HomeMy WebLinkAboutP-2023-02648 Cornish and Beattie 24-10-21 DecisionPublic Service
Grievance Board
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180 Dundas St. West
Toronto, Ontario M5G 1Z8
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Commission des
griefs de la fonction
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Tél. : (416) 326-1388
PSGB# P-2023-02648; P-2023-02650
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Cornish & Beattie Complainant
- and -
The Crown in Right of Ontario
(Ministry of the Solicitor General) Employer
BEFORE Brian Smeenk Chair
FOR THE
COMPLAINANTS
Samantha Cornish
Roderick Beattie
FOR THE EMPLOYER Peter Dailleboust
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING
September 11, 2024
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DECISION
[1] The Complainants, Samantha Cornish and Roderick Beattie, were both
Sergeants at the Toronto South Detention Centre. It is operated by the Ministry of
the Solicitor General (“the Employer”). In these applications under The Public
Service of Ontario Act, 20061, the Complainants challenge their treatment in
relation to the Ministry’s restructuring of certain classifications, including the
Sergeant position.
[2] While filed as individual applications, as they are fundamentally the same, they
have been heard and argued together.
[3] In a decision dated June 7, 2024 (“the “Preliminary Decision”)2, I dismissed the
Employer’s preliminary objections to the Board’s jurisdiction to hear these
applications. The merits were then argued based on agreed facts and documents
admitted on consent. On the agreement of the parties, any issue of remedy will
be dealt with separately. This decision therefore deals with the merits of both
applications.
THE ISSUES IN THESE COMPLAINTS
[4] In their earlier, written submissions on the jurisdictional issue, the Complainants
helpfully summarized what they are complaining about. They boiled their
complaints down to three points, which I will paraphrase here:
a. The Employer reneged on and violated an agreement it made with both
Complainants when they each responded to the Employer’s letter dated
January 30, 2023 by making a “final and binding” election to remain in
the Sergeant classification and then be reclassified as Correctional
Supervisor, i.e. Corporal. (These titles have been used interchangeably.
For ease of reference, I will generally use the title “Correctional
Supervisor”);
b. They were required to compete in an unfair process for the Correctional
Supervisor position, a newly-established position in the bargaining unit
represented by the Ontario Public Service Employees’ Union
(“OPSEU”); and
c. The entire process of the organizational restructuring since January
2023 was not honest, transparent or governed by integrity, authenticity
1 S.O 2006, c.35, Sched. A
2 Now reported as Cornish & Beattie v Ontario (Solicitor General), 2024 CanLII 62864 (ON PSGB)
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or demonstrated accountability, thus violating various Employer policies
including its Employment Policy, Code of Conduct and Professionalism,
and a document entitled, “Operational Leadership Behaviours.”
[5] Consistent with the Preliminary Decision, the issue before me is therefore
whether the Employer breached the existing terms and conditions of the
Complainants’ employment, including the requirement that those terms and
conditions be administered and applied reasonably, in good faith and not
arbitrarily, in any of the ways which they allege.3
CONCLUSION
[6] For the reasons that follow, I have concluded that the complaints succeed
in part, in relation to the Complainants’ first and third arguments.
THE FACTS
[7] The “Background Facts” were outlined in the Preliminary Decision as follows:
BACKGROUND FACTS
[10] The relevant facts are not in dispute. For the sake of clarity and completeness I
will expand to some extent on the statements of fact that the parties have agreed upon
by referencing other facts set out in the documents admitted into evidence on consent
[11] Protracted litigation occurred before the Ontario Labour Relations Board
(“OLRB”) in respect of efforts by the Public Service [Alliance] of Canada (“PSAC”) to
represent Sergeants in the Employer’s Corrections division. The OLRB ruled[2] that if
Sergeants were deemed not to be managers pursuant to the traditional management
function test, then either OPSEU or the Association of Management, Administrative and
Professional Crown Employees of Ontario (“AMAPCEO”) must represent those positions
as a result of restrictions within the Crown Employees Collective Bargaining Act, 1993.
[12] On February 24, 2022, the GSB issued the decision of Arbitrator Brian McLean
(“McLean Decision No. 1”). The arbitrator found that AMAPCEO had relinquished its
bargaining rights for the Sergeant and Staff Sergeant cadre. He found that any such
rights were assumed by OPSEU as the bargaining agent for all employees employed at
correctional institutions.
