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HomeMy WebLinkAbout2001-0901.Globerman.06-08-02 DecisionCrown Employees Grievance Settlement Board Suite 600 180 Dundas St. West Toronto, Ontario M5G 1Z8 Tel. (416) 326-1388 Fax (416) 326-1396 Commission de règlement des griefs des employés de la Couronne Bureau 600 180, rue Dundas Ouest Toronto (Ontario) M5G 1Z8 Tél. : (416) 326-1388 Téléc. : (416) 326-1396 GSB# 2001-0901 IN THE MATTER OF AN ARBITRATION Under THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT Before THE GRIEVANCE SETTLEMENT BOARD BETWEEN Association of Management, Administrative and Professional Crown Employees of Ontario (Globerman) Association - and - The Crown in Right of Ontario (Ministry of Health and Long-Term Care) Employer BEFORE Ken Petryshen Vice-Chair FOR THE UNION James McDonald Sack Goldblatt Mitchell LLP Barristers and Solicitors FOR THE EMPLOYER Yasmeena Mohamed Senior Counsel Ministry of Government Services HEARING May 14, June 29 & 30, July 12 & 13, October 21, December 15, 2004; February 14, 15 & 18, July 11, 13 & 14, 2005. 2 Decision I have three grievances before me filed by Mr. D. Globerman. During the last few months of his employment, Mr. Globerman was on a temporary assignment with the Ontario Seniors’ Secretariat (“the OSS”). Prior to this temporary assignment, he had been employed with the Ministry of Health and Long-Term Care (hereinafter referred to as “the Ministry” or “the Employer”). While employed with the Ministry, Mr. Globerman became involved with establishing and operating a charity known as The Running to Daylight Foundation (“the Foundation”). The circumstances giving rise to Mr. Globerman’s grievances, for the most part, relate to his activities with the Foundation. After he was requested in March of 2000 to comply with his duty to disclose a potential conflict of interest, Mr. Globerman disclosed his involvement in the Foundation to the Ministry’s Deputy Minister. In a letter dated June 28, 2000, Deputy Minister D. Burns advised Mr. Globerman to either terminate his involvement with the Foundation or terminate his status as a public servant. In a grievance dated May 1, 2001, Mr. Globerman claims that, “the employer has improperly, unfairly and unreasonably directed me to terminate all involvement with The Running to Daylight Foundation; and in so doing, has discriminated by reason of my family status and failed to accommodate my family status contrary to the Ontario Human Rights Code”. The Association did not pursue the allegation that the Ministry had discriminated against Mr. Globerman contrary to the Human Rights Code. Rather, it took the position that the Deputy’s direction to Mr. Globerman violates his fundamental rights of freedom of expression and association as guaranteed by the Canadian Charter of Rights and Freedoms (“the Charter”). 3 Mr. Globerman was issued a reprimand for insubordination when an article about him and the Foundation appeared in the September 2001 edition of Homemakers magazine. In a grievance dated November 29, 2001, Mr. Globerman claims that, “the employer has improperly, unfairly, unreasonably and without just cause issued to me a letter of reprimand dated October 24, 2001; and in so doing, has discriminated by reason of my family status and failed to accommodate my family status contrary to the Ontario Human Rights Code.” In September of 2003, Mr. Globerman and the Foundation co-sponsored and participated in a Forum on “Rage Against Ageism in Health Care”. This was the culminating event which lead to his discharge. In a grievance dated December 18, 2003, Mr. Globerman complains that, “the employer has discharged me without just cause; and that in so doing, the employer has violated my rights under the Canadian Charter of Rights and Freedoms, and has discriminated by reason of my family status and failed to accommodate my family status contrary to the Ontario Human Rights Code.” After a suspension with pay pending an investigation, Mr. Globerman was discharged by letter dated December 8, 2003. As well as referring to the events which led to his discharge, this letter refers to earlier events which gave rise to his other grievances. The discharge letter reads as follows: Dear David: On October 3, 2003, you were placed on a non-disciplinary suspension, pending the outcome of an investigation into the events leading up to the publication of an article entitled “Ageism in health care is really hidden rationing” in the September 26, 2003 edition of the Toronto Star. On November 7, 2003, we met with you and your AMAPCEO representative as part of our investigation. This article summarized many of your comments delivered at a Symposium on Ageism in Health Care, an event co-sponsored by The Running to Daylight Foundation on September 23, 2003 at the St. Lawrence Centre in Toronto. The article was based on the 4 reporter’s coverage of the event supplemented by an interview that you granted the following day. Our investigation has revealed the following: - On May 30, 2001, I was advised in writing that you had resigned from your position as president of the Running to Daylight Foundation and had “ceased any active involvement in the organization”. Despite this assurance that you had finally complied with the Deputy Minister’s previous direction, you never stopped your Foundation related activities and you did not resign as president. Your explanation is that this commitment was obtained under duress. Your position on this matter is that no one, including your Deputy Minister, has the right to restrict your activities related to the Running to Daylight Foundation. - In March of 2003, you indicated that you were fit to return to work from an extensive sick leave that you began in May 2001. To facilitate your return to meaningful work, and as a possible settlement for your two outstanding grievances, it was agreed that you would assume a six month acting assignment at the Ontario Seniors’ Secretariat as a Policy Advisor. On March 29, 2003, when you met with the manager of this position, she advised you that while on this acting assignment, you would be required to disclose any perceived or potential conflict of interest related to the Running to Daylight Foundation or any other activity. You were advised to refrain from any activity that would place you in a conflict of interest. You advised your manager that the Foundation was still inactive. - The co-sponsoring organization of the September 23 Symposium was The Ontario Coalition of Senior Citizens Organizations, a key stakeholder of the Ontario Seniors’ Secretariat where you have been working on secondment since July 2, 2003. You were in preliminary discussions regarding this event at the time you first met with the Ontario Seniors’ Secretariat. Planning and delivery of the event took place during your secondment. At no time before or during your secondment did you disclose to your manager or to the Deputy Minister the details of your involvement with the Foundation, in particular, your co- sponsoring of this event. On the contrary, you were secretive about your activities. As you put it at the November 7 meeting, you did not want “another hassle”. - As the president of the Running to Daylight Foundation, you formed a relationship with The Ontario Coalition of Senior Citizens Organizations. You indicated at our meeting that this relationship was formed for the purpose of directing financial support to your Foundation. - The Running to Daylight Foundation was instrumental in promoting and staging the Symposium, giving your phone number and the Running to Daylight email address as a contact on promotional and resource material. You were a key speaker at the event. - On September 19, 2003, your manager at the Ontario Seniors’ Secretariat saw a 5 promotional flyer for this Symposium. She expressed her alarm and concern to discover that the Running to Daylight Foundation was co-sponsoring this event since you had previously told her that the Foundation was inactive. When she asked you what your involvement would be and why you had not disclosed this in advance, you indicated that she had no cause for concern. You still did not disclose that you were a speaker at this event. By way of background, let me remind you of all of the events that has brought us to where we are today. On March 22, 2000, having seen and heard about your new Foundation, I met with you to express my concern that your activities as the president of the Running to Daylight Foundation may be a conflict of interest. As a result you made a disclosure to the Deputy Minister on April 28, 2000. On June 28, 2000, the Deputy Minister communicated his opinion to you in writing, advising you to either terminate your status as a civil servant or terminate all involvement with the Running to Daylight Foundation. The letter contained the opinion that continued involvement with the Foundation, while a civil servant, constituted at least a perceived and potential conflict of interest. The letter made it clear to you that a public servant must avoid all conflicts of interest, whether actual, potential or perceived. On February 12, 2001, the Running to Daylight Foundation appeared as a presenter on a standing committee agenda for Bill 135, Public Hospitals Amendment Act. Although you did not appear at this committee meeting, the speech appears on the hard drive of your computer so it is clear to me that you are the author. The content of the speech was critical of the quality of care received by seniors in the publicly funded health care system in Ontario. On February 17, 2001, an article appeared in the Toronto Star entitled “Group helps seniors navigate health system”. As well as being further evidence that your Foundation was still active, the article also contained critical comments regarding the quality of care the elderly receive in the publicly funded health care system. The columnist refers to you as “…Globerman, who ironically is a financial consultant with the Ontario Ministry of Health ….”. In the September 2001 edition of Homemakers Magazine, an article appeared entitled “Live or Let Die”. This article contained further criticism from you regarding the quality of the publicly funded health care system. On October 24, 2001, I issued a letter of reprimand for being insubordinate to me and to the Deputy Minister by your continued association with the Foundation, thus perpetuating the conflict of interest. You were warned that further actions that perpetuate this conflict of interest would result in further discipline, up to and including dismissal. To summarize, the Ontario Seniors’ Secretariat has advised me that they have lost all confidence in your ability to carry out your duties as a Policy Advisor, free from a conflict of interest. They no longer trust that you are able to exercise the judgment required of that position, which requires frequent interface with external stakeholders for the purpose of participating on working groups and committees on behalf of the Secretariat. This participation, in turn, requires an understanding of political sensitivities across ministries and sectors. In your recent private activities you have not displayed such understanding. 6 I have also lost all confidence that you will ever remove the conflict of interest that flows from your participation in the Running to Daylight Foundation and your status as a civil servant. You have been directed to terminate all involvement in the Foundation or terminate your status as a civil servant. You have done neither. Your actions in the past and in particular, your recent participation in the Symposium on Ageism in Health Care demonstrate a conscious decision on your part to disobey a direction from the Deputy Minister. This constitutes insubordination, a perpetuation of a conflict of interest and a breach of you duty of trust, loyalty and good faith owed to the employer, the Crown in Right of Ontario. Your actions have undermined your employment relationship to the point where your continued employment is no longer possible. As a result, by the authority delegated to me by the Deputy Minister under Section 22 (3) of the Public Service Act, I hereby dismiss you for cause, effective today. You have the right to grieve under Article 20 of the AMAPCEO collective agreement April 1, 2001to March 31, 2004. Please return all Ministry of Health and Long-Term Care and Ontario Seniors’ Secretariat assets to Archie Outar by December 31, 2003. Any personal effects will be sent to you. The Association takes the position that the Ministry and the Deputy Minister were wrong when they determined the Mr. Globerman’s involvement with the Foundation constitutes at least a perceived and potential conflict of interest. As noted previously, it also claims that the Ministry violated Mr. Globerman’s Charter rights. The Association takes the position that there was no just cause for the reprimand issued to Mr. Globerman and for his discharge. The Association seeks reinstatement for Mr. Globerman and compensation for his losses. Thirteen hearing days were required for these grievances, including almost three days for argument. Well in excess of one hundred documents were filed as exhibits. I concur with counsel for the Association’s assessment that this is a complicated case. The Employer called four witnesses, namely, Mr. M. Springman, Counsel and Group Leader in the Ministry’s Legal Service Branch, Mr. A. Outar, Manager, Finance and Information, Health Care Programs, Toronto Region, Ms. M. Weber, Regional Director, Toronto Region and Ms. E. Esteves, 7 Manager, Policy Initiatives, in the OSS. The Association called Mr. Globerman to testify. In determining the facts, I considered the oral and documentary evidence and the submissions relating thereto. I resolved conflicts in the evidence by utilizing the usual tests, including an assessment of what is most probable in the circumstances. I note that