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 late 2024, School Board Research completed a systematic audit of 60 English-language publicly funded school boards in Ontario, evaluating their compliance with PPM 128’s core requirements for codes of conduct.[2] The findings were striking: 55 out of 60 boards — more than 90% — were missing at least one mandatory element.[2] Over half lacked a defined reporting mechanism for parents.[2] Roughly two-thirds had no clear escalation route for unresolved concerns.[2] And approximately one in four boards did not make their code of conduct policies publicly accessible online.[2]
Five boards demonstrated zero compliance across the key criteria examined: the Bruce-Grey Catholic District School Board, Greater Essex County District School Board, London District Catholic School Board, Simcoe Muskoka Catholic District School Board, and the Toronto Catholic District School Board.[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, the code of conduct should outline next steps — whether that is the superintendent, the director of education, or another defined contact. Over half of the boards audited lacked this clarity.[2]
The full audit results, including board-by-board findings, are available on the Safe Schools Policies page of this site. Parents are encouraged to review their own board’s standing and to use the findings 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 Compliance Audit of 60 English-Language Ontario School Boards, completed late 2024. All statistics cited — 55/60 boards non-compliant, over half lacking reporting mechanisms, two-thirds without escalation routes, one in four without publicly accessible codes of conduct, and the five zero-compliance boards — are drawn from this audit.
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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