the conditions under which the Service operates.
This distinction becomes particularly important where independent investigations identify structural problems.
If the issue is a single officer’s misconduct, disciplinary action may be sufficient.
If the issue is a systemic reporting failure, inadequate training, organizational culture or inadequate supervision, governance intervention may be required.
The OHRC explicitly addressed TPSB responsibilities in its recommendations. Its framework emphasizes that accountability for systemic anti-Black racism cannot rest solely with individual officers.
Oversight Mechanisms: SIU, LECA and Professional Standards
Ontario’s police accountability framework is deliberately divided among different institutions.
Special Investigations Unit
The SIU is an independent civilian law-enforcement agency that investigates incidents involving police where its statutory mandate is triggered, including death, serious injury and allegations of sexual assault.
Its purpose is to determine whether there are reasonable grounds to believe an officer committed a criminal offence.
The SIU’s investigations into Conal Quinn, Mandip Sandhu, Regis Korchinski-Paquet, Andrew Loku and Parsa Hazeri demonstrate the range of matters in which its independence becomes important.
Law Enforcement Complaints Agency
LECA is responsible for public complaints under Ontario’s policing accountability framework.
Its role is distinct from the SIU.
The SIU investigates certain serious incidents for possible criminal liability.
LECA handles public complaints and misconduct processes under its statutory authority.
TPS Professional Standards
TPS also maintains internal Professional Standards mechanisms.
These processes can result in disciplinary charges, hearings and sanctions.
The Usman Haroon case illustrates how internal discipline can operate even where criminal charges are not brought.
The existence of multiple mechanisms is important, but it can also make the accountability system difficult for the public to understand.
The G20 Policing Controversy
The 2010 G20 Summit remains one of the most significant police-accountability controversies in Toronto’s recent history.
The Office of the Independent Police Review Director’s 2012 G20 systemic review described the summit as resulting in the largest mass arrests in Canadian history and stated that the events had a profound impact on public confidence in police and policing.
The OIPRD review examined:
- public complaints;
- police planning;
- crowd-management strategies;
- detention;
- command structures;
- use of powers;
- and accountability.
The G20 controversy illustrates that institutional culture cannot be understood solely through personnel complaints.
Operational culture also matters.
How does an organization behave during a major crisis?
How are extraordinary powers used?
How are officers supervised?
What happens when large numbers of arrests occur?
How quickly are complaints investigated?
How transparently are failures acknowledged?
These questions continue to influence public discussions about Toronto policing.
Case Study: Andrew Loku
In 2015, Toronto Police shot and killed Andrew Loku, a 45-year-old Black man.
The SIU investigated the shooting and ultimately concluded that there were no reasonable grounds to believe the subject officer committed a criminal offence. The Director determined that the force used fell within the ambit of legally justifiable force in the circumstances.
The decision did not end public debate.
Loku’s death became a significant point of reference in discussions concerning:
- Black communities;
- police use of force;
- mental-health responses;
- transparency;
- public confidence.
This is an important distinction.
A decision that criminal charges are not warranted answers a criminal-law question.
It does not necessarily answer every policy or social question concerning the incident.
Case Study: Regis Korchinski-Paquet
In May 2020, 29-year-old Regis Korchinski-Paquet fell from the balcony of a Toronto apartment while six police officers were in and around the apartment.
The SIU conducted an investigation involving multiple officers and civilian witnesses.
In August 2020, the SIU concluded that there were no reasonable grounds to criminally charge any TPS officer in connection with her death.
The conclusion illustrates again the distinction between criminal accountability and institutional accountability.
The absence of criminal charges does not mean there was no public controversy.
The case generated extensive public debate concerning race, mental health, policing practices and trust in investigative institutions.
Carding and Street Checks
Long before the OHRC’s final inquiry, Toronto’s policing culture had already been the subject of significant controversy over so-called “carding” or street checks.
Critics argued that Black and racialized communities were disproportionately stopped and documented.
The practice became a major point of conflict between police organizations, civil-liberties advocates and racialized communities.
The controversy eventually contributed to regulatory and policy reforms and helped establish the case for more systematic race-based data collection.
The subsequent OHRC inquiry can therefore be viewed partly as an extension of a much longer debate rather than a completely new controversy.
Human Rights and Discrimination Complaints
Human-rights law provides a different accountability pathway from criminal and police-discipline systems.
The Ontario Human Rights Code protects against discrimination and harassment in employment and other protected social areas.
TPS’s own human-rights procedure expressly recognizes that the Code applies to equal treatment in employment and addresses complaints involving alleged violations of human-rights protections.
