HomeMy WebLinkAbout2001-0542.Hastie et al.03-01-23 Decision
Crown Employees Commission de tij
Grievance Settlement reglement des griefs
Board des employes de la
Couronne
"'11_'"
Suite 600 Bureau 600 Ontario
180 Dundas Sl. West 180 rue Dundas Ouest
Toronto Ontario M5G 1Z8 Toronto (Ontario) M5G 1Z8
Tel. (416) 326-1388 Tel. (416) 326-1388
Fax (416) 326-1396 Telec. (416) 326-1396
GSB# 0542/01 0559/01 0560/01 0561/01 0831/01 0908/01
UNION# 01F478 01C400 01C401 01C402,01B275 01B298
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontano PublIc ServIce Employees Umon
(HastIe et al ) Grievor
- and -
The Crown In RIght of Ontano
(Mimstry of Natural Resources) Employer
BEFORE Ken Petryshen Vice-Chair
FOR THE UNION Donald Eady
PalIare Roland Rosenberg RothensteIn LLP
Barnsters and SOlICItorS
FOR THE EMPLOYER Stephen Patterson
AssocIated DIrector Labour PractIce Group
Management Board Secretanat
HEARING November 22,2001 January 14 June 25 26
27 July 9 16 17 & 18 2002
2
DECISION
After an InVestIgatIOn Into the Inappropnate use of e-maIl by employees wIthIn the
Mimstry of Natural Resources ("the MNR") the Employer dIscIplIned 66 employees for
contravemng the Workplace DISCnmInatIOn and Harassment PreventIOn operatIng polIcy
("the WDHP PolIcy") and the OperatIng Procedure on Usage ofI.T Resources ("the IT
PolIcy") The Outlook e-maIl accounts of these employees contaIned Inappropnate
matenal whIch was sexually explICIt. The dIscIplIne Imposed Includes letters of
repnmand, suspenSIOns of varyIng lengths to a maXImum of20 days and the dIsmIssal of
6 employees There was no challenge to my JunsdIctIOn to hear and determIne the 26
gnevances referred to the Gnevance Settlement Board.
The partIes agreed to first deal wIth the gnevances of the dIscharged employees, namely
Mr J Vallee, Mr L Wickett, Mr T Walmsely Mr R. Nadeau, Mr J HastIe and Mr P
CurtIS ("the gnevors") Although concedIng that the gnevors engaged In conduct
deservIng of dIscIplIne, the Umon took the posItIOn that dIscharge was an exceSSIve
response In the CIrcumstances Confronted wIth the prospect of many heanng days, the
partIes agreed to a process whereby the Employer would set out ItS best case to support
the dIscharges and counsel would make theIr submIssIOns on whether the dIscharges
could pOSSIbly be upheld In the CIrcumstances It was agreed that In determInIng whether
the dIscharges could pOSSIbly be upheld, I could take Into account the gnevors'
dIscIplInary records If! determIned that the dIscharges could not be upheld on the basIs
of the Employer's best case and that reInstatement was an appropnate remedIal response
3
In the cIrcumstances, I would reInstate the gnevors and the partIes would then have to
deal wIth the Issue of what penalty should be substItuted for the dIscharges If!
determIned that the dIscharges could possibly be upheld on the basIs of the Employer's
best case, the partIes would then have to address whether the dIscharges could In fact be
upheld, takIng Into account any mItIgatIOn or other relevant eVIdence Of course, because
the CIrcumstances of each gnevor are not IdentIcal, It IS possIble that the result could vary
for each gnevor Even If the gnevors were not reInstated at thIS stage of the proceedIng,
the partIes recogmzed that It was lIkely that the heanng of all of the gnevances would
proceed more expedItIOusly havIng first dealt wIth the dIscharges on the basIs of the
Employer's best case Due to the volume of the matenal and the thoroughness of
counsel's submIssIOns, the heanng to deal wIth the Employer's best case reqUIred 7
heanng days
As part of the matenal for ItS best case, the Employer filed a statement of facts
whIch deals wIth the CIrcumstances gIVIng nse to ItS InVestIgatIOn and the nature of ItS
InVestIgatIOn, WIth reference to the eVIdence gathenng, the fact findIng and the dIscIplIne
stages The statement of facts, absent references to the supportIng matenal, reads as
follows
A. The Beginning of the Complaints
1) Bancroft DIstnct ComplaInt ("Field ComplaInt")
3 On or about January 17 2001 Dan SmIth ("SmIth") Enforcement
SupervIsor Bancroft DIstnct, telephoned Janet Addyman ("Addyman") the
Workplace DISCnmInatIOn and Harassment PreventIOn ("WDHP") Co-
ordInator for the Mimstry of Natural Resources ("MNR") to advIse her that
one of hIS employees had showed hIm matenal whIch was potentIally
Inappropnate under the WDHP PolIcy SmIth advIsed Addyman that, as he
4
was walkIng by the work area of ConservatIOn Officer Marcel Lamont
("Lamont") he overheard Lamont speakIng to Barry Wilson ("Wilson"), a
ConservatIOn Officer about "hand warmers" When SmIth walked by
Lamont's desk area, Lamont showed SmIth a graphIc Image of three nude
women.
4 As SmIth was Lamont's dIrect supervIsor SmIth called Lamont Into hIS office
and advIsed hIm that such matenal was Inappropnate In the workplace, wIth
the use ofMNR eqUIpment. Further SmIth questIOned Lamont about where
he got the Image and Lamont advIsed that he had receIved the Image bye-mall
from a co-worker Barry Wilson.
