HomeMy WebLinkAbout1992-3155.Howe,Dalton,Loach.94-10-11
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ONTARIO EMPLOYES DE LA COURONNE
-'.j. CROWN EMPLOYEES DEl'ONTARIO
1111 GRIEVANCE CpMMISSION DE
SETTLEMENT REGLEMENT
BOARD DES GRIEFS ~
180 DUNDAS STREE-T WEST SUITE 2100, TOF/ONTO, ONTARIO. M5G 1Z8 TELEPHONE/TELEPHONE (416) 326-1388
180, RUE DUNDAS OUEST BUREAU 2100, TORONTO (ONTARIO) M5G lZ8 FACSIMILE /TELECOPIE (416) 326-1396
3155/92, 643/93, 656/93, 2168/93
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
I
..J
Before
THE GRIEVANCE SETTLEMENT BOARD
BETlfEEN
OPSEU (Howe/Dalton/Loach)
Grievor
- and -
The Crown in Right of ontario
(Ministry of Correctional services)
Employer
BEFORE N Dissanayake Vice-Chairperson
T Browes-Bugden Member
M Milich Member
FOR THE I Anderson
GRIEVOR Counsel
Scott & Aylen
Barristers & Solicitors
FOR THE A Gulbinski
EMPLOYER Grievance Administration Officer
Ministry of Correctional services
HEARING June 23, 1994
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INTERIM DECISION
This Board is seized with five grievances, two filed by
Ms Diane Howe, tW0 by Ms Cynthia Loach and one by Ms Nancy
Dalton
Ms Loach is a part-time casual cook at the Haileybury
jail In October 1992 she complained to the employer that she
had been subjected to sexual harassment by Mr Eric Erickson,
the Superintendent of the jail The employer initiated an
independent investigation into her complaint. The
investigator concluded that her complaint was partially
substantiated. As a result Ms Loach was issued a letter of
apology Mr. Erickson was transferred The employer has
informed the union that the transfer of Mr Erickson was in
response to the findings in the investigation report
In November 1992, Ms Dal ton and Ms Howe laid complaints
alleging sexual harassment on the part of Mr Erickson and Mr.
Mike O'Donnell, a lieutenant at the Haileybury jail An
independent investigator appointed by the employer concluded
that some of the allegations against Mr O'Donnell were
substantiated Mr. Dalton and Ms Howe received a letter of
apology with regard to the actions of Mr. O'Donnell The
union claims that while the employees were informed that
disciplinary action was taken against Mr O'Donnell, the
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employer has persistently refused to disclose the nature of
that discipline.
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No evidence was called at this stage of the proceeding
union counsel set out the foregoing factual background in very
general terms, and informed the Board that the union will be
taking the position that as a direct result of the conduct of
Mr. Erickson and Mr. O'Donnell, both of whom are members of
management, a poisoned environment has been created at the
Haileybury jail. It is alleged that the employer contributed
to the continuation of the poisoned environment by failing to
take appropriate action in response to the grievors'
complaints. In these grievances the union contends that the
investigations conducted, as well as the action taken in
response to the investigation results were so inadequate that
the employer has thereby failed to comply with its obligations
under article A and/or article 27 10 of the collective
agreement.
The parties mutually requested the Board to rule upon a
dispute between them as to the scope of the Board's remedial
jurisdiction in the event the grievances are upheld The
Board was advised that the union will be seeking, inter alia,
a direction that the employer take specific action against Mr.
Erickson and Mr. O'Donnell, namely, that they be transferred
or discharged The issue between the parties was whether the
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Board had the jurisdiction to make such a remedial order
Employer counsel assured the Board that Mr Erickson and Mr
O'Donnell received notice of this proceeding and that both had
indicated that they did not wish to participate in the hearing
on the issue of the Board's remedial jurisdiction However,
the parties felt t~at it was necessary to obtain a ruling from
the Board on this issue prior to hearing the merits of the
grievances, so that Mr. Erickson and Mr. O'Donnell would be
able to make an informed decision whether to participate in
the hearing with their own counsel as affected third parties
The Board having agreed to the parties' request, the
issue to be determined was framed as follows
Does the Grievance Settlement Board have jurisdiction to
I direct the employer to take any specific disciplinary action
,
against a member of management, as a remedy in a sexual
harassment/discrimination grievance?