This is significant because police employees are employees first and police officers second for many workplace-law purposes.
A police service cannot simply substitute internal discipline for human-rights obligations.
The McWilliam case illustrates the point.
A matter that originated as a workplace dispute ultimately resulted in findings by the Human Rights Tribunal that included discrimination, sexual harassment and sexual assault.
Workplace Law and Human Rights Obligations
Occupational Health and Safety Act
Ontario employers have duties concerning workplace harassment and workplace violence.
The statutory framework requires workplace-harassment policies and procedures and establishes expectations concerning investigation and response.
Police employers are subject to the same provincial workplace-law architecture.
Ontario Human Rights Code
The Human Rights Code protects employees and members of the public against discrimination and harassment on protected grounds.
Those grounds include, among others:
- race;
- sex;
- disability;
- sexual orientation;
- gender identity;
- ancestry;
- ethnic origin;
- citizenship;
- creed.
TPS’s own Human Rights procedure expressly incorporates these protections.
When Workplace Misconduct Becomes Criminal
It is important to be precise here.
A supervisor having a consensual sexual relationship with an adult subordinate is not automatically a criminal offence in Canada.
The criminal law does not create a blanket prohibition against workplace relationships.
However, criminal liability may arise where the facts involve coercion, threats, intimidation, unwanted sexual touching, sexual assault, criminal harassment, or abuse of authority that affects the legal validity of consent.
Relevant provisions include:
Section 122 — Breach of Trust by a Public Officer
Potentially relevant to serious abuse of public office.
Section 264 — Criminal Harassment
Potentially relevant where repeated following, communication, surveillance or threatening conduct causes reasonable fear for safety.
Section 264.1 — Uttering Threats
Relevant to threats involving death, bodily harm or property damage.
Section 265 — Assault
Covers non-consensual application of force.
Section 271 — Sexual Assault
Applies where sexual contact occurs without legally valid consent.
Section 273.1 — Consent
The Criminal Code specifically recognizes circumstances in which consent is legally absent, including where an accused induces participation by abusing a position of trust, power or authority.
Section 423 — Intimidation
Potentially relevant to conduct intended to compel another person through prohibited forms of threats or coercion.
The important distinction is that rank alone does not make a relationship criminal. The criminal analysis depends on what actually occurred and whether the statutory elements of an offence are established.
The Conal Quinn prosecution illustrates how abuse of police authority can become a central issue in a criminal sexual-assault case. The sentencing court described the offence as a grave breach of trust and misuse of the officer’s position.
Civil Liability
Police misconduct can also lead to civil proceedings.
Potential causes of action can include:
- negligence;
- assault and battery;
- intentional infliction of mental suffering;
- misfeasance in public office;
- employment-related claims;
- human-rights remedies;
- Charter claims.
Civil litigation has a different purpose from criminal prosecution.
A person may therefore have a civil remedy even where no criminal conviction occurs.
Likewise, a criminal acquittal does not necessarily resolve all civil or human-rights questions arising from the same factual circumstances.
Mental Health and Organizational Stress
Workplace culture is also connected to employee health.
Police officers may experience repeated exposure to:
- death;
- violence;
- traumatic incidents;
- child abuse investigations;
- suicide;
- serious injury;
- emotionally difficult interactions.
The Deloitte review identified mental-health stigma as one of its recurring themes.
That is important because an institutional culture that celebrates resilience but discourages vulnerability may unintentionally discourage employees from seeking assistance.
Mental-health reform therefore intersects with culture reform.
An employee who feels unable to report either harassment or psychological distress can become increasingly isolated from organizational support.
Diversity, Representation, and Promotion
Diversity is not only a recruitment issue.
It also concerns:
- who becomes a supervisor;
- who receives specialized assignments;
- who reaches senior leadership;
- whether promotion processes are perceived as equitable;
- whether racialized and female employees feel their careers can progress.
The Deloitte review specifically identified diversity and gender-related concerns as recurring themes.
The OHRC inquiry likewise found that systemic discrimination cannot be addressed purely through individual training.
This is why many modern police-reform recommendations focus simultaneously on:
recruitment + retention + promotion + leadership + accountability.
The “Blue Wall of Silence”
A recurring concept in policing research is the so-called “blue wall of silence”: the perceived reluctance of officers to report misconduct by colleagues.
The term is controversial.
Not every police service has the same organizational dynamics, and not every officer who fails to report misconduct is protecting a colleague.
Nevertheless, reporting barriers remain a recurring subject in workplace culture reviews.
The Deloitte review’s finding that fewer than half of respondents who experienced or witnessed harassment or discrimination reported it is particularly important in this context.