Mr. Globerman was not present for all of Ms. Weber’s testimony. Before the commencement of the hearing on October 21, 2004, Mr. Globerman made a statement to Ms. Weber which caused her to become upset. She indicated that she was not prepared to continue with her testimony on that day and that she did not want to continue her testimony at a later time in the presence of Mr. Globerman. Without the need for any intervention from me, the parties agreed to adjourn the hearing for that day and that Mr. Globerman would not be present for the remainder of Ms. Weber’s testimony. Although not in the hearing room, Mr. Globerman was able to hear the remaining testimony of Ms. Weber and consult with counsel by telephone. Before addressing the specific circumstances giving rise to each grievance, it is helpful to set out a general overview of the facts. When this hearing commenced in May of 2004, Mr. Globerman was fifty-two years of age. He commenced his employment with the Ministry in July of 1985. During the relevant period, Mr. Globerman was employed as a senior financial consultant in the Health Care Programs Division of the Ministry’s Toronto Region. This position is included within the Association’s bargaining unit of professional and supervisory public servants. Mr. Globerman reported to Mr. Outar, his Manager, and Mr. Outar reported to the Regional Manager, Ms. Weber. In general, the Ministry funds and administers the health care system in Ontario and it regulates hospitals and nursing homes. With a budget in excess of four billion dollars, the Toronto Region has responsibility for most of the health institutions within its area, including hospitals, long-term care facilities and various community agencies. Mr. Globerman was the lead for the mental health program in the Toronto Region, with most of 8 his time devoted to financial management, analysis and monitoring of the Centre for Addiction and Mental Health (“the CAMH”). Mr. Globerman created the Foundation to honour the life of his father, Mr. Ben Globerman. Ben Globerman died in 1996 at an Ottawa hospital at eighty-five years of age from the effects of a stroke. Mr. Globerman strongly believes that his father received sub-standard medical care, that such care was directly responsible for his death and that the reason his father did not receive appropriate care was because of his age. After meeting others who also believed their elderly relatives received sub-standard care, Mr. Globerman decided to create the Foundation to address ageism in the health care system and to improve the standard of care for the elderly, particularly when they are in hospitals and long-term care facilities. Between 1997 and October of 1999, Mr. Globerman spent considerable time in developing the Foundation. In 1997, the Foundation was registered with the Toronto Community Foundation, an umbrella organization that provides assistance to smaller funds. During this initial period, Mr. Globerman solicited financial and other support for his concept, defined the goals of the Foundation, recruited advisory and honorary Board members, a special consultant and prepared for the launch of the Foundation. The Ministry discovered a record of these activities on the hard drive of Mr. Globerman’s Ministry computer. A media release sent out prior to the launch of the Foundation indicates that the Foundation “will provide elderly patients with Patient Representatives who will help them access quality health care, act as intermediaries with health care professionals when needed and educate the patient and family.” The media release also indicates that, “The launch begins an ambitious fund-raising program for the innovative support program that will provide representatives for the 9 elderly, initially starting in the Ottawa and Toronto areas.” As a Foundation pamphlet makes clear, the Foundation would not provide patient representatives directly to elderly patients. Rather, it would allocate funds to registered charities, such as nursing and seniors organizations, to allow them to provide support for the elderly. The launch of the Foundation occurred on October 25, 1999, in the Queen Victoria Ballroom of the Sutton Place Hotel in Toronto. Ms. Jane Hawtin, a television/radio broadcaster, made the opening and closing remarks. Presentations were made by five individuals, including Dr. Carolyn Bennett, MP for the riding of St. Paul’s in Toronto, Councillor Anne Johnston representing the Toronto Task Force on Seniors and Mr. Globerman, as President of the Foundation. In written material provided at this event, a biography for Mr. Globerman indicates that, “Foundation President David Globerman is a financial consultant with the Health Care Programs Division of the Ontario Ministry of Health and Long Term Care. He has worked on a number of health care issues in the Ministry’s mental health, substance abuse and corporate policy areas since he joined the Ministry in 1985…” This material also discloses that the honorary Board members of the Foundation include Dr. Carolyn Bennett, Jane Hawtin and Karen Kain. Dr. Michael Gordon is described as a special consultant to the Foundation. The written material refers to vision and mission statements, and the values and goals of the Foundation. The goals of the Foundation are as follows: 1. To provide patient representatives, who on behalf of the patient and family, will confer with the health care team to review the treatment and care provided and work to resolve outstanding issues. 2. To educate and consult to patients and families, to make them informed, active and effective participants in the decision-making around treatment and care. 3. To affect change at the system level by providing public education, stimulating discussion, fostering research, participating in the development of public policy, 10 collaborating with planners and working with service providers, professional associations and regulatory bodies around issues relating to the access and quality of treatment and care of the elderly. The Foundation pamphlet, under the heading “THE NEED” notes that, “Furthermore, it is important that the planning and funding of our health care system keep pace with the needs of an aging population. This can only occur if the opinions of elderly patients and their families are given voice in those areas responsible for developing and managing the system.” The pamphlet advises where contributions to the Foundation may be directed. One of the purposes of the launch, as evidenced by the media release, was to announce the existence of the Foundation and to generate some media attention. I was provided with a number of articles in publications that referred to Mr. Globerman and the Foundation. There was no suggestion by Mr. Globerman that the articles contained any inaccurate information. In an article entitled “Ageism is rampant in health care” that appeared in the Life section of the Toronto Star on October 30, 1999, Mr. Globerman and the Foundation were featured. A picture of Mr. Globerman, his father and nephew accompanied the article with the notation that the Foundation had been launched that week. The article made brief references to Ben Globerman’s hospital experience, to the Foundation’s efforts to raise money to help community organizations train and provide patient representatives and to some of the Foundation’s Board of Directors. The author noted that Mr. Globerman “…ironically works in the policy branch at the Ontario Ministry of Health.” In the January 17, 2000 edition of MacLean’s, an article entitled “All in the Family” dealt with taking care of aging relatives and the shortcomings of institutional 11 care. The reference to Mr. Globerman and the Foundation is as follows: David Globerman, for one, was so incensed by the care his father received by an Ottawa hospital in 1996 that he started the Running to Daylight Foundation, a Toronto-based organization devoted to improving institutional eldercare. Globerman, 46, says he believes his 85-year old father was given low priority by medical staff because of his age: he died within weeks of entering hospital, largely Globerman believes, because doctors treated him for pneumonia when in fact he had suffered a stroke. “Clearly, there is a bias in the health-care system against the elderly,” says Globerman, who is a financial consultant to the Ontario ministry of health in Toronto. As a society, we don’t value them. So when there is a lack of resources, they fall to the bottom of the barrel.” Mr. Globerman and the Foundation were mentioned in a Sunday Sun article on February 5, 2000, entitled “Looming crisis for elderly”. After referring to Mr. Globerman as a financial consultant with the Ministry, his father’s treatment and the purpose of the Foundation, the author wrote: He worries that kind of neglect of the elderly may only become more prevalent as more seniors flood an overcrowded, under funded system, especially in a society that does not particularly value the elderly. “You have a recipe for disaster” warns Globerman. “Right now, the number of Canadians 65 and older is one in eight. When I’m 65, it’ll be one in five. It’s time now for the baby boomers to take responsibility for improving the health- care system for our parents and ourselves – because we’re not that far behind.” In an Ottawa Citizen article that appeared on November 23, 1999, the author writes about the Foundation, Mr. Globerman and the goals of the Foundation, particularly the funding of patient representatives. After commenting on the fact that in twenty years the number of persons sixty-five years and older will be one in five, Mr. Globerman is quoted as saying, “It is going to be an issue that affects everybody because, unfortunately, the health system is not working the way it should. Because if it did, there wouldn’t be a need for an organization like this.” 12 Mr. Globerman did not consider it necessary to advise the Ministry about his activities with the Foundation. Ms. Weber became aware of his involvement when some of the articles in the press came to her attention. She was immediately concerned about his involvement with the Foundation and what he said about the health care system, given his position as a senior financial consultant with the Ministry. She took some time to review the conflict of interest policy and got advice from the Ministry’s Human Resources Division. Ms. Weber then met with Mr. Globerman on March 22, 2000. She provided Mr. Globerman with a copy of the “Government of Ontario Conflict of Interest and Post Service Directive for Public Servants and Public Officials” (“the Conflict of Interest Directive”), a directive based on Regulation 453/97 under the Public Service Act. She reviewed certain provisions of the Conflict of Interest Directive with him in detail. Ms. Weber also told him that his activities with the Foundation may be in conflict with his role as a senior financial consultant and she asked him to comply with the duty to disclose set out in section 23 of the Conflict of Interest Directive. Mr. Globerman complied with his duty to disclose by filing a written submission to the Deputy Minister D. Burns dated April 28, 2000. He referred to his position with the Ministry as that of a “Regional Financial Consultant”. His submission referred to the purpose and activities of the Foundation in detail and he set out his views on why there was no conflict of interest. Mr. Globerman included with his submission the material about the Foundation that was available at the launch on October 25, 1999, including the pamphlet, the media release and a document disclosing who was on the Honorary Board. The package relating to Mr. Globerman’s disclosure was sent to Mr. Springman by the Deputy Minister’s office. Mr. Springman has been counsel in the Ministry’s Legal Services Branch since July of 1991, and a group leader for over four years. Prior to joining the Ministry, 13 he was with the Ontario Law Reform Commission for over seventeen years and was Director for six years. He has also taught law at Osgoode, the University of Toronto and Queen’s. For the last thirteen years, Mr. Springman has been the lawyer who deals with the conflict of interest issues that arise in the Ministry. Mr. Springman reviewed the package consisting of Mr. Globerman’s written submissions as well as the information about the Foundation. He then consulted with Ms. Weber to determine Mr. Globerman’s duties as a senior financial consultant and then compared his role with the Ministry with his activities with the Foundation. Mr. Springman reviewed previous conflict of interest files where a public servant performed services for a charity. He then prepared a draft opinion for the Deputy Minister about whether Mr. Globerman was in an actual, a perceived or a potential conflict of interest, as well as a draft letter to Mr. Globerman for the Deputy Minister to sign. Ms. Weber and Human Resources reviewed and approved the draft opinion. Mr. Springman concluded that Mr. Globerman was in an egregious conflict of interest that could not be managed and that the only option in the circumstances was for the Deputy Minister to direct Mr. Globerman to resign from the Foundation or resign from his position with the Ministry. The Deputy Minister agreed with Mr. Springman’s opinion. In a letter dated June 28, 2000, Mr. Burns provided Mr. Globerman with the following directive: Re: Conflict of Interest (Running to Daylight Foundation) Thank you for your April 28, 2000 letter advising me of your involvement in the Running to Daylight Foundation, The Ben Globerman Memorial. You have asked my advice concerning whether this private activity constitutes a conflict of interest under Regulation 453/97, made under the Public Service Act, or under the conflict of interest directives of the Ministry. 