[13] The issue of whether the Sergeant position was incorrectly excluded from the
OPSEU bargaining unit for being supervisory or managerial, was left for future
3 See paragraphs 30, 39. 46 and 51 of the Preliminary Decision.
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determination. Arbitrator McLean referred the matter back to the Employer and OPSEU
to jointly address.
[14] On May 5, 2022, the Employer announced that it had begun an organizational
review of the supervisory and management functions within the correctional system, as a
response to McLean Decision No. 1.
[15] On November 2, 2022, the Employer announced the result of the organizational
review. It advised staff of a restructuring of the management level, introducing a
supervisory level within the Institutional Services Division of the Employer. More
particularly, the Employer stated that, “In this new structure, the current Sergeant rank
will no longer be utilized, and the existing responsibilities will be shared by a new
position, the Correctional Supervisor, and a strengthened Staff Sergeant complement.”
[16] On December 14, 2022, the allocation of Staff Sergeant and Corporal (I.e.
Correctional Supervisor) positions was announced. All together there had been 620
Sergeant and Staff Sergeant positions, out of which 572 were Sergeant and 48 Staff
Sergeant positions. 572 Sergeant positions were eliminated, and the Staff Sergeant
positions were inflated from 48 to 438. 182 Corporal positions were created within the
OPSEU bargaining unit.
[17] On January 30, 2023, “Option Letters” were sent out to Sergeants asking them to
choose between being assigned to a Staff Sergeant or a Corporal position. They also
had the option to resign or retire from the Ontario Public Service. They were given
twenty business days to make their decision.
[18] In their election packages, the Complainants were required to check, sign and
date one of the three options. Each option was expressly stated to be “FINAL AND
BINDING”. (emphasis in the original). “Option1” was worded as follows:
I elect to remain in my Sergeant position which I understand will
be reclassified to a Correctional Supervisor position in the OPSEU-
COR bargaining unit at Toronto South Detention Centre. I understand
that this selection is FINAL AND BINDING
.
[19] At the bottom of the election form, the following passages appear:
“If you do not respond to this letter, you will be deemed to have selected
Option 1 (elect to be reclassified to a Correctional Supervisor position in the
OPSEU-COR bargaining unit at Toronto South Detention Centre).
All elections at Toronto South Detention Centre will be considered aggregately to
ensure that operational needs of each institution are met. Effective dates of new
assignments will be determined by the Ministry at a future date.
(emphasis in the original)
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[20] Both Complainants chose or were deemed to have chosen Option 1. Ms. Cornish
signed and dated her option form February 27, 2023 and submitted it. Ms. Beattie did
not and received a letter dated March 6, 2023 from the Employer stating in part as
follows:
Accordingly, you have been deemed to have selected Option 1 (elect to be
reclassified to Correctional Supervisor position in the OPSEU-COR
bargaining unit at Toronto South Detention Centre).
The effective date of this change will be communicated to you at a later
date.
[21] On June 27, 2023, the GSB issued another decision of Arbitrator McLean
(“McLean Decision No. 2”). It dealt with OPSEU’s contention that the Employer was in
violation of its collective agreement when it purported to directly assign individuals
including Sergeants into the newly-created Corporal position. Arbitrator McLean ruled
that the Employer had no right to do so and upheld OPSEU’s grievance. The Employer
was required to respect the job posting provision of the OPSEU collective agreement,
which would enable OPSEU members to apply for the new positions along with the non-
union Sergeants.
[22] By way of letters to the Complainants dated October 31, 2023, the Employer
announced that no choice between the two options would be available to the Sergeants
anymore. It was no longer able to offer the Corporal position in the OPSEU bargaining
unit to those who had opted for that. The Complainants and other Sergeants were told
that, while they could compete for the Corporal positions through the competitive
process, if there were no such positions available to an individual, they would be
automatically reclassified as a Staff Sergeant in their home institution. The precise
wording of the relevant part of the letter is as follows:
As a result of the above-noted GSB decision, the Ministry is unable to
reclassify you to the Corporal position in the OPSEU-COR bargaining unit.
As such, regular (classified) permanent Sergeants (M07) that previously
elected, or were deemed to have elected, to be reclassified to a Corporal
position, will now remain as managers and will be directly assigned to the
Staff Sergeant (M08) position at their home institution upon implementation
of the new structure.
