Policy/Program Memorandum 128 (PPM 128) is not a suggestion. It is a Ministry of Education mandate governing student behaviour and school safety — the provincial baseline that every publicly funded school board in Ontario is required to meet.[1] And yet, an audit conducted by School Board Research reveals that the majority of boards are falling short.
In 2025, School Board Research ran a pilot study assessing selected PPM 128 code-of-conduct clauses across 60 of Ontario’s English-language publicly funded school boards — a subset of the province’s 72 boards, chosen to test our method before a full launch.[2] Even on this limited set of clauses, the pattern was striking: 55 of the 60 boards assessed — 92% — were missing at least one mandatory element among the clauses reviewed.[2] 82% — 49 of 60 boards — did not communicate how parents or the public could report unacceptable behaviour.[2] And 18% — 11 of 60 boards — did not make both their code of conduct policies and procedures publicly accessible online.[2]
These are not obscure administrative requirements. Codes of conduct set the foundation for how schools address violence, bullying, and student safety. When a board fails to implement — or even post — its code of conduct, parents are left without a clear understanding of the standards their children’s school is supposed to uphold, and without a defined path for reporting when those standards are breached.
Watch: Code of Conduct Failures
Anwar Knight of the Hold Schools Accountable Parent Network produced this brief overview of the audit findings and what they mean for parents across Ontario.
Watch: A Failing Grade — The Full Interview
In this in-depth conversation with Anwar Knight, School Board Research founder Elizabeth Lance walks through the audit methodology, the specific compliance gaps identified, and what the findings reveal about systemic patterns of non-compliance. The discussion covers how AI-assisted policy analysis was used to scale the audit across all 60 boards, what parents should expect from their local board’s code of conduct, and why transparency in governance documents is an equity issue.
What Parents Can Do
Every parent in Ontario has the right to access their school board’s code of conduct. If you cannot find it on your board’s website, that is itself a compliance gap. Here is what the evidence shows parents should look for:
Check whether your board’s code of conduct is publicly posted and accessible online. Under PPM 128, boards are required to make this document available to the school community.[1] If it is buried or absent, that is worth raising with your board.
Look for a clear reporting mechanism. The code of conduct should include a defined process for parents to report incidents — not just a general email address, but a structured pathway that identifies who receives reports, what happens next, and what timelines apply.
Ask about escalation. If your concern is not addressed at the school level, ask who the next contact is — the superintendent, the director of education, or another named person. PPM 128 does not require boards to publish an escalation route in their code of conduct, so many do not. Our separate review of bullying policies found that two-thirds of boards named no next step for a parent dissatisfied with the school’s response.[3]
Board-by-board findings will be published in our forthcoming Board Report Card, which is launching soon. In the meantime, parents are encouraged to request their own board’s code of conduct directly and to use the patterns described above as a starting point for informed conversations with their school communities.
Sources
[1] Ontario Ministry of Education, Policy/Program Memorandum 128: The Provincial Code of Conduct and School Board Codes of Conduct, effective September 1, 2024.
[2] School Board Research, PPM 128 Pilot Study — Selected Code of Conduct Clauses, 60 English-Language Ontario School Boards, review period June–August 2025. Statistics cited — 55 of 60 boards (92%) failing at least one mandatory requirement, 82% (49 of 60) lacking a communicated route for reporting unacceptable behaviour, and 18% (11 of 60) without publicly accessible code of conduct policies and procedures — are drawn from this audit.
[3] School Board Research, Bullying Prevention and Intervention (PPM 144): 2025 Compliance Pilot, 29 English-language Ontario school boards, documents collected June–August 2025. Two-thirds of boards named no escalation route for a dissatisfied parent.
School Board Research is an independent, evidence-based research initiative examining how Ontario’s 72 publicly funded school boards translate provincial safety mandates into local policy. For more on PPM 128 and other safe schools directives, visit our Safe Schools Policies page.
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