The following provisions are relevant to this issue
Article A-1 and 27.10.1 and 27 10 2 of the collective
agreement
All There shall be no discrimination practised
by reason of race, ancestry, place of origin,
colour, ethnic origin, citizenship, creed, sex,
sexual orientation, age, marital status, family
status, or handicap, as defined in section 10(1) of
the 0ntario Human Rights Code (OHRC).
27.10 1 All employees covered by this Agreement
have a right to freedom from harassment in the
workplace because of sex by his or her Employer or
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agent of the Employer or by another employee.
Harassment means engaging in a course of vexatious
comment or conduct that is known or ought
reasonably to be known to be unwelcome
27 10 2 Every employee covered by this Collective
Agreement has a right to be free from,
(a) a sexual solicitation of advance made by
a person in a position to confer, grant
or deny a benefit or advancement to the
employee where the person making the
solicitation or advance knows or ought
reasonably to know that it is unwelcome;
or
(b) a reprisal or a threat of reprisal for
the rejection of a sexual solicitation or
advance where the reprisal is made or
threatened by a person in a position to
confer, grant or deny a be~efit or
advancement to the employee.
Sections 18(1) (a) and 19(1) of the Crown Employees
Collective Bargaininq Act:
18-(1) Every collective agreement shall be deemed
to provide that it is the exclusive function of the
employer to manage which functions, without
limiting the generality of the foregoing, includes
the right to determine,
(a) employment, appointment, complement,
organization, assignment, discipline,
dismissal, suspension, work methods and
procedures, kinds and locations of
equipment and classification of
positions;
19-(1) Every collective agreement shall be deemed
to provide that int he eve~t the parties are unable
to effect a settlement of any differences between
them arising from the interpretation, application,
administration or alleged contravention of the
agreement, including any question as to whether a
matter is arbitrable, such matter may be referred
for arbitration to the Grievance Settlement Board
and the Board after giving full opportunity to the
parties to present their evidence and to make their
submissions, shall decide the matter and its
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decision is final and binding upon the parties and
the employees covered by the agreement
The employer relied Re CUPE and OPEIU. LOCAL 491, -
on
(1962) 4 L A.C. (3d) 385 (Swinton) (hereinafter "CUPE case");
Re Canada Post corporation 1983, 11 LAC 3d 13 (Norman)
(hereinafter "Canada Post case" ) and Re Newfoundland Farm.
Products corp (1988) 35 L A.C. (3rd) 165 (Dicks), (hereinafter
"Newfoundland Farm Products case"). Counsel for the union
relied on a number of authorities including, OPSEU and Carol
Berry et. al v. ontario Ministry of community , social
Services (1986) 15 0 A C P i5 (Ont Div ct ) (hereinafter
"the Berry case"), and Re courtenay, GSB 912/88 (Wilson)
Counsel for the union pointed out that the awards relied
on by the employer are all from the private sector In each
of the cases the arbitrator concluded that the remedy sought
in the particular circumstances was punitive and therefore
refused to grant it He submits that in the present case that
is not so because the removal of the harassers either through
transfer or discharge is necessary to remedy the grievances
He submits that the fact that discipline. is stated to be an
exclusive management function under section 18 (1) of the Crown
Employees Collective Bargaining Act does not exclude the
Board's jurisdiction to order that specific action be taken
against the two management personnel, where it is necessary to
provide redress to the grievors.
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Counsel for the employer points out that under section 22
of the Public service Act, the authority to discipline public
servants lies with-the Deputy Minister._or his designate She
further noted that discipline is explicitly mentioned in
section 18(1) of the Crown Employees Collective Bargaining Act
as an exclusive m~nagement function over which this Board had
no jurisdiction. While conceding that the authority conferred
on the Board by section 19 (1) of the Crown Employees
Collective Bargaining Act to "decide the matter" included the
authority to provide an effective remedy or a breach of the
collective agreement, she points out that section 19(1) does
not expressly empower the Board to impose discipline as part
of that remedial authority She submits that where the Board
finds a contravention of the agreement, the purpose of any
remedial order must be limited to making the grievor "whole",
that is, to put her as much as possible in the position she
would have been in if the contravention had not occurred She
submi~s that an order that Mr Erickson or Mr O'Donnell be
discharged or transferred does not have the effect of making
the grievors whole It simply results in punishing them
Employer counsel submits that in any event such an order
is inappropriate because it is ineffective in eradicating the
root problem at the workplace, which is the poisoned
environment. Relying on the arbitration awards cited above,
she submits that any order for the removal of a member of
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management by transfer or discharge must necessarily be
punitive by the very nature of the impact it has on the
individuals. It is her position that while the Board may have
authority to review the employer's conduct for reasonableness
after the employer has exercised its exclusive management
functions, the Board does not have jurisdiction to exercise
the exclusive management functions itself. She contends that
this is exactly what the Board would be doing by granting the
type of order sought.