5 SmIth then spoke to Wilson about the dIstnbutIOn of Inappropnate matenal In
the workplace, wIth the use ofMNR eqUIpment. Wilson admItted that he had
receIved Inappropnate matenal for a long penod of tIme from co-worker
Richard Nadeau ("Nadeau") MNR ConservatIOn Officer
6 Addyman then commenced an InVestIgatIOn and Instructed the IT Branch to
copy OUTLOOK accounts for Lamont, Wilson and Nadeau. The OUTLOOK
account of an MNR employee contaInS the user's e-maIls sent and receIved
from the user's e-maIl address, and any e-maIl stored on the user's computer
11) Chrysler ComplaInt
7 On or about January 18 2001 Addyman receIved an e-maIl and a telephone
call from Sue Rooney ("Rooney"), ActIng ExecutIve AssIstant to the AssIstant
Deputy Mimster Corporate ServIces DIvIsIOn. Rooney advIsed that Thomas
E Cross ("Cross") Manager Industnal Secunty at Daimler-Chrysler Canada,
had called her to advIse that an MNR employee had sent Inappropnate e-maIls
to Chrysler employees on two separate occaSIOns
8 AccordIng to Rooney Cross had provIded Rooney wIth the Inappropnate e-
malls that were sent to the Chrysler employee, and she then forwarded the e-
malls to Addyman. The e-maIls IndIcated that Jim HastIe, MNR OperatIOns
Co-ordInator ImtIally sent the Images to Al Matthews, MNR OperatIOns Co-
ordInator The e-maIls also showed that Al Matthews had forwarded the
Inappropnate Images externally to the Chrysler employee The first Included
eIght Images of a woman named Amber and the second e-maIl Included an
Image of a woman entItled Superheroes
5
9 On or about January 18 2001 Addyman requested the IT Branch of MNR to
retneve and copy the OUTLOOK accounts for Al Mathews and Jim HastIe
10 A reVIew of HastIe's and Al Mathews' accounts uncovered a large volume of
Inappropnate matenal that was sent and receIved by both of them. In
addItIOn, both accounts revealed the names of other MNR employees who had
eIther sent or receIved Inappropnate matenals from Matthews and/or HastIe
B. The Investigation of the Complaints
11 Because of the large volume and sensItIve nature of the Images and
allegatIOns, MNR made a decIsIOn to retaIn an external consultant to lead the
InVestIgatIOn. Grace Shore who IS affilIated wIth the firm of Charles
Novogrodsky & AssocIates ("CN & AssocIates") was retaIned as the
InVestIgator
12 Because of the large number of employees and Images Involved In the
InVestIgatIOn, It was determIned that It would be too tIme consumIng and
costly to have Shore reVIew each of the OUTLOOK accounts by herself As a
result, It was decIded that another external InVestIgator Edward Laas
("Laas"), and Addyman would also assIst Shore wIth the eVIdence-gathenng
component of the InVestIgatIOn.
13 The eVIdence gathenng process of the InVestIgatIOn commenced In late
January 2001
14 In the eVIdence gathenng stage, Shore created an eVIdence summary sheet.
ThIS was a document that IdentIfied the partIcular employee, hIS or her
posItIOn, and a summary of the type of matenal that was found on the
employee's OUTLOOK account. Shore, Addyman and Lass then completed
these sheets for those employees who were IdentIfied as potentIally havIng
Inappropnate matenal on theIr OUTLOOK accounts The actual
Inappropnate Images were pnnted and attached to the eVIdence summary
sheets These eVIdence summary sheets, wIth the noted attachments, were
forwarded to Shore In groups, as soon as they were completed.
15 After the eVIdence was compIled and forwarded to Shore, she revIewed each
employee file to determIne the type of Images found on the employee's file
the number of Images or text; whether the Images or text were sImply receIved
6
by the employee or whether the employee actIvely dIstnbuted Images or text;
and the frequency and/or volume of the exchange or receIpt of matenals
16 The eVIdence gathenng component of the InVestIgatIOn was a very long
process A reVIew of one employee's account would lead to the IdentIficatIOn
of other employees who had not been IdentIfied through other accounts Once
reference to a new employee name was found, Addyman contacted the IT
Branch and requested a copy of theIr OUTLOOK account.
17 After conductIng thIS reVIew Shore determIned that there were a number of
employees who had a relatIvely mInor number of Inappropnate e-maIls that
were not nearly as explIcIt as the matenal found on other employee e-maIl
accounts A reVIew of the relatIvely mIld Images/text IndIcated that they were
In a dIfferent class than that of the other matenal that was found. A
companson of the two groups of e-maIls made It clear that the recIpIents dId
not warrant the same InVestIgatIve process
18 The employer then made a decIsIOn to dIvIde the employees Into two dIStInCt
groups One group the A-LISt, would Include those employees who had a
large volume of Inappropnate matenal found on theIr e-maIl accounts as well
as those employees who were Involved wIth dIstnbutIng Inappropnate e-
malls ThIS group would also Include those employees wIth any Images or
text that were ObvIOusly Inappropnate The second group the B-LISt, would
Include those employees who had a very small number 1 e less than five, of
mIld Images found on theIr accounts and employees who receIved
questIOnable matenal, but dId not dIstnbute them.
19 Shore was responsible for determInIng whether an employee belonged to the
A-LISt or the B-LISt. She determIned that 90 employees were on the A-LISt.
Of these, sIxteen (16) were In management or management excluded posItIOns
and 74 were umomzed. Ninety-mne (99) employees were placed on the B-
LISt.
20 MNR decIded It would not reqUIre employees on the B-LISt to partIcIpate In
the same type of IntervIews as employees on the A-LISt. Instead, employees
on the B-LISt were reqUIred to have formal meetIngs wIth theIr managers and
were provIded wIth copIes of the WDHP PolIcy and summary sheets The
maJonty of these Informal meetIngs occurred dunng or around the week of
May 7 2001 and were not dIscIplInary In nature There was no dIscIplInary
actIOn taken as a result of these Informal meetIngs
21 CommencIng on or about March 20 2001 and contInuIng untIl about June
2001 employees on the A-LISt were provIded wIth a letter adVISIng them that
a management ImtIated WDHP InVestIgatIOn concermng allegatIOns of
Inappropnate computer usage was underway It advIsed the partIcular
7
employee that he or she had been IdentIfied as a respondent In the
InVestIgatIOn and that hIS or her semor manager would be In contact to set up
an IntervIew
22 To a large extent, thIS process contInued untIl late spnng because other
employees, wIth Inappropnate matenal, contInued to be IdentIfied. At the end
of the eVIdence gathenng component of the InVestIgatIOn, a total of 189 MNR
employees had been IdentIfied as havIng Inappropnate matenal
23 The fact findIng component of the InVestIgatIOn Involved IntervIeWIng the
employees, adVISIng them of the allegatIOns that were beIng made agaInst
them, and provIdIng the employees wIth an opportumty to respond to the
allegatIons
24 Shore prepared a set of standard IntervIew questIOns for bargaInIng umt
employees and another set of questIOns for employees occupYIng managenal
or excluded posItIOns For some partIcular employees, supplemental
questIOns were added to the standardIzed questIOns because those employees
had partIcular eVIdence on theIr accounts
25 In or about the thIrd week of March 2001 It was decIded that the matenals
Shore had prepared for the employee IntervIews would be useful In the
InVestIgatIOn of the Chrysler complaInt. Thus, by mId-March the two
InVestIgatIOns were largely merged Into one InVestIgatIOn process
26 MeetIngs/teleconferences were held on or about March 21 2001 and March
22,2001 The purpose of these meetIngs/teleconferences was to advIse and/or
update managers who had employees ImplIcated In the InVestIgatIOn, on the
InVestIgatIOn process The meetIngs/teleconferences were also to prepare
managers for the IntervIew process Shore revIewed the IntervIew questIOns
she had prepared and dIscussed the process and procedure for the IntervIews
WIth managers at the meetIngs/teleconferences
27 There were approxImately thIrty managers who conducted the vanous
IntervIews For each employee's IntervIew there were two (2) managers In the
SMG 1 and/or SMG 2 classIficatIOn present for the meetIng. About thIrty (30)
managers were Involved In the entIre IntervIew process
28 After the IntervIews were conducted wIth the employees wIthIn the A-LISt, the
managers returned the IntervIew packages to Addyman. These packages
consIsted of the IntervIew questIOns and hand-wntten answers of the
managers, an eVIdence summary sheet, and appended Images that were found
on the employee's account. The completed packages were sent to Addyman
who In turn forwarded them to Shore so that she could begIn on the analysIs
component of the InVestIgatIOn. The eVIdence packages were sent to Shore In
groups, as soon as Addyman receIved them
8
29 Shore was the only person Involved In completIng the analysIs and draft report
component of the InVestIgatIOn. In prepanng these drafts Shore made
reference to the e-maIls, the polIcIes, the IntervIew documents and any letters
provIded by the employees In prepanng these reports Shore summansed the
eVIdence on a form whIch was provIded to her by MNR, and whIch reqUIred
the IdentIficatIOn of the eVIdence on cntena of volume, nature of Involvement
by the employees and nature of the matenals ThIS form provIded a rough
way In whIch to summanze the nature of the employee's conduct.
