Audit
of
Employment Equity
July 2008
Audit of Employment Equity
Report Clearance Steps
Planning phase completed
Field work completed
Report Writing
Report sent for management response
Management response received
Report completed
Report presented to the External Audit Advisory Committee
Approved by the Deputy Minister
October 2007
January 2008
February 2008
March 2008
March 2008
March 2008
April 2008
July 2008
Prepared by Audit and Evaluation
Acknowledgments
The Audit and Evaluation Project Team, including Julie Clavet-Drolet, Lise Gravel and
led by Sophie Boisvert under the direction of Jean Leclerc, would like to thank those
individuals who contributed to this project and, in particular, departmental interviewees,
and specialists from other government departments, Central Agencies and the
Canadian Human Rights Commission, who provided insights and comments crucial to
this audit.
Original signed by:
__________________
Stephen McClellan
Chief Audit Executive
Environment Canada
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Table of Contents
EXECUTIVE SUMMARY ................................................................................................ iv
1 INTRODUCTION ..................................................................................................... 1
1.1
Background ..................................................................................................... 1
1.2
Scope and methodology .................................................................................. 1
2 FINDINGS AND RECOMMENDATIONS .................................................................. 2
2.1
Status of the Five Requirements from the Canadian Human Rights
Commission’s 2003 Report .......................................................................................... 2
2.2
Employment Equity Goals and Accountability .................................................. 5
2.2.1 Required representation rates ...................................................................... 5
2.2.2 Self-Identification of Designated Employees ................................................ 6
2.2.3 Identification of barriers to employment equity ............................................. 7
2.2.4 Accountability ............................................................................................... 8
2.3
Consultations, Communication and Training .................................................... 8
2.3.1 Consultations ............................................................................................... 8
2.3.2 Communication ............................................................................................ 9
2.3.3 Training ...................................................................................................... 10
2.4
Value for Money............................................................................................. 10
2.4.1 Resources dedicated to employment equity ............................................... 10
2.4.2 Comparison with Other Government Departments..................................... 11
2.5
Long-Term Commitments .............................................................................. 12
2.5.1 Outreach .................................................................................................... 12
2.5.2 Networks .................................................................................................... 12
2.5.3 Champion .................................................................................................. 13
3 CONCLUSION ....................................................................................................... 15
Appendix A - EE Audit Response April 10, 2008 .......................................................... 16
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EXECUTIVE SUMMARY
Environment Canada, as an employer, must comply with the Employment Equity Act. In
2003, the Canadian Human Rights Commission (the Commission) concluded that the
department was in compliance with the Employment Equity Act, provided that it
implemented the five requirements outlined in the Commission’s report. It is expected
that in 2008 the Commission will follow up to assess whether the department is meeting
those five requirements and whether it has made reasonable progress in implementing
its Employment Equity and Diversity Management Plan, in order to reach full compliance
with the Act.
In preparation for the Commission’s follow-up, a compliance and value-for-money audit
of employment equity was included in the 2007-2008 Audit and Evaluation Plan, as
approved by the departmental Audit and Evaluation Committee on April 18, 2007.
Objectives and Scope
The objectives of this audit were to assess the department’s current level of compliance
with the Employment Equity Act and related policies, regulations and guidelines, as well
as to assess the effectiveness, efficiency and economy of the department’s program
through a value-for-money audit.
The audit focused on the department’s employment equity representation rates, and on
the probable causes for not meeting the required representation rates. The audit results
are based on research, documentation analysis and interviews.
Conclusions
Women, Aboriginal persons and persons with disabilities are represented in the
departmental workforce at their availability level or at a higher level. However, the
department has not achieved its required representation rates for visible minorities. In
addition, Environment Canada has not fully implemented the Commission’s five
requirements, as outlined in its 2003 report.
It appears that, for various reasons, employment equity became less of a priority for the
department during the past few years. More specifically, interviews revealed that
managers had no specific employment equity objectives, making their performance in
that regard not measurable. It was also noted that communication with employees was
limited and could be diversified, and that more communication between the Employment
Equity section, managers and human resources specialists would be beneficial to the
department. In addition, training on diversity is no longer mandatory and there have
been less frequent consultations with stakeholders.
In 2005, the employment equity function was carried out by 2.5 full time employees at
the corporate level. In addition, employment equity also had a regional component
through the EE coordinators. However, during the departmental transformation, the
network of EE coordinators was less active than in previous years. In addition, one full
time employee within the Employment Equity unit was redirected to other human
resources priorities. Therefore, whereas in 2005 there was the equivalent of 2.5 full time
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employees working on employment equity issues and actions at the corporate level,
there is now 1.5 full time employees dedicated to the program.
It should be noted that the Department recently implemented a short-term EE Blitz to
reduce representation gaps within the Department. It focuses on staffing from
designated groups within programs and activities that are actively hiring. It is too early
to comment on the effectiveness of this initiative.
Possible consequences for not complying with the Employment Equity Act include,
ultimately, the Commission referring the Department to an Employment Equity Review
Tribunal.
Recommendation No. 1
The Assistant Deputy Minister, Human Resources Branch should:

develop a new employment equity plan that is in compliance with the
requirements of the Act; the plan should be realistic, with a focus on measurable
outcomes, and its implementation should be monitored. It should also define the
roles and responsibilities of the Human Resources Branch and of management.
The Assistant Deputy Minister, Human Resources Branch, should consider including the
following when preparing the Employment Equity Plan:
Self-identification and accountability:



periodically send out reminders to invite employees to self identify and ensure
that both the Human Resources Branch and managers periodically remind
employees of the importance of self-identification;
monitor the return of self-identification forms and conduct a follow-up when
forms are not returned; and
ensure that departmental representation rates and gaps are communicated to
management, and cascaded down to employees.
Consultations, communications and training:






ensure utilization of diversified communication channels, in order to increase the
effectiveness of communications; the information communicated should include
progress and issues, representation rates, available tools and best practices;
advise senior management to actively promote employment equity initiatives and
progress to their management teams and employees;
develop mechanisms to collaborate internally and reduce silos, such as
periodically including employment equity as an agenda item on the Human
Resources management meetings;
ensure that consultations resume;
ensure that employment equity training is available to all employees and
consider making it mandatory for managers; and
ensure that, as part of their new training plan, specific employment equity
training is mandatory for all human resources advisors.
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Outreach activities and Networks:



promote existing outreach activities across the department and provide advice
and assistance to branches in implementing outreach programs;
initiate, as soon as possible, a plan to replace the champion and provide the
Employment Equity section with the required support; and
with the support of the champion, use the full potential of the designated group
networks to communicate, consult and promote employment equity.
Recommendation No. 2
The Assistant Deputy Minister, Human Resources Branch should also:

conduct a new Employment Systems Review, as required by the Employment Equity
Act and Regulations.
Management Response
The Human Resources Branch agrees with the recommendations. Appendix A provides
the detailed work plan of the specific actions to be taken in response to the
recommendations, with objectives, timelines and Leads indicated.
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1 INTRODUCTION
1.1 Background
The Canadian government, as an employer, must comply with the Employment Equity
Act (hereinafter referred to as the Act). According to the Treasury Board Secretariat
Policy on Employment Equity, the department is responsible for implementing the
requirements of the Act.
The Canadian Human Rights Commission (hereinafter referred to as the Commission) is
responsible for the verification of the employers’ compliance with the statutory
requirements of the Act. In 2003, the Commission presented the results of its
employment equity compliance review of Environment Canada. The Commission
concluded that Environment Canada was in compliance with the statutory requirements
of the Act, provided that it implemented the Commission’s five requirements outlined in
the report. It is expected that in 2008, the Commission will follow up to assess whether
the department is meeting the five requirements and if it has made reasonable progress
toward implementation of its Employment Equity and Diversity Management Plan, in
order to reach full compliance with the Act.
As per sections 25 to 30 of the Act, should the department be found non-compliant, the
Commission will inform the department and negotiate a written undertaking from the
department to remedy the deficiencies. Should the department fail to comply with the
undertaking, the Commission may decide to issue a direction. Should the department
fail to comply with the Commission’s direction, the Commission may refer the
department to an Employment Equity Review Tribunal for remedial action.
In preparation for the Commission’s follow-up, a compliance and value-for-money audit
of employment equity was included in the 2007-2008 Audit and Evaluation Plan, as
approved by the departmental Audit and Evaluation Committee, on April 18, 2007.
1.2 Scope and methodology
The objectives of this audit were to assess the current compliance level of the
department with the Employment Equity Act and related policies, regulations and
guidelines, as well as to assess the effectiveness, efficiency and economy of the
program through a value-for-money audit.
In developing the audit methodology, the audit team contacted the Compliance Review
Manager at the Canadian Human Rights Commission to discuss the objectives of the
Commission’s upcoming review and the approach the Commission intended to take.
The Commission will assess the department’s progress in meeting the requirements of
the Act and the recommendations contained in the Commission’s report. The review will
focus on the following:

the achievement of employment-equity representation rates, and the reasons for
failing to achieve them, where applicable;
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Audit of Employment Equity