As an alternate argument counsel submitted that since the
employer has already imposed discipline on the two individuals
to a degree it felt appropriate, imposition of further
discipline by the employer at the direction of the Board would
result in "double jeopardy" The two individuals would be
left with no recourse against the Board's orders This, she
submits, will result in a denial of natural justice
In the CUPE case (supra) a female grieved that she had
been unjustly dismissed for absenteeism which she claimed
resulted from years of sexual harassment by a co-worker, to
her employer's knowledge By way of remedy she sought
reinstatement, restoration of her sick 'leave credits, the
removal of the alleged harasser from the office and an apology
from the employer and the alleged harasser.
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At pp 388-389, the Board states
There are few Canadian cases on point In Re
united packinghouse Workers, Local 114 and Canada
" Packers Ltd.- (1958),9 LA C 200 (Laskin), the
union sought removal of a sub foreman from his
supervisory position because of his abusive
language and belligerent attitude The board held
that the substantive terms of the collective
agreement did not cover sach an issue In terms of
remedy, the board held that it could order
cessation of the offending conduct and left open
whether it could order the supervisor's removal (at
p 203) In Re stanley Works Ltd. and Intll Assoc.
of Machinists. Local 1226 (1979), 24 LAC (2d)
395 (Hinnegan), an employee requested an apology
from another employee who shouted at her The
board held that it was the exclusive function of
management to maintain order and discipline
Furthermore, it doubted the utility of an apology
as a remedy.
American arbitrators show a similar reluctance
to order the employer to discipline another
employee e g , Re Marinette General Hos~ital and
Marinette General HosJ:>ital Employees, Local 1752
(1976), 67 L A 785 (Schoenfeld) at p 787; Re San
Antonia Packing Co. and Amalgamated Meatcutters and
Butcher Workmen of North America, Local 171 (1977),
68 L A 893 (Bailey) at p 897. In Elkouri and
Elkouri, How Arbitration Works, 3rd ed (1973), it
is stated that American arbitrators are generally
reluctant to require discipline of supervisors,
either because such a matter is not arbitrable or
the board has no jurisdiction to award such
punishment (at p. 548).
We agree with the reasons underlying these
cases From a grievor's perspective, the concern
is a remedy Traditionally, those remedies have
been compensatory in nature, based on contractual
considerations, as Polvrner indicates They include
reinstatement (a form of specific performance),
damages, compliance orders and declaratory relief
An order to the employer to discipline another
employee, particularly one outside the bargaining
unit, or to require him to apologize is not
compensatory in nature Rather, it has the flavour
of punitive action demanded by the grievor
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That is not to say that if one employee's
conduct constituted a violation of the collective
agreement the grievor would be without remedy It
would be entirely appropriate, in some cases, for
an arbitration board to order that the employer
cease from violating the collective agreement or
tha t the employer comply with its obligations to
provide a safe work place or one free from
discrimination The result might well be the
dis,cipline of the offending employee, if the
employer felt that was the best way to ensure
compliance.