30 Shore began draftIng reports In the begInmng of Apnl2001 Shore drafted
reports on IndIVIdual employees and then forwarded them In groups to
Addyman to dIstnbute to the employees Addyman began to dIsclose the draft
InVestIgatIOn reports to employees on or around May 7 2001 Along wIth the
draft InVestIgatIOn reports, MNR Included a letter askIng the employees to
respond wIth theIr comments or concerns wIthIn five days of reCeIVIng the
draft reports The Employer also advIsed the employees that extensIOns to the
five day penod would be provIded If necessary
31 Addyman provIded respondent comments to Shore as she receIved them, and
Shore then prepared a final report for each respondent.
32 Shore revIewed the responses provIded by the employees and determIned
whether the employees' response changed the findIngs of the report. Not all
the employees provIded responses to the draft InVestIgatIOn report. Shore
began provIdIng Addyman wIth final reports as they were prepared, wIth most
final reports provIded by the week of May 28 2001
33 Addyman was the mImstry contact responsIble for acceptIng or reJectIng the
InVestIgator's findIngs In each case UltImately she accepted the findIngs In
all the reports
34 Out of the 90 employees on the A-LISt, allegatIOns agaInst 83 of the
employees were substantIated, and 7 were not substantIated.
35 BegInmng on or around June 4 2001 the letters were delIvered to
respondents, adVISIng them that they were found to have vIOlated the IT and
WDHP polIcIes The letter also advIsed that theIr manager would be meetIng
wIth them In the near future to dISCUSS the matter
C. The Discipline Stage
36 On or about May 28 and 29 2001 a managers meetIng was held In Toronto
The purpose of the conference was to advIse managers of the outcome of the
InVestIgatIOn, detaIl next steps, provIde managers wIth tools to assIst them In
9
makIng dIscIplInary deCISIOns, and provIde InformatIOn on dealIng wIth
workplace Issues ansIng from the InVestIgatIOn. On the Issue of dIscIplIne,
pnor to the meetIng, managers were provIded wIth two Issue papers relatIng
to dIscIplIne and the exerCIse of management dIscretIOn. Managers were
asked to reVIew the Issue papers and at the meetIng, Lon AselstIne, Staff
RelatIOns Officer MNR, revIewed the manager's responsibIlItIes for makIng
dIscIplInary deCIsIOns wIth reference to the two Issue papers
37 At the meetIng, managers were also able to compare the eVIdence of theIr
employees and the other employees Lon AselstIne provIded the managers
wIth recommendatIOns on dIscIplIne AselstIne's recommendatIOns on
dIscIplIne were based solely on the eVIdence packages, and dId not take Into
account any mItIgatIng or aggravatIng factors The ultImate dIscIplInary
deCIsIOn, takIng Into account any mItIgatIng or aggravatIng factors, rested wIth
the manager wIth the delegated authonty
38 Managers began havIng theIr final dIscIplInary meetIngs wIth respondents
begInmng on or around June 7 2001 These meetIngs were to provIde
respondents wIth a final opportumty to raise explanatIOns of theIr conduct or
to IdentIfy mItIgatIng factors that mIght affect the manager's decIsIOn
regardIng what, If any dIsCIplIne would be Imposed.
39 Subsequent to those meetIngs, MNR Human Resources Branch was advIsed
by each of the managers of the specIfic actIOn that was taken agaInst each
respondent.
In support of ItS best case the Employer filed seven boxes of matenal whIch
provIded a complete documentary pIcture of ItS WDHP InVestIgatIOn and the dIscIplInary
process relatIng to the IndIVIduals on the A-LISt. The matenal Includes the WDHP
PolIcy the IT PolIcy a Memorandum to all MNR staff from the then Deputy Mimster
dealIng wIth the WDHP PolIcy and the two Issue papers provIded to the managers The
matenal also Includes documents relatIng to each person on the A-LISt, such as the
dIscIplIne letter executed by the manager the letter from Mr D Lynch, DIrector Human
Resources Branch, notIfYIng each person of the InVestIgatIOn and the IntervIew the two
sets of IntervIew questIOns and responses prepared by the two managers at each
IntervIew the draft and final InVestIgatIve reports prepared by the external WDHP
10
InVestIgator and any response to the report by the person under InVestIgatIOn and a
manager's chart prepared by each manager Involved In dIscIplImng an IndIVIdual The
bulk of the matenal consIsts of the text and Images reproduced from the Outlook
accounts, along wIth the e-maIl cover sheets The Employer also filed CDs whIch
contaIned the matenal retneved from Outlook accounts and relIed upon by the Employer
For each employee the Employer filed a summary chart and an eVIdence table The
summary chart provIdes some basIc InformatIOn about the matenal In each person's
Outlook account, such as the date who the matenal was receIved from and/or sent to the
subJect and content of each Item and whether It was deleted. The eVIdence table prepared
for each person provIdes another useful summary of the Inappropnate matenal contaIned
In the Outlook accounts and Illustrates the manner In whIch the Employer analyzed the
matenal One column separates the Items on the basIs of "receIved and deleted"
"receIved and saved" "receIved and dIstnbuted" "dIstnbuted" and "dIstributed wIth
comments" Another column categonzes the matenal on the basIs of "sexual content"
"nudIty" "exposed gem talI a" "sexually graphIC" "vIOlence/ degradatIOn/and
dehumamzatIOn" and "other/racIal, ethmc, place of on gIn, sexual onentatIOn, etc"
Although there were some errors made on the summary sheets and eVIdence tables for the
gnevors, they were mInor In nature and they dId not, In my VIew alter the essence of
each gnevor's conduct. The Employer also filed 39 "wIll-say statements" from
IndIVIduals who the Employer would have called as wItnesses There are wIll-say
statements by the persons referred to In the statement of facts and the managers who were
Involved In decIdIng what dIscIplInary response was appropnate for persons on the A-
LISt.