the increase in representation rates of designated groups; and
the implementation of the employment equity plan and actions related to the
designated groups, where representation has not been achieved.
Based on this new approach, the audit team decided to adopt a similar methodology and
scope. Therefore, the audit team did not focus on the 87 action items contained in the
2002-2005 Employment Equity and Diversity Management Plan, nor did the audit team
consider the Employment Systems Review and the Workforce Analysis. Rather, the
audit focused on the department’s employment equity representation rates, and on the
probable causes of failing to meet the required representation rates. The audit results
are based on research, documentation analysis and interviews. This report is structured
along the following lines of inquiries:
1.
2.
3.
4.
5.
Status of the Five Requirements of the Commission’s 2003 Report
Employment Equity Goals and Accountability
Communication, Consultation and Training
Value-for-Money Analysis
Long-Term Commitments
2 FINDINGS AND RECOMMENDATIONS
2.1 Status of the Five Requirements from the Canadian Human
Rights Commission’s 2003 Report
The Commission concluded in 2003 that Environment Canada was in compliance with
the statutory requirements of the Act, provided the department implemented the five
requirements outlined in the Commission’s report. The interviews conducted in this
audit and documentation provided to the audit team revealed the following with respect
to these five requirements:
Requirement No. 1. Environment Canada must provide the self-identification Question
and Answer Brochure to new and existing employees in the event of a staffing
action.
 Although no Question and Answer Brochure is provided with Environment
Canada’s Self-Identification Form, the form does contain some information
regarding self-identification and employment equity, and also provides a list of
contacts for more information. The department also has an employment equity
Web page that contains a series of questions and answers; however, the link to
the Web site is not provided on the self-identification form. It must also be
noted that, as mentioned by some interviewees, the self-identification form is
not systematically distributed to new employees. (Refer to Section 2.2.2 of this
report for further details on self-identification).
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Requirement No. 2. Environment Canada must implement the requirements related to
recruitment:
2.1 When managers are staffing positions on a casual basis, they must request the
referral of designated group candidates at 1.5 times their availability.
 Based on the interviews, it appears that individuals involved in staffing did not
comply with this requirement.
2.2 Managers are to be reminded of the extended staffing delegation and how it
should be applied.
 The audit team has evidence that the extended staffing delegation is being used.
However, the interviews provided evidence that not all managers are aware of
this tool. (provides managers with the authority to recruit under-represented
designated group members without competition in term or indeterminate
positions).
2.3 When managers are using their personal networks to find candidates, they must
ask for a referral of designated group candidates, at which point the extended
staffing delegation may be applied.
 Based on the interviews, no evidence was provided that interviewees use their
personal networks to find candidates from designated groups.
Requirement No. 3. Environment Canada must develop a plan to permit the
department to reach full physical accessibility.
 There is no department-wide plan to reach full physical accessibility.
Management informed the audit team that the Treasury Board Real Property
Accessibility Standards provides for exemptions and minor variations. In 1995,
Departments were required to be fully compliant with the standard. At the time,
EC exempted a number of facilities/sites from the standard including:
1. Remote locations;
2. Unattended monitoring stations;
3. Facilities where operational requirements preclude reasonable access by
persons with disabilities.
 Reporting to TB at the time indicated that the department was compliant with the
standard.
Requirement No. 4. Employees must be advised that all communication materials
relating to employment equity will be made available in alternate format upon
request, and Environment Canada must take additional steps to inform employees
about employment equity and disseminate various materials to staff using other
media formats.
 Based on the interviews: information is available in alternate format for
recruitment actions; dissemination of various employment equity materials was
not always done on a consistent basis; and the department is not using a
diversified communication strategy (refer to Section 2.3.2 of this report for further
details).
Environment Canada
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Environment Canada
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Requirement No. 5. Environment Canada must establish a formal mechanism to
consult with the non-unionized workforce as stipulated by the Act, and must consult
with the unionized workforce as required by the Act.
 Based on the information received during interviews and information provided by
the Employment Equity unit, the audit team has evidence that a formal
consultation mechanism was in place. However, because there was no
Employment Equity champion (hereinafter referred to as the champion) in place
for a six-month period (June 2006 to January 2007), consultations became less
active. With the appointment of the new champion, efforts were made in 2007
for consultations to resume (refer to Section 2.3.1 of this report for further
details).
At the time of the Commission’s review, the department was complying with the
requirement of the Act, Section 10, to have a plan in place. However, since 2006, the
department does not have an updated/approved plan that would meet this requirement.
As mentioned previously, non-compliance with the Act can have a significant
consequence for the department.
2.2 Employment Equity Goals and Accountability
2.2.1 Required representation rates
The department has achieved representation rates for women, Aboriginal people and
persons with disabilities at their availability level or at a higher level; however, the
department has not achieved its required representation rates for visible minorities,
which are still underrepresented by approximately 1.5%, or 89 individuals. Currently, in
the department, 705 visible minority members self-identified.
In addition, as per the Employment Equity Act, Part I, section 5, consideration must be
given to representation within occupational groups. The occupational categories are
clustered into six groups. They are: Executive; Scientific and Professional;
Administrative and Foreign Service; Technical; Administrative Support; and Operational.
In addition, the department includes Ministerial Staff for reporting purposes. The latest
workforce analysis, conducted on January 31, 2008, reveals the following:

Although representation of women has increased during the past 3 years, they
remain under-represented in the Executive and Technical categories.