If you remain interested in working as Corporal, please be advised that a
job advertisement for vacant positions will be posted in the near future and
you are welcome to apply and compete through that process. Offers for
permanent Corporal positions will be made prior to implementation of the
new organizational structure. Please see the attached poster regarding
resume and interview prep sessions offered through the Strategic Business
Unit.
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[23] That was the status of the situation at the time the Complainants filed their
respective applications in December 2023. However, both Complainants applied for the
Corporal positions through the competitive process as the October 31 letter had invited
them to do. Both were successful and now occupy that position.
[Footnotes omitted.]
[8] Certain of those background facts must be expanded upon because of their
relevance for the parties’ submissions on the merits.
[9] After the Employer announced the result of its organizational review on
November 2, 2022, OPSEU advised the Employer of a number of objections to
the latter’s plans. The parties had a meeting on November 3, 2022. By letter
dated December 14, 2022 (coincidentally the same day the Employer announced
the allocation of new positions in each of the classifications affected), OPSEU
stated that it was confirming the objections discussed at the meeting of
November 3. The letter included its objection to the Employer’s stated plan to
directly assign non-union staff (such as the Complainants) to the new unionized
position. The letter states:
4. The Ministry’s intention to directly assign excluded staff to the
new Correctional Supervisor positions without a posting or
competition is a violation of the collective agreement. Hundreds
of bargaining unit members have an interest in those new
bargaining unit positions and their contractual right to apply for
the positions must be respected.
[10] Several grievances were filed by OPSEU on this issue and proceeded to a
hearing before Arbitrator Brian McLean on May 12, 2023. The Complainants,
and to my knowledge all other Sergeants who might be interested in the matter,
were not notified by the Employer about OPSEU’s objections, the grievances or
the arbitration hearing. They were not notified that their interests might be
affected. Nor were they advised whether they might seek to participate in the
arbitration.
[11] In the interim, in April 2023 there was a posting for the position of Correctional
Supervisor. It closed on May 10. While the precise results of that posting are not
before me, it is not disputed that some appointments to the Correctional
Supervisor position resulted from it. Neither Complainant applied. It is agreed that
the Complainants saw no need to do so, due to the elections they had made.
Furthermore, the evidence shows that Ms. Cornish was advised by the Employer
in May 2023 to pick up her Correctional Supervisor uniform epaulets.
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[12] Arbitrator McLean then issued his decision on this issue on June 27, 2023
(“McLean Decision No. 2”)4, upholding the grievances. He agreed with OPSEU’s
contention that the Employer was in violation of its collective agreement when it
purported to directly assign individuals including Sergeants into the newly-created
Correctional Supervisor position.
[13] The Complainants were not notified by the Employer about McLean Decision No.
2 until October 31, 2023. Nor were they notified until then as to the Employer’s
stance regarding the decision or how it might affect the elections they had made
to take up the Correctional Supervisor position. On October 31 the Employer
advised the Complainants that the Correctional Supervisor position which they
had irrevocably elected was no longer being offered to them. As noted in the
Background Facts above, they were advised that they would have to compete for
such positions through a competitive process that included union members. The
Complainants were told that, if they did not successfully bid for another position,
they would automatically be reclassified as a Staff Sergeant instead. This was a
position that neither Complainant wanted.
[14] In the end, both Complainants applied in response to a second posting of
Correctional Supervisor positions, in November 2023. While they did not know
what the outcome would be when they initiated these applications in December
2023, both Complainants were ultimately successful in obtaining that position in
their home institution.
ANALYSIS AND DECISION
The Complainants’ First Argument – Final and Binding Elections
[15] As outlined above, the Complainants’ first argument is that the Employer
breached their terms and conditions of employment when it reneged on the
agreement it made with them when they each made a “final and binding”
election. They had elected to remain in the Sergeant classification and then be
reclassified as Correctional Supervisor. Ms. Cornish argues that a reasonable
and objective reading of the election form dated January 31, 2023 that she
submitted, means that it was final and binding for both parties. The form did not
advise her to obtain legal advice. She clearly reached a contractual agreement
with the Employer in making her irrevocable election. It would be unconscionable
to interpret the form or agreement in a manner that allows the Employer to walk
away from it, she argues. Similarly, Mr. Beattie argues that he fully expected his
4 Ontario Public Service Employees’ Union v Ontario (Ministry of Children, Community and Social
Services and the Solicitor General), 2023 CanLII 61433 (ON GSB)
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election to be honoured. He submits that the Employer’s reneging on the “final
and binding” election, constitutes a breach of contract.