11
HavIng regard to the nature of the submIssIOns, I revIewed the matenal relatIng to
the gnevors, as well as the matenal relatIng to others on the A-LISt, IncludIng managers
and employees who were Issued sIgmficant suspensIOns ThIS was a tIme consumIng
process and gIven the nature and volume of the Inappropnate matenal, It was not a
pleasant exerCIse Although the Umon raised some process concerns and suggested that
the Employer "rushed to Judgement" and felt compelled to dIscharge some employees
sImply because of ItS zero tolerance approach, a reVIew of the matenal suggests
otherwIse It appears from the matenal that the Employer conducted a careful and
extensIve InVestIgatIOn and that the dIscIplInary process was handled In a fair and
professIOnal manner As well, an eXamInatIOn of all of the matenal confirms the OpInIOn
I formed at the heanng to the effect that the IndIVIduals responsIble for gathenng and
orgamZIng the matenal for the Employer's best case dId a very thorough and competent
Job At the conclusIOn of the heanng, counsel for the Umon commended the Employer
for ItS efforts In thIS regard and I echoed that sentIment. In my VIew the nature of the
matenals filed wIll lIkely ensure that the gnevances wIll be addressed more expedItIOusly
than would otherwIse have been the case
As noted prevIOusly the Employer alleges that the dIscIplIned employees
contravened the WDHP PolIcy and the IT PolIcy The Umon does not dIspute that the
employees who were dIscIplIned faIled to comply wIth the IT PolIcy The IT PolIcy filed
wIth me IS dated July 21 2000 I was referred by counsel to the folloWIng sectIOns of the
IT PolIcy
12
PURPOSE
To protect the government's Interest In ensunng that InformatIOn Technology
Resources are used only for government busIness and other approved purposes
PRINCIPLES
User Accountabilitv
Unacceptable use of InformatIOn and InformatIOn Technology Resources may
result In restncted Access to those resources and/or dIscIplInary actIOn.
Business Purposes
InformatIOn and InformatIOn Technology Resources are to be used for
government busIness purposes that support the goals and obJectIves of mImstnes
and agencIes Use of government computers, Networks, systems and software
may be subJect to momtonng.
Unauthorized Use of Resources
Computer systems and Networks must not be used for Illegal or unacceptable
actIvIty
Unacceptable activity
In the context of I. T resources, unacceptable actIvIty Includes
- Access, dIsplay or storage of any software, Data, graphIc or Image whIch IS
offensIve and conducIve to a pOIsoned work envIronment (as per WDHP
PolIcy)
RESPONSIBILITIES
Users
Users are responsIble for
- USIng InformatIOn Technology resources only when authonzed by
management and only for government busIness or approved purposes
Appendix
Unacceptable and illegal activities Include but IS not lImIted to
13
Child pornography and obscenity possessIng or dIstnbutIng chIld
pornography dISSemInatIng obscene matenals
Hatred wIlfully promotIng hatred agaInst any IdentIfiable group by
commumcatIng such statements outsIde of pnvate conversatIOns
The computer system provIdes a warmng on every mImstry computer whIch
appears before entenng the user's name and password. The user IS warned that
unauthonzed use of the computer system IS prohIbIted. A second warmng appears before
loggIng onto the Outlook e-maIl account. The user must clIck the OK box below the
warmng to acknowledge readIng the advIsory notIce before proceedIng. ThIS warnIng
reads as follows
As wIth other government resources, InformatIOn Technology (IT) resources [e g.
EmaIl, Internet/Intranet] are to be used exclusIvely for government busIness,
unless authonzed by the employee's manager As has always been the case, the
government has an Interest In ensunng that government resources are used by
employees only for busIness purposes SpecIfically IT resources are not to be
used for purposes that the OperatIng Procedure on Usage ofIT Resources lIsts as
unacceptable, such as to access, dIsplay or store offensIve data, for personal or
pnvate busIness, or to send anonymous messages Consequently If the
government has reasonable belIef that IT resources are beIng used
Inappropnately by an employee, It wIll momtor thIS usage to determIne whether
any dIscIplInary or other actIOn should be taken. The full text of the OperatIng
Procedure IS avaIlable for reVIew at Intra.cpb.gov.on.ca By selectIng the box
IndIcated below you acknowledge that you have read thIS advIsory notIce
One of the ways the Employer has attempted to create a workplace envIronment
consIstent WIth the obJectIves of the Ontano Human RIghts Code ("the Code") IS WIth the
creatIOn and enforcement of the WDHP PolIcy ThIS polIcy was first Introduced In 1990
wIth the current verSIOn effectIve from 1998 The WDHP polIcy IS Intended to promote
fair employment practIces and to Improve the workIng envIronment for all employees In
14
addressIng the Inappropnate use of e-maIl In thIS Instance It appears that the Employer's
pnmary focus was on thIS polIcy Counsel referred me to the folloWIng aspects of the
WDHP PolIcy
PURPOSE
ThIS polIcy supports
- a posItIve and respectful workplace that IS free from dISCnmInatIOn and
harrassment based on the Ontano Human RIghts Code
- preventIng, IdentIfYIng and correctIng actIOns of one employee toward another
that, left unchecked, would result In employment-related dISCnmInatIOn or
harassment.
APPLICATION AND SCOPE
ThIS polIcy covers
- the Code's prohIbIted grounds of employment-related dISCnmInatIOn and
harassment whIch are race, ancestry place of on gIn, color ethmc on gIn,
cItIzenshIp creed, sex (includIng pregnancy), sexual onentatIOn, age, record
of offences, mantal status, famIly status or handIcap (dIsabIlIty)
- behavIOrs and practIces based on prohIbIted grounds, IncludIng
0 creatIng, contnbutIng or condomng a pOIsoned work envIronment.
0 faIlure of management, In keepIng wIth ItS authonty to respond
adequately to InformatIOn about dISCnmInatIOn, harassment or
pOIsoned work envIronment; such faIlure may be consIdered
condomng of dISCnmInatIOn and/or harassment.
