HomeMy WebLinkAbout1989-0143.Lau.90-06-12 ONTA~O EMBOSS DE ~ COURONNE
CROWN EMPLOYEE$ DE L'ONTA~O
GRIEVANCE CQMMISSION DE
SETFLEMENT REGLEMENT
BOARD DES GRIEFS
t80 DUNDAS S~T WES~ TORONT~ ON~Rt~ M5G 1~ - S~ 21~ TELEPHONE/TEL~HONE
t84 RUE DUNDAS OUES~ TORONTO, (ON~ M5G 1~- BUR~U 2100 ~1~ 598-0~8
143/8~
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLENENT BOARD
BETWEEN:
OPSEU (Lau)
Grievor
- and -
The Crown in Right of Ontario
(Ministry of Municigal Affairs)
Employer
BEFORE: G.J. Brandt Vice-Chairperson
M. Vorster , Member
A. Merritt Member
FOR THE N. Roland
GRIEVOR: Counsel
Cornish & Associates
Barristers & Solicitors
FOR THE I. Werker
EMPLOYER: Counsel
Fraser & Beatty
Barristers & Solicitors
HEARINGS: August 2, 3, 1989
October 13, 20, 1989
November 1, 24, 1.989
AWARD
The grievor is a probationary employee who was "released" from
employment on January 20, 1989 following an unsatisfactory
performance appraisal. Both the performance appraisal and the
"release" are before the board in this proceeding. The grievance
characterizes the "release" as a "dismissal" which has been
effected without cause.
At the outset the Ministry argued that the Board lacked
jurisdiction to hear the complaint against the termination of tke
grievor's employment since, as a "release" under the Public Service
Act, it was not arbitrable. Consequently, the Board heard evidence
concerning the grievor's employment for the purpose of determining
whether or not the .action of the Ministry could be characterized
as a "release" or as a "dismissal". That evidence also serves to
permit the Board to deal with the performance appraisal grievance
as well.
The grievor was hired as a Financial Analyst in the Financial
Management Branch of the Ministry of Municipal Affairs following
a competition wherein she was judged by the selection panel to be
the best candidate among the 4 candidates who had been interviewed.
Although the selection committee had been seekin~ someone for an
entry level position and did not require that candidates possess
any formal qualifications,, the grievor, who has both a Bachelor
of Commerce (Concordia) and is a Certified Management Accountant,
3
had qualifications far superior to those of any of the other
candidates and she was awarded the job.
The Financial Management Branch provides a service to
municipal treasurers and auditors with respect to financial
reporting obligations arising under the Municipal Act. Financial
Advisors, (all of whom have some accounting designation, viz, CGA,
CMA or CA) review financial statements submitted by the
municipalities with a view to determinin~ whether or not they are-
in compliance with ~he requirements of the Act and with the
provisions of the .Municipal Financial Reporting Handbogk
(hereinafter referred to as the handbook).
The handbook sets out various accounting principles which
are uniquely applicable to municipalities, establishes the
standards for what should'be included in a financial statement of
a municipality, and prescribes the format of those s~a~ements.
The handbook is used by municipal treasurers and auditors ak a
guide to assist them in the preparation of the financial ssa%emends
which are to be returned to the Ministry.
The job of Financial Analyst involved essentially three
functions: review of financial statements for compliance with the
handbook; the Preparation of letters, to be sent to treasurers and
municipal auditors, identifying omissions or errors 'in financial
statements; and maintenance of a data base of errors (which data
might be used for such purposes as clarifying provisions of the
handbook).
4
The review of the financial statements (estimated to comprise
approximately 80~ of the duties) and the consequential
identification of errors found therein is accomplished through the
use of a checklist. The Financial Analyst goes through the
.financial statements and checks off on the checklist whether or
not the statement complies substance and in. form with the
requirements of the handbook. In many instances all that is
required is a "yes" or "no" answer. However, in some instances~
some element of judgment is required.
For the first three weeks (approximately) of her training
the Grievor was Given the opportunity to review the contents of
the handbook and checklist and to familiarize herself with the
Municipal Act. At the completion of this period she began training
on the job of reviewing a financial statement. It was intended
initially that each of the Financial Advisors (of whom there were
5 in the Branch) would select ten financial statements fcr the
Grievor to review and that she would discuss her work with each
of them individually. This had been the practice that the 'Branch
had followed with respect to summer students who had done this work
in earlier years. However, this practice was changed with respect
to the Grievor. Mr. Murray Lawson, the 'manager of the Branch,
testified that it had been decided that, it would be better to co-
Ordinate the Grievor's training in order to minimize the risk that
she might receive inconsistent or confusing training from different
advisors.
5
Such inconsistency apDeared~ to have arisen with resDec~ to
certain reviews which the ~rievor did for one of her advisors,
Mr. Kimura. Apparently Mr. Kimura had given the grievor different
instructions than she was getting from others. Consequently, it was
decided around the end of July that, while the grievor would
continue to receive her assignments from all of the advisors, she
would be trained primarily by one of them selected by Mr. Lawson.
That person was Ms. Mare Brown.
The grievor stated that she understood that Hs. Brown was to
be making all of the decisions concerning her review of the
statements; that she was to take all of her directions from Ms.
Brown. Consequently,. she minimized the contact which she had with
the other advisors for whom she was conducting checklist reviews.
Ministry evidence conflicted with this understanding. It was
the evidence of Mr. Lawson that each of the advisors was to have
some responsibility for the training of the grievor. Furtker, the
grievor had~been told that she .should speak to the other advisors
or with Mr. Lawson himself if she had questions concerning the
particular financial statements that she had been assigned to do
by them. Ms. Brown confirmed that the grievor believed that she
was working for all of the advisors and asked for some confirmation
from Mr. Lawson when she was told that Ms. Brown would have some
specific authority over her.
The grievor offered another exDlanation for her general
reluctance tO discuss her work with the other advisors. Shortly
after she arrived in the office she learned of various problems
and conflicts within the branch. In particular she learned that
Mr. Kimura (a 20 year employee) was upset ~hat Ms. Brown (a 2-3
year employee) had received a promotion. Rather than involve
herself in "office politics" she decided to keep to herself,
thereby reinforcing what she described as her natural tendency not
to be very "outgoing". In cross examination she denied the
suggestion that any subsequent difficulties which she had with Ms.
Brown were a result of her feelings concerning.this conflict.
Although Mr. Lawson and Ms. Brown were available generally to
deal with problems which the grievor may have had each of them was
engaged in other pursuits in the early period of her training. Mr.
Lawson was seconded from the branch from July 5 to August 22 and,
4 days after his return from this secondment, he took a vacation
from which he returned on August 22.