[16] The Employer argues that the election forms given to the Complainants did not
constitute binding offers of jobs in the Correctional Supervisor position. Rather,
the Employer sought to know how many Sergeants wanted to choose each
option: the Correctional Supervisor position; the Staff Sergeant position; or the
resignation/retirement option. The election was intended to be binding on the
employees so that the Employer had a firm understanding as to who chose each
option. The Employer argues that the wording of the form makes it clear that it
retained flexibility regarding placement of the Sergeants whose jobs would be
disappearing, where it stated as follows:
All elections at Toronto South Detention Centre will be considered
aggregately to ensure that operational needs of each institution are met.
Effective dates of new assignments will be determined by the Ministry at a
future date.
[17] The Employer argues that the clear intention of the election form was to provide
options to the employees, not to enter into a firm commitment by it to assign any
particular job to the individual making the election.
[18] In my view, the Complainants’ interpretation of the election forms must prevail.
The parties thereby entered into binding agreements regarding the jobs into
which the Complainants would be assigned, if not when that would be effective.
The Employer thus later breached those contractual agreements. I come to this
conclusion for several reasons.
[19] The first reason is the plain meaning of the language of the election letter. It
prefaces the description of the three options by saying, “… Sergeants at Toronto
South Detention Centre will have the following three (3) options….” For those
electing Option 1, as did the Complainants, this offer was unqualified. It simply
stated: “Elect to remain in the Sergeant position and be reclassified to a
Correctional Supervisor position in the OPSEU-COR bargaining unit.” Consistent
with this, the part of the form checked and signed by Ms. Cornish said, “…I
understand this selection to be FINAL AND BINDING.” In the case of Mr. Beattie,
who did not sign and return the form, it advised him: “If you do not respond to this
letter, you will be deemed to have selected Option 1 (elect to be reclassified to a
Correctional Supervisor position…”.
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[20] There was no indication in the form that “final and binding” only bound the
employees and did not bind the Employer. As Ms. Cornish argues, an objective
reading of the election form leads one to the conclusion that it was final and
binding on both parties.
[21] The Employer argues, however, that the following paragraph in the election form
gave it flexibility and meant that it was not bound to assign those who chose
Option 1 to the Correctional Supervisor position. It argues that this paragraph
means the Complainants had no right to the job they elected:
All elections at Toronto South Detention Centre will be considered
aggregately to ensure that operational needs of each institution are met.
Effective dates of new assignments will be determined by the Ministry at a
future date.
[22] I do not agree with this Employer argument. On a plain reading, the quoted
paragraph does not say that the Employer is not bound to fulfilling the employee’s
election. It says that the elections will be considered aggregately to ensure that
operational needs are met. It then speaks of the effective dates being determined
by the Employer. The clear implication is that the Employer’s operational needs
would drive the effective dates of the new assignments having regard to the
aggregate results. There is no inference that operational needs or any other
factor would allow the Employer to resile from the “final and binding” offer of the
Employer and election of the employee. This is reinforced by the letter sent to
Mr. Beattie dated March 6, 2023, advising him that he had been deemed to have
selected Option 1 (elect to be reclassified to the Correctional Supervisor
position). It goes on to say, “The effective date of this change will be
communicated to you at a later date.” While the date was a moving target, there
was no suggestion that the Employer might resile altogether from the parties’
agreement.
[23] Finally, the evidence that Ms. Cornish was advised by the Employer to pick up
her Correctional Supervisor uniform epaulets in May 2023, is relevant. It provides
confirmation that management understood her election to be effective and
binding at that point in time.
[24] The Employer further argues that the only reason that the Complainants’
elections were not fulfilled was the unexpected outcome of McLean Decision No.
2. This was beyond the Employer’s control. The election form allowed and indeed
required the Employer to resile from its intended direct assignments of Sergeants
into the Correctional Supervisor position.
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[25] I do not agree with this submission. In addition to the above reasons, while the
outcome of McLean Decision No. 2 may have been unexpected by the Employer,
that does not affect the issue of whether it had entered into binding agreements
with the Complainants. If the Decision made it impossible for the Employer to
honour such agreements for a period of time or at all, it must bear the
consequences of such a breach, not the Complainants.