The decision whether or not to discipline or
how to control employees is one best left to
management, as the cases discussed above have
found A major part of "management rights" is the
employer's right to select and direct staff and to
decide the severity of disciplinary action
required
In the Canada Post case (supra), the Board concluded that
a supervisor had sexually harassed the female grievor and that
the employer was vicariously liable for the violation of the
collective agreement that resulted The collective agreement
empowered the arbitrator to "grant any remedy or compensation
he deems appropriate". The union sought a number of remedies
including an order directing that the employer require the
harasser to make an apology to the grievor After reviewing
the CUPE decision (supra) arbitrator Norman simply held at p
21 that "I am persuaded that an apology ought not to be
ordered" . Instead, he issued a declaration that the
collective agreement was violated and also awarded monetary
damages for mental sUffering
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In the Newfoundland Farm Products Corp case (supra) also,
the arbitrator concluded that the collective agreement had
been contravened when a temporary foreman sexually harassed
the female grievor. The arbitrator reviewed the arbitral
jurisprudence, including the CUPE and Canada Post decisions,
and concluded at p 175 as follows
These cases establish the authority of an
arbitrator dealing with cases of sexual harassment
A board of arbitration does not have the broad
remedial authority given to the Human Rights
Commission. As was stated in Re C.U.P.E. and
O.P.E.I.U., the remedies are compensatory rather
than punitive in nature consequently, inl a case
such as this where it is not the grievor who has
been disciplined, th~ remedies may include damages,
compliance orders and declaratory relief Orders
to the employer to discipline another employee or
to require him to apologize are punitive rather
than compensatory and therefore beyond the
jurisdiction of an arbitrator. consequently, in
this case, I see no legal basis on which I can
order the request to remove the management employee
from the work place
The starting point for a review of this Board's remedial
jurisdiction has to be section 19(1) of the Crown Emplovees
Collective Bargaininq Act The mandate and the obligation of
the Board is contained in the words "shall decide the matter"
The extent of the Board's remedial jurisdiction flowing from
these words was considered by the ontario Divisional Court in
the Berrv Case (supra). There the issue was whether the
Board, having found that the employer had improperly
classified the grievors' positions, had power to require the
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employer to find or create a classification for grievors The
court held that it did In that case also the argument
against jurisdiction was the fact that under section 18(1)
"classification of positions" was an exclusive management
function over which the Board had no jurisdiction In the
present case the argument is the same. It is claimed that
since discipline is an exclusive ~anagement function, this
Board has no jurisdiction to direct the employer to exercise
that function in any specific way in order to remedy a
grievance
After observing that" it is a commonplace of the law that
the existence of a right implies the existence of a remedy",
the court stated in the Berrv case:
(25) The employer initiated the process which led
to grievors being wrongly classified The employer
alone can create classifications yet it has failed
or refused to do so and seeks to take advantage of
its failure Classification is not a mere matter
of title, it is a matter of money The employer
has given grievors added responsibility yet refuses
to compensate them accordingly That situation has
existed since "the end of 1983", to state a fact
asserted in applicant's factum and accepted by
respondents.
(26) The object of arbitration boards, both in the
public and private sector, is the resolution of
differences That is the mandate of this board
It has been stated in unequivocal terms by this
court In R. v. O.P.S.E.U. (1982) 38 0 R 670,
Linden, J., said for the Divisional Court, (at p
675)
" . We are of the view that the board was correct
in its interpretation of s 18 (1) in the
circumstances of this case. The plain and natural
meaning of the words has been adopted by the board
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In order to 'decide the matter' at issue between
the parties, the board had the power, pursuant to
the wording of s 18(1), to grant the job to an
unsuccessful applicant in appropriate
circumstances- That is the clear mandate of the
board pursuant to s 18(1) and the labour relations
jurisprudence of this province Our courts have
interpreted other labour relations legislation in a
consistent way in the past in order to arm
arbitration boards with sufficient weaponry to
perform their responsibilities effectively Courts
have been unwilling to limit the remedial powers of
arbitration boards so as to enfeeble them On the
contrary, our courts have sought to ensure that
arbitration boards can effectively brinq about the
final and binding settlement of all differences
between the parties As Mr Justice Lacourciere
stated in Re Samuel Cooper & Co. Ltd. and Int'l
Ladies' Garment Workers, (1973) 2 0 R 841 at 846,
35 0 L R (3d) 501:
". . the special tribunals created by
unions and employers, and directed by
statute to bring about final and binding
settlement of all differences, ought to
have the necessary powers to achieve such
results." (emphasis added)
(27) The board's obligation under s 19(1) is to
"decide the matter" When looked at without the
confinement imposed by Article 5.1.2 "the matter"
grieved was wrong classification If the board
concluded that the classification was wrong, its
mandate was to effect a proper classification. Its
jurisdiction is unrestricted Its mandate is
remedial In making the decision it made the board
refused to decide the matter, it simply finessed
it In doing so it erred in law Its error was so
serious that, in my opinion, it falls into the
category of cases requiring the intervention of
this court, in accordance with O.P.S.E.U. v. Forer,
supra
In OPSEU & David Anderson et al and the Crown in Right of
ontario, (judgement dated september 21, 1990), the Divisional
Court of ontario had another occasion to comment upon the
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extent to which section 18(1) of the Crown Employees
Collective Barqaininq Act restricts the Board's remedial
jurisdiction in a olassification grievance At pp 18-20 the
court stated
Does the third principle, management's right
to classify positions under s 18 (1) (a) and the
corresponding restriction on the Board's
jurisdiction, require the defeat of the employee's
right to grieve classification and the Board's duty
to effect final settlement of all grievances?