Ms. Brown was working on a pilot project which took her out
of the office for two days a week (Monday and Friday) during the
months of July and August. Moreover, when she was in the office
she was involved for part of her time~ working on the project
although, in Mr. Lawson's estimation, not to such a.n extent that
she was not sufficiently available to provide supervisioa and
training for the grievor
It was the grievor's evidence that, during this early period
of her training, Ms. Brown was neither very available nor very
helpful. When in the office she was frequently on the telephone'
or working at her computer and, according to the grievor, had
indicated that she was too busy and did not want to be disturbed.
7
~o regular schedule of formal training sessions was
established; generally the grievor was expected to approach Ms.
Brown with any questions that she may have had concerning the
review of financial statements. According to Ms. Brown the
grievor, who began to review some statements in the month of July,
did not approach ~er or any of the other advisors with any .
questions. Such contact as there was, according to MS. Brown,
consisted of arguments over how she was completing the checklists.
The grievor disputed that evidence. She stated that she had gone
to see Ms. Brown several times but that she was either on the phone
or working at the computer and had indicated that, she did not wish
to be disturbed.
In late July Ms. Brown, who remained concerned abou~ the
absence of any questions from the grievor, verbally.asked her To
provide her with a list of the financial s~atements she had
reviewed to date, along with a description of the errors and the
types of errors found, to be accompanied by the financial
statements reviewed and the 1987 review checklist. This was tc
give Ms. Brown an opportunity to assess the grievor's work in
reviewing financial statements.
When Ms. Brown repeated this request in writing on August 16,
and asked that the material be made available by August 18. the.
grievor inquired as to why Ms. Brown had put such an early
deadline on the completion of the work. It then became evident that
the grievor had misunderstood Ms. Brown's request and had thought
that she was expected to complete the review of all the financial
$
statements that she had been assigned to date. As she had been
told by Mr. Lawson that the assignments did not have to be
completed until the end of August she was confused over the August
18 deadline established by Ms. Brown.
Ms. Brown, after checking some of the statements found what
she regarded to be a large number of errors in the grievor's work.
Rather than check all of the statements, she prepared a list of
her comments on the statements that she had checked and,., at a
meeting on September 22, gave those comments to the grievor wi~h
a request that she prepare a redly (as a basis for discussioni,
Further she instructed the grievor to re-do the other statements
"with more care" and repeated the invitation to ask questions if
she was not sure whether or not something was an error.
At the September 22 meeting Ms. Brown discussed some of h~r
concerns with the grievor. She pointed out that in earlier years
summer students had been able to perform the work without
difficulty and that the grievor's attendance record was Door. The
grievor stated that she found the financial reviews "boring", that
she preferred to be in the library reading rather than work in her
office; and that she thought that she and Ms. Brown had a
personality conflict, a conclusion with which Ms. Brown disagreed.
Subsequently, Ms. Brown met with Mr. Lawson and told him that,
in view of the difficulties she was having with the grievor, she
should no longer be involved in supervising her. Mr. Lawson
requested her to put her concerns in writing and Ms. Brown gave him
a draft. That draft included a description of the grievor as
"dishonest", based on Ms. Brown having observed the grievor filling
a bag with extra cream,and sugar at a restaurant. Mr. Lawson asked
Ms. Brown to prepare a second draft and to delete the reference to
dishonest which he found to be irrelevant.
The revised draft, {to which was attached Ms. Brown's comments
on the grievor's checklist review), contained a number of comments
respecting the grievor's performance. It described her Overall
Performance as "Unsatisfactory", and her Attitude as
"Argumentative, stubborn, uncooperative, refuses to take
constructive criticism, reactive, rude, refuses to accept verbal
instructions - insists on everything being in writing." Her
Technical Competence was described as "unsatisfactory" in that she
was unable to follow written instructions and that she showed lack
-of due care in financial statemen% review. In general it was Ms.
Brown's view that the grievor had "antagonized everyone in the
department to the point where most people .will not speak to her
directly" No recommendation for release of the grievor was made
at this point.
Ms. Brown was cross examined at length on her comments in the
September 22 memorandum. With respect to the claim that the
grievor "insisted on having everything' in writing" Ms. Brown
conceded that a request, in an August 24 memorandum from the
grievor~ to Ms. Brown, asking that any "significant changes or
additions to her responsibilities" be put in writing was a
reasonable request.
10
The August 24 memorandum also "welcomed" comments from Ms.
Brown. However, Ms. Brown persisted in her claim that the Griever
always reacted defensively to criticism and that, generally, she
had a poor attitude.
As evidence oX an inability to follow written instructions,
which Ms. Brown saw as "unsatisfactory" technical competence,
reference was made in the memorandum to an incident in which the
Griever f~iled to correctly read a memorandum concerning {he
arrangements for a staff meeting which was to be held at Ms.
Brown's farm in Stratford on August 10. Members of the Branch were
expected to have lunch, attend the theatre and have a barbecue
following which the meeting was to be held in the evening. Ms.
Brown stated that the order and times of events was clearly set out
in the memorandum. However she claimed that the griever was under
the impression that the barbecue would be held at mid-day and that
the meeting would be held immediately after, that ~s, in the
afternoon. When the griever learned that the meeting was not until
the·evening she. returned to Toronto as she had made no arrangements
for anyone to look after her child.
[It was the griever's evidence that she arrived at Stratford
in the morning, that when it appeared that a number of people would
be late for the meeting Mr. Isaac (the Branch Director) said the
meeting would have to be held back at the office. Consequently,
after having had lunch the griever said that she was returning-to
Toronto. No one said anything to her at that time about missing
the meeting.]
ii
Ms. Brown conceded in evidence ~hat missing the meeting was
"not a big point" but maintained that it was evidence of 'how the
grievor was careless in reading instructions. [The memorandum
announcing the meeting was not Produced in evidence.] Nor did Mr.
Lawson regard the incident as very serious at the time. Apparently
there were no minutes taken of the meeting although Ms. Brown
denied that it was merely a social occasion. She stated that the
purpose of the meeting was to discuss" where the Branch was-.going
as a Branch". However, in this regard it should be noted that a
number of other people, including Mr. Lawson {who was at that time
on vacation), did not attend the meesing.
In her evidence the grievor denied many of the allegations
contained in the memorandum of September 22 from Ms. Brown to Mr.
Lawson, viz, that she insisted that everything be in writing; that
she "refused" to take direction, that she refused to accept verbal
instructions.
Generally Ms. Brown denied the Suggestion, put to her in
cross examination, that she "disliked" the grievor. She stated
that she always tried to maintain her objectivity but that she'was
"frustrated" by her inability to "get through" to the grievor. Mr.