PRINCIPLES
The OPS as an employer IS commItted to
- zero tolerance of dISCnmInatIOn and harassment
- proactIve, preventIOn-onented and cost-effectIve practIces
- alternate dIspute resolutIOn processes, and
- resolutIOn of dISCnmInatIOn and harassment, as soon as possIble, and In a way
that least dISruptS ongoIng workIng relatIOnshIps
- All aspects of workplace dISCnmInatIOn and harassment preventIOn processes
wIll be fair responSIve, tImely confidentIal, professIOnal, ImpartIal,
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consIstently applIed, and wIll aim to preserve the dIgmty self-respect and
nghts of all partIes
- Responses to dISCnmInatIOn and harassment wIll aim to correct IdentIfied
problems and to prevent repeated vIOlatIOns of thIS polIcy
MANDA TORY REQUIREMENTS
PreventIOn, commumcatIOn and educatIOn
- Employees must not be subJected to offensIve remarks, behavIOr or
surroundIngs (based on the prohIbIted grounds) that create IntImIdatIng or
humIlIatIng workIng condItIOns
PenaltIes
- Employees found to have vIOlated thIS polIcy wIll receIve penaltIes, If
appropnate (dependIng on the CIrcumstances of each case) up to and IncludIng
dIsmIssal
RESPONSIBILITIES
Managers and Supervisors
- ensunng that theIr workplaces are free from dISCnmInatIOn and harassment;
IncludIng clanfYIng the type of workplace behavIOr expected under thIS
polIcy
ALL EMPLOYEES
All employees are responsIble for
- refraInIng from dISCnmInatIOn and harassment, IncludIng offensIve remarks or
other actIOns that create IntImIdatIng hostIle or humIlIatIng workIng
condItIOns based on the prohIbIted grounds of thIS polIcy
- adhenng to thIS polIcy and related mImstry processes
Employees are encouraged, where possible, to tell alleged offenders about
unwelcome conduct or actIOns perceIved to be dISCnmInatory WhIle employees
cannot be reqUIred to report expenences of dISCnmInatIOn or harassment, they are
also encouraged to qUIckly notIfy the first level of management not Involved In
the complaInt (free of bIas or conflIct of Interest) about alleged vIOlatIOns of the
polIcy ThIS procedure helps to resolve Issues qUIckly and In the least adversanal
way
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DEFINITIONS
Poisoned work environment
An Infnngement of every person's nght to equal treatment wIth respect to
employment whIch refers to comments, behavIOur or work envIronment that
ndIcules, belIttles or degrades people or groups IdentIfied by one or more
prohIbIted grounds of thIS polIcy A pOIsoned work envIronment could result
from a senous and sIngle event, remark or actIOn and need not be dIrected at a
partIcular IndIVIdual
In July 1998 Deputy Mimster R. Vrancart Issued a memorandum ("the
Deputy's memorandum") to all MNR staff about the WDHP PolIcy and zero tolerance
For purposes of the Employer's best case, I wIll assume that the gnevors receIved or were
aware of thIS com mum catIOn. The relevant paragraphs of the Deputy's memorandum
read as follows
The Mimstry of Natural Resources has a zero tolerance polIcy wIth respect to
dISCnmInatIOn and harassment In the workplace ThIS polIcy IS called the
Workplace DISCnmInatIOn and Harassment PreventIOn (WDHP) OperatIng
PolIcy As the Deputy Mimster I am commItted to thIS zero tolerance polIcy
ThIS polIcy applIes to dISCnmInatIOn In all aspects of employment such as
recruItment, promotIOn, traInIng, Job transfer receIpt of benefits, dIsmIssal,
dIscIplIne and performance appraisals All MNR employees have the nght to fair
and eqUItable treatment In employment wIthout dISCnmInatIOn or harassment
based on specIfic grounds as outlIned In the Ontano Human RIghts Code Those
grounds are race ancestry place of on gIn, color ethmc ongIn, cItIzenshIp creed,
sex (includIng pregnancy), sexual onentatIOn, age, record of offences, mantal
status or handIcap (dIsabIlIty) SImIlarly no employee IS to be subJected to a
pOIsoned work envIronment or partIcIpate In the creatIOn of one A pOIsoned
work envIronment IS charactenzed by comments or behavIOrs that ndIcule,
belIttle or degrade people or groups IdentIfied by one or more prohIbIted grounds
ThIS behavIOr does not need to be dIrected at specIfic IndIVIduals
The number of WDHP complaInts InvestIgated Increased over the last year
IndIcatIng a need to reInforce the mImstry's zero tolerance polIcy Please
beadvIsed that as deputy Mimster I take these matters very senously and It IS my
expectatIOn that all staff are able to work free of dISCnmInatIOn and harassment.
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It has been brought to my attentIOn that there IS a dIsturbIng new trend that many
employers, IncludIng MNR, are currently expenenCIng - specIfically the use of
mImstry computers to access pornographIc and other questIOnable matenal from
the Internet. It goes wIthout saYIng that the use of computers for anythIng other
than government busIness IS not allowed. However you also need to be made
aware that the acceSSIng, presence and/or dIsplaYIng of pornographIc or other
offensIve matenals on mImstry computers can create a pOIsoned work
envIronment and may be In dIrect vIOlatIOn of the WDHP polIcy DependIng on
the matenal, there may also be ImplIcatIOns under the CnmInal Code of Canada.
The use of mImstry eqUIpment and/or work tIme to access offensIve matenals of
any kInd IS unacceptable and wIll not be tolerated. It wIll result In dIscIplInary
actIOn, up to and IncludIng dIsmIssal As the computer eqUIpment and systems
are the property of the Mimstry to be used solely for busIness related purposes,
the Mimstry maIntaInS the nght to momtor computer use and content from tIme to
tIme as deemed appropnate and wIthout notIce to the employee
As the matenal filed dIscloses, the problem of e-maIl abuse was qUIte wIdespread, gIven
the number of IndIVIduals who were InvestIgated relatIve to the total number ofMNR
employees Inappropnate matenal was found In the Outlook accounts of OPSEU
employees, some employees represented by AMAPCEO Human Resources staff and a
WDHP advIsor As well, there were a fairly sIgmficant number of managers on the A-
LISt. There are examples of employees sendIng Inappropnate e-maIl to managers and
managers sendIng such matenal to employees Although the maJonty of persons on the
A-LISt are males, there are a number of women on that lIst, some of whom were
dIscIplIned.
The persons who were dIscIplIned sent and receIved Inappropnate e-maIl to and
from persons both wIthIn and outsIde the MNR. It appears that the recIpIents of the
Inappropnate Items dId not consIder the matenal offensIve Many of the Items were
attempts at humor and at the tIme many employees dId not VIew theIr conduct as senous
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Dunng the InVestIgatIOn the employees dId not deny the actIvIty as reflected In theIr
Outlook accounts The Inappropnate matenal was sent to and dIstnbuted by the MNR
employees wIthout any employee complaInIng In general or under the WDHP PolIcy
One of the dIsputes between the partIes concerns the sIgmficance of there beIng no such
complaInt.