Overall representation of Aboriginal persons has remained constant over the
past 3 years, with under-representation in the Executive category.

Overall representation of persons with disabilities has remained constant over
the past 3 years, with under-representation in the Scientific and Professional
categories.
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Audit of Employment Equity

Although representation of visible minorities has increased over the past 3
years, they remain under-represented in the Scientific and Professional,
Administrative and Foreign Service, Technical and Operational categories.
The following chart shows the number of representational gaps by occupational group.
Table 1.Representation gaps in Environment Canada
Number of individuals missing in each group
Women
Occupational
Group
Aboriginal
People
Persons with
Disabilities
Individuals
%
Individuals
%
2
1.7
5
4.1
Target met
Target met
Target met
Target met
Target met
Target met
Target met
Target met
11
Target met
Target met
Technical
39
3.5
Administrative
Support
Operational
Executive
Ministerial
Staff
Scientific and
Professional
Administrative
and Foreign
Service
Individuals
Visible
Minorities
%
0.4
Individuals
%
32
1.1
Target met
17
0.9
Target met
Target met
45
4.0
Target met
Target met
Target met
Target met
Target met
Target met
Target met
2
3.5
Source: Environment Canada Workforce Analysis, January 31st, 2008.
It should be noted that the department recently implemented a short-term strategy to
reduce representational gaps within the department. It focuses on staffing from
designated groups within programs and activities that are actively hiring. It is too early
to comment on the effectiveness of this initiative. A monitoring of the results of the blitz
should be conducted to assess the effectiveness of such a strategy.
2.2.2 Self-Identification of Designated Employees
As per the Act, Part I, section 9, every employer shall collect information and conduct an
analysis of its workforce, in order to determine the degree of the under-representation of
persons in designated groups in each occupational group. At Environment Canada, the
Employment Equity section is responsible for conducting this analysis. The analysis is
conducted at least once a year.
The Labour Market Availability rates are used to assess the degree of representation for
each of the designated groups; these rates are based on the Canadian census and are
provided to the department by the Treasury Board Secretariat. Once they are
communicated to the department, the Employment Equity unit compares the availability
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Audit of Employment Equity
rates with the departmental representation rates to identify possible gaps in the level of
representation.
The only means for the department to legally collect data on designated groups is
through self-identification of the employees. Only those employees who self-identified
can be counted as members of designated groups. The official representation rates
may not represent a true picture of the department’s actual representation rates, since
self identification is voluntary. That is why the department must actively encourage selfidentification throughout the organization on a continual basis.
The method used by Environment Canada to promote self-identification is by giving the
self-identification form to employees with every letter of offer at the time of appointment.
It is mandatory that all employees hired by the department complete the mandatory
sections of the form and return it, whether they choose to self-identify or not. Although
the return of the form is mandatory, no monitoring is conducted on the return rate, which
makes it impossible to assess the number of missing forms. Because some
interviewees said that when they were hired, the form was not given to them, it is
suspected that representation rates for the department may be underestimated,
therefore increasing the risk for the department of not being in compliance with the
Employment Equity Act. This inconsistency in the distribution of the self-identification
form may be due to the significant turnover and lack of training of staffing advisors, who
are responsible for including the form with the letters of offer. (Refer to Section 2.3.3 of
this report for further details regarding training.)
2.2.3 Identification of barriers to employment equity
Part I, section 9.(1)(b) of the Act states that an employer shall “conduct a review of [its]
employment systems, policies and practices, [...] in order to identify employment barriers
against persons in designated groups that result from those systems, policies and
practices”.
This analysis is called the Employment Systems Review and focuses on areas where
representation gaps have been identified in the workforce analysis. Although the Act
does not explicitly require employers to periodically conduct an Employment Systems
Review, the Treasury Board Secretariat Employment Equity Policy Guidelines stipulate
that departments have the obligation of “conducting an employment systems review (if
under-representation exists) and removing any barriers that may exist and that are not
authorized by law”.
Environment Canada conducted an Employment Systems Review in 2002, based on the
representation gaps identified in the workforce analysis of 2001. The fact that the
department is still facing similar representation gaps as it had in 2001 suggests that