Lawson, whose September 28th performance appraisal was based on Ms.
Brown's September 22 memorandum, did however concede that in
various respects Ms. Brown had exaggerated the failings, of the
grievor. For example, the claim that the grievor "insists on
everything b~ing in writing" was admitted to be an exaggeration.
12
However, while this concerned Mr. Lawson, he did not think 5hat it
indicated any Dersonal dislike of the grievor by Ms. Brown.
Ms. Brown had also suggested that the grievor was
uncooperative in that she had "refused" to take directions from
Ms. Brown unless told to do so sDecifically by him [Lawson], a
reference to the misinterDreted assignment. ~supra). Mr. Lawson
conceded that in the circumstances the grievor's conduct did not
constitute a "refusal" to carry out instructions as Ms. Brown had
claimed.
As for the claim that the grievor lacked Technical Competence,
.as evidenced by her alleged failure to .read correctly the
memorandum respecting the~ barbecue cum staff meeting, Mr. Lawson
readily conceded that this example had little to do with .the
ability of the grievor as a~ accountant. He also conceded that the
selection of this incident, one involving a failure to attend at
an event which was hosted by Ms. Brown, as the first example relied
upon by her as indicating a lack of technical competence, suggested
that Ms. Brown'was not entirely objective in her assessment of ~he
grievor.
However, notwithstanding the fact that Mr. Lawson had certain
concerns about Ms. Brown's objectivity, he nevertheless steadfastly
held to the belief that she had remained "fair and reasonable" in
her assessment of the grievor.
As indicated, on September 28 Mr. Lawson met with the grievor
to conduct a formal performance appraisal for the quarterly Deriod
June 13 to SeDtember 13. In preparation for that meeting he
13
prepared a written performance evaluation which was based on The
memorandum of September 22 from Ms. Brown and on discussions wi~h
other advisors who had contact with the grievor. He also
familiarized himself with ~he criti'cisms that Ms. Brown had made
of the grievor's review of financial statements thus far. In that
regard he conducted his own independent review of those, statements
and satisfied himself that the comments made were relevant and
appropriate.
The performance evaluation only evaluated the grievor on h~r
work in connection with the reviewing of financial statements since.
she had not been in the branch long.enough to permit an evaluation
of other aspects of her duties, viz, writing letters, etc. I ~ '
,addition the grievor was also evaluated on various personal
factors, viz, dependability, attitude, co-operation in the work
place, motivation and attendance.
The evaluation stated that the griever had "failed to identify
a number of errors or failed to provide more information on certain
errors which were identified. Monica needs to ask more questions
of senior advisors when reviewing statements in order to ensure
that the reviews are thorough and correct." The grievor was upset
about Mr Lawson's comments and felt they were unjustified in that
they relied too heavily on the opinion of Ms. Brown. Mr. Lawson
replied that he had done his own independent, review and that he
agreed with Ms. Brown's comments.
The grievor was criticized for not seeking advice from other
advisors. Although Mr. Lawson admitted that primary responsibility
14
for the early portion of the grievor's training, when she was
learning how to review financial statements, rested with Ms. Brown,
he maintained that the grievor was not restricted from speaking to
other 'advisors or to himself.
Mr. Lawson proceeded to a discussion of the factors of
Dependability, Attitude and Attendance but generally was faced with
disagreement from the grievor over most of his observations.
Eventually the meeting ended with the Grievor refusing to sign the
performance appraisal. Mr. Lawson testified that the grievor
"walked out" of the meeting, a claim which the grievor denied.
In evidence the grievo~ stated that she was very upset at the
tone of the performance appraisal and surprised at much of the
phrasing which she regarded as questioning her ability. She was
particularly upset about the inclusion in the performance appraisal
of references to certain criticisms of Beth Harlow concerning the
grievor's lateness for and performance in two computer courses
which she had attended. She did not believe that matters of that
kind should be the subject oX a performance appraisal particularly
when they were based on what she regarded as false hearsay from Ms.
Har 1 ow.
Ms. Brown continued to act as the ~rievor's supervisor until
October 28 when she advised Mr. Lawson that she could no longer
supervise the ~rievor and recommended that she be released. From
this point Mr. Lawson became her direct supervisor although the
Grievor claims that she was never told of this change.
15
In early November a meeting was held to discuss the
performance appraisal, of September 28. In attendance a~ 5hat
meeting were the grievor, Mr. Lawson and ~r. Isaac. The grievor
expressed her concern over the performance appraisal and what it
mean to her job prospects if she applied elsewhere. She was
assured that there was nothing in it that could not be overcome if
she set her mind to correcting her Droblems. The grievor said that
she felt that Ms. 'Brown had not been fair in her review o.f the
grievor's work. It was suggested by Mr. Isaac that the grievor and
Mr. Lawson get together to review the financial statements that had
been the. subject of Ms. Brown's critical comments and which had
formed, in part, the basis for Mr. Lawson's appraisal of the
grievor's work performance.
To that end a meeting was held on November 7 at which time
the grievor and Mr. Lawson went through each of the financial
statements and the accompanying checklists point by point with Mr.
Lawson explaining to the grievor why Ms. Brown had made the
comments that she had. Apparently this proceeded without
difficulty until they came to consider the financial statement for
the Village of Grande Valley and, in particular began to discuss
an error that neither the grievor nor Ms. Brown had picked up in
~heir respective reviews.
An argument broke out over the proper way to complete the
checklist where discrepancies existed between the opening.and
closing balances in successive years. It is unnecessary to recite
the details of the dispute. It is sufficient to state that the
16
handbook indicated that a discrepancy should have an accompanying
policy note and the checklist required that where no note was
present the discrepancy should be recorded. There ~as no note on
this statement but the grievor declined to check this off as she
had been able to reconcile the discrepancy. Mr. Lawson tried to
explain to her that it did not matter that she was able to
reconcile the figures; that a checkmark was still required
indicating that the balances did not agree. However she remained
adamant in her opinion and would not accept Mr. Lawson's advice.
The meeting degenerated into a shouting match and was terminated
by Mr. Lawson.
On the following day, November 8, Mr. Lawson wrote a
memorandum reviewing the events of.the previous day and commenting
again on the failure or reluctance of the grievor to seek advice
from other advisors, and on her reluctance to take any criticism
of her work. The memorandum concluded by stating tha~ if her
tendency to adopt a defensive and/or argumentative mode was not
corrected, her training would be seriously impeded and she may no5
be able to assume the. full responsibilities of the position.