IndIvIduals were asked dunng the IntervIew process whether they had receIved
WDHP traInIng and Invanably the response was In the affirmatIve The Employer
provIdes employees wIth extensIve WDHP traInIng. However there IS no IndIcatIOn In
the matenal that the WDHP traInIng addressed Inappropnate computer and e-maIl usage
and what Impact the dIstributIOn of pornography bye-mall can have In the workplace
The final WDHP report for each gnevor provIdes a summary of the Inappropnate
e-maIl actIvIty from theIr Outlook account. Although some mInor InaccuracIes are
contaIned In the final reports, whIch IS not surpnSIng, the reports do provIde the essentIal
actIvIty upon whIch the Employer based ItS decIsIOn to dIscharge each gnevor I do not
Intend to detaIl the nature of the matenal contaIned In the Outlook account of each
gnevor or the matenal In the accounts of those persons who receIved sIgmficant
suspensIOns Although some of the Items In the gnevors' accounts are racIst,
homophobIC and contaIn bestIalIty many of the Items obJectIfy demgrate and show
hoStIlIty to women. The depIctIOn of women ranges from the dIsplay of breasts and other
parts of the female anatomy to women engaged In a vanety of sexual acts Some of the
Items InvolVIng women are vIOlent and degradIng. One of the most offensIve Items, an
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InteractIve vIdeo cartoon entItled "DIrty Sanchez" was found In the Outlook accounts of
Mr Walmsely Mr HastIe and Mr CurtIS There IS lIttle doubt that but for the presence
of thIS Item In hIS Outlook account, Mr Walmsely would not have been termInated. The
folloWIng descnptIOn of thIS Item IS accurately set out In Mr CurtIS' final WDHP report
as follows
" The sInger Bntney Spears' face IS supenmposed on a women cartoon figure
She IS beIng spanked and beaten dunng Intercourse The man then Inserts hIS
Index finger Into her anus, removes It, smffs It and then smears feces across
Bntney Spear's upper IIp The words DIRTY SANCHEZ appear After VIeWIng
thIS you may select three optIOns 1) Do It agaIn 2) KICk her out of the WIndow or
3) Snuff mOVIe By selectIng #1 the vIdeo cartoon repeats Itself By selectIng
#2, you see a cryIng Bntney Spear saYIng he used and degraded me whIle she IS
kIcked out a glass WIndow fallIng to her death. By selectIng #3 you see a cryIng
Bntney Spear saYIng he used and degraded me SILENCE OF THE LAMB S
appears across the screen and the VIewer gets to select where to shoot her wIth a
sIlencer on a gun. A vIdeo message appears YOU SADISTIC BASTARD
Throughout the whole vIdeo laughIng IS heard."
Before reVIeWIng the summary paragraphs contaIned In each gnevor's final
WDHP report, I note that at the heanng counsel for the Employer wIshed to enter and
rely on some Inappropnate matenal sent or receIved by some of the gnevors whIch was
not referred to In the WDHP reports There were not many such Items and counsel noted
that they dId not sIgmficantly alter the charactenzatIOn of each gnevor's conduct. SInce
these Items were avaIlable to the Employer but were not relIed upon when decIdIng
dIscIplIne counsel for the Umon took the posItIOn that the Employer should not be
permItted to rely on these Items at thIS stage It IS my conclusIOn that the Employer
cannot rely on these addItIOnal Items because they were avaIlable to the Employer pnor
to the dIsmIssals See, Dupont Canada Inc V CommumcatIOn, Energy and Paperworkers
Umon of Canada, Local 28-0 [2001] O.L AA No 676 (Roach) In any event, I also
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agree wIth counsel for the Employer's assessment that these addItIOnal Items do not
affect the analysIs of the conduct of each gnevor
Jean-Jaques Vallee
At the tIme of hIS dIsmIssal, Mr Vallee worked In the MNR as a Semor Fish and
WildlIfe SpecIalIst. He was a classIfied employee based out of Chapleau In the Northeast
RegIOn. ThIrty Items were IdentIfied In Mr Vallee's Outlook account, wIth 27 Items
receIved and 3 sent. The final WDHP report summanzes hIS Inappropnate e-maIl actIvIty
as follows
Of the twenty-seven Items receIved they were charactenzed In the folloWIng
manner SIX Items contaIned matenals wIth sexual content; SIX Items contaIn-
ed Items contaIned matenals wIth nudIty three Items contaIned matenals wIth
exposed gemtalIa, SIX Items contaIned sexually graphIc matenals and, SIX Items
contaIned matenals wIth degradIng, dehumamzIng and racIal content. The
respondent redIstnbuted mne Items eIther InsIde the MNR or outsIde the OPS and
deleted the remaInIng 18 Items
Of the three Items sent by the respondent, two Items contaIned nudIty and one
Item contaIned degradIng matenal The respondent dIstnbuted these Items eIther
InsIde the MNR or outsIde the OPS
Larry Wickett
Mr Wickett was an unclassIfied employee who at the tIme of hIS dIsmIssal,
worked as a Highway 407 ProJect BIOlogISt, based out of the Aurora DIstnct. Of the 55
Items IdentIfied on hIS Outlook account, Mr Wickett receIved 47 Items and sent 8 Items
His final WDHP report contaInS the folloWIng summary
Of the 47 Items receIved 45 EmaIls contaIned matenals that were charactenzed In
the folloWIng manner 13 Items contaIned matenals wIth sexual content; 10 Items
contaIned nudIty 10 Items contaIned matenals wIth exposed gem talI a, five Items
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contaIned sexually graphIc matenals and, seven Items WIth degradIng,
dehumamzIng and vIOlent matenals The respondent re-forwarded seven Items
InsIde the MNR and outsIde the OPS stored 32 Items and deleted the remaInIng
SIX Items
Of the eIght Items dIstnbuted by the respondent, eIght EmaIls were charactenzed
In the folloWIng manner three Items contaIned sexual content; three Items
contaIned nudIty one Item contaIned exposed gemtalIa. These matenals were
dIstnbuted InsIde the MNR and outsIde the OPS
Terry Walmsely
Mr Walmsely was an unclassIfied employee who worked In the MNR as a
FIshenes TechmcIan, based out of Owen Sound. Of the 9 Items IdentIfied on hIS Outlook
account, he receIved 8 Items and sent 1 Item. There were 5 addItIOnal Items that were
cross referenced from other MNR accounts His final WDHP report contaInS the
folloWIng summary
Of the eIght Items receIved they contaIned matenals that were charactenzed In the
folloWIng manner 5 Items contaIned matenals wIth nudIty 2 Items contaIn- ed
sexually graphIc matenals and one Item WIth degradIng, dehumamzIng and
vIOlent matenal The respondent re forwarded all of these Items outsIde the OPS
The one Item dIstnbuted by the respondent contaIned ethmc and sexual content
and was dIstnbuted InsIde the MNR.
Of the five cross-referenced Items three Items contaIned exposed gemtalIa, one
Item contaIned degradIng matenal and one Item contaIned sexual and racIal
content. These five Items were deleted.