[26] The Employer further argues that even if the elections are found to have created
new terms and conditions of employment (as I find they have), the Employer is
entitled to unilaterally change them. It was not obligated to allow the
Complainants and others to make the elections in the first place. It could thus
remove those options. This is what it did, in response to McLean Decision No. 2.
The Board cannot prevent the Employer from making such changes to terms and
conditions of employment, the Employer argues.
[27] In my view, however, it is not this Board that is preventing the Employer from
changing terms and conditions of employment. It is the Employer that made a
final and binding commitment. While it may have the right, generally, to change
terms and conditions of employment of non-union employees, it cannot resile
from a binding agreement without bearing any responsibility for the
consequences. As noted in the Preliminary Decision at para. 34, the Board has
found in the past that a breach of a promise to appoint a public servant to a job
may constitute a breach of terms and conditions of employment.
[28] In conclusion regarding the Complainants’ first argument, I find that by engaging
in the election process on the terms initiated by the Employer’s letter of January
31, 2023, the parties entered into binding agreements regarding the assignment
of the Complainants to the Correctional Supervisor position. The Employer later
breached that agreement by resiling from the appointments and requiring the
Complainants to compete in a job posting process for the jobs they’d already
been promised.
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The Complainants’ Second Argument – Allegedly Unfair Competition for Job
[29] The Complainants’ second argument is that their terms and conditions of
employment were violated by being required – if they wanted the job - to compete
in an unfair process for the Correctional Supervisor position.
[30] The Complainants argue that this process was unfair in part because some of the
Correctional Supervisor positions had been awarded in the April/May job posting
process, when they had no indication that they needed to apply.
[31] The Employer responds with two submissions. First, it submits that the Board has
no jurisdiction to adjudicate the fairness of a competition process for jobs within
the OPSEU bargaining unit. Any such issues are governed by the OPSEU
collective agreement and its grievance and arbitration process. Second, the
Employer submits that if this fairness complaint is about the Complainants having
to participate in the competition process at all, this issue is subsumed within the
Complainants’ first argument.
[32] I agree with the Employer’s submissions on this issue. This Board does not have
jurisdiction to review or remedy any perceived flaws in competitions for jobs that
fall under the OPSEU collective agreement. There is another forum for that.
[33] I also agree that the issue of whether the requirement to apply and compete for
the Correctional Supervisor job was a violation of the Complainants’ terms and
conditions of employment, is subsumed within the first issue dealt with above. It
is a consequence of their elections not being honoured. Had the election process
never been put into place by the Employer, the Complainants would have no
cause to complain if the Employer had invited them to apply for OPSEU
positions. This does not constitute a separate violation of their rights.
The Complainants’ Third Argument – Breach of Employer’s Policies
[34] As noted above, the Complainants’ third argument is that the process of the
organizational restructuring violated various Employer policies including its
Employment Policy, its Code of Conduct and Professionalism, and a document
entitled, “Operational Leadership Behaviours.” They also argue that these terms
and conditions of employment were applied in an unfair, unreasonable, arbitrary
or bad faith manner.
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[35] In the Preliminary Decision, at paragraph 47, I rejected the Complainant’s attempt
to rely on the document entitled “Operational Leadership Behaviours.” That issue
has thus been disposed of.
[36] Regarding the Employer’s Employment Policy, the Complainants rely on Sections
6.2 and 6.6. The Policy describes its purpose and application as follows:
4. Purpose
This policy establishes a set of principles and requirements for managing public
service employment and enables timely, flexible and accountable employment
practices.
5. Application and Scope
5.1.This policy covers the following activities:
• recruitment and selection
• appointment, assignment and transfer
• workforce adjustment.
• suspension and termination.
[37] Section 6 of the Employment Policy describes the following “Principles”, in
material part:
6.2. Employment practices:
• ….
• are fair, objective, reasonable and transparent
• ….
• support employee efforts for ongoing development and employability
• balance organizational and individual interests
• ….
• are supported by timely and accurate documentation.
….
6.5. Workforce adjustment activities enable ministry business and human resource plans
by ensuring qualified employees are assigned to, or retained in, the work to be
performed.
6.6. Employees are treated with fairness and dignity throughout the employment
relationship, including those affected by organizational change initiatives.
[emphasis added]
….