The institutional question is therefore not simply:
“Are officers reporting misconduct?”
It is:
“Do officers believe that reporting misconduct is safe, worthwhile and likely to produce a fair outcome?”
That is a much more demanding test of organizational culture.
Comparison with the RCMP
Toronto’s workplace-culture debate should also be understood within Canada’s broader policing experience.
The RCMP has faced some of the most extensive workplace-harassment litigation in Canadian history.
The Merlo-Davidson class action involved thousands of current and former women associated with the RCMP and allegations spanning decades.
The subsequent Bastarache process and Broken Dreams, Broken Lives report documented widespread allegations involving:
- harassment;
- sexual misconduct;
- discrimination;
- abuse of authority;
- retaliation.
The RCMP experience demonstrates that workplace culture challenges can persist across generations and can survive the introduction of new policies.
That comparison is useful for TPS because it highlights a central reform problem:
institutional change must be measured by outcomes, not merely by the existence of new policies.
Why Cultural Reform Is Difficult
Policies can be rewritten quickly.
Culture takes longer.
A police service may adopt:
- a new harassment policy;
- a new reporting procedure;
- new anti-racism training;
- new data systems;
- new advisory panels.
None of these necessarily changes how employees behave on a difficult shift.
Meaningful cultural reform therefore requires changes in:
- incentives;
- supervision;
- leadership;
- reporting;
- disciplinary consistency;
- transparency;
- employee confidence.
The OHRC itself warned that while TPS and TPSB had made progress on several reforms, further work was necessary for long-term sustainable change.
Measuring Reform
A useful accountability framework should ask measurable questions.
Employee Metrics
- How many employees report harassment?
- How many choose not to report?
- How satisfied are complainants with investigations?
- Do employees trust anti-retaliation protections?
- Do workplace survey results improve over time?
Community Metrics
- Are racial disparities declining?
- Is public confidence increasing?
- Are complaints decreasing or simply changing?
- Do community members perceive improvements?
Accountability Metrics
- How quickly are complaints investigated?
- How many disciplinary findings occur?
- How many findings involve supervisors?
- How often are recommendations implemented?
- Are outcomes publicly reported?
The point is not to create a simplistic scorecard.
The point is to make institutional reform measurable.
Public Confidence as a Strategic Asset
Police services depend upon cooperation.
Members of the public must be willing to:
- report crimes;
- provide information;
- act as witnesses;
- preserve evidence;
- testify in court.
If people believe that a police service does not treat misconduct seriously, that confidence can deteriorate.
The same is true internally.
If employees believe the organization does not protect complainants, misconduct may become under-reported.
Internal and external legitimacy are therefore connected.
The institution’s treatment of its own employees can affect how the public perceives the institution as a whole.
Individual Misconduct Versus Systemic Problems
This distinction is essential.
One officer committing misconduct does not prove that an entire police service is corrupt or systemically abusive.
Conversely, the absence of wrongdoing by most employees does not prove that systemic problems do not exist.
The two concepts operate at different levels.
Individual misconduct
Concerns the behavior of a particular officer.
Examples include:
- assault;
- sexual misconduct;
- corruption;
- breach of trust;
- discriminatory conduct.
Systemic problems
Concern policies, structures, incentives or institutional practices that produce recurring effects.
The OHRC inquiry was primarily concerned with systemic questions.
The Deloitte review was primarily concerned with organizational culture.
Disciplinary hearings typically determine individual responsibility.
The most useful investigative analysis therefore places all three levels together without pretending they are interchangeable.
Why These Cases Matter
The cases discussed in this article involve very different circumstances.
They include:
- sexual assault convictions;
- sexual-assault charges;
- workplace sexual-harassment findings;
- unwanted workplace touching;
- off-duty criminal conduct;
- use-of-force controversies;
- deaths investigated by the SIU;
- human-rights litigation;
- race-based policing disparities;
- and large-scale operational controversies such as the G20.
None of these cases, standing alone, establishes a universal proposition about Toronto Police Service employees.
Taken together with independent reports, however, they illustrate why questions about organizational culture are legitimate subjects of public inquiry.
The cases also reveal something else: police accountability is not a single process.
A single incident can potentially pass through:
internal Professional Standards → SIU → criminal court → disciplinary tribunal → civil court → human-rights process → governance review.
Each process answers a different question.
That complexity can make accountability more robust, but it can also make it difficult for the public to understand where responsibility ultimately lies.
Conclusion
The public record concerning the Toronto Police Service reveals a complicated picture.
There is no legitimate basis for treating every allegation against an officer as established fact. Nor is it reasonable to infer that an entire police service is defined by the misconduct of a subset of its members.