Although Berry did not deal with this precise
set of facts nothing in its language suggests that
the right to grieve classification and the duty to
settle all grievances finally and efficiently must
yield to management classification l:"ights or the
corresponding restriction on the board's
jurisdiction
In fact the language of Berry, the explicit
reference to a remedial mandate with unrestricted
jurisdiction once the board concludes that the
classification is wrong, suggests a wide view of
the remedial power necessary to give effect to the
right to grieve classification and the duty to
settle such grievances finally and efficiently
The statutory right to grieve classification
under s. 18(2) (a), and the Berry duty to effect a
proper classification once the board concludes the
classification is wrong, have coexisted with
management's right to classify and the
corresponding restriction on the board's power.
The power contended for by the employee does
involve the board in some classification activity,
but no more than is necessarily incidental to the
employee's right to grieve classification and the
board's power board to effect the final settlement
of classification grievances. This necessarily
incidental activity on the fringe of the
classification system reserved to the employer
under s 18(1) (a) does not represent any incursion
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into the statutorily protected zone of management
classification rights
The statutory restriction on the Board's
jurisdiction must be read subject to the employee's
statutory right to grieve classification, the
board's statutory duty to effect a final settlement
of classification grievances, and the narrow ambit
of necessarily incidental Board activity around the
outer edge of management's protected classification
zone.
The only decision of the Grievance Settlement Board to
deal with this issue appears to be Re courtenay, 912/88
(Wilson) '. There the Board held quite unequivocally that it
did possess the authority to direct the removal of a harasser
from the workplace as a remedy in a sexual harassment
grievance. However, in the particular circumstances before it,
the Board declined to exercise that authority The Board
reviewed the Canada Post and CUPE awards and stated at p. 82-
83 I
I
These decisions are somewhat ambiguous as to
what the scope of authority of a board of
arbitration is. As a matter of policy, they both
in effect state that they do not think an
arbitration board should be meting out punishment
or making punitive orders against employees not
subject to the collective agreement from which they
derive their jurisdiction As a matter of policy,
I would agree that a board of arbitration should
not get itself into the business of punishing non-
bargaining unit employees. Even in the case of
discipline of bargaining unit employees, a board
only reviews the discipline originally imposed the
employer. The question of what remedies a board
feels are necessary to put an end to sexual
harassment is of course the real issue. In that
regard. I have not doubt that this board under s.
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16
19 of Crown Employees Collective Bargaining Act has
extensive powers. Indeed. the Divisional Court has
repeatedly reminded the Grievance Settlement Board
of the scope of its remedial powers. as for example
in the areas of iob classification and the
Beresford type cases. The same is certainly true
in the area of sexual harassment. Of course, for
any order made by this board either directly
against such a non-bargaining unit employee or
indirectly imposed by an order directed to the
employer under which that non-bargaining unit
employee is effectively ordered to be transferred,
the rules of natural justice must be complied with.