On November !0 the gr~vor presented Mr. Lawson with a
memorandum setting out her views concerning the performance·
evaluation of September 22 and the memorandum of November S. She
blamed much of her difficulty on the fact that almost all of her
contact, was with Ms. Brown with whom she had a difficult
relationship. She regarded Ms. Brown as "over zealous" in her role
as supervisor, as Drone to take a "predominant role" in their
17
discussions and to "dominate" in her opinions. As for the
observations tha5 she failed' to consult with other advisors the
grievor stated that in her time in the branch she had done only
financial statement reviews and ~hat at no time had she had other
assignments with brought her into contact with other advisors.
Such contact as she had with the advisors was, in he~ opinion,
"mutually agreeable"
With respect to the argument which developed between her and
Mr. Lawson a~ the November 7 meeting over the review of the Village
of Grande Valley statement she stated that her reaction was ~o the
attitude that Mr. Lawson took, that is, that~this particular error
supported his evaluation of her. She claimed that his criSicism
was unfounded because he had not examined a revised financial
statement from the Village.which statement apparently contained the
appropriate policy no~e. Mr. Lawson testified that the financial
statemen~ which the grievor had brought ~o the November 7 meeting
and which had been discussed by them was an unrevised statement.
It was also his evidence that during the discussion she made no
men~ion of ~any revised statement.
He admitted that if the grievor had reviewed a revised
statemen~ there would have been ne error in her work. He also
admitted that, on the assumption ~hat she had worked oa a ~evised
statement, his insistence that she had made an error mi~kt
reasonably lead her to be "defensive" and "argumentative" over his
attribution of errors to her. However, he persisted in his claim
that he' was not aware that she had worked on any revised statement
i$
and stated that if he had been aware of that there would have been
no ar~umenu. No evidence was produced which would indicate that
the grievor had in fact ~orked on a revised statement.
The next dispute between the grievor and Mr. Lawson was over
her work in connection with the review of all of the financial
statements prepared by a particular audit firm. When Mr. Lawson
examined her work he discovered what he considered to be a. number
of errors and sent his comments to the grievor in a memorandum of
November 24.
The grievor responded by memorandum of December 2 in which
she argued that of the 25 "errors" which Mr. Lawson discovered only
3 could be considered as errors. As for the rest she suggested
either that Mr. Lawson had "failed to identify additional
information" or "did not extend the depth of his analysis" or that
there was insufficient i'nformation in the statements to warrant a
conclusion that there was an error or that'the "error" was subject
to a difference of opinion in the interpretation of the handbook.
She questioned the "intent" and "credibility" of "the reviewer's"
remarks and suggested that his remarks reflect a "lack of
appreciation of the efforts made [by her] to carry out the job" and
a "personal insult to her ability" Attached to her memorandum was
an outline of her position with respect to each of+the statements
that had been reviewed, a position which she maintained at the
hearing.
After this memorandum was received by Mr. Lawson he met with
the grievor on December 5 to discuss their disagreements. While
19
they agreed on one or two matters it became apparent that each had
a radically different approach to what c~nstituted an error. On
each point they argued extensively over their respective positions
and, with rare exceptions, could agree on none of them.
When they came to discuss the statement for the Town of Paris
they disagreed over the same issue that had divided them concerning
the Village of Grande Valley, viz, whether or not it was
appropriate for the griever to omit making a mark on the checklist
where she was able to "reconcile" discrepancies in the opening and
closing~fund balances. Mr. Lawson testified that, contrary to his
instructions, the grievor insisted that she would continue to
ignore these errors if she could reconcile the balances. When Mr.
Lawson told her that he. was Giving her an "order" to do it and she
persisted in her refusal, he teYminated the meeting. No evidence
was called by the grievor to refute this incident.
Later, on December 12, Mr. Lawson wrote a memorandum to the
grievor confirming' the December 5 meeting and commenting on the
events that transpired at the meeting. He observed that it was
apparent to him that "your only intent was to attemp2 to prove tha5
I was wrong and that you were right." The grievor testified that
this was an unfair characterization of the events. She stated ~haz
she merely w~nted 5o clarify things as there was ~ conflic% between
what Mr. Lawson had been telling her and a previous checklist.
Shortly after the conclusion of the December 5 meeting Mr.
Lawson came to the decision that the Grievor should be released.
Consequently he went to Mr. Isaac and requested him to have the
2O
Personnel Branch prepare a letter of termination on the basis that
the grievor could not be trained to fulfil the responsibilities of
her position.
In due course a letter, originally dated December 9, addressed
to the grievor was prepared by Mr. Vidan for Mr. Isaac's signature.
That letter concluded that the grievor's training had not been
successful and informed her that she .was being released from
employment "for failure to meet the requirements of the position".
It was apparently intended to deliver this letter to her on
December 9. However, owing to a family emergency it became
necessary for the grieuor to seek permission to take her vacation.
That permission was granted by Mr. Lawson and the grievor was
absent on vacation from December 15 to December 30 and was
scheduled to return to the office on January 3, 1989.
The decision to grant her a leave of absence postponed the
time when the Ministry could release the grievor. Moreover, it
was' believed that it would still be ~necessary to monitor her
assignments and to continue to evaluate her performance until such
time as she was released. In that regard Mr. Lawson prepared a
memorandum (December 12) for the grievor reciting the events of the
December 5 meeting, informing her that her continued employment
depended on her ability to be trained successfully, and telling her
that upon her return she wou~d be given further assignments. No
mention was made of any decision to release her from employment.
At some point, [it is not clear when] Mr. Lawson received an
assignment which he had given the grievor to do on November 22,
21
viz, review of some statements and preparation of sample letters.
He reviewed that work ~nd, on December 15, wrote a memorandum to
the griever in which, he identified some errors in her completion
of the checklist and informed her that she'had neglected to do some
of the letters that he had asked her to do and also that those
which she had done were not in acceptable either in form or in
content.
Mr. Lawson asked her to re-do the original letters and prepare
the ones that had been missed initially and to submit her work to
the acting Manager by January 4, 1989. [He planned to be absent on
vacation from December 22 to January 15.] As she had already left
for her vacation this memorandum was left on her desk.
.The acting Manager .who was-responsible 'for supervising the
grievor upon' her return from her vacation was Ms. Brown. On
January 4 she gave the grievor an assignment, due on January 6, to
answer certain questions with respect to all of the data points on
the REVIEW CHECKLIST of 1987 0- GENERAL MUNICIPAL CONSOLIDATED
FINANCIAL STATEMENTS, viz, why it is a checklist point, what is the
effect of non-compliance, what is the suggested action. She
testified that the reason for giving This assignment was that she
was having difficulty understanding why the grievor couldn't do a
simple checklist and she wanted to know whether or not the grievor
understood what was involved in completing the checklist.