14 A public servant must refrain from engaging in any private conduct that would place him or her in an actual, potential or perceived conflict. In our view, your public service responsibilities and your active role in a charity whose goals and policies may wholly or partly conflict with those of the Ministry places you in at least a perceived and potential conflict of interest. As a public servant, you have a broad advisory and resource allocation role in the area of mental health services, an area that relates in part to the care of the elderly (the exclusive focus of the Foundation). Yours responsibilities include the provision of advice and services to transfer payment agencies, consumers and members of the public respecting Ministry policies, guidelines, procedures and practices. You are also to provide advice on the allocation of Ministry funds within Toronto Region. These ministerial duties are particularly problematic in light of the stated “vision” and “goals” of the Foundation and your central position in it. With respect to advancing the interests of the elderly, the policies that you actively advocate on the part of the Foundation might well clash with some or all of the Ministry policies for which you are directly or indirectly responsible as a public servant. Accordingly, a reasonable perception and potential is that this difference of views would or might influence or detrimentally affect your ability to perform those ministerial duties, particularly the more public duties that you see as contrary to the goals of the Foundation. A further reasonable perception is that the Foundation has or might have some unfair advantage over other charities as a result of your position in the Ministry. I note, in this connection, that your biography accompanying the creation of the Foundation specifically indicated that you were employed by the Ministry. This information may create the impression that you have a kind of expertise, or experience in the Ministry, and perhaps Ministry “contacts”, that could benefit the Foundation. Given my view that your private involvement with the Foundation, however commendable, constitutes at least a perceived and potential conflict of interest, it is my advice that you either terminate all such involvement or terminate your status as a public servant. Thank you for seeking my advice in accordance with the Public Service Act regulations and Ministry directives. In December of 2000, many months after the Deputy’s directive, Ms. Weber asked Mr. Globerman if he had responded to the Deputy Minister’s letter. He responded by indicating that the Deputy’s letter did not indicate that a response was required. As Ms. Weber was attempting to address compliance with the Deputy’s directive to Mr. Globerman, she became aware of the agenda for a Standing Committee of the Legislative Assembly dealing with Bill 135, an act to amend the Public Hospitals Act to regulate the use of restraints that are not part of medical 15 treatment. The agenda disclosed that Jane Hawtin and Mr. Globerman as President would be appearing before the Standing Committee on behalf of the Foundation on February 13, 2001. In light of the Deputy’s decision, Ms. Weber was concerned that Mr. Globerman was continuing to participate in Foundation activities. Ms. Weber met with Mr. Globerman on February 6, 2000, to discuss his attendance before the Standing Committee. Mr. Outar also attended the meeting. Although Mr. Globerman believed that his attendance before the Standing Committee was not problematic, Ms. Weber impressed upon him that he should not participate or attend at the event. During the meeting, Mr. Globerman discussed the Foundation and his view that many seniors are not receiving proper medical attention in a health care system that has issues relating to a shortage of nurses and medical staff. He indicated that he could not resign because he is an integral part of the Foundation and that he also needed a job. Later that day, Mr. Globerman advised Ms. Weber that he would not appear before the Standing Committee and that he would remove references to his name from the presentation. At that time, Ms. Weber told Mr. Globerman to take two days off with pay to decide how he will respond to the Deputy’s directive. Ms. Jane Hawtin made the presentation to the Standing Committee on behalf of the Foundation. Mr. Globerman wrote the presentation, as evidenced by the fact the presentation was on the hard drive of his Ministry computer. Ms. Hawtin spoke at some length before the Standing Committee indicating the Foundation’s support for the Bill 135. During the presentation, reference was made to some concerns of the Foundation, namely the cutbacks in nursing and other health care resources and the fact that there are not enough safeguards built into the system. The presentation included the comment that, “We would not be adjusting the standards to what we are willing to finance but rather adjusting the finances needed to meet the standards.” It also included the following perspective: “While it’s true that the responsibility for 16 guaranteeing access to the highest-quality care is the responsibility for all of us – the funders, the planners, the service providers, the professional associations, the consumers, and the media – the ultimate responsibility has to lie with government. The buck has to stop somewhere.” Between February and May of 2000, after the meeting in which Ms. Weber told him to decide how he would respond to the Deputy’s directive, Mr. Globerman, through counsel and at times with the assistance of his bargaining agent, attempted to convince Ministry officials that there was no conflict of interest or that he could alter his role with the Foundation to eliminate any conflict. During this period, Mr. Springman continued to be involved in providing advice to Ministry officials. In a letter dated February 21, 2001, to Ms. Weber, Mr. Globerman’s counsel raised a number of matters on behalf of Mr. Globerman. In response to the description of Mr. Globerman’s duties and responsibilities as set out in the Deputy’s directive dated June 28, 2000, she wrote as follows: In particular, Mr. Globerman’s funding responsibilities as a Financial Consultant at the AM-19 level, are restricted to community health programs and the Centre for Addiction and Mental Health (“CAMH”) which is a specialty psychiatric hospital. Community mental health programs and the CAMH focus specifically on the seriously mentally ill population, and not the elderly per se. His funding responsibilities for the community mental health programs are restricted to the review of one time and surplus requests and are in an advisory capacity only. Final approval is given by the Regional Director. As far as CAMH, Mr. Globerman is involved in funding analysis (surpluses/deficits) based on objective criteria, and any base or one time allocations are not within his scope but rather within the realm of senior management. Mr. Globerman does not have any direct or indirect influence on the funding of general hospitals, long-term care facilities, community care access centres or other organizations that deal with the elderly as the majority of their target population. The letter notes that the Foundation has not requested funding from the Ministry and that it does not intend to do so. It also indicates that any material the Foundation distributes will no longer refer to Mr. Globerman’s position with the Ministry and that Mr. Globerman will make a 17 concerted effort to ensure that any coverage of the Foundation will not mention his involvement with the Ministry. The point is made that the Foundation is complementary to the work of the Ministry, just like other charities such as the Cancer Society and the Kidney Foundation. Counsel expressed the hope that the parties could meet and resolve the issues. In a written response to Mr. Globerman dated March 5, 2000, Ms. Weber advised that the Deputy Minister had reviewed the information provided from his counsel and that the Deputy concluded that Mr. Globerman was still in a conflict of interest. She indicated that the Ministry was prepared to meet to discuss whether the conflict of interest can be eliminated. The meeting between Mr. Globerman and his representatives and Ministry officials took place on March 22, 2001. In a letter dated March 29, 2001, sent to Ms. Weber subsequent to the meeting, counsel for Mr. Globerman put forward the following two options for the Ministry to consider: Option 1 Mr. Globerman remains as President of the Running to Daylight Foundation but will focus his involvement on fund-raising for the Foundation and answering queries on behalf of the public (e.g. information about the Foundation, referral to other services, referral to patient representatives, hearing complaints, offering suggestions for resolution of clinical impasses). In an effort to reduce his public profile and visibility, he would not be involved in any public speaking about the Foundation or the health care system nor would he liaise with the media regarding the organization. Option 2 Mr. Globerman resigns as President of the Running to Daylight Foundation but will focus his involvement on fund-raising for the Foundation and answering queries on behalf of the public (e.g. information about the Foundation, referral to other services, referral to patient representatives, hearing complaints, offering suggestions for resolution of clinical impasses). In an effort to reduce his public profile and visibility, he would not be involved in any public speaking about the Foundation or the health care system nor would he liaise with the media regarding the organization. Counsel indicated in this letter that if Ministry still took the position that Mr. Globerman must remove himself from all involvement with the Foundation, he would comply without prejudice to 18 his right to file a grievance. On behalf of Mr. Globerman, counsel requested that he be granted until May 31, 2001, to develop an infrastructure to take his place. It was asserted that Mr. Globerman needed the time to select and train a new president, personnel to take over fund- raising and administrative duties and volunteers to handle the large volume of public queries he receives. In a letter to Mr. Globerman dated April 23, 2001, Ms. Weber responded on behalf of the Ministry by indicating that the proposed options would not serve to remove the conflict of interest. In this letter, Ms. Weber indicated that Mr. Globerman could have until May 31, 2001 to terminate all involvement with the Foundation, with certain conditions. One of the conditions was that Mr. Globerman had to provide, as of May 31, evidence that he has fully complied with the Deputy Minister’s directive. He was advised that the failure to provide such evidence may result in disciplinary action. Mr. Globerman found the Ministry’s response to his proposals to resolve the dispute “bizarre” and he concluded that Ms. Weber was not bargaining in good faith. He testified that it was obvious to him that Ms. Weber was trying to destroy the Foundation. In a letter to Ms. Weber dated May 30, 2001, Mr. Globerman’s counsel advised her of his decision as follows: Further to your letter to Mr. David Globerman dated April 23, 2001, we advise that Mr. Globerman has resigned from his position as President of the Running to Daylight Foundation. The new President of the Foundation is Danial Globerman. David has ceased any active involvement with the organization. Shortly after receiving the Ministry’s response dated April 23, 2001, Mr. Globerman filed his grievance. In early May of 2001, he also provided Mr. Outar with a doctor’s note and advised him that he would be taking a medical leave, which he commenced on May 14, 2001. Mr. Globerman testified that he found his dealings with the Ministry over the conflict of interest 19 issue to be very stressful and that he experienced a deep depression. Mr. Globerman was off work for medical reasons for almost two years. In a letter to Mr. Outar dated February 18, 2003, Mr. Globerman advised him that he would be returning to work on March 3, 2003. Mr. Globerman did not actually return to work until July 2, 2003, when he commenced his temporary assignment with the OSS. Approximately four months after Mr. Globerman commenced his medical leave, an article appeared in a magazine that caused the Employer some concern. In an article on ageism entitled “Live or Let Die” in the September 2001 edition of Homemakers magazine, the author refers to Ben Globerman’s hospital experience, the family’s lawsuit against the hospital, Mr. Globerman’s launch of the Foundation and briefly what the Foundation does. These references are only a small portion of a lengthy article on ageism. Mr. Globerman is referred to in the article as a “Toronto financial consultant”. This article led to Mr. Globerman’s reprimand. Mr. Globerman testified that while on the medical leave he had a conversation with Mr. Outar about the conflict of interest issue which affected his perception of the Ministry’s conduct. On March 25, 2002, at approximately the time when the office was being relocated, Mr. Globerman went to the office and discovered that his personnel belongings had been removed. He testified that during a discussion with Mr. Outar about this issue, Mr. Outar told him at one point that Ms. Weber had ordered someone to throw out the boxes with his belongings. Mr. Globerman testified that he did not believe Mr. Outar when he said this because “he did not have a track record of being believed.” Mr. Globerman testified that he then raised the conflict of interest issue by asking Mr. Outar where all this was coming from and suggested that it was not coming from Ms. Weber, but from the Minister’s and Premier’s office. Mr. Globerman further testified that he asked Mr. Outar whether their dispute is really about a conflict of interest or is it 20 about the issues the Foundation was raising and that Mr. Outar responded that it was about the issues the Foundation was