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[38] At page 40 of the Policy, in a section entitled “Responsibilities”, there is a list of
responsibilities of deputy ministers. That list includes the following:
Provide leadership in creating workplaces that are supportive of staffing decision
making that is timely, flexible, accountable, inclusive, accessible and effective.
[39] The Complainants also rely on certain provisions of the Ontario Correctional
Services Code of Conduct and Professionalism (“COCAP”). In its introduction
section, it describes its intent and application as follows:
The broad principles set out in the Code of Conduct and Professionalism (COCAP)
policy are intended to guide Correctional Services employees in actions and decisions
and to provide a tool to enhance understanding of the many Ontario Public Service
(OPS) wide policies and standards that govern the work we do…
The COCAP policy outlines the behaviours expected of all employees,
regardless of position or rank and also defines behavioural standards and
infractions…
[emphasis added]
[40] Section I of the COCAP policy is about “on-duty” conduct. It states in part:
…The standards below set out ministry expectations for employee behaviour and
conduct in the workplace.
1. …We should be willing and able to explain, answer to, and justify the appropriateness
of our actions and decisions. Accountability is also about acceptance, being
responsible and providing necessary support, feedback and oversight. …
As employees we will:
….
b. Act with propriety, honesty, integrity, impartiality, fairness and in an ethical manner.
….
d. Ensure all employees and clients or any other persons have reasonable and equitable
access to available services and information.
….
6. Maintain the privacy and confidentiality of information…
As employees we will:
d. Engage in information sharing practices with employees and clients in a timely
manner…
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[41] The Complainants argue that the Employment Policy and COCAP policy were
breached by the Employer in several respects. They argue that the Employer’s
duty to have fair and transparent employment practices, supported by timely and
accurate documentation, was violated when they were kept in the dark about the
proceedings before Arbitrator McLean that led to McLean Decision No. 2. These
duties were further violated when they received no information for three months
between the issuance of that decision and the Employer’s letter to them of
October 31, 2023 announcing that their elections would not be honoured. They
had missed the opportunity to participate in the April/May competition for
Correctional Supervisor positions, reasonably believing that it was unnecessary
to apply.
[42] Ms. Cornish described the October 31st letter as “having the rug pulled out from
under me” after a period of total silence from the Employer since her election.
She argues that this conduct by the Employer and the resulting stress caused by
having to compete for a reduced number of positions in November 2023, meant
that she was not, “…treated with fairness and dignity throughout the employment
relationship, including [the]… organizational change initiatives,” as required by
Section 6.6 of the Employment Policy. She further argues that the deputy minister
failed in his duty to lead a workplace that includes, “staffing decision making that
is timely, flexible, accountable, … and effective”. Ms. Cornish also relies on
Section 1 (d) of the COCAP policy. She asserts that her managers failed in their
duty to ensure that she had “reasonable and equitable access to… information”
about OPSEU’s challenge to her direct assignment and what was to happen as a
result of McLean Decision No. 2. She argues that this lack of information also
constituted a violation by her managers of their duty to act with “fairness and in
an ethical manner” pursuant to section 1(b) of the COCAP policy.
[43] For his part, Mr. Beattie argues that when it “reneged” on the “final and binding”
agreement to assign him to the Correctional Supervisor position, the Employer
violated its duty to treat him fairly , as set forth in sections 6.2 and 6.6 of the
Employment Policy. He also argues that the Employer’s lack of transparency
regarding the grievances before Arbitrator McLean and any discussions it might
have had with OPSEU in that regard, before or after McLean Decision No. 2,
violated the transparency obligation contained in section 6.2 of the Employment
Policy. (While Mr. Beattie said he understood there were settlement negotiations
or discussions between OPSEU and the Employer about the direct assignment
issue, there is no evidence before me to that effect. It is clear, however, that
there was no communication from the Employer to the Complainants or other
Sergeants about the grievances and arbitration that led to McLean Decision No.
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2, or about what might flow from that decision, until the letter of October 31,
2023.)