Richard Nadeau
Mr Nadeau was a classIfied employee who worked In the MNR as a
ConservatIOn Officer based out of the Hearst DIstnct In the Northeast RegIOn. A
dIstInctIOn between Mr Nadeau and the other gnevors IS the Employer's relIance on the
fact that he subscnbed to Inappropnate web sItes and downloaded matenal from those
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sItes There were actually 46 Items IdentIfied on hIS Outlook account. Of these Items, 43
were receIved and 3 Items were sent. There were 3 Items ongInatIng from Mr Nadeau
whIch were cross-referenced from other MNR accounts His final WDHP report contaInS
the folloWIng summary
The 43 EmaIls receIved contaIned matenals that were charactenzed In the
folloWIng manner 19 Items contaIned matenals wIth sexual content; two Items
contaIned matenals wIth nudIty 7 Items contaIned matenals wIth exposed
gemtalIa, 8 Items contaIned sexually graphIc matenals four Items WIth degradIng,
dehumamzIng matenals and 3 Items WIth sexual onentatIOn and place of ongIn
content. The respondent re-forwarded 11 of these Items, stored seven Items and
deleted 26 Items from hIS account.
Of the three Items dIstnbuted by the respondent, one was IdentIfied as contaInIng
sexual content. ThIS Item was dIstnbuted InsIde and outsIde the OPS The three
cross-referenced matenals were charactenzed as follows one Item contaIned
exposed gemtalIa, one Item was sexually graphIc and one Item contaIned
degradIng matenal These Items were dIstnbuted InsIde the MNR, InsIde the OPS
and outsIde the OPS
Jim HastIe
Mr HastIe was a classIfied employee who worked In the MNR as an OperatIOns
CoordInator based out of Owen Sound. Of the 76 Items IdentIfied on hIS Outlook
account, Mr HastIe receIved 53 Items and sent 23 Items The summary set out In hIS
final WDHP report IS as follows
Of the 53 Items receIved 53 EmaIls contaIned matenals that were charactenzed In
the folloWIng manner 15 Items contaIned matenals wIth sexual content; 14 Items
contaIned matenals wIth nudIty mne Items contaIned exposed gemtalIa, SIX Items
contaIned sexually graphIc matenals and eIght Items WIth degradIng,
dehumamzIng and vIOlent matenals The respondent re-forwarded 18 Items
WIthIn the MNR, stored two Items and deleted the remaInIng Items
Of the 23 Items dIstnbuted by the respondent, 23 EmaIls were charactenzed In the
folloWIng manner 6 Items contaIned sexual content; 10 Items contaIned nudIty
SIX Items contaIned exposed gemtalIa, one Item contaIned sexually graphIc
matenal three Items contaIned Images that were eIther vIOlent, degradIng or
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dehumamzIng; and one Item contaIned racIal content. These matenals were
dIstnbuted InsIde the MNR and outsIde the OPS
PhIl CurtIS
Mr CurtIS was an unclassIfied employee who worked In the MNR as an
Assessment TechmcIan SInce Apnl2nd, 2001 based In Owen Sound. Pnor to Apnl2nd,
2001 he worked as a Harvest Survey TechmcIan. Of the 50 Items IdentIfied on hIS
Outlook account, he receIved 22 Items and sent 28 Items The summary In hIS final
WDHP report references the folloWIng actIvIty
Of the 22 Items receIved 18 EmaIls contaIned matenals that were charactenzed In
folloWIng manner 4 Items contaIned matenals wIth sexual content; 8 Items
contaIned matenals wIth nudIty 2 Items contaIned sexually graphIc matenals,
and, four Items WIth degradIng, dehumamzIng and vIOlent matenals The
respondent re-forwarded all of these Items InsIde the MNR and outsIde the OPS
Of the 28 Items dIstnbuted by the respondent, 28 EmaIls were charactenzed In the
folloWIng manner 12 Items contaIned sexual content; 4 Items contaIned nudIty
3 Items contaIned exposed gemtalIa, five Items contaIned sexually graphIc
matenal and four Items contaIned Images that were eIther vIOlent, degradIng or
dehumamzIng. These matenals were dIstnbuted InsIde the MNR and outsIde the
OPS Three Items were personal correspondence contaInIng offensIve language
and sexual dIscussIOn.
Ms Lon AselstIne, a Staff RelatIOns Officer In the Human Resources Branch of
the MNR, played a sIgmficant role In the dIscIplInary decISIOn makIng process Her
pnmary role was to ensure consIstency Her wIll-say statement refers to part of her
efforts In thIS regard as follows
29 Between May 8 and May 24 2001 I revIewed each and every pIece of
eVIdence In the eVIdence package for each respondent, and read the
correspondIng draft report. I began to orgamze the eVIdence packages by
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lImng up files, based on content only In a rough order from least to most
offensIve When I began to relatIvely order/orgamze the eVIdence packages,
they seemed to gravItate Into three natural groupIngs I dId not set out to
create three groupIngs I sImply started separatIng the eVIdence packages
based on theIr levels of offensIveness, and the matenals naturally gravItated to
three groups
30 We revIewed a number of eVIdence packages In the three dIfferent groupIngs,
and determIned a range of dIscIplIne for each of the three groupIngs GrouPIng
#1 from a non-dIscIplInary letter of counsel up to five days suspenSIOn wIthout
pay Group #2 from five days up to 15 days dIscIplInary suspensIOn wIthout
pay Group #3 from 10 days dIscIplInary suspensIOn wIthout pay up to
dIsmIssal I made a conscIOUS decIsIOn to have an overlap of potentIal
dIscIplInary suspensIOn between GrouPIngs 2 & 3
31 After havIng orgamzed the eVIdence packages Into three maIn groupIngs, and
settIng a range of dIscIplIne for each of the three groupIngs, I further
compared eVIdence packages wIthIn each maIn groupIng, and further
subdIvIded each maIn groupIng Into three sub-groups ThIS resulted In mne
sub-groupIngs
32 HavIng come to a decIsIOn regardIng the appropnate level of dIscIplIne for
these specIfic respondents, I then revIewed all of the remaInIng respondents'
files agaIn, and determIned a recommended level of dIscIplIne for each of the
remaInIng respondents
33 My recommendatIOns on dIscIplIne were based solely on the eVIdence
packages My recommendatIOns dId not take Into account any mItIgatIng or
aggravatIng factors that mIght have applIed In partIcular cIrcumstances
34 I produced a spreadsheet that IdentIfied my categonzatIOn of each
respondent's eVIdence package, and my recommendatIOn on dIscIplIne I
Included a column for any changes that mIght occur In my recommendatIOn,
as well as a column for the manager's final decIsIOn In each case
At the manager's conference In Toronto on May 28 and 29 2001 a process
occurred whIch resulted In some changes to Ms AselstIne's recommendatIOns She
descnbes that process In her wIll-say statement as follows
39 I encouraged managers to reVIew theIr respondents' eVIdence packages and
dIscIplInary recommendatIOns and to compare them to other cases around the
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room. I asked them to IdentIfy what they thought to be relatIve
InCOnsIstencIes In my categonzatIOn of the eVIdence or dIscIplInary
recommendatIOns Where managers IdentIfied potentIal InCOnsIstencIes to me,
we revIewed the eVIdence packages agaIn. In some cases I changed my
categonzatIOn or recommendatIOn where I was convInced that my decIsIOns
were not relatIvely consIstent. In other cases I dId not change my
categonzatIOn or recommendatIOn where I was convInced that my decIsIOns
were relatIvely consIstent.