raising. Mr. Globerman then left the office very upset with the view that everything started to make sense as to why the Ministry took an all or nothing approach and why it wanted to shut him and the Foundation down. He testified that he now believed that the Ministry was lying to him and playing games with him. He testified that he concluded that the issue between them related to the substandard care seniors received, not a conflict of interest, and that there was an abuse of power “coming from the top.” As will become evident, Mr. Globerman relies in part on this conversation with Mr. Outar and the conclusions he reached based on the conversation to justify his subsequent conduct. Mr. Outar testified that the March 25, 2002, conversation was not unlike others with Mr. Globerman where Mr. Globerman would do all the talking and not give him much opportunity to respond. Mr. Outar testified that at times the relationship with Mr. Globerman was very stressful and that Mr. Globerman was abusive in his tone and the words he used. He indicated that he would not respond to many of the things Mr. Globerman said. Mr. Outar strongly denied that he told Mr. Globerman that the dispute was really about the issues the Foundation was raising and never implied that there was involvement from the Minister’s and Premier’s office. It was put to Mr. Outar during cross-examination that he told Mr. Globerman during this conversation that the Ministry would make his life miserable when he returned to work. Mr. Outar denied that he said this. In his evidence, Mr. Globerman did not indicate that Mr. Outar made such a statement to him. In reviewing the testimony relating to the March 25, 2003 conversation in the context of all the evidence, I find it impossible to believe Mr. Globerman’s version of the conversation. Counsel suggested that Mr. Outar’s silence in the face of various statements put to him by Mr. 21 Globerman amounted to agreement to what Mr. Globerman asserted or at least that it was not unreasonable for Mr. Globerman to believe that Mr. Outar agreed with him. However, Mr. Globerman testified that Mr. Outar specifically told him that the Ministry’s concern was with the issues raised by the Foundation and not with a conflict of interest. There is no basis to believe that Mr. Outar would tell Mr. Globerman any such thing. Mr. Globerman may have believed that the dispute had to do more with political considerations than a conflict of interest. However, his testimony about his conversation with Mr. Outar appears to be an effort to prove that his views in this regard were corroborated by the Employer and to rely on this corroboration to justify his subsequent conduct. I accept Mr. Outar’s testimony that he did not make the statement attributed to him by Mr. Globerman and that Mr. Globerman was not truthful when he testified that Mr. Outar had conveyed to him that the dispute was not really about a conflict of interest. Mr. Springman testified about a telephone call he received from Mr. Globerman during the course of these events. During this call, Mr. Globerman was yelling at Mr. Springman while alleging that there was a conspiracy by the Government against the Foundation. Mr. Globerman alleged that Mr. Springman knew there was a conspiracy and that he was participating in it. Mr. Springman found the call disturbing. He ended the call by denying any conspiracy and advising Mr. Globerman that he could not discuss the matter further. Mr. Springman noticed from the call display feature on his telephone that Mr. Globerman called him several times after the initial call, but he did not answer. At some point, Mr. Globerman had expressed an interest in securing a position outside of the Ministry. Mr. Outar made inquiries to see if this was possible and his efforts were responsible in part for securing Mr. Globerman a temporary assignment with the OSS. Mr. 22 Globerman met with Ms. Esteves on May 29, 2003, to discuss a temporary assignment with Policy Initiatives, OSS. Based on this discussion, Ms. Esteves was prepared to offer Mr. Globerman the temporary assignment. I will comment on this discussion later in more detail. As noted previously, Mr. Globerman commenced working for the OSS as a policy advisor on July 2, 2003. While on this secondment, his home position remained with the Ministry. The Foundation co-sponsored and participated in a Forum entitled “Rage Against Ageism in Health Care” at the St. Lawrence Centre in Toronto on September 23, 2003. The other sponsor of the Forum was the Ontario Coalition of Senior Citizens Organizations, a stakeholder of the OSS. Ms. Hawtin was the emcee at the Forum, making the opening and closing remarks. Mr. Globerman, who was identified as the President of the Foundation, also spoke at the Forum. A media release about the Forum notes that the Foundation “is also involved in strengthening the healthcare system by providing public education, encouraging discussion, fostering research and participating in the development of public policy.” The material distributed at the Forum included a Toronto Star article from the February 17, 2001 edition which refers to the Foundation and describes Mr. Globerman as a “financial consultant with the Ontario Ministry of Health.” Mr. Globerman was interviewed on the day after the Forum and an article appeared in the Toronto Star on September 26, 2003. The article referred to Mr. Globerman, the Foundation and examples of sub-standard care received by the elderly in hospitals and long-term care facilities. Mr. Globerman was not identified in the article as a Ministry employee. Mr. Globerman testified that he began preparing for the Forum in early 2003 and that it occurred on the seventh anniversary of his father’s death. Because of his participation in the Forum on behalf of the Foundation and the article in the Toronto Star, Ms. Weber suspended Mr. Globerman with pay pending an investigation. Ms. 23 Esteves terminated his temporary assignment. An investigation meeting was held on November 7, 2003, which was attended by Ms. Esteves and Mr. Springman. After spending some time to review its options and the appropriate response, the Ministry terminated Mr. Globerman’s employment for the reasons set out in the letter dated December 8, 2004. With respect to the delay in moving forward with the conflict of interest grievance, I note that I was advised during opening statements that the parties met with a Vice-Chair in February of 2002 to attempt to settle the grievances which were then outstanding. These efforts were obviously unsuccessful. The settlement discussions led to another proceeding however, eventually all three grievances were scheduled for hearing before me. The Conflict of Interest The Conflict of Interest Directive is based on a regulation under the Public Service Act. The purpose of the Conflict of Interest Directive is to “enhance public confidence in the integrity of public servants and the decision making process in government…” A conflict of interest arises in “any situation where an individual’s private interests may be incompatible or in conflict with their public service responsibilities.” One of the principles every public servant shall conform to is set out in section 6(d) of the Conflict of Interest Directive as follows: “When appointed to office, and thereafter, public servants and public officials must arrange their private interests to prevent real or potential conflicts of interest. If a conflict does arise between the private interests of a public servant or public official and the official duties and responsibilities of that individual, the conflict shall be resolved in favour of the public interest.” Section 7(a) provides that “A public servant or public official who does not comply with the measures in this directive will be disciplined as appropriate. Disciplinary measures may include discharge or termination of employment.” The relevant parts of section 10 provide as follows: 24 A public servant or public official shall not engage in any outside work or business undertaking: (a) that is likely to result in a conflict of interest (b) that interferes with the individual’s ability to perform his or her duties and responsibilities; for example, by placing demands on the individual that are inconsistent with his or her duties or calling into question the individual’s responsibility to perform his or her official duties objectively (c) in which an advantage is derived from his or her employment as a public servant or public official … (d) in a professional capacity that will, or is likely to, influence or affect the carrying out of his or her duties as a public servant or public official Mr. Springman testified at some length about how he engaged in the exercise of determining whether Mr. Globerman was in a conflict of interest. It is useful to review a portion of his opinion letter to the Deputy Minister in order to appreciate the basis for his conclusion that Mr. Globerman was in a conflict of interest and how this situation should be remedied. After referring in some detail to Mr. Globerman’s public service position and the purpose and activity of the Foundation, Mr. Springman writes in his opinion letter dated June 12, 2000, as follows: ISSUES 1. Whether Mr. Globerman’s involvement in the Running to Daylight Foundation constitutes an actual, potential or perceived conflict of interest, in breach of the Public Service Act regulations and/or Ministry directives. 2. What action ought to be taken by the Ministry if it is determined that Mr. Globerman is in a conflict of interest. OPINION AND RECOMMENDATION Mr. Globerman’s role as the creator and active will of, and the public spokesperson for, a charity whose goals and policies may wholly or partly conflict with those of the Ministry places him in at least a perceived and potential conflict of interest, in breach of the Public Service Act regulations and/or Ministry directives. Accordingly, it is recommended that Mr. Globerman should be given the choice to either terminate all involvement with the Foundation or terminate his employment with the Ministry. The program area agrees with this approach. I have drafted a letter from you to Mr. Globerman reflecting this recommendation. 25 DISCUSSION Whether a conflict exists A conflict of interest may be actual, potential or perceived. A public servant should not engage in a private activity that constitutes any type of conflict. The requirement to avoid conflicts is particularly important for public servants, on whom a public trust is reposed. One of the goals of the Running to Daylight Foundation is stated as follows: To effect change at the system level by providing public education, stimulating discussion, fostering research, participating in the development of public policy, collaborating with planners and working with service providers, professional associations and regulatory bodies around issues relating to the access and quality of treatment and care of the elderly. In other words, the Foundation, through its “key spokesperson” Mr. Globerman, is involved in actively seeking “change at the system level” in order to advance the health- care interests of the elderly. Presumably, “participating in the development of public policy”, “building strategic partnerships with a broad range of stakeholders” and “addressing [the] shortcomings” of the “health care system” could easily involve Mr. Globerman in activities that pit his private interests at the Foundation against the interests of the Ministry. After setting out in his letter the “vision statement” of both the Foundation and the Ministry, Mr. Globerman states that “It is obvious that the Ministry’s and the Foundation’s goals are not incompatible rather they are basically the same”. Indeed, he concludes that “positive changes by any one of those entities could hardly be seen as in conflict”. However, for our purposes the proper focus ought not to be on the very broad “vision statement” or “goals” of the Foundation and the Ministry, however compatible Mr. Globerman assumes them to be. Rather, the essence of the possible conflict lies in the specific activities of both entities in actually implementing these goals and in the specific role played by Mr. Globerman in each entity. Mr. Globerman concludes his letter by stressing that the Foundation is “a viable organization representing the public interest” and, as such, “looks forward to working with the Ministry of Health to advance our health care system”. The letter makes clear the anticipated working relationship between the Foundation (his private interest) and the Ministry (his employer, and obviously representing the public interest). There is, however, clearly no guarantee that the Foundation and the Ministry will come to the same conclusions respecting what, if anything, is required to provide elderly people “with the highest quality care” (the Foundation’s Vision Statement) and, if action is needed, how to provide it. Accordingly, while Mr. Globerman’s Foundation has stated an interest in partnering with the Ministry in advancing the health care of the elderly, it is hardly inconceivable that the goals and actions of these two entities will clash, either in respect of specific policy initiatives or, indeed, globally. 