[44] The Employer submits that the only reason that the Complainants’ elections were
not honoured was the result of McLean Decision No. 2. That decision made the
Employer’s intention to directly assign the Complainants to the Correctional
Supervisor position illegal. It also caused the delay that is complained of. That
was beyond the Employer’s control. It cannot therefore give rise to any finding of
bad faith or improper conduct by the Employer. While the Complainants’
frustration is understandable, the delays and gaps in the flow of information were
the result of the grievance arbitration process and the Employer did the best it
could to inform staff, it argues. Management decisions flowing from an arbitration
process or decision naturally take time. Once the grievances were before
Arbitrator McLean and the litigation process was underway, the Employer was
not in a position to advise the Complainants about their situation or about the
grievances. The rhetorical question is posed, what could the Employer
reasonably say to all of the Sergeants about the situation while the arbitration
process was underway? The Employer argues that there is no term and
condition of employment to the effect that the Complainants had a right to be
notified of the OPSEU grievances affecting them or the arbitration proceedings.
[45] Furthermore, the Employer relies on the fact that the election form and
subsequent appointment letters received by the Complainants clearly state, “The
effective date of this change will be communicated to you at a later date.”
Therefore, submits the Employer, no right of the Complainants was violated as a
result of the delays which flowed from the grievance process that resulted in
McLean Decision No. 2.
[46] Regarding the Employment Policy, the Employer argues that the principles
relating to fairness and dignity in Section 6 were fulfilled by it. Even had they not
succeeded in obtaining the Correctional Supervisor position as a result of the
second posting, the default was that the Complainants would have been
promoted to Staff Sergeant. This is inherently fair, argues the Employer.
Furthermore, ample supports were in place and avenues were open to the
Complainants to obtain further information if they required it. The Employer
argues that it followed the workforce adjustment provisions of the Employment
Policy.
[47] Regarding the COCAP policy, the Employer argues that it is focused on day-to-
day operations in Correctional Services, not on matters such as workforce
adjustments. While managers cannot ignore the COCAP policy, the Board must
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be careful not to apply it too broadly, it is submitted. In any event, it is argued
that the managers did comply with their obligations to provide appropriate
information to the Complainants.
[48] Having carefully considered these submissions, in my view, the Employer
violated its obligations towards the Complainants under the Employment Policy in
several respects. Having so found, it is unnecessary to decide whether there
were also violations of the COCAP policy in these circumstances. The
Employment Policy, at least, was violated when the Employer failed to advise the
Complainants about the arbitration that led to McLean Decision No.2. This failure
persisted for several months, from the time those grievances were referred to
arbitration until the decision was issued on June 27, 2023. The Policy was further
violated by the Employer’s total silence towards the Complainants for a period of
three months between the issuance of the decision and its letters of October 31,
2023.
[49] The Employment Policy explicitly applies to workforce adjustment situations.
Section 6.2 provides that employment practices must be “fair, ... reasonable and
transparent.” Section 6.6 requires that employees be “…treated with fairness and
dignity… including those affected by organizational change initiatives.” It
requires that employment practices be, “…supported by timely and accurate
documentation.”
[50] To be left uninformed about arbitration proceedings that could have a significant
impact on the Complainants, possibly for the balance of their careers in the OPS,
is inherently unfair to them. It was the antithesis of transparency. This should
have been apparent to the Employer from the outset. It was commented on in
McLean Decision No. 2, when the arbitrator stated as follows at paragraph 18:
I recognize that the result of this decision may have terrible consequences
for some former Sergeants. Many of them wished to be represented by PSAC.
That was denied. Many wished to be represented by AMAPCEO. That was
denied. No doubt, many are content to be represented by OPSEU. However,
the end result is that at the moment of success when non managerial employees
(if any) were finally represented by a trade union the Employer embarked on a
course of action and the Union enforced its strict legal rights with the outcome
that it is possible that former Sergeants may lose their jobs with the public
service. These circumstances cry out for immediate open-minded and flexible
action by both parties to alleviate a situation that is deeply unfair.
[emphasis added]
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[51] Third party interests in the outcome of a grievance under a collective agreement
have been recognized and applied in labour arbitrations for decades. This
generally involves giving notice (at least) and standing (where it is sought and
only if appropriate) to other parties who may be affected by the outcome and
have an interest adverse to the union involved. As Laskin, J.A. stated in Bradley5
many years ago:
The common law has been specially sensitive to deprivation of property or contractual
advantages in proceedings of an adjudicative character without previous notice
thereof to persons likely to be directly affected, unless there is clear statutory
exclusion of such notice. In the present case, there is none.