either the Employment Systems Review was unsuccessful in identifying all the barriers
or that the action plan was not fully and consistently implemented. The Employment
Equity unit mentioned its intention to conduct a new Employment Systems Review in
April 2008 and the results of this audit suggest that this would be both timely and
relevant.
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Audit of Employment Equity
Fifty-nine recommendations resulted from the Employment Systems Review conducted
in 2002. The Employment Equity Plan developed to address those barriers and
recommendations included more than 87 actions, making it complex to implement and
to monitor. This should be taken into consideration when the new Employment Systems
Review is conducted and when the new Employment Equity plan is developed.
In the course of the audit, some interviewees mentioned that it may be difficult to
achieve required representation rates for persons with disabilities for some positions in
the Scientific and Professional category, due to the operational context and work
constraints such as field work, shift work and health and safety requirements. These
constraints make it more difficult to accommodate persons with disabilities. These
potential barriers should be considered in the new Employment Systems Review.
2.2.4 Accountability
As stated in the Treasury Board Secretariat Employment Equity Policy, the department
must “hold management at all levels accountable for the implementation of employment
equity by integrating employment equity objectives into managers' accountability
statements and performance assessments”.
During the interviews, it was mentioned that a few years ago, employment equity was
integrated into Regional Director Generals’ and Assistant Deputy Ministers’
accountability statements. However, the Inclusiveness Strategy, which replaced the
Employment Equity Plan in 2006, did not include specific performance indicators.
Although managers’ accountability statements and performance assessments do
contain the obligation to implement the departmental Human Resources Integrated Plan
- which includes a component on employment equity - managers have no specific
employment equity objectives. Therefore, their performance in regards to employment
equity is not measurable.
In addition, although representation goals and departmental progress are communicated
to senior management, they are not consistently cascaded down to all levels of
management and employees. This situation contributes further to the lack of
accountability, since some managers are not aware of where gaps exist or what they
should do in order to eliminate them.
2.3 Consultations, Communication and Training
2.3.1 Consultations
Section 15 of the Employment Equity Act requires an employer to consult with
employees and union representatives on the development, implementation and revision
of the employer’s employment equity plan, and on the assistance they could give with
respect to communication and implementation of employment equity in the organization.
The conduct of the interviews and a documentation review provided evidence that a
formal consultation mechanism was in place. Consultations with the unions were held
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Audit of Employment Equity
during Union-Management Consultation Committee meetings, as well as at the
Departmental Employment Equity and Diversity Management Consultative Committee.
The non-unionized representatives were also consulted through the Departmental
Employment Equity and Diversity Management Consultative Committee; this committee
brings together unions, senior managers, managers, designated group members and
youth networks, and regional employment equity coordinators. It was chaired by the
employment equity champion. However, due to other priorities during the departmental
transformation, and because there was no champion in place for a period of six months
(June 2006 to January 2007), consultations became less active. With the appointment
of the new champion, efforts were made in 2007 for consultations to resume. The
department is currently without a champion.
2.3.2 Communication
Section 14 of the Employment Equity Act requires an employer to provide information to
its employees about employment equity. The Treasury Board Policy outlines in more
detail that it is the responsibility of the Deputy Minister to communicate with employees
by distributing information regularly to all employees about employment equity initiatives
and progress, to use all available internal media, and to ensure that the information is
accessible to employees with disabilities.
During the interviews, it was noted that insufficient information is being communicated
regarding employment equity programs, objectives and achievements. Dissemination of
various employment equity materials was not always done on a consistent basis, and
the department is not using a variety of media forms to communicate. Also, there is
limited communication between the entities responsible for employment equity,
particularly between the employment equity group, human resources advisors and
managers. Rather, they tend to work in silos. There is little opportunity for those
implementing the policy to provide feedback to those providing oversight. This impedes
effective monitoring and prevents ongoing adjustments to the employment equity
strategy.
Information gathered during the interviews suggests the following communication
issues:

There are many tools and best practices available to assist in the implementation of
employment equity; however, not all employees, managers and human resources
advisors are made aware of their existence. For instance:
o Some managers are not aware of the possibility to recruit under-represented
designated group members without competition in term or indeterminate
positions from outside or within the public service.
o Some employees are not aware of the Adaptive Computer Technology
program, developed and maintained by the department, which assists
persons with visual, mobility, or sensory impairments to use a computer that
reduces or eliminates the barriers presented by a standard computer.
o The Objective Eye, designed to assist managers and human resources
advisors in finding qualified selection board members from designated
groups, is not sufficiently promoted and is therefore underutilized.
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Audit of Employment Equity


Information is generally communicated through e-mails and/or posters but tends to
be limited to advertisements for employment equity events, such as the Aboriginal
week and the women’s week. As well, due to the volume of e-mails received daily, it
may not be the most effective way to communicate with employees.
The employment equity departmental Web site provides a variety of information and
tools and should be publicized to a greater extent.
2.3.3 Training
Training is an important component of an awareness strategy to promote employment
equity and diversity and can contribute to improving the department’s performance.
Information gathered during interviews with staff revealed the following issues related to
training:


Diversity training is no longer mandatory for managers; as a result, some managers
are not fully aware of the tools available to assist them in hiring and integrating
designated group members. However, the Employment Equity section mentioned
that the new departmental Employment Equity Plan currently being developed will
include mandatory training on employment equity for all managers and supervisors.
In the past, human resources advisors received training on employment equity and
diversity as part of their certification. Since changes were made to the Public Service
Employment Act in 2003, the certification program is no longer in place.
Furthermore, not all new human resources advisors have the necessary expertise or
experience to help managers find innovative ways to hire designated group
members. This is exacerbated by the high turnover rate in human resources staff.
The Human Resources Branch is planning to include mandatory training on
employment equity for human resources advisors as part of their development plan.
According to those interviewed communication, consultation and training are crucial in
helping employees and managers to understand the importance of employment equity
and diversity, to eliminate negative perceptions and to build an inclusive workforce.
Less sensitivity and awareness to diversity may have an impact on employees, clients
and the public. It could limit Environment Canada’s ability to hire and retain designated
group members. Good communication, consultation and training regarding employment
equity can be a key factor in the success of the department as it seeks to achieve its
employment equity goals and specific targets.
2.4 Value for Money
2.4.1 Resources dedicated to employment equity
The employment equity unit had a forecast budget of $74,270 for the 2007-2008 fiscal
year. Part of this amount was allocated to the activities of the champion ($20,000) and
to the accommodation fund ($50,000). The remaining money was dedicated to travel
($4,270). The amount given to the champion was for professional services. The
accommodation fund was for expenses related to equipment considered non-standard
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Audit of Employment Equity
purchases, such as magnification devices, screen-magnification software, speechrecognition technology, etc. Travel expenses were for members of the employment
equity team to attend conference, courses, off-site meetings, etc.
In 2005, the employment equity function was carried out by 2.5 full time employees at
the corporate level. In addition, employment equity also had a regional component
through the EE coordinators. However, during the departmental transformation, the
network of EE coordinators was less active than in previous years. In addition, one full
time employee within the Employment Equity unit was redirected to other human
resources priorities. Therefore, whereas in 2005 there was the equivalent of 2.5 full time
employees working on employment equity issues and actions at the corporate level,
there is now only 1.5 full time employees dedicated to the program.
A comparison of the level of resources invested in employment equity versus the
representation rates by designated group members was conducted for the last five
years. This analysis did not find any correlation between the representational rates and
the level of resources. Value for money is difficult to assess in the context of this audit,
as the audit findings cannot determine whether implementation of employment equity
requirements and results would be different with more resources. The value–for- money
analysis cannot conclude whether additional resources allocated to the employment
equity unit would result in an increase in representation rates. However, the other audit
findings reveal that there are other avenues that require attention in order to implement
employment equity.
2.4.2 Comparison with Other Government Departments
In order to conduct a comparative analysis with other government departments, the
audit team obtained information from the Canada Public Service Agency about how
other departments were performing with regard to employment equity. The analysis
focused on five departments that were identified as having a similar scientific mandate
and a comparable number of employees. The Canada Public Service Agency confirmed
that Environment Canada is performing in a relatively similar fashion to the five specified
departments with respect to the representation of women and Aboriginal people, when
compared with their respective Workforce Analysis. However, with respect to persons
with disabilities and especially persons from visible minorities, Environment Canada is
not performing as well as the other five specified departments. With regard to visible
minority representation, of the five departments, Environment Canada is one of the two
that are not reaching their required representation rates.
The audit team also contacted these same five departments to obtain information on the
number of employees dedicated to employment equity within each organization. The
results are highly variable from one department to another, the lowest being one fulltime employee and the highest being five full-time employees.
Due to the fact that the Canada Public Service Agency provided only the relative
performance of Environment Canada, without providing the performance of other
departments, it was impossible for the audit team to compare the number of employees
allocated to employment equity functions with the level of representation achieved by
Environment Canada
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Audit of Employment Equity
the departments. The audit team also consulted the Annual Report on Employment
Equity in the Public Service of Canada 2005-2006, submitted to Parliament by the
Canada Public Service Agency. This report presents representation rates for every
department, in absolute terms, without including the availability rates for each one; it
was therefore impossible to use the data to perform a comparative analysis.
2.5 Long-Term Commitments
2.5.1 Outreach
Outreach activities have been performed by some branches to support employment
equity and diversity, some of which are innovative and could be considered best
practices. However, these initiatives are not communicated across branches, and
human resources advisors are not fully aware of them. There would be value in
disseminating the information across the department, in order to provide ideas and
examples for other managers. The following examples of outreach activities were
identified during the audit interviews:


The Meteorological Services of Canada actively promotes career opportunities at
high schools to encourage women, Aboriginal persons and persons from visible
minorities to pursue their studies and a career in that field.
The Meteorological Services of Canada is working with Human Resources and
Social Development Canada to develop with the Arctic College a program in
meteorology designed specifically to attract Aboriginal persons.
2.5.2 Networks
Although networks of designated groups are not a legal requirement of the Employment
Equity Act, they are, however, an important communication, consultation and support
mechanism. Currently, there is a network for three out of the four designated groups in
the department; there are networks for visible minorities, for Aboriginal persons and for
persons with disabilities, the most active being the visible minorities network. The
department does not have a national network for women, although there is a Women in
Science and Technology Committee.
Since the departmental transformation, and due to other priorities, the networks for the
designated groups have not been used to their full potential, and have also experienced
decreased participation. There has been a decline in communication and consultation
between the designated groups’ networks and the Human Resources Branch, as well as
between the networks and their members. The leaders of some networks noted that
they were receiving more information from their regional Federal Councils, from the
interdepartmental employment equity national networks or from Environment Canada’s
Visible Minorities’ Networks than from the department’s Human Resources Branch.
There is currently no budget for the networks, although the Human Resources Branch
does pay for network conference calls. Some interviewees also indicated that
managers have little financial flexibility to allow their employees to participate in
networks.
Environment Canada
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Audit of Employment Equity
2.5.3 Champion
Although it is not a requirement of the Act, having a champion who is a senior manager
and comes from a program area helps to promote employment equity, break silos and
enable actions. Environment Canada had, until recently, an employment equity
champion. However, the former champion has now left the department (please refer to
Section 2.3.1 of this report).
Recommendation No. 1
The Assistant Deputy Minister, Human Resources Branch, should:

develop a new employment equity plan that is in compliance with the
requirements of the Act; the plan should be realistic, with a focus on measurable
outcomes, and its implementation should be monitored. It should also define the
roles and responsibilities of the Human Resources Branch and of management.
The Assistant Deputy Minister, Human Resources Branch, should consider including the
following when preparing the employment equity plan:
Self-identification and accountability:



periodically send out reminders to invite employees to self identify and ensure that
both the Human Resources Branch and managers periodically remind employees of
the importance of self-identification;
monitor the return of self-identification forms and conduct a follow-up when forms
are not returned; and
ensure that departmental representation rates and gaps are communicated to
management and cascaded down to employees.
Consultations, communications and training:






ensure utilization of diversified communication channels, in order to increase the
effectiveness of communications; the information communicated should include
progress and issues, representation rates, available tools and best practices;
advise senior management to actively promote employment equity initiatives and
progress to their management teams and employees;
develop mechanisms to collaborate internally and reduce silos, for example
periodically including employment equity as an agenda item for Human Resources
management meetings;
ensure that consultations resume;
ensure that employment equity training is available to all employees and consider
making it mandatory for managers; and
ensure that, as part of their new training plan, specific employment equity training is
mandatory for all human resources advisors.
Outreach activities and networks:
Environment Canada
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Audit of Employment Equity



promote existing outreach activities across the department and provide advice and
assistance to branches in implementing outreach programs;
initiate, as soon as possible, a plan to replace the champion and provide the
Employment Equity section with the required support; and
with the support of the champion, use the full potential of the designated group
networks to communicate, consult and promote employment equity.
Recommendation No. 2
The Assistant Deputy Minister, Human Resources Branch, should also:

conduct a new employment systems review, as required by the Employment Equity
Act and Regulations.
Management Response
The Human Resources Branch agrees with the recommendations. Appendix A provides
the detailed work plan of the specific actions to be taken in response to the
recommendations, with objectives, timelines and Leads indicated.
Environment Canada
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Audit of Employment Equity
3 CONCLUSION
The objectives of this audit were to assess the current compliance level of the
department in fulfilling its obligations with respect to the Employment Equity Act and
related policies, regulations and guidelines, as well as to assess the effectiveness,
efficiency and economy of the program through a value-for-money audit.
The audit was based primarily on document reviews and interviews with managers,
designated group members, and human resources specialists.
For various reasons, employment equity has become less of a priority in the past few
years. With the upcoming follow-up review to be conducted by the Canadian Human
Rights Commission, employment equity needs to be more of a priority. The recent
initiative to hire designated group members in program areas actively hiring is a good
example of the kind of concrete actions needed. The value-for-money analysis cannot
conclude whether or not additional resources allocated to the employment equity unit
would result in an increase in representational rates. The other audit findings reveal that
there are other avenues that require attention in order to implement employment equity.
However, to comply with the Act, employment equity needs ongoing attention
throughout the department. Clearer and more deliberate accountabilities along with
effective monitoring would be important mechanisms for achieving this. In addition,
communication needs to be strengthened. Employees should receive regular updates
through a variety of media and managers and human resource specialists need to make
sure that employment equity is a subject of regular communication between themselves
and employees. Innovative practices should be made known and promoted,
consultations should resume, and training should be increased. A new champion should
be nominated as soon as possible, in order to help promote employment equity and to
support employment equity activities.
In our professional judgment, sufficient and appropriate audit procedures have been
conducted and evidence gathered to support the accuracy of the conclusions reached
and contained in this report. The conclusions were based on a comparison of the
situations as they existed at the time of the audit against the audit criteria.
Environment Canada
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Audit of Employment Equity
Appendix A Employment Equity Audit Response
April 10, 2008
Management Response: The HR Branch agrees with the recommendations of the Audit. The DG Corporate HR Programs has the overall accountability within the
HR Branch for addressing the recommendations. Below is a workplan of specific actions to be taken with objectives, timelines and Leads.
Recommendation 1: Preparation of an Employment Equity (EE) Plan
Start
Strategies
Expected
Date
Completion
CHRC
Requirements
Leads
Spring 2008
-Appoint a new champion for EE
Completed
Consultation
Deputy Minister
Spring 2008
Develop and implement Communications Strategy
- Announcement of Champion
- Self-Identification Awareness campaign.
- Publish EE Accommodation Policy
- General awareness
Spring 2008
Collection of workforce
information
HR Branch in consultation with Communications
Spring 2008
Spring 2008
Spring 2008
Spring 2008
Develop a learning and development strategy
- Human Resource Advisors
- Managers/Employees
Gaps to be confirmed and addressed through current
HR Planning process
- Evaluate impact of current EE Blitz
- Branch Heads to identify targets
-Targeted recruitment campaigns where appropriate
Establish process to ensure that all employees receive
and complete self-identification and calculate return
rates.
Conduct analyses on share of recruitment, promotion,
terminations and clustering.
Environment Canada
EE Plan
HR Branch
Spring 2008
Workforce Analysis
Branch Heads
Employment equity targets to be set as part of annual HR plans by
Branch Heads, supported by HR Branch
Spring 2008
Collection of workforce
information
-HR Branch
-Return rate to be monitored and special campaigns conducted if
required
Summer 2008
Workforce Analysis
HR Branch
Share analysis to be part of the ongoing monitoring of EE Plan
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Audit of Employment Equity
Start
Date
Strategies
Expected
Completion
CHRC
Requirements
Leads
- Report to EMC biannually and Plan to be readjusted as required.
Spring 2008
Fall 2008
Consultation
EE champion, supported by HR Branch
Monitor progress of EE Plan – especially initiatives that address
barriers and findings of ESR. Readjust Plan as required.
Summer 2008
Develop and implement consultation plan
- Unionized employees
- Non-unionized workforce
- EE Networks/Advisory Committee
-First meeting of the advisory committee on EE
Fall 2008
Consultation
-EE Champion supported by HR Branch
Ensure regular meeting and renew membership as require
Summer 2008
-Establish process to ensure all records are kept to date
Fall 2008
EE records
Summer 2008
- ongoing implementation of communication strategy,
including awareness strategy for employees, managers
and HR advisors
Winter 2008
Information about EE
-HR Branch
Monitor on a regular basis
-HR Branch supported by communications
Monitor communication strategy and readjust if require
Spring 2008
Fall 2008
Spring 2009
Employment systems
review
EE Plan
-HR Branch
-HR Branch supported by champion
-HR Branch supported by Champion, EE Committees, Advisory
Committee and Communications
Fall 2008
-Hire consultant
-Analysis of report
- Based on results of Employment Systems Review and
updated gap analysis, develop new plan including:
 positive policies and practices
 special measures
 Accommodation
 Measures to eliminate barriers identified in ESR
 Timetables and assigned responsibilities
 Short-term and Long-term numerical goals for
hiring and promotions
-Monitor and Report to EMC
Quarterly starting
Spring 2009
Implementation and
monitoring of EE Plan
Fall 2008
-Establish process for revision
Spring 2009
Periodic review and
revision of EE Plan
-Monitor Plan to Monitor Plan on an annual basis to ensure
reasonable progress and report to EMC annually. Readjust Plan
based on the analysis results and policy changes as required.
-Review Plan and readjust based on the analysis results and policy
changes if required
Recommendation 2: Conduct Employment Systems Review
Spring 2008
Fall 2008
Fall 2008
Environment Canada
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