In determInIng whether the Employer was consIstent In ItS applIcatIOn of dIscIplIne In thIS
stage of the proceedIng, It IS necessary to focus on the recommendatIOns ofMs AselstIne
whIch were made as of the manager's conference In May 2001 pnor to the consIderatIOn
of mItIgatIng and other factors by the managers As of the manager's conference the
recommendatIOn was that each gnevor be dIsmIssed. Although Ms AselstIne
recommended that Mr B PeterkIn also be dIsmIssed, hIS manager gave hIm a 20-day
suspensIOn after consIdenng mItIgatIng factors
Counsel for the Employer submItted that the Inappropnate conduct of the gnevors
contravened the IT PolIcy and the WDHP PolIcy and raises an Important human nghts
Issue Counsel argued that the conduct of the gnevors created a pOIsoned work
envIronment, one that IS hostIle to women, IS racIally taInted and homophobIc
Confronted wIth a pOIsoned work envIronment that was "tOXIC In the extreme" In effect
"a tIckIng tIme bomb" counsel submItted that, when facIng the nsks assocIated wIth such
an envIronment, the Employer was reqUIred to take strong measures to meet ItS
oblIgatIOns to create a workplace conSIstent WIth the obJectIves of the Code To
demonstrate that employers are reqUIred to take posItIve, strong and effectIve measures to
address Code Issues, counsel referred to Magill v Atlantic Turbines Inc (1997),28
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C.H.R.R. D/293 (PEl. Bd. Inq) 25 Burton v Chalifour Bros. Construction Ltd (1994),
21 C.H.R.R. D/501 (B C C.H.R.) 45 Ferguson v Muench Works Ltd (1997),33
C.H.R.R. D/87 (B C C.H.R.) 9 SInce the Umon dId not dIspute the Employer's
oblIgatIOns In thIS regard, It IS unnecessary to reVIew these decIsIOns
In assessIng the nature of the conduct at Issue, counsel submItted that It IS
appropnate for an employer to take Into account the degree of offensIveness of the
matenal Contrary to the Umon's VIew counsel also submItted that, not only stonng and
dIstnbutIng Items, but In thIS context the receIpt and deletIOn of pornographIc Items IS
dIscIplInable conduct. Counsel argued that the sImple receIpt and deletIOn of
Inappropnate matenalIs not a paSSIve actIvIty when IndIVIduals explIcItly or ImplIcItly
IndIcate that they are wIllIng to receIve such matenal
Counsel argued, agaIn contrary to the Umon's posItIOn, that there need not be a
complaInt from an employee before there can be a contraventIOn of the WDHP PolIcy
Counsel also submItted that the presence of the Inappropnate matenal In the workplace,
by Itself, contnbutes to a pOIsoned work envIronment. In what he charactenzed as a
common sense proposItIOn, counsel argued that the presence of pornography pOIsons the
work envIronment and contnbutes to the creatIOn of a culture InCOnsIstent WIth the Code
Over the Umon's obJectIOn, counsel filed what he descnbed as an expert OpInIOn to
support the Employer's contentIOn about the effects of pornography In the workplace If
there had been any doubt about the matter counsel submItted that the Deputy's
27
memorandum made a clear lInk for employees between pornography on mImstry
computers and a pOIsoned work envIronment.
In consIdenng the appropnate penalty for the gnevors, counsel argued that the
Employer dId take Into account the pnncIple of progressIve dISCIplIne Counsel argued
that the conduct of the gnevors was dIfferent In qualIty from the others who were
InvestIgated, partIcularly the employees who were gIven 20-day suspensIOns When
asseSSIng the volume and nature of theIr Inappropnate e-maIl actIvIty as well as the
extremely offensIve nature of the matenal, counsel argued that dIscharge was the
necessary response, even though the gnevors had not prevIOusly been dIscIplIned.
Although the matenal was not cnmInal In nature and It was not argued that the gnevors
engaged In the Inappropnate conduct when they should have been workIng, the Employer
took the posItIOn that the conduct of the gnevors was so egregIOus that dIscharge was not
only appropnate, but a necessary response In the CIrcumstances
In support of the posItIOn that the conduct of the gnevors constItuted a dIsmIssIble
offense, counsel relIed on he folloWIng three decIsIOns In Re Telus Mobility and T W C
(Lee) (2001), 102 L AC (4th) 239 (SIms) the gnevor a two year employee wIth no
dIscIplInary record, was termInated for mISUSIng the Employer's e-maIl to receIve and
transmIt some pornographIc Images The dIscovery of Inappropnate pornographIc
matenal sent by the gnevor to another employee led hIS manager wIthout refernng to the
Inappropnate matenal, to reVIew WIth the gnevor a recently developed Code of EthICS
and to advIse hIm that e-maIl was not to be used for sexually offensIve matenal The
gnevor's demal of havIng receIved thIS dIrectIOn from the manager was not belIeved by
28
the arbItrator Less than a month after the dIscussIOn wIth hIS manager the gnevor sent a
vIdeo clIp graphIcally depIctIng bestIalIty to two people outsIde the company and hIS
Outlook account contaIned two stIll graphIc files shoWIng a woman's breasts clothed In a
brassIer bUIlt to look lIke a man's hands The arbItrator determIned that, although the
employer had a rule whIch addressed the conduct at Issue no rule was needed SInce any
employee would realIze that It IS unacceptable to send senously pornographIc matenal to
other employees or elsewhere He also found that by Ignonng hIS manager's warmng, the
gnevor added an element of InsubordInatIOn to the offense The arbItrator was persuaded
thIS was a senous offense for the folloWIng reasons
" FIrst, there IS the partIcularly offensIve nature of the "mInIstal" attachment
and sImIlarly of the "flamIngass" attachment. Only the first clIp IS dIrectly the
subJect of dIscIplIne, but the eXIstence of the second reInforces my conclusIOn that
the gnevor was eXerCISIng lIttle or no dIscretIOn about the nature of the matenals
he chose to dISSemInate The nature of the matenalIs an