We have done so in this case by giving Fawcett full
status The real question therefore is not what
powers this board has, but what specific orders out
to be made on the facts in a case if a violation
has been found. (Emphasis added)
At p. 85 the Board gave its reasons for not exercising
its extreme remedial powers:
The Grievor is entitled to a declaration that
sexual harassment to the extent found by this Board
did occur I however do not think that it would be
appropriate to direct the Employer to transfer
William Fawcett The findings against him are not
anywhere near as serious as the allegations made
against him. Such an order would be only be
justified if there was no hope of remedying the
situation without such an order. I do not believe
that the facts disclose such a situation. The
Employer is directed to comply with the Collective
Agreement as provided in Article 27 and to take
whatever steps are appropriate to maintain a work
environment free from sexual harassment In
particular, it is so directed with respect to
william Fawcett behaviour towards the Grievor I
personally believe that he will comply it is a
matter of exercising self restraint and refraining
from inappropriate comments such we have found he
made in the past (Emphasis added)
We agree that the only clear principle that emerges out
of the arbitral jurisprudence in the private sector is that
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discipline or punishment of employees is a management
function, which is beyond the scope of the jurisdiction of a
Board of arbitration In the circumstances before them, the
Boards concluded that the orders sought were punitive. The
difficulty, however, with those awards is that the Boards make
general statements which appear to assume that any
disciplinary action directed by a Board of arbitration is in
every case "punitive". This, in our view, is not necessarily
so.
In the case at hand, one of the allegations is that the
manner in which the employer exercised its management
authority to discipline contributed to or caused the poisoned
environment. That very conduct is said to constitute a
violation of the collective agreement. The union is claiming
inter alia, that by taking inadequate action against the
perpetrators, the employer continued to expose the grievors to
the poisoned environment. The employer has already decided
the appropriate level of discipline required ~n its judgement
If the Board agrees with the union that the choice made by the
employer in that regard constituted a violation of the
agreement, it does not make sense to allow the employer to
hide behind the management function theory. It makes no sense
to make a general direction to the employer to take whatever
action it deems necessary to eradicate the problem, because it
already has made that decision and that very action has been
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found to be a contravention of the collective agreement In
the Berrv Case at para 25 (sut'ra), the Divisional court
stated: "The employer alone can create classifications Yet
it has failed to do so and seeks to take advantage of its
failure" Here if we conclude that the employer has failed to
properly exercise the management function of its disciplinary
authority and that it has thereby contravened the collective
agreement, the Board has an obligation to remedy that
contravention. The only effective way of doing that in these
circumstances is by directing the employer to do whatever is
required to remedy the grievors.
In our view the Divisional Court decision in Anderson
(supra) also supports the Board's jurisdiction in these
circumstances It is true that unlike the right to grieve
improper classifications, section 18(2) of the Act does not
specifically guarantee the right to grieve sexual harassment.
Nevertheless, the specific rights recognized in section 18(2)
are said to be "in addition to any other rights of grievance
under a collective agreement". There can be no doubt that
under the collective agreement an employee has a right to
grieve sexual harassment When she grieves, it becomes "a
difference . arising from the interpretation, application,
administration or alleged contravention of the agreement"
within the meaning of section 19(1) of the Crown Emplovees
Collective Bargaining Act The statute requires the Board to
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"decide the matter" and render a final and binding decision
Therefore, we have no doubt that the Act recognizes the right
of an employee to grieve a violation of the collective
agreement, including a violation of articles A and 27 10
Therefore, the reasoning of the court in Anderson at pp.
18-20 quoted above applies equally to this case The issue
here, as it was in Anderson, is whether the employees' right
to grieve and the statutory mandate of this Board to decide
all grievances finally and efficiently must yield to the
reservation of the management functions to the employer or the
corresponding restriction on the Board's jurisdiction.
Just as the Board's exercise of its remedial powers in
Anderson resulted in some incursion into the management's
exclusive rights relating to classification of positions, an
order for the removal of the harasser by a transfer or
discharge will have a similar effect However, as the court
stated, that incursion will only be to the extent "necessarily
incidental to the employee's right to grieve and the
Board's power to effect final settlement of ... grievances".
As the court held, the restriction on the Board's jurisdiction
over exclusive management functions "must be read subject to
the employee's statutory right to grieve . . " and "the
,
Board's statutory duty to effect a final settlement of .
grievances".