At the same time, it would be equally difficult to dismiss the broader issues as isolated incidents.
The Deloitte workplace review reported that approximately 60% of respondents had experienced or witnessed harassment or discrimination within five years and found significant reporting barriers.
The Ontario Human Rights Commission’s multi-year inquiry concluded that systemic anti-Black racism, racial profiling and racial discrimination affected Black people’s interactions with TPS and TPSB and produced 107 recommendations for reform.
TPS’s own race-based data show measurable disparities in use-of-force incidents, including a reported 1.6-times overrepresentation of Black people compared with their representation among enforcement actions.
Specific cases demonstrate different forms of accountability. Mandip Sandhu was convicted of sexual assault and his sentence was upheld on appeal, with the court describing the offence as involving sexual violence and an egregious abuse of public trust and authority.
Conal Quinn was convicted of sexual assault and sentenced to four years’ imprisonment after a case involving abuse of his position as an on-duty police officer.
Usman Haroon pleaded guilty to discreditable conduct involving unwanted touching of a fellow officer and received a temporary reduction in rank and mandatory Respectful Workplace training.
Heather McWilliam’s human-rights case resulted in findings concerning a poisoned work environment, sexual harassment, sexual assault and discrimination by superior-ranking officers.
More recent criminal proceedings involving Bojan Antal and Parsa Hazeri show that allegations of serious misconduct by serving officers remain a contemporary issue; those matters must be treated as allegations unless and until determined by the courts.
The SIU investigations into Andrew Loku and Regis Korchinski-Paquet demonstrate another dimension: a decision not to lay criminal charges can coexist with substantial public debate regarding policing, race, use of force, mental health, transparency and trust.
The lesson is therefore not that every police officer is guilty of misconduct, nor that every allegation demonstrates systemic failure.
The lesson is that accountability has to operate at multiple levels.
Individual officers must be accountable for individual conduct.
Supervisors must be accountable for supervision.
Investigators must be accountable for investigative quality.
Executives must be accountable for organizational culture.
And governance bodies must be accountable for ensuring that reforms do not remain merely written commitments.
For a public institution entrusted with exceptional state authority, the ultimate test is not whether it can produce policies after a controversy.
The test is whether employees feel safe reporting misconduct, whether complainants can obtain fair investigations, whether disciplinary and criminal processes operate independently where appropriate, whether systemic disparities are identified and addressed, and whether the public can see measurable evidence of improvement.
That is the continuing accountability challenge facing the Toronto Police Service and the Toronto Police Service Board.
Sources and Further Reading
1. TPS Workplace Culture and Harassment
Deloitte — Workplace Well-Being, Harassment and Discrimination Review
Official TPSB/Deloitte report:
CityNews coverage of the principal findings:
2. Heather McWilliam — Human Rights Tribunal Case
McWilliam v. Toronto Police Services Board and Angelo Costa and TPA, 2020 HRTO 574
Case discussion and decision information:
Earlier procedural decision:
https://www.minicounsel.ca/hrto/2015/594
Toronto City Council discussion of the HRTO decision and remedies:
https://secure.toronto.ca/council/agenda-item.do?item=2020.EX16.1
3. Usman Haroon — TPS Disciplinary Decision
Toronto Police Service Discipline Hearing
Constable Usman Haroon — 19/2016:
https://www.tps.ca/media/tribunal/2025/19-2016-usman_haroon.pdf
The decision records the guilty plea, unwanted touching of a female colleague, the video evidence, the disciplinary finding, temporary reduction in rank, and mandatory Respectful Workplace training.
4. Conal Quinn — Sexual Assault and Breach of Trust
SIU — Charges
https://siu.on.ca/en/news_template.php?nrid=6571
R. v. Quinn, 2024 ONSC 1073
https://www.minicounsel.ca/scj/2024/1073
Ontario Court of Appeal — R. v. Quinn
The 2025 appeal decision is referenced through the Ontario case record and confirms dismissal of the appeal.
TPS Tribunal Page
5. Mandip Sandhu — Sexual Assault Conviction
SIU — Original Charge
https://siu.on.ca/en/news_template.php?nrid=760
R. v. Mandip Sandhu, 2015 ONSC 1679
https://www.minicounsel.ca/scj/2015/1679
SIU Annual Report
https://siu.on.ca/pdfs/siu_ar_2013_14_english_ltr_final_v2.pdf
The appellate judgment confirms the conviction and 15-month custodial sentence.
6. Bojan Antal — Recent Criminal Charges
CityNews
https://toronto.citynews.ca/2022/06/15/toronto-police-harassment-discrimination-review/
Global News
The articles report charges including sexual assault, assault, breach of trust, criminal harassment, intimidation, mischief and uttering threats. These remain allegations unless proven in court.