26 Any such clash could result in the Foundation’s active pursuit of a “public policy” wholly or partly inimical to the policy or the other interests of the Ministry. In this connection, I should point out that the program area client who has dealt with Mr. Globerman has said that he is a passionate advocate of the right of the elderly. However commendable such a passion may be, as a public servant Mr. Globerman owes to the Crown a duty of good faith and loyalty and must not place himself in a position where his duties to the Ministry and his private interest compete, may potentially compete or may be perceived to compete. Having regard, therefore, to Mr. Globerman’s relatively broad range of advisory, fund allocation and other functions, including regular contact with stakeholders and the general public, a reasonable person may come to the conclusion that his role as a public servant conflicts or may conflict with his role as President of the Foundation. It is entirely possible that the Foundation would not endorse some or all Ministry decisions or the absence of any decisions, relating to the health care of the elderly. The perception may well be that this difference in opinion would or might influence or detrimentally affect Mr. Globerman’s ability to perform any ministerial duties, particularly his more public duties, that he sees as contrary to the goals of the Foundation. A further reasonable perception is that the Foundation has some unfair advantage over other charities as a result of Mr. Globerman’s position in the Ministry. For example, it may be thought that the Foundation has better access to decision-making within the Ministry and, therefore, to any funds that may be allotted to charities by the Ministry. From the Ministry’s perspective, Mr. Globerman’s dual employment and involvement in the Foundation may make it extremely difficult even to consider any future allocation of funds for the Foundation, since such action may give rise to a perception that the Foundation has derived an unfair advantage because of that employment. In connection with this kind of perceived identification or relationship with the Ministry, I should re-emphasize the fact that Mr. Globerman’s biography accompanying the creation of the charity specifically indicated that he was employed at the Ministry. It is a reasonable assumption that mention of his public service employment is intended to convey a particular message to potential donors and others, namely, that he has a kind of professional expertise or experience, and perhaps ministry “contacts”, that could benefit the Foundation and its goals and therefore that ought to instil a significant measure of confidence in those who might wish to contribute to the charity in some fashion. Again, a reasonable perception is that the Foundation, and Mr. Globerman, derive a private advantage from Mr. Globerman’s employment as a public servant. In short, Mr. Globerman’s involvement in the Foundation constitutes at least a perceived and potential conflict of interest, in violation of the Public Service Act regulations and Ministry directives. The program area agrees with the foregoing assessment and its implications. 27 The Remedy if a Conflict Exists Having determined that Mr. Globerman’s activities with the Foundation constitute at least a perceived and potential conflict of interest, the next issue concerns what action the Ministry ought to take. The mere existence of a conflict does not necessarily mandate a particular Ministry response. There are a number of obvious alternatives once it is determined that a conflict exists: 1. Mr. Globerman could be given the choice of either terminating all involvement with the Foundation or terminating his status as a public servant. 2. Mr. Globerman could be given the choice of either resigning as President of the Foundation and not involving himself in any of the decision-making activities of the Foundation (for example, as a member of the Board) or terminating his status as a public servant. 3. Mr. Globerman could be permitted to retain his presidency of and involvement with the Foundation, but could be prohibited from becoming involved in any Foundation decision, negotiation or matter that directly or indirectly involves the Ministry, particularly where the issue of Foundation funding by the Ministry or the Provinces is raised. 4. If Mr. Globerman is allowed to remain involved in some way with the Foundation (see options 2 and 3), the Ministry could impose as a condition a prohibition against identifying himself, either directly or indirectly, as a Ministry or Crown employee in any Foundation literature or activity. Alternative 1 is the remedy used most often, since its goal is the full elimination of the source of the conflict. It has been employed in previous conflict situations involving charitable involvement, although in virtually all of those cases the Ministry also served as at least a partial funder of the charity in question. Of course, the issue of possible Ministry or provincial funding or other support for the Foundation may well be raised by Mr. Globerman at some future date. In another case, Alternative 3 was used; however, this approach was adopted with some misgivings. This alternative is frequently used in the context of conflicts involving directors of private corporations. But it is certainly arguable that, in the public interest, public servants and the Ministry ought to be held (and almost invariably are held) to a higher standard than private citizens and private entities. Alternative 2 is a bit of a hybrid. On the one hand, it attempts to remove Mr. Globerman from the decision-making of the Foundation, but it also leaves him free to engage himself otherwise in its activities. Like Alternative 3, Alternative 2 has much to do with optics. In both cases, although in different degrees, to a significant extent we are left to trust that Mr. Globerman will not take part in any prohibited activity, despite his continued involvement in the Foundation. 28 Alternative 2 is more draconian, of course, since it effectively removes Mr. Globerman from decision-making that may, in fact, have nothing whatsoever to do with the Ministry and may possibly have no bearing on the public perception of the impact of his dual roles on his Ministry duties. Alternative 3, on the other hand, more specifically addresses the cause of the conflict, since it allows him to act as President, etc., but seeks to prohibit him from carrying on only those activities that involve the Ministry. The decision concerning which approach to adopt depends in no small measure on the individual in question. I understand from the client that, as a passionate advocate of the interests of the elderly Mr. Globerman has tended to show an insufficient sensitivity to the distinction between his Foundation role and his public service duties. Indeed, his letter to you indicated that he had invited the Minister to be the keynote speaker at the formal launch of the Foundation. He obviously did not perceive such an invitation as in itself inappropriate, nor did he see anything untoward for the Minister. Therefore, on balance, to permit Mr. Globerman to retain any position or involvement with the Foundation, however formally circumscribed, while remaining a public servant at the Ministry does not seem to be a reasonable option in the best interests of the Ministry or in the public interest. It is therefore recommended that Mr. Globerman should be given the choice to either terminate all involvement with the Foundation or terminate his employment with the Ministry. The program area agrees with this approach. I would be pleased to discuss this matter with you further, at your convenience. As noted previously, the parties engaged in attempts to resolve the conflict of interest dispute between February and May of 2001, subsequent to the Deputy’s directive. During this process, the parties spent some time exploring the issue in detail. Mr. Globerman and his representatives took advantage of the opportunity to make proposals with a view to convincing the Ministry that there was no conflict of interest or that it could be managed if there was a conflict. The Ministry gave due consideration to the submissions that were made on behalf of Mr. Globerman. The evidence discloses that the Ministry even considered options that were not advanced by Mr. Globerman’s representatives. At the end of the process, the Ministry continued to be of the view that Mr. Globerman’s activities with the Foundation constitute a perceived and potential conflict of interest. The process concluded with the Ministry’s response as set out in Ms. Weber’s letter dated April 23, 2001 to the two options proposed by Mr. Globerman. The relevant portion of the response reads as follows: 29 … It is the Ministry’s view that neither proposed option would serve to remove the conflict of interest. Your proposal to maintain your involvement with the Foundation, even on a reduced level, and particularly your intention to focus on fundraising and on responding to questions from the public, continue to be problematic in light of the nature and scope of the conflict. Both activities reflect your ongoing public identification with the Foundation while you remain a public servant with the Ministry. Moreover, we do not agree with the opinion of your counsel that either option would place you in the same position as a “volunteer” for any kind of health care entity. In the ordinary case, a volunteer has no formal institutional connection with the creation of the particular organization and is not, in essence, the directing or controlling mind of that body in terms of its overall “vision” and “goals” and its day-to-day activities. At the heart of the conflict is not simply your formal status as President, nor your overtly public identification with the Foundation. Rather, the essence of the conflict lies in the inherent tension between your public service duties and the “vision”, “goals” and policies of the Foundation in which you will continue to have a central, although somewhat reduced, role, even under either proposed option. The courses of action actively advanced by the Foundation may well come in conflict with those adopted or considered by the Ministry. These Ministry policies are ones for which you are or may be directly or indirectly responsible as a public servant. … The central issues before me are whether there was at least a perceived or potential conflict of interest between Mr. Globerman’s involvement with the Foundation and his role as a public servant, and whether the direction from the Deputy Minister which was confirmed by the Ministry in Ms. Weber’s letter of April 23, 2001, was a reasonable response in the circumstances. The Association and Mr. Globerman do not challenge the validity of Regulation 453/97 under the Public Service Act and the Conflict of Interest Directive. They do not dispute that Mr. Globerman owes a duty of fidelity and loyalty to his Employer. What they do challenge is their application to Mr. Globerman and his involvement with the Foundation in the circumstances of this case. As noted previously, the Association takes the position that the Deputy’s directive to Mr. Globerman violates his Charter rights and cannot be justified under section 1 of the Charter. The Ministry takes the position that any infringement of Mr. Globerman’s Charter rights constitutes a reasonable and justifiable limit in the circumstances. 30 The relevant provisions of the Charter are as follows: 1. The Canadian Charter of Rights and Freedoms guarantees the rights and freedoms set out in it subject only to such reasonable limits prescribed by law as can be demonstrably justified in a free and democratic society. 2. Everyone has the following fundamental freedoms: (a) freedom of conscience and religion; (b) freedom of thought, belief, opinion and expression, including freedom of the press and other media of communication; (c) freedom of peaceful assembly; and (d) freedom of association. During their extensive submissions on the Charter issue, counsel referred to a number of decisions. Counsel for the Ministry relied on the following decisions: Re Ministry of Attorney General, Corrections Branch and British Columbia Government Employees’ Union (1981), 3 L.A.C. (3rd) 140 (Weiler); Re Canada Post Corporation and Canadian Union of Postal Workers (1984), 19 L.A.C. (3rd) 356 (Swan); Re Amoco Fabrics Ltd. and Amalgamated Clothing and Textile Workers Union, Local 1606 (1984), 17 L.A.C. (3rd) 425) (O’Shea); Fraser v. Canada (Public Service Staff Relations Board), [1985] 2 S.C.R. 455; Forgie and Treasury Board (Immigration Appeal Board), [1986] C.P.S.S.R.B. No. 310 (Bendel); Re British Columbia and B.C.G.E.U. (1988), 14 C.L.A.S. 1 (Ladner); Re Gilbert Plains Health Centre Inc. and M.O.N.A., Local 38 (1989), 15 C.L.A.S. 72 (Hamilton); Port Moody, District 43, Police Services Union v. Port Moody District Police Board, [1991] B.C.J. No. 243 (B.C.C.A.); Re Sun-Rype Products Ltd. and Teamsters Union, Local 213 (1994), 34 C.L.A.S. 630 ( Taylor); Re Alberta and A.U.P.E., Loc 6 (Smith) (1996), 57 L.A.C. (4th) 400 (Moreau); Re Burnaby (City) and Burnaby Firefighters’ Assn., Loc 323 (Kilpatrick) (1997), 66 L.A.C. (4th) 169 (Devine); Re Philip Utilities Management Corp. and I.U.O.E., Loc. 772 (Gorda) (2000), 86 L.A.C. (4th) 225 (Rose); Scott v. 31 Canada Customs and revenue Agency, [2001] C.P.S.S.R.B. No. 60 (Giguere); Re Treasury Board (Health Canada) and Chopra (2003), 124 L.A.C. (4th) 149 (P.S.S.R.B); Stenhouse v. Canada (Attorney General), [2004] F.C.J. No. 469; Haydon v. Canada (Treasury Board), [2004] F.C.J. No. 932; Read v. Canada (Attorney General), [2005] F.C.J. No. 990; Re British Columbia Public School Employers’ Association and British Columbia Teacher’s Federation (2004), 129 L.A.C. (4th) 245 (Munroe); and, Haydon v. Canada (Treasury Board), [2004] F.C.J. No. 932. In addition to the Fraser decision, counsel for the Association relied on the following decisions: Osborne v. The Queen and two other actions (1991), 82 D.L.R. (4th) 321 (S.C.C.); Re Treasury Board (Indian and Northern Affairs Canada) and Horn (1992), 32 L.A.C. (4th) 250 (P.S.S.R.B.); Re Treasury Board (Health Canada) and Chopra (2001), 96 L.A.C. (4th) 367 (P.S.S.R.B.); Haydon v. Canada (T.D.), [2001] 2 F.C. 82; Alberta Union of Provincial Employees v. Alberta, 2002 ABCA 202 (CanL11) (Alta C.A.); Re Hallborg and The Crown in Right of Ontario (Ministry of Revenue) (1979), 22 L.A.C. (2nd) 289 (G.S.B.); and, Ross v. New Brunswick School District No. 15 (1996), 133 D.L.R. (4th) 1 (S.C.C.). The majority of these decisions can be described as “criticism cases”. They are cases in which an employee, often a public servant, was disciplined for being publicly critical of his or her employer. For example, in Fraser, supra, a pre-Charter decision, a supervisor employed by Revenue Canada was suspended and then terminated for criticizing policies concerning metrification and the constitutional entrenchment of a charter of rights. The Public Staff Relations Board found that the discharge was appropriate and the decision was upheld by the Supreme Court of Canada. The Court noted that the right to free expression is not absolute and that the importance of maintaining an impartial public service and the duty of loyalty must be 32 balanced with an employee’s right to freedom of expression. The result of this balancing of rights depends on the circumstances of the particular case. In the world of the Charter, a similar balancing of interests takes place. One of the disputes between the parties is whether the instant case can be characterized as a criticism case. Counsel for the Employer relied on the criticism cases when arguing that Mr. Globerman was critical of the Government and therefore breached his duty of loyalty to the Crown. Although there can be an overlap between the two types of cases, there is a difference between a criticism case and a conflict of interest case. In the instant case, Mr. Globerman did not simply engage in public commentary on Government policy, as occurred in Fraser. Rather, through the Foundation, he engaged in outside activities that allegedly gave rise to a conflict of interest concern. Although troubled by the interviews he gave to the press and the articles that were written, the Employer did not discipline him for being critical of the Government. The Ministry treated the case at hand as a conflict of interest case by comparing his outside activities and his role as a public servant. This is clearly the focus of Mr. Springman’s opinion letter to the Deputy Minister. As counsel for the Association pointed out, Mr. Springman does not even refer to Mr. Globerman’s public statements relating to the Foundation. I will therefore consider this as a conflict of interest case in the classic sense and that the issues before me are those described previously. This does not mean that Mr. Globerman’s public statements on behalf of the Foundation are irrelevant. In my view, they are relevant to the extent that they assist in illustrating the goals and the activities of the Foundation. The criticism cases are of assistance only to the extent they provide some guidance in addressing the issues that arise in a conflict of interest case. 33 During his submissions, counsel for the Association noted that Mr. Springman was not an expert witness and that he was an advocate for the Ministry in this case. For various reasons, counsel argued that I should give little or no weight to the opinion Mr. Springman gave to the Deputy Minister. For example, he emphasized that Mr. Springman was working with a job description that did not describe Mr. Globerman’s position and that he incorrectly determined that Mr. Globerman performed certain functions, particularly with respect to fund allocation. Counsel submitted that, having heard the evidence, I was in the best position to determine the relevant facts and whether a conflict of interest exists in this case. I certainly agree that I must determine the facts and the result in this case based on the evidence before me. Whether or not Mr. Springman relied on inaccurate information is not particularly relevant because my task is to decide, based on the evidence, whether Mr. Globerman was in at least a perceived or potential conflict of interest because of his activities with the Foundation. Mr. Springman’s opinion is not determinative of this issue. In determining whether a conflict exists within the meaning of the Conflict of Interest Directive, it is necessary to focus on the job of the public servant and the nature of public servant’s outside activities. The Courts have recognized as legitimate the objective of Government to maintain an effective and impartial public service. The purpose of the Conflict of Interest Directive is designed in part to achieve that end. As noted by Mr. Springman, a conflict of interest may be actual, perceived or potential. Certainly, a perceived or potential conflict of interest can detrimentally affect the effectiveness and impartiality of the public service. An assessment of whether a conflict exists on any of these levels must be made objectively using the test of a reasonable well-informed person. 34 What is particularly significant about Mr. Globerman’s job is that he is employed by the Ministry in the Toronto Region. As a senior financial consultant working as the lead in the mental health program, he analyzes financial matters, primarily for the CAMH, and to a lesser extent for other mental health agencies. These health entities provide services to a population that includes the elderly. In essence, Mr. Globerman is involved with the financial allocation process with respect to the CAMH, which involves at least a $160 million operation. He analyzes funding and budget requests and brings forward his analysis of budget requests to senior management. He analyzes one time and surplus requests for community health programs on Toronto. At the request of senior management, he will produce financial requests tables to support their decisions. Mr. Globerman is not directly responsible for the allocation of funds. However, senior management relies on his analysis and recommendations regarding the allocation of funds within the mental health program in the Toronto Region. In performing his functions, Mr. Globerman is required to have knowledge of health care policy. By his attendance at staff meetings, he would be privy to discussions about Ministry policy, funding issues and funding strategies in the Toronto Region, and within the Ministry generally. Mr. Globerman’s duties do not involve him in simply “crunching numbers”, as argued by counsel for the Association. His responsibilities involve funding issues and the proper use of financial resources as dictated by Ministry policy for the mental health program in the Toronto Region. The Foundation is a relatively small charity whose general goal is to improve the medical treatment and care received by the elderly. Although a relatively small charity, Mr. Globerman has been able to obtain the support and participation in the Foundation of persons with a high public profile. Partly for this reason and because the focus of the Foundation is on health care, Mr. Globerman and the Foundation have been able to achieve a relatively high public profile through coverage in the media. 35 Mr. Globerman’s role with the Foundation is quite different from that of a volunteer. He created the Foundation. He is the President and primary spokesperson for the Foundation. He initiates all of the activities of the Foundation, including fund raising. As the evidence amply demonstrates, the Foundation would not likely exist but for the involvement of Mr. Globerman. And there is also no doubt that through the Foundation he is a passionate advocate for the elderly. He is very strongly committed to achieving the goals of the Foundation. The goals of the Foundation are quite broad. One of its objectives is to assist in the provision of patient representatives to help the elderly in dealing with issues that might arise in an institutional setting. Other goals are more policy orientated. One of the goals is to effect change at the system level by means that include participating in the development of public policy and collaborating with service providers and regulatory bodies about issues that deal with the treatment and care of the elderly. At the launch of the Foundation in October of 1999, Mr. Globerman identified himself as a financial consultant with the Ministry. As noted previously, he indicated that, “He has worked on a number of health care issues in the Ministry’s mental health, substance abuse and corporate policy areas…” Subsequent newspaper articles referred to his public service position, thereby also linking that role with his position with the Foundation. Although he subsequently undertook to stop referring to his position as a public servant with the Ministry when engaging in Foundation activities, it is almost impossible to eliminate the association once it has been made, particularly within the community in which the Ministry and the Foundation operate. 36 After reviewing Mr. Globerman’s role as a public servant and his activities with the Foundation, it is my conclusion there was at least a perceived and potential conflict of interest between these two roles. At a very basic level, Mr. Globerman was working as a financial consultant with a Ministry that funds, administers and to a degree regulates the health care system in the Province of Ontario. Although their may be some commonality in the general goals of the Ministry and the Foundation, the central message of the Foundation is that the health care system is not meeting the needs of the elderly. One of the goals of the Foundation is to address the health care needs of the elderly at the system level. Mr. Globerman was quoted as saying in an Ottawa Citizen article on November 23, 1999, that there would not be a need for the Foundation if the health care system was working the way it should. Through the Foundation, Mr. Globerman is a passionate advocate for the elderly. A reasonable person could only view this situation as creating at least a perceived or potential conflict of interest. I agree with Mr. Springman’s assessment that it is inevitable that a conflict will arise over the implementation of specific policies. Indeed, there is evidence in this proceeding that illustrates that the Foundation has taken issue publicly with some of the Ministry’s policies that affect the elderly. One need only examine the submission the Foundation made to the Standing Committee on February 13, 2001, many months after the Deputy’s directive, to see examples of where the Foundation has disagreed with the Ministry. As preciously noted, Mr. Globerman wrote the submission that was presented to the Standing Committee by Ms. Hawtin. There is a clear indication in the submission that the Foundation believes that the standards of health care are being adjusted to what the Ministry is willing to finance as opposed to adjusting finances to meet the standards. Reference is made of some specific problems, namely the cut back of approximately ten thousand nursing positions, the number of elderly people who are experiencing the schedule of night time dialysis and the many patients who have to travel to the 37 United States for cancer treatment. Reference is made in the submission to not having enough safeguards built into the system and to the lack of regulation for health care providers. Reference is made also to the fact that the ultimate responsibility for guaranteeing access to the highest quality care has to lie with Government, which is where the buck stops. These examples serve to demonstrate that becoming an advocate for better health care will inevitably lead to a conflict with the Ministry. After examining the Foundation’s perspective on the issues referred to in the submission to the Standing Committee, a reasonable person would have little difficulty in recognizing that there is at least a perceived conflict of interest, and perhaps even an actual conflict, between Mr. Globerman’s activities with the Foundation and his role as a public servant. It is not particularly surprising that a reporter would think it ironic that Mr. Globerman works as a financial consultant with the Ministry, given the goals and activities of the Foundation. Although there is no indication that Mr. Globerman’s views on how the health care system treats the elderly has an impact on how he performs his duties as a senior financial consultant, a reasonable perception is that the recommendations he makes to senior management in the Ministry might be influenced by his private advocacy role with the Foundation. The fact that he would hold particular views on the health care received by the elderly, even if there were no Foundation, misses the point because he does engage in private activities through a Foundation that operates openly. The identification of Mr. Globerman as a public servant with the Ministry creates a reasonable prospect that people would believe that the Foundation has an advantage over other charities because he has access to information and individuals which others outside of Government do not. Whatever his reason for identifying himself as public servant with the 38 Ministry, a reasonable perception is that the Foundation, his private interest, benefits from such a connection. Counsel for the Association submitted that Mr. Springman’s opinion and the Deputy’s directive are suspect because neither refers to Mr. Globerman’s Charter rights and the balancing exercise that is necessary for a section 1 analysis, as mandated by the Courts. Although not mentioned explicitly, it is clear that the Ministry was engaged in balancing the appropriate interests and rights when they considered various options to determine whether the conflict could be eliminated or managed. After considering various options presented on behalf of Mr. Globerman, and other options as well, the Ministry concluded that the solutions proposed did not eliminate the conflict of interest and that the only recourse it had in the circumstances was to direct Mr. Globerman to comply with the Deputy’s directive. Given Mr. Globerman’s passionate advocacy for the elderly and the fact that he is the heart and soul of the Foundation, the Ministry determined that the proposed options did not adequately address the perceived and potential conflict of interest. In my view, the Ministry properly concluded that the goals and the activities of the Foundation remained unchanged in any of the proposals and that Mr. Globerman would continue to have a central role in the Foundation. Given that Mr. Globerman’s involvement with the Foundation placed him in at least a perceived or potential conflict of interest, the Ministry was obliged and entitled under the Conflict of Interest Directive to take steps to protect the impartiality and integrity of the public service. The directive of the Deputy Minister does infringe on Mr. Globerman’s rights to freedom of expression and association. However, in balancing the Ministry’s and the public’s right to an impartial and effective public service with Mr. Globerman’s Charter rights, I am satisfied, taking into account the three aspects of the proportionality requirement, in particular 39 the test of minimal impairment, that the Ministry has established that the Deputy’s direction to Mr. Globerman constitutes a reasonable limit to his Charter rights in the circumstances. Under any of the proposed options, Mr. Globerman would continue to have a central role in the Foundation, giving rise to at least a perceived or potential conflict of interest. There are some outside activities in which public servants cannot engage and, given his position with the Ministry, Mr. Globerman’s involvement with the Foundation falls into this category. Accordingly, Mr. Globerman’s grievance dated May 1, 2001 is hereby dismissed. As will become evident later, I note that the resolution of the conflict of interest issue is not determinative of whether the Ministry had just cause to discharge Mr. Globerman. The Reprimand Ms. Weber was concerned when she reviewed the article “Live or Let Die” in the September of 2001 edition of Homemakers magazine because it appeared that Mr. Globerman continued to be active with the Foundation. She wrote him asking a number a questions relating to his involvement with the article. In his written response, Mr. Globerman advised her that he gave the interview in early 2000, before he received any direction from the Ministry, and that he did not know when the article would be published. He confirmed that he did not attempt to dissociate himself from the article. Mr. Globerman confirmed this response during his testimony. He testified that he was unaware of the article until Ms. Weber brought it to his attention. Mr. A. Outar issued the letter of reprimand dated October 24, 2001. The text of the letter reads as follows: 40 RE: Letter of Reprimand - Insubordination Further to our telephone discussion this letter is to outline my concern regarding your decision to not follow through on the conditions outlined to you in the letter of April 23, 2001, from the Regional Director of Toronto Region in relation to your activities with The Running to Daylight Foundation. As indicated in previous letters concerning your activities with The Running to Daylight Foundation, you were directed to refrain from any public advocacy on behalf of the Foundation and/or its goals or policies; to refrain from any public speaking about the Foundation and/or its goals or policies or about the health care system and to refrain from any contact with the media concerning the Foundation and/or its goals and objectives. As you have admitted many times during our discussion and have indicated in your response of September 12, 2001, you did not make any attempt to disassociate yourself or your connection to your Foundation from the article in the September issue of Homemakers magazine titled Live or Let Die. You have not removed yourself from the conflict of interest as directed by the Deputy Minister in his correspondence dated June 28, 2000 and agreed to by you in the letter from Kate Stephenson dated May 30, 2001. This is a letter of reprimand which will be placed in your corporate file. Your actions constitute blatant insubordination to the directive you have received from both management and the Deputy Minister. Further actions on your part that perpetuate this conflict of interest will result in further disciplinary action, up to and including dismissal. Although there is some indication that the Ministry attempted to determine whether Mr. Globerman’s responses to Ms. Weber’s questions were truthful, there was no evidence called to contradict Mr. Globerman’s testimony about his involvement with the article in question. He was interviewed for the article by telephone many months before he disclosed the potential conflict of interest and before the Deputy Minister gave his directive in June of 2001. Mr. Globerman did not know when or if the article would appear in the magazine. Given the number of interviews he gave subsequent to the launch of the Foundation, there was no reason why this particular interview would stand out in his mind. The April 23, 2001 letter from Ms. Weber that is referred to in the reprimand letter sets out conditions for Mr. Globerman, but it is implicit that these conditions only applied until May 31, 2001, when Mr. Globerman was to cease any active involvement with the Foundation. In any event, at no time did the Ministry specifically direct Mr. Globerman to dissociate himself from any of his earlier contacts with the media. Although 41 the Ministry had become somewhat frustrated with Mr. Globerman and concerned about his credibility, characterizing his conduct in this instance as “blatant insubordination” is rather extreme. In my view, it is difficult to attach any fault to Mr. Globerman for the article in question. It is my conclusion that the Ministry did not have just cause to issue him a reprimand in these circumstances. The Discharge The discharge letter dated December 8, 2003, which I previously reproduced, refers to a number of matters, some of which I will note again. It refers to the Deputy’s directive and to the fact that Mr. Globerman had advised the Ministry that he had resigned as President of the Foundation and had ceased any active involvement with the Foundation. It notes that Mr. Globerman did not cease his activities with the Foundation. It refers to the Foundation’s and Mr. Globerman’s participation in the Forum, his relationship with the Ontario Coalition of Senior Citizens Organizations and the interview Mr. Globerman gave for the article which subsequently appeared in the Toronto Star. It refers to Mr. Globerman’s failure to disclose his activities with the Foundation to Ms. Esteves or to the relevant Deputy Minister. It refers to the Ministry’s conclusion that Mr. Globerman’s conduct constitutes insubordination. It also refers to the Ministry’s conclusion that Mr. Globerman breached his duty of trust, among other things, and has undermined the employment relationship to the point where his continued employment was no longer possible. From the time when Ms. Weber raised the conflict of interest issue with Mr. Globerman and advised him of his duty to disclose, Mr. Globerman has never believed that his activities with the Foundation created a conflict with his position as a public servant. Although not a position advanced by the Association in this proceeding, Mr. Globerman believes the Ministry 42 was acting in bad faith on the conflict of interest issue. Indeed, he came to believe the Ministry and the Government were engaged in a political conspiracy to interfere with and stop the work of the Foundation. Presumably, Mr. Springman, the Deputy Minister, Ms. Weber and Mr. Outar would have had to participate in this conspiracy. However, there is simply no evidence to indicate that the Ministry was acting in bad faith when it determined that Mr. Globerman was in a conflict of interest or that there was a political conspiracy to frustrate the work of the Foundation. Given the Deputy Minister’s directive and the Ministry’s conclusion that the conflict could not be managed, Mr. Globerman had a choice to make. He had to choose between continued participation with the Foundation or his career as a public servant. It would have been quite clear to Mr. Globerman that he likely would have been disciplined and perhaps eventually discharged if he did not give up his Foundation activities. In May of 2001, Mr. Globerman, through counsel, advised the Ministry that he resigned as President of the Foundation, that his brother was the new President and that he had ceased any active involvement in the Foundation. In so advising the Ministry, Mr. Globerman was following the well known arbitral dictum of obey now and grieve later. It is likely that he received advice from his lawyer and the Association when he elected to take this course of action. He grieved the directive of the Deputy Minister and he led the Ministry to believe that he was no longer active with the Foundation and that this would continue until a determination was made on his grievance. Although his Foundation activities may have may have been reduced to some degree during of his medical leave, the evidence indicates that Mr. Globerman did not cease his activities with the Foundation. He had advised Ms. Weber that he needed until May 31, 2001 to make arrangements for others to take over his Foundation duties. There is no evidence to 43 indicate that Mr. Globerman’s brother took over as President of the Foundation or that any other arrangements were made for the Foundation to continue functioning without Mr. Globerman. While off on medical leave, Mr. Globerman continued to counsel individuals who sought advice about elderly relatives in hospitals or long term care facilities. In early 2003, Mr. Globerman began planning for the Forum that was to take place in September of 2003 and he continued working on the Forum while employed as a Policy Advisor with the OSS. Mr. Globerman spoke at the Forum on behalf of the Foundation and he dealt with the media as President of the Foundation. An interview he gave led to an article in the Toronto Star. Ms. Esteves knew Mr. Globerman as a colleague from her time at the Ministry and she was interested in exploring the possibility of a temporary assignment. Before her meeting with Mr. Globerman, Mr. Outar told her about the conflict of interest issue and the directive from the Deputy Minister. She also discussed this matter with Ms. J. Myers, an E. R. Consultant with the Ministry. Ms. Esteves was concerned about the conflict of interest issue and she wanted to ensure that Mr. Globerman was not in a conflict situation and that he was complying with the directive from the Deputy. After discussing such matters as the role of the OSS, the duties of a policy advisor and Mr. Globerman’s skills at the meeting on May 29, 2003, Ms. Esteves testified that she raised the conflict of interest issue with Mr. Globerman. She testified that she told him that she was aware of the Deputy’s directive and that he would have to disclose any involvement with the Foundation. She also stated that she asked him about the status of the Foundation and whether he was still involved with it. She testified that Mr. Globerman said he understood her concern but that he was not doing anything with the Foundation, that the Foundation was inactive and that the Foundation was not going to be an issue. 44 Mr. Globerman’s version of what was discussed about the conflict of interest issue and the Foundation at the meeting is quite different. He testified that he raised the conflict of interest issue to explain what he had been through and how poorly he had been treated by the Ministry. He indicated that he told her that there was no conflict of interest and that the entire matter was politically motivated. He claims that the only thing discussed about the Foundation was that he was precluded from having any involvement with the Foundation when there was no conflict of interest. Mr. Globerman specifically denied that he was asked by Ms. Esteves about his current role with the Foundation and whether the Foundation was active. When asked during his evidence in chief about why he did not tell Ms. Esteves that he was actively involved with the Foundation and still President, he replied that he was never asked by her about this and because Mr. Outar had confirmed to him during their discussion on March 25, 2002, that the concern about his Foundation activities had nothing to do with a conflict of interest. In submitting that I should accept Mr. Globerman’s version of his discussion with Ms. Esteves, counsel for the Association submitted that it is highly improbable that Mr. Globerman would indicate that the Foundation was inactive when he would expect that his involvement with the Forum would eventually come to the attention of Ms. Esteves and Ministry officials. I agree that it is somewhat surprising that Mr. Globerman would say that the Foundation was inactive in these circumstances and will comment further about this later. However, I have no hesitation in accepting Ms. Esteves’s version of the discussion that occurred on May 29, 2003. There is no reason for Ms. Esteves to mislead me about what Mr. Globerman said to her at that time. She was aware of the conflict of interest issue before her meeting with Mr. Globerman and she knew about the directive of the Deputy Minister. In order to avoid any conflict of interest issues for the OSS, it is not surprising that she would ask Mr. Globerman about his status with the Foundation. It is very probable that Mr. Globerman would not have been offered the temporary 45 assignment if he told her that he was still active with the Foundation, contrary to the Deputy’s directive and his undertaking. I believe Ms. Esteves when she stated that she told Mr. Globerman that he would have to disclose any conflict of interest and that Mr. Globerman told her that the Foundation was not active and that the Foundation would not be a problem. Ms. Esteves saw a flyer referring to the Forum late in the day on Friday, September 19, 2003. The flyer noted the subject of the Forum and indicated that it was co-sponsored by the Foundation and the Ontario Coalition of Senior Citizens Organizations, a major stakeholder of the OSS. She testified that at that moment “her heart sank” and she was “shocked and disappointed”. She immediately confronted Mr. Globerman and asked why he did not tell her he was organizing the Forum and pointed out that he had told her the Foundation was inactive. Mr. Globerman told her that he was fed up, that there was no conflict of interest and that he had a right to be involved with the Forum on his own time. I accept Ms. Esteves’s testimony that she did not realize at the time that Mr. Globerman would be speaking at the Forum. She advised Mr. Globerman that she would be consulting with the Assistant Deputy Minister. Ms. Esteves did not specifically direct Mr. Globerman not to attend the Forum. Contrary to the submission from counsel for the Association, it is my view that her failure to so direct him is not significant in the circumstances. In my view, it would have been clear to Mr. Globerman that Ms. Esteves did not want him to participate in the Forum and that his doing so was contrary to the Deputy’s directive and his undertaking. Ms. Esteves briefed the Assistant Deputy Minister and told the Human Resources Branch about the situation. She asked one of her staff to attend the Forum and this person advised her that Mr. Globerman was a speaker at the Forum. The Toronto Star article about the Forum and the Foundation came to her attention on September 26, 2003. She again met with Mr. 46 Globerman and asked him why he did not tell her that he would speak at the Forum and why he did not tell her about what was still to come. He told her that while at the Forum he did not indicate that he was an employee of the OSS and that he was not critical of the Government. Ms. Esteves testified that many of the individuals who attended the Forum knew that Mr. Globerman worked for the OSS and that she believed that he had been critical of the Government. Ms. Esteves felt betrayed by Mr. Globerman. Ms. Esteves recommended that the temporary assignment with the OSS be terminated because Mr. Globerman had not been truthful with her and she believed that his credibility with stakeholders of the OSS had been permanently damaged. In a letter to Ms. Weber and Mr. Outar dated October 6, 2003, she summarized her position on this issue as follows: The Ontario Coalition of Senior Citizens Organizations (OCSCO) is a key stakeholder of the Ontario Seniors’ Secretariat. The OCSCO is one of eight members of the Ontario Seniors’ Secretariat Liaison Committee that meets on a regular basis with the Ontario Seniors’ Secretariat. As a result of Mr. Globerman’s actions, I can no longer trust that Mr. Globerman is able to exercise the judgment required of the Policy Advisor position. The Policy advisor position requires frequent interface with external stakeholders for the purpose of participating on working groups and committees and recommending policy positions as well as consulting with external stakeholders in an appropriate manner through an understanding of political sensitivities across Ministries and sectors. The investigation meeting that took place on November 7, 2003, lasted at least 1 ½ hours. The parties discussed events that occurred since the Deputy’s directive up to the Forum and the Toronto Star article. Among other things, Mr. Globerman indicated that he started working with the Ontario Coalition of Senior Citizen Organizations during the summer of 2003. He also indicated that he had a legal right to operate the Foundation, that the Deputy’s direction was a violation of his human rights, that there was no conflict of interest and that he was under duress when he resigned from the Foundation. He stated that he did not disclose that the Foundation was active to Ms. Estaves because he did not want any hassle. Mr. Globerman did 47 not mention at this meeting the comments he attributed to Mr. Outar during their March 25, 2002 discussion as a justification for his conduct. Mr. Globerman was asked by his counsel why he organized and participated in the Forum in light of the Deputy’s directive and his previous involvement with the conflict of interest issue. He responded that there were two reasons. One was that he had been contacted by many people from across Canada who described horror stories about the treatment of the elderly in the health care system and that it was important to provide people with an opportunity to share their experiences. The other reason was that he had come to realize that the “charges against him were trumped up” and “were bogus”. To support this view he relied on the conduct of the Ministry, particularly its unwillingness to negotiate reasonably the conflict of interest issue. He also indicated again that his views were confirmed by Mr. Outar during their discussion on March 25, 2002. In essence, Mr. Globerman relied on his belief that the conflict of interest issue was contrived and politically motivated as justification for his continued involvement with the Foundation. It is my conclusion after reviewing the evidence and considering the submissions that the allegations against Mr. Globerman in the Employer’s discharge letter of December 8, 2003, are well founded. In the face of the Deputy’s directive and warnings from the Ministry that a failure to comply with this directive could result in discipline, Mr. Mr. Globerman did not remain inactive in the Foundation. His activities in connection with the Forum amply demonstrate that he was very active in the Foundation and, as far as the Ministry and the OSS were concerned, secretly so. By engaging in these Foundation activities, Mr. Globerman failed to comply with the representation he made to the Ministry to the effect that he would not be active in the Foundation until his grievance was resolved. By failing to comply with the Deputy 48 Minister’s directive dated June 28, 2000, and the subsequent direction from the Ministry, Mr. Globerman was insubordinate. Counsel for the Association argued that Mr. Globerman could not be disciplined for insubordination because Mr. Globerman was not obliged to obey now and grieve later in these circumstances. In support of this submission, counsel referred to the following decisions: Re British Columbia Telephone Co. and Telecommunications Workers Union (1997), 15 L.A.C. (2nd) 426 (Larson); Re Auto Haulaway Ltd. and Teamsters Union, Local 938 (1994), L.A.C. (4th) 76 (Rayner); Re Sudbury Broadcasting Co. Ltd. and National Association of Broadcast Employees & Technicians (1972), L.A.C. 130 (O’Shea); and, Re Wilson Erectors ltd. and International Union of Operating Engineers, Local 793 (1972), L.A.C. 418 (O’Shea). These cases deal with exceptions to the general rule that an employee must comply with a management directive and then grieve. Given the determination that the Ministry was within its rights to direct Mr. Globerman to make a choice between the Foundation and his position as a public servant, the submission becomes academic. However, even if the Ministry did not have the right to make such a direction to Mr. Globerman, it is not clear that the general rule of obey now and grieve later would not apply. In any event, the submission is not relevant to these circumstances because Mr. Globerman followed the rule and led the Ministry to believe that, in effect, he would not engage in Foundation activities until the conflict of interest dispute was resolved. Having undertaken to comply with the Deputy’s directive, Mr. Globerman cannot now claim that he was under no obligation to remain inactive in the Foundation until his grievance was resolved. 49 Mr. Globerman did not disclose his activities with the Foundation to Ms. Esteves or to the Deputy Minister of the Ministry of Citizenship. As previously noted, it is my conclusion that Ms. Esteves had advised him about his obligation in this regard during their meeting on May 29, 2003. Even if she had not done so, Mr. Globerman was now well aware of his obligation to disclose under the Conflict of Interest Directive when he engaged in outside activities that could be a conflict of interest. There is no doubt that Mr. Globerman, as a policy advisor with the OSS, was obliged to disclose his activities with the Forum, including his association with the Ontario Coalition of Senior Citizens Organizations, a major stakeholder for the OSS. In my view, he did not disclose this information about a significant public event because he recognized that the OSS would consider his outside activities to be inappropriate. The failure to disclose pursuant to the Conflict of Interest Directive is itself a basis for the imposition of discipline. In addition to failing to comply with his undertaking, his insubordination in the face of the Deputy’s directive and his failure to disclose his activities in connection with the Forum, Mr. Globerman did not tell Ms. Esteves the truth when told her the Foundation was inactive. It is trite to point out that an employee is obliged to tell the employer the truth at all times, but particularly in circumstances involving important issues. The failure to tell the truth can have a significant effect on the viability of an employment relationship. It is not surprising that Ms. Estaves felt betrayed by Mr. Globerman and decided to terminate the temporary assignment. Mr. Globerman’s actions and lack of action referred to above constitute serious misconduct. It is my conclusion that the Employer has established that it had just cause to discharge Mr. Globerman for this misconduct. 50 Counsel for the Association made a number of forceful submissions to the effect that the penalty of discharge should be substituted with a lesser penalty. Among other things, he referred to Mr. Globerman’s age, the absence of a disciplinary record, his years of service and the fact that all of his misconduct was focused on his involvement with the Foundation. After considering all of the factors relevant to this issue, it is my conclusion that the substitution of a lesser penalty would not be appropriate in the instant case. In addition to the seriousness of his misconduct, Mr. Globerman does not acknowledge his misconduct, nor does he demonstrate any remorse for his behaviour. Without any valid proof, he is prepared to make the serious allegation that the Government of the day was engaged in a political conspiracy against him and the Foundation because it did not want the issue of sub- standard elder care to be publicized. What is particularly noteworthy is his lack of honesty. Mr. Globerman was dishonest with the Ministry and with Ms. Esteves. He undertook, in effect, to refrain from Foundation activities, but elected to continue with those activities without advising the Ministry or the OSS that he was doing so. He advised Ms Esteves during their May 29, 2003 meeting that the Foundation was inactive and that he was not doing anything with the Foundation when he was engaged in planning the Forum, a significant public event. He attributed comments to Mr. Outar which he then relied on to justify continuing his activities with the Foundation and for not disclosing these activities. As I noted earlier, I found his testimony about what Mr. Outar allegedly said to him about the conflict of interest issue during their March 25, 2002 meeting to be a complete fabrication. Mr. Outar did not confirm to him, explicitly or implicitly, that the real dispute between them was based on the Foundation’s focus on the medical system’s sub-standard care of the elderly, and not on a conflict of interest. It is one thing to suggest that the Ministry 51 was not acting in good faith. It is quite another to suggest falsely that someone in Mr. Outar’s position confirmed to him that the Ministry was not acting in good faith. Not only was Mr. Globerman dishonest with his Employer, but he did not testify truthfully about some aspects of these matters. In my view, the nature of his misconduct and the dishonesty with his Employer has resulted in a situation where the Employer can no longer trust Mr. Globerman, thereby causing irreparable harm to this employment relationship. Reinstatement is not a viable and realistic option in these circumstances. Mr. Globerman’s explanation that he did not want to disclose his Foundation activities in order to avoid “a hassle” is in no way a satisfactory or complete explanation for his conduct. As noted previously, he must have known that his Foundation activities and his false representation to Ms. Esteves would be discovered eventually. In my view, it is reasonable to conclude that Mr. Globerman chose to continue his Foundation activities without advising the OSS or the Ministry with the knowledge that by doing so he was placing his employment at risk. It is apparent that Mr. Globerman was affected deeply by his perception of the circumstances of his father’s death. He testified at some length about what he and the Foundation have accomplished and he expressed the view that the Foundation’s activities have benefited the elderly, even to the point of saving lives. No one, including the Ministry, has questioned the value of the Foundation and its objectives. His efforts to improve the treatment and care of the elderly and to address ageism in the healthcare system are commendable. It is unfortunate that this outside activity gave rise to a perceived and potential conflict with his job as a senior financial consultant with the Ministry. It is also unfortunate that he engaged in conduct which caused irreparable damage to the employment relationship. 52 For the forgoing reasons, it is my conclusion that the Ministry has established just cause for the discharge of Mr. Globerman. Accordingly, the discharge grievance dated December 18, 2003, is hereby dismissed. Dated at Toronto, this 2nd day of August, 2006. Ken Petryshen – Vice-Chair