[52] It is not for me to decide whether the Complainants would have been given
standing before Arbitrator McLean had they sought it, if they’d been advised of
the arbitration. It is for me to determine whether the Employer’s policies required
the Employer to be transparent with the Complainants once the grievances
challenging their direct assignment were before Arbitrator McLean. In my view,
the duties of fairness and transparency that are embedded in the Employment
Policy did require the Employer to advise the Complainants that its intended
redeployment actions had been grieved and were now the subject of litigation,
such that their reclassification to Correctional Supervisor might be in jeopardy,
[53] It is no answer for the Employer to argue that advising the Complainants would
be problematic or awkward or that the Complainants would remain employed in
any event. This is a matter of respecting the Complainants’ rights and the
Employer complying with its own policies. It knew that the Complainants and
others had elected to be assigned to the Correctional Supervisor position (and
not the Staff Sergeant position). It knew that the intended assignments were
being challenged and that the Complainants’ interests might be affected. It should
have advised them of this. As for how that might affect the arbitration, if at all, that
would be for the arbitrator to determine.
[54] Contrary to the Employer’s stated fear, this conclusion does not make it a general
term and condition of employment that managers be given notice of OPSEU
grievances that involve them. Grievances that involve a manager, qua manager,
are the daily fare of grievance arbitration. In those cases, the manager is acting
on behalf of the Employer and it is the actions of the Employer that are being
5 Re Bradley et al. and Ottawa Professional Fire Fighters Association et al., 1967 CanLII 160 (ON CA);
[1967] 2 O.R. 311. And for a good discussion of the development of the law regarding third party notices
in labour arbitration, see for example Stelco Inc. (Hilton Works) and U.S.W.A., Loc. 1005 (Re), 2001
CanLII 62048 (ON LA - H.D. Brown)
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challenged. In this case, the managers’ own contractual terms of employment
with the Employer were at issue. The Complainants’ employment interests were
not the same as the Employer’s broader interests. Thus, this is a straightforward
application of the existing terms of the Employment Policy based on the facts of
this case, where the Complainants’ contractual rights were likely to be affected by
the arbitration.
[55] I turn next to the issue of the three-month delay in informing the Complainants
about McLean Decision No. 2 and the implications for them arising from it.
Although it is a less clear issue, in my view this delay was also a violation of the
Complainants’ rights under the Employment Policy.
[56] The three-month delay in advising the Complainants about the decision itself was
a violation of those policies because it constituted a failure to be transparent with
them and was not timely, as set out in the Policy’s Principles. There is no
evidence demonstrating why it was not feasible to promptly inform the
Complainants about the decision. This is especially perplexing and problematic
given that the decision would have been immediately known to OPSEU and,
presumably, many of its members including those who had grieved.
[57] That said, I have some sympathy for the Employer’s argument that it naturally
takes time for the Employer to be able to determine how to respond to a major
decision such as McLean Decision No. 2. In finding that the failure to inform the
Complainants about the decision itself for three months was a violation of these
policies, I am not deciding that such a delay in advising the Complainants about
how the decision would be implemented was a violation. That process would
naturally take longer, especially if negotiations with the Union were also involved
(a matter about which I have no evidence). But I can see no reason why the
Complainants could not have been advised promptly of the decision itself. I also
see no reason why, in the interest of transparency, they could not, for example,
have been advised about the steps the Employer expected to take in reviewing
its options, whether there was to be any discussions with OPSEU about it, and
what all of this might mean, in general terms, for the Complainants. Such an
approach, even if no definitive outcomes could have been communicated sooner,
would have been more consistent with the Employment Policy. While I do not
find there to have been any bad faith involved, the Employer nonetheless failed to
live up to its own standards as enunciated in these policies.
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SUMMARY
[58] For all of these reasons, I have concluded that these complaints succeed in part.
In conclusion:
(a) I hereby find that by engaging in the election process, the parties entered into
final and binding agreements, committing the Employer to assign the
Complainants to the Correctional Supervisor position. The Employer
breached that contractual agreement with each Complainant when it
announced that it was unable to make the direct assignment to that position.
(b) I hereby find that the Employer violated the Employment Policy when it failed
to advise the Complainants of the grievances being referred to the arbitration
that resulted in McLean Decision No. 2. It further violated that Policy when it
failed to notify the Complainants in a timely manner about that decision.
[59] I remain seized with these applications. The Registrar is directed to schedule a
hearing to deal with any and all remedial issues.
Dated at Toronto, Ontario this 21st day of October 2024.
“Brian Smeenk”
Brian Smeenk, K.C., Chair