7. Parsa Hazeri — 2026 SIU Charges
Special Investigations Unit
https://siu.on.ca/siu-charges-toronto-police-officer-in-sexual-assault-investigation-en11253
The SIU’s June 4, 2026 release sets out the charges under Criminal Code sections 271, 151, 152, 171.1, 172.1, 122 and 86.
8. Calvin Au — Off-Duty Assault
R. v. Au, 2024 ONSC 6587
https://www.minicounsel.ca/scj/2024/6587
R. v. Au, 2025 ONSC 3559 — Sentencing
https://www.minicounsel.ca/scj/2025/3559
The court found Au guilty of assault and later imposed a suspended sentence and 12 months’ probation.
9. Ontario Human Rights Commission — Anti-Black Racism Inquiry
From Impact to Action — Final Report
https://www.ohrc.on.ca/en/impact-action-final-report-anti-black-racism-toronto-police-service
Executive Summary
Chapter 1 — Introduction
107 Recommendations
The OHRC identifies 107 recommendations and states that current TPS culture, gaps in policies, procedures, training and education, and lack of accountability mechanisms contribute to systemic anti-Black racism.
10. OHRC — A Disparate Impact
This report examined race-based policing data and forms a major part of the OHRC’s evidence base concerning racial disparities in Toronto policing.
11. OHRC — A Collective Impact
The inquiry’s earlier work included community consultation, including approximately 130 Black community members across Toronto.
12. Toronto Police Service — Race-Based Data Collection
RBDC Frequently Asked Questions
https://www.tps.ca/race-identity-based-data-collection/rbdc-frequently-asked-questions
The TPS reports the following relative representation in use-of-force incidents:
- Black: 1.6×
- East/Southeast Asian: 1.2×
- Middle Eastern: 1.2×
- Latino: 1.5×
13. Andrew Loku — SIU Investigation
SIU Decision
https://www.siu.on.ca/en/news_template.php?nrid=2578
The SIU concluded that there were no reasonable grounds to criminally charge the officer involved in Loku’s death.
14. Regis Korchinski-Paquet — SIU Investigation
SIU Decision
https://www.siu.on.ca/en/news_template.php?nrid=5977
Director’s Report
https://www.siu.on.ca/en/directors_report_details.php?drid=908
The SIU concluded that there were no reasonable grounds to criminally charge any TPS officer in connection with the death.
15. G20 Systemic Review
OIPRD G20 Systemic Review
https://www.oiprd.on.ca/wp-content/uploads/G20-Systemic-Review-Report.pdf
The OIPRD described the 2010 G20 events as resulting in the largest mass arrests in Canadian history and stated that they had a profound impact on public confidence in police and policing.
16. TPS Human Rights Procedure
TPS Procedure 13-14 — Human Rights
https://www.tps.ca/media/procedures/40ba4908-b7a3-41fc-95a6-29237a52cee8.pdf
The procedure states that TPS is committed to protecting and promoting human rights in both the workplace and policing services and incorporates Ontario Human Rights Code protections.
17. Police Accountability and Oversight
Toronto Police Service Board
Toronto Police Service Tribunal Decisions
Special Investigations Unit
Law Enforcement Complaints Agency
Ontario Civilian Police Commission
https://tribunalsontario.ca/ocpc
18. Canadian Criminal Law
Criminal Code of Canada
https://laws-lois.justice.gc.ca/eng/acts/C-46
Particularly relevant provisions include:
- s. 122 — Breach of Trust by Public Officer
- s. 264 — Criminal Harassment
- s. 264.1 — Uttering Threats
- s. 265 — Assault
- s. 271 — Sexual Assault
- s. 273.1 — Consent and Abuse of Trust, Power or Authority
- s. 423 — Intimidation
19. Workplace and Human Rights Law
Occupational Health and Safety Act
https://www.ontario.ca/laws/statute/90o01
Ontario Human Rights Code
https://www.ontario.ca/laws/statute/90h19
20. Comparative Canadian Policing: RCMP
RCMP Merlo-Davidson Settlement
https://www.rcmp-grc.gc.ca/en/merlo-davidson-settlement
RCMP Independent Centre for Harassment Resolution
https://www.rcmp-grc.gc.ca/en/independent-centre-harassment-resolution
Bastarache Report and RCMP Workplace Harassment Materials
The RCMP experience provides important comparative context because it demonstrates that workplace culture, harassment and institutional accountability challenges have affected multiple Canadian policing organizations over extended periods.