20
In Re Courteney (supra) at p 85, the Board stated that
an order for the transfer of a harasser "would be only
justified if there was no hope of remedying the situation
without such an order " In our view, whether a particular
remedial order is absolutely necessary to finally and
effectively remedy a grievance is directly linked to the
question of whether the Board has jurisdiction to grant that
order If the grievor can be redressed without such an order,
the granting of such an order will not be "necessarily
incidental" to the employees' right to grieve and the Board's
statutory duty to finally decide grievances, as contemplated
by the courts It would rather be an incursion by the Board
into the prohibited zone of management rights Similarly, if
such an order is not absolutely necessary to remedy the
grievance, it takes the flavour of punitive action as opposed
to remedial action In other words, it is the necessity of a
particular order to remedy a grievance, which makes it a
remedial order within the Board's powers rather than an
unauthorized exercise of management functions or punitive
action
In the case before us the grievors were subjected to
sexual harassment What does it take to put a stop to that?
As already noted, the Board must give specific directions to
the employer because it has already exercised its management
rights in a manner that contravened the collective agreement
.
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21
(assuming that the Board agrees with the union in that
regard) . Is it sufficient to simply issue a cease and desist
order against a members of management who have been found to
have engaged in-sexual harassment of an employee or is it
necessary to direct his removal from the grievor's workplace?
Again it depends on the degree of confidence or the lack of it
gained by the Board on the basis of all of the evidence as to
whether the harasser will cease his offensive conduct For
example in Re courteney the Board had the confidence that the
harasser would comply with a direction from the Board, and
therefore the Board declined to direct that he be transferred
The same considerations will apply where the direction sought
is for the discharge of the harasser Remembering that the
mandate of the Board in these grievances is to provide redress
to the particular grievors, the appropriateness of such an
order will depend on whether the Board is satisfied that
nothing short of such drastic action can reasonably be
expected to achieve that result. One of the factors that may
be pertinent is whether a less drastic order, such as a
transfer, would not ensure that the grievors will not be
exposed to further harassment by the individuals. Union
counsel submitted that discharge would be the only appropriate
order, because if the harasser is transferred, the harassment
"is going to continue in some other institution within the
OPS". We do not agree that that necessarily will be the case.
In a given case the Board may well decide, as it did in Re
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22
courtenev, that a less drastic remedial order will be
sufficient to deter the harasser Besides, while the
cleansing of the OPS from harassers may be a very noble
objective, this Board does not, in our view, have such a broad
mandate in the course of remedying individual grievances
To summarize then our decision flowing from all of the
foregoing, we find that, if based on all of the evidence the
Board concludes that it is absolutely necessary to direct the
employer to take specific disciplinary action against a member
of management, in order to remedy a grievance, it has the
jurisdiction to do so Because such an order is absolutely
necessary, it is remedial in nature, and within the Board's
jurisdiction The fact that such an order may have the
incidental result of penalizing the member of management, and
of encroaching into areas reserved to the employer as
exclusive management rights, does not mean that the Board must
decline to exercise its authority to remedy a violation of the
collective agreement found to exist
The other side of the coin is that if the Board is
satisfied that other remedial orders can reasonably be
expected to provide full redress, the direction of specific
discipline takes the flavour of a punitive direction which
will be beyond the jurisdiction of the Board Then it is also
. ---_.._-~
23
an unauthorized usurpation on the part of the Board of the
management's exclusive functions
We do not find any merit in the alternate submissions of
employer counsel based on "double jeopardy" and denial of
natural justice If the Board makes an order, all that the
employer would be doing is complying with an order of the
Board, as it is bound by law to do No double jeopardy issue
arises. Similarly no denial of natural justice results to the
individuals affected by a Board order, as long as they have
been given full opportunity to participate in the proceedings
that resulted in those orders They are in no different
position than any other third party affected by a Board order,
such as an incumbent who is ousted from a position as a result
of a Board order in a job competition grievance
Having regard to the reasons the parties sought a ruling
on this issue, the short answer is that the Board has
jurisdiction to direct the removal of a harasser through a
transfer or discharge, if the Board concludes on the basis of
the evidence that the particular order sought is absolutely
necessary to finally and effectively remedy these grievances
The parties are directed to provide appropriate notice
of the hearing into the merits of these grievances to each
affected individual together with a copy of this decision. It
.
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24
will be up to the individuals to decide the extent to which
they would participate in the proceedings
The Board will reconvene on October 14, 1994 to commence
the hearing in to the merits of these grievances
Dated this 11th day of October i994 at Hamilton, ontario
~e7~
N Dissanayake
Vice-Chairperson
T Browes....Bugden
Member
"I Dissent" Dissent to follow
M Milich
Member