An employer's duty of care to provide reasonable support to employees who are the subject of workplace complaints is distinct from any duty relating to the conduct of the investigation itself, and is not precluded by the Paige line of authority. However, to establish causation of psychiatric injury, expert evidence must be based on the facts actually proved at trial as constituting breaches of duty, not on a broader factual basis including non-justiciable matters such as the fact of the investigation itself. The content of the employer's support duty may include briefing the employee on complaints and the investigation process, providing a dedicated support person, and ensuring the employee understands that removal from a role does not indicate prejudgment.
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