The following day the grievor requested, by memorandum, a copy
of the REVIEW CHECKLIST referred to in Ms. Brown's request in order
that she coqld attend to the job. The grievor had understood the
22
assignment to involve a particular completed checklist and not a
blank one as Ms. Brown had intended. Ms. Brown conceded that it
was possible that the grievor could have been confused on this
issue. Once this confusion was cleared up the assignment was
completed and handed in on January 9.
What'she handed in was 7 legal size pages of handwritten
material. The grievor testified that, independent of research
time, it took her approximately .20 hours to complete the
assignment, some of which time was spent working at home on the
weekend. Ms. Brown had requested that 'it be done on her computer.
However, the grievor was having difficulty with creating columns
'on her computer and she wrote out the assignment instead. She
stated that she found it easier to concentrate when she was. writing
than when working at the computer.
In addition to her concerns about the fact that the
assignment was not done on the computer as requested Ms. Brown was
also of the opinion that the work showed a basic lack of
comprehension of municipal accounting principles.
On January 5, Ms. Brown wrote to the grievor concerning 5he
assignment which Mr. Lawson had left with her, viz, the writin~ o~
sample letters, which assignment had been due on January 4 but
which had not yet been handed in. lit may be recalled thai the
grievor had done some of these for Mr. Lawson but that some had
not been done and that he had requested her both to re-do the ones
already completed and to do the ones that had been omitted.[
23
In her memorandum Ms. Brown stated ~hat there was no excus'e
for hot completing this work in that it was a "small job" and she.
had "no other work as. signments" She regarded this level of
performance as "totally unacceptable" and ask for an explanation
in writing for her failure to complete the job within the deadline
set. The grievor responded by noting that the assignment was not
a "small job", that'the work did not involve simple retyping but
required her to analyze whether or not additional comments should
or should not be in the letters. She maintained that view in her
evidence stating that the job had taken her longer than a day, that
she did not simply want to copy the precedent word for word but
wanted to do some research using the handbook and Che statute so
that s.he could.~o a good job.
Ms. Brown, in her evidence, persisted in maintaining that the
job was neither a lsngthy nor difficult one. She ~hought that all
that was required as a revision of Mr. Lawson's response and the
incorporation of that response in the letter, a job which ought to
take her no more than 2 hours. However, Ms. Brown did concede in
cross examination that it was not accurate to state, as she had,
that the grievor had no other assignments. In fact she had been
given a quite substantial assignment, viz, .the review of the
reasons etc. for the 120 data points in the checklist, on January
4, the very day that the Lawson assignment was due.
On January 9 one of the letters, prepared in handwriting
(owing to problems Which the grievor claimed she was having with
her word processor) was handed in. Ms. Brown regarded it as
24
showing a lack of comprehension of basic accounting principles and
as containing paragraphs which did not reflect Branch policy.
The concerns which Ms. Brown had with the grievor concerning
these letters were never discussed with her as the grievor was
released on January 20, 1989.
It is appropriate at the outset to review generally the
positions taken by'the parties with respect to the two grievances
which are before us. The Ministry submits that, having regard to
principles established by the Board with respect to grievances
against a performance appraisal, the grievance should fail on the
merits. It is further submitted that the Board lacks jurisdiction
to entertain the "dismissal" grievance as it is properly
characterized as a "release" under the Public Service Act~
The Union submits that the performance appraisal was flawed
in that it was based on irrelevant and pejorative informauion
obtained from a supervisor who had a strong personal dislike of
the grievor. It is further submitted that insofar as the appraisal
was inextricably linked to the "release", the "release" should be
considered as actuated by bad faith such ~hat the Board has
jurisdiction to review it within ~he principles set d6wn in the
cases. Finally, it is submitted that, insofar as the purported
release of the grievor was "vindictive" and "retaliatory", it
should be characterized as a disciplinary dismissal for which,
given the "vindictive" and "retaliatory" m°tivati~n behind the
action, there is no just cause.
25
We deal first with the question of arbitrabiiity. The
resolution of the question of the arbirability of the termination
of employment of an employee within the first year of service turns
upon the proper characterization of the "termination". Section
22(5) of the Public Service Act provides that a "deputy minister
may "release" from employment any public servant during the first
year of his employment for failure to meet the requirements of the
position."
The extent to which the Board may review the exercise of a
decision to "release" a probationary employee first arose in Leslie
(80/77). The Board conducted an extensive review of the
relationship between the Crown Employees Collective Bargaining Act
and the Public Service Act and concluded as follows:
..... we are of the opinion that the bona fides release
of an employee from employment.made in good faith during
the first year of his employment for failure to meet the
requirements of his position cannot be considered a
dismissal as that term is used in both the Public Service
Act and the Crown Employees Collective Bargaining Act ....
...... this Board is of the opinion that the employer
cannot camouflage either discipline or the termination
of an employee for a reason other than the employee's
failure to meet the requirements of the position .... by
the guise of 'a "release" under section 22(5) of the
Public Service Act. This Board, therefore, has
jurisdiction to review a contested release to insure that
it is~what'it purports to be. But in the adjudication
of such a grievance, this. Board is without jurisdiction
to evaluate and weigh the reasons of the employer unless
the collective agreement provides otherwise. The Board
must only be satisfied that the employer, in good faith,
released the employee for a failure to me~t the
requirement~s of the position. As long as the Board can
be satisfied that the employer has made an evaluation of
that kind, it has no jurisdiction to review the fairness
or correctness of that termination under section
~7(2) (c)." (Now 15(2) (c) of the Crown Employees
Collective Bargainin~ Act.)
No useful purpose would be served by reviewing the
jurisprudence of the Board following Leslie. it suffices to note
that the Board has continually reaffirmed Leslie as establishing
the basic principle upon which tke issue of the arbitrability of
a' "release" is to be determined. (See Tucker 206/78; Walton,
612/81, 613/81; Ferraro 373/84; kbdull~ 1103/85; Clarke 443/82;
Turcotte 344/80; Haladay 94/78.)
Thus the fundamental issue before us is whether or not on the
facts it can be said that the employer has acted bona ~ide and in
good faith in "releasing" the grievor or whether, as the Union
maintains, the "release" is really a disguised dismissal.
It is submitted by the Union that the memorandum of September
22 from Ms. Brown to Mr. Lawson~ upon which the performance
appraisal was substantially based, was motivated by a negative
"social judgment" which Ms. Brown formed about the grievor, which
carried over into her evaluation of the grievor's performance.
It is submitted that the grievor's fate was sealed when she
chose not to attend the barbecue organized by Ms. Brown at her
farm. It was sugges~ted that Ms. Brown took great personal pride
in this event and that she re~arded it as an important meeting
which went far beyond a mere social occasion.
It was noted by counsel that this was essentially the first
~pportunity that Ms. Brown had to make any kind of evaluation of
the grievor. Prior to the barbecue there had been little
27
opportunity for her to make any professional assessment of the
grievor since she, Ms. Brown, was either absen5 from the office
working on her St. Mary's project (on Mondays and Fridays) or,
while in the office, was busy on the telephone or her computer.
Consequently, her first formal evaluation of the grievor's
performance was made following the barbecue and, in counsel's
submission, she permitted her own feelings of dislike of the
grievor, generated as a result of what she regarded as a social
snub, to influence her evaluation~
Thus, in her memorandum she cites, as 5he firs5 example of
Technical Incompetence, the failure of the grievor to read the
memorandum setting out the schedule of events for the
barbecue/meeting, an example, which Mr. Lawson readily, conceded
had very little to do with proficiency in accounting. Moreoverr
she used language, eg. "insists on everything being .in writing",
"refuses" to accept criticism, which Mr. Lawson also conceded ~o
be an overstatement.
This evaluation, it was submitted, was accepted uncritically
by Mr. Lawson and formed the primary basis for his performance
appraisal. Moreover, given that the performance appraisal was
based on an evaluation made in bad faith and actuated by personal
dislike for'the grievor'it ought to be removed from the grievor's
record.
With respect to the release i~ is submitted that, insofar as
it flowed naturally from the unsatisfactory performance appraisal
(which in itself is tainted by bad faith), it ought to
28
characterized as a disguised dismissal which is both susceptible
of review by the'Board and which ought to be struck down as being
w~tkout just cause.
In further support of this position it was noted by counsel
that the person whose recommendation for release was ultimately.
acted upon was none other than Ms. Brown, the supervisor with whom
the grievor had had a bad relationship and from whom. she had
received very Door evaluation, and who was now serving as Acting
Manager of the Branch.
We do not believe that the evidence, taken as a whole, permits
us to reach the conclusion urged.upon us by counsel for the Union
and the grievor. In essence it is claimed that all of the
grievor's problems originated from a single social snub, viz, the
failure to attend at the barbecue/staff meeting organized by Ms.
Brown. While it is true that the first significant evaluation of
the grievor's work did not occur until after this event the
evidence does not support the claim advanced that Ms. Brown was
offended at the failure of the grievor to attend. Both Mr. Lawson
and Ms. Brown conceded that missing it was not "such a big thing".
And from the evidence it must be concluded that it was not: it was
generally a social event; no minutes were taken; even the Branch
Manager, Mr. Lawson, was not in attendance.
Union counsel puts a good deal of emphasis on two pieces of
evidence: the initial characterization by Ms. Br~wn of the meeting
as one which was to discuss "where the Branch was going", i.e. a
29
characterization which would suggest that the meeting was important
when it really was not; and secondly, the use of the grievor's
failure to properly read the instructions for this event as the
first example of her Technical Incompetence.
We do not regard this evidence standing alone as sufficient
to support a conclusion that from the time of the meeting on the
Ministry, through Ms. Brown, was acting in bad faith in its
treatment of the grievor. On the contrary, there is considerable
evidence in support of the conclusion that the Ministry made
repeated efforts to train the grievor but frequently found itself
faced with an employee who was very reluctant to admit to making
errors and to taking criticism and instruction.
It is true that Ms. Brown's evaluation of the grievor in her
September 22 memorandum to Mr. Lawson was exceptionally .negative
in tone; that it exaggerated the grievor's failings ("insists on
everything being in writing, refuses to accept instruction); and
that it chose, as examples of the grievor's defects, incidents
which had little to do with accounting skills. It is fair to say
that it does not contain a single comment or observation of a
positive nature.
We are, however, reluctant to conclude from that that Ms.
Brow~ was acting in "bad faith" Clearly, there was a personality
conflict; but that is not sufficient to support a finding of bad
faith. It is no doubt the case that the grievor may have found Ms.
Brown to be unhelpful and overzealous; equally there is little
doubt that Ms. Brown found the grievor to be defensive and
3O
argumentative. There is evidence which would support the
conclusion that each of them had some justification for feeling the
way they did about the other.
In any event a full and complete assessment of the grievor's
treatment by the Ministry goes further than a consideration of how
she was treated by Ms. Brown. In order to assess the claim of the
Union that the grievor's termination was not a bona fide release,
it is necessary to consider her relationship with Mr. Lawson. Was
he motivated by improper considerations in his treatment of the
grievor?
The evidence does not support such a conclusion. On the
contrary it confirms, in certain respects, that Ms. Brown's earlier
evaluation of the grievor's attitude, was not entirely without'
basis in fact. What emerges from a review of that evidence is a
picture of the grievor as a person who found it exceptionally
difficult to accept criticism of her work and who preferred to
treat such criticism as stemming from some failure on the part of
her evaluator to assess her fairly or accurately.
A brief summary of the relevant evidence will suffice. In
his September 2$th performance appraisal Mr. Lawson did not, as
the Union claims, "accept uncritically" Ms. Brown's evaluation of
the grievor. He did his own independent review of the work which
the grievor had done for Ms. Brown and confirmed that, in fact,
her comments thereon were appropriate. He also consulted with
other advisors to obtain their views of the.griever.
31
On October 28 Ms. Brown asked to be relieved of any further
responsibility for supervising the grievor .and recommended ~hat
¢
she be released. Mr. Lawson did not act on that recommendation,~
instead he chose to take over responsibility for the supervision
of the grievor in order that she.have an opportunity to be trained
in some of the duties of the position in which she had not yet been
trained, viz, letter writing, etc.
in early November Mr. Lawson assured the grievor that she
could overcome her poor performance appraisal if she corrected her
problems. At that meeting the grievor insisted that Ms. Brown's
assessment of her abilities was unfair and wanted a further
opportunity to establish that with Mr. Lawson.
That opportunity was given. At a meeting on November 7 Mr.
Lawson met with the grievor in an effort to explain the errors
which had been identified by Ms. Brown and which he, Lawson, had
confirmed as errors. This meeting resulted in an argumen~ over
the proper way to fill out the checklist where there are
discrepancies in the opening and closing balances.
On the following day Mr. Lawson sent the grievor a memorandum
warning her that unless she corrected her tendency to adopt a
defensive/argumentative mode, her training would be seriously
impeded and she might not be able to meet the full responsibilities
of the position.
Two days later the grievor responded with a memorandum which
continued ~o blame Ms. Brown for the poor evaluation and which'
accepted little personal responsibility for the errors. Moreover,
32
she suggested that Mr. Lawson himself had improperly attributed an
error to .her as a result of his having examined a differen~
financial statement than the one which she had examined. In'short,
the error was not hers - but his.
On November 24 Mr. Lawson sent the grievor a memorandum
pointing out some errors in another assignment which he had given
her. On December 2 she disputed 22 of his 25 claims of error and
claimed generally that the "intent" and "credibility" of the
remarks made by Mr, Lawson was "questionable" and reflected a "lack
of appreciation o~ the efforts made to carry out the job End a
personal insult to [the grievor's] ability." Again, the grievor
appeared unwilling to accept that she may have made errors.
Instead she impugned Mr. Lawson's motives - not unlike her
characterization of Ms. Brown's evaluations of her.
Notwithstanding the somewhat insulting tone of her December
2 letter to him Mr. Lawson met with the grievor on December 5 to
discuss their disagreements. Although some agreement was reached
on some issues they remained apart on many and the meeting ended
in a bitter argument, again, over the question of the proper way
of completing the checklist where closing and opening balances do
not match. Mr. Lawson insisted that sh~ complete the checklist in
future as instructed; the grievor persisted in her view that an
error should not be recorded where it was possible to reconcile the
balances.
It was' at this point that Mr. Lawson decided to release the
grievor; yet, even then he responded favourably to a request from
33
the grievor for a leave of absence to permit her to attend to an'
urgent family matter. This had the effect of.postponing the time
when the grievor could be released and obliged Mr. Lawson to
continue with her supervision.
We find it difficult to conclude from this evidence that Hr..
Brown, in his dealings with the grievor, was acting in bad faith.
The Board has stated that the "suitability of a probationary
employee must be examined by th~ Employer on the broades~ of
grounds which would include inter alia, character, attitude, ,
compatibility, absenteeism, quality of work as well as the ability
of the Employee to meet the present requirements demanded by 5he
Employer" (Blundell 685/81).
It has also been stated that "failure" under section 22(5) of
the Public Service Act can include both voluntary and involuntary
deficiencies such as attitude and capacity and that such~
deficiencies can for the basis of a release ~ven though the grievor
might have been able to improve her attitude or behaviour.
(Bartello 61/$2)
We have litt'le doubt in concluding in this case that the
grievor was "released" from her employment for failure to meet the
requirements of the position. She was Given work on duties which
would have comprised approximately 80% of the duties and made
numerous err6rs in her work. When thos.e errors were drawn to her
attention she repeatedly disputed the judgments of those
responsible for her supervision and training and appeared quite
unwilling to accept instruction.
34
One incident in particuiar serves to describe the attitude
\
towards the process of training that she was~engaged in. We refer
to her disagreement with Mr. Lawson concerning the proper way to
complete the checklist where there is a discrepancy between opening
and closing balances. She held the steadfast view that.if she
could reconcile the discrepancy there was n0 need to record that
there had been a discrepancy; she held this view even over the
express direction of Mr. Lawson to the contrary. Whether she was
correct or not is beside the point. Her supervisor, who had
written the manual and the checklist 'and who had extensive
experience in municipal accounting, was attempting to instruct her
in the proper way of' conducting the review of a financial
statement. She was simply not prepared to cooperate wi%h him.
Thus, the grievor emerges as an employee who, although highly
qualified f~r the position, was found both unable to perform the
major tasks of the job and unwilling to accept any instruction as
to how to perform the job correctly. In these circumstances the
response of the Ministry to terminate the ~rievor's employment must
be characterized as a release and not as a disguised dismissal.
In ~he result we have no jurisdiction over the ~ismissal
grievance.
This brings us to the appraisal grievance.
There is no question that w~ have jurisdiction to deal with
this grievance under section t8(2)'(b) of the Crown Employees'
Collective Bargaining Act. The Union submitted that the
performance appraisal was vitiated because of the existence of bad
35
faith of Ms. Brown on whose memorandum of 'September 22 the
performance appraisal was .based. We have earlier declined to
conclude that Ms. Brown was acting in bad faith.
Moreover, in any event, the performance appraisal was not
solely the' product of Ms. Brown's September 22 memorandum. Mr.
Lawson did an independent review of the work that the grievor had
done for Ms. Brown and had spoken to other advisors. Furthermore,
while it contains a number of critical comments, it is not, unlike
the September 22 memorandum, uniformly negative in its appraisal
of the grievor. It notes that she has completed her reviews
"within the 'time parameters set by her manager", that she has
"carried out the assignments given to her", that she has made a
good effort to learn the job, and that her attendance has been
good. Finally, in a number of respects, the comments made, viz,
that she has "challenged the advice, explanations and assistance
offered", and that she "has become very defensive and has been
unwilling to accept any responsibility for the problem" are well
documented in the evidence which we have reviewed above.
Consequently, the performance appraisal grievance is
dismissed.
In summary:
1) The Board finds that, insofar as the grievor was '"released"
from employment, the Board lacks jurisdiction to hear her grievance
~rotesting that action.
2} The Board dismisses the performance appraisal grievance.
36
Dated at LONDON, Ont. this 12~h day of ,T]]n~ , 1990.
G. J. Brandt, Vi ce-C.~hai rperson
"I DISSENT" (Dissent attached)
M. Vorster, Member
A. Merrttt, Member
DISSENT FROM UNION NOMINEE - MENNO VORSTER
RE: OPSEU (MONICA LAU) AND THE MINISTRY OF MUNICIPAL AFFAIRS
GSB 143/89
The Board had two grievances to consider from Ms. Monica Lau, a
probationary Financial Analyst with the Financial Management
Branch of the Ministry of Municipal Affairs. One dealt with a
performance appraisal and the other concerned the allegation that
her dismissal from the position was without just cause.
The majority found that the grievance on the termination of her
employment was inarbitrable and dismissed the performance
appraisal grievance. I disagree with the majority in both
decisions.
The first problem encountered by Ms. Lau, I would submit, came
from an inadequate training process. The work for which Ms. Lau
was hired was, in the evidence of her Supervisor, Mare Brown,
"different from other types of accounting". Ms. Brown further
testified that municipal accounting of this type was only to be
learned on the job.
After the grievor began the job on June 13, 1988, Mr. Lawson
assigned Mare Brown to act as the grievor's immediate supervisor.
While summer students had performed some parts of Ms. Lau's
duties in the past, Ms. Brown had never been involved with either
their training or with monitoring their work.
2
During the first three weeks of her employment, Ms. Lau was
expected to review the Branch's procedures and the relevant
legislation. On July 5, Mr. Lawson began a special-assignment
while being seconded by the Deputy Minister's Office until August
2. A few days after his return to regular duties, Mr. Lawson
went on vacation and did not return until August 22. While Mr.
Lawson spent time in the office during this period, he had very
little to do with office operation and spent-no time with the
grievor. He also testified that he did not inform Ms. Lau of his
special duties.
Mare Brown, in the meantime, assumed a special project in St.
Mary's, Ontario which she herself had ~nitiated. By her own
evidence, Ms. Brown spent at least two :days a week out of the
office during July and August and more frequently in September.
The requirements of the special project were in addition to her
regular duties as Senior Financial Advisor.
Supervisory arrangements concerning her new position were not
confirmed with Ms. Lau until at least two weeks after her
starting date, according to Mare Brown. Ms. Lau was expected to
seek advice and counsel from other Advisors bdt she was not
informed of this expectation during the initial part of her
training. Mare Brown was not aware of this expectation either.
In cross examination, Mare Brown reversed her earlier assertion
that the requirements of Ms. Lau position ~eq~ired no judgement
and she admitted that there was indeed judgement to be exercised
and that differences of opinion could arise in the normal course
of the job.
In early July, Ms~ Brown went to the grievor to begin training on
the checklists. Evidence showed that since Ms. Lau had been'lad
to believe that her instructions would also come from other
Advisors, she wanted the arrangement confirmed by Murray Lawson.
Mare Brown informed her fellow Advisors at a Section meeting
that, henceforth, Ms. Lau wo~ld check her work with the Advisor
involved and that Ms. Brown would be responsible for co-
ordinating responses created by Ms. Lau.
No schedule for meeting with Ms. Lau was arranged by Brown for
training or supervision purBoses: Rather, according to Ms.
Brown, they would "just talk when necessary". Ms. Lau testified
that each time she tried to see Ms. Brown, she was busy with
other duties and Ms. Lau did not interrupt.
With this confusing training program as the background, the stage
was set for more substantive difficulties. Mare Brown admits her
contact with the grievor had been 'very little until mid-August.
On August 16, Brown wrote a memo to Lau asking her for the
financial statements she had reviewed along with other detail.
4
The information was to be "available by August 18, 9:00 a.m."
Previously, however, Mr. Lawson had told the grievor that these
same statements need not be prepared until the end of August. No
explanation was provided to Ms. Lau regarding this move which she
took to be an abrupt change in training schedule.
Mare Brown testified that her reasons for requesting the
statements was to assist Ms, Lau before she had completed the
review. Criticism of the review later appeared on a September
22 memo from Brown to Lawson in which Ms~ Brown refers to Lau's
refusal to accept verbal instructions.
Ms. Lau responded to the memo on August 24, 1988, by supplying
Mare Brown with a iisi of financial statements she had reviewed
to date. Of some note was the comment that, "I would like to
have any significant changes or additions to the list in writing,
so that I can maintain a list for future reference". This was
interpreted by Mare Brown as being the first indication that Lau
wanted everything in writing. Furthermore, Brown testified that
it was not intended that Lau complete the review of all the
statements, but rather submit those which she had done. In the
September 22 memo, however, Brown criticizes the grievor for only
providing half of the information requested.
5
In the backdrop of this growing antagonism came the "barbecue
incident".
Ms. Brown had what she referred to as a Branch Meeting at her
weekend home near Stratford. Ms. Lau. left the event before the
evening meeting. In the September 22 memo to Mr. Lawson, Ms.
Brown criticized the grievor by stating that Ms. Lau would not
recognize her mistake, Ms. Brown further criticized Lau for not
reading the memo regarding the event accurately. Ms. Lau
testified that she ~had not seen the memo and Murray Lawson
admitted that he had not either.
.The evidence from both Mr. Lawson .and Ms. Brown makes it clear
that the was no written agenda for the meeting, it was intended
to include only social events during the working day, that no
minutes were kept at the meeting and that Murray Lawson and
several others also missed the meeting. Mr. Lawson candidly
admitted that he knew that the issues discussed at the evening
meeting weren't very important.
I would submit that commencing in August, Mare Brown became more
aggressive and the grievor became more defensive.
6
A major reason was the confusion stemming from the lack of any
structured training process for Ms. Lau. And the confusion did
not end there. At the same time as her September 22 memo,.Mare
Brown stated she declined to supervise Monica Lau further.
Murray Lawson took over direct supervision in late October but
Ms.Lau was not informed.
When Murray Lawson left in the new year for another assignme~'t,
Mare Brown was made Acting Manager. This was most unfortunate
for the grievor since, as she testified, Ms. Brown had already
reached the decision in late October that Monica Lau should be
dismissed.
I must respectfully submit that this type of training and
supervision could not afford the grievor the opportunity to
succeed, and that the employer did indeed act improperly. I
believe this view is reinforced by the actions surrounding the
one and only performance review of the grievor dated October 3,
1988.
Murray Lawson requested a report from' Ms. 'Brown on the
performance of Monica Lau on September 15 to complete the
necessary performance appraisal. By his own admission, Mr.
7
Lawson had very little contact with the grievor. Ms. Brown
prepared an initial report which Mr. Lawson described as "overly
critical" and had her delete several references. The final memo,
completed on September 22, was not too much kinder to Ms. Lau.
Under cross examination, Mr. Lawson admitted that the memo was
exaggerated in .a number of areas and that one was indeed
"shocking" (in reference to amendments Ms. Lau had entered to the
citator). Under cross examination Mr. Lawson further admitted
that these exaggerations gave him concern about the entire
document. Yet Lawson conceded that he based his performance
appraisal on this report.
Mr. Lawson was further asked if he had any reason to doubt that
Ms. Lau gave up after receiving nothing positive out of the
appraisal. His answer was to the effect that it was probably
~not. Additional performance appraisals may have had further
bearing on this case but, although Mr. Lawson was required to and
had indicated to the grievor that he would, no later appraisals
were forthcoming.
I believe the performance appraisal process was so seriously
flawed that a fair judgement of Ms. Lau's performance could not
be made. Her performange was no doubt influenced by an
inadequate training program. Criticism of her work for which she
8
had not been trained was exaggerated and tainted by personal
antagonism on the part of her supervisor. Her performance
appraisal simply reflected the biases of that supervisor as
accepted by the Branch Director. It is not surprising that
events after the initial flawed appraisal, which occurred in a
context of suspicion and accusation, led shortly afterwards to
the decision to dismissed the grievor and her actual termination
a few months later.
I submit the employer did not meet the onus of proving that the
termination of the grievor's employment constituted a release.
The Board should have retained jurisdiction with regards to-the
dismissal grievance. I further would have allowed the grievance
on the performance review.
Respectfully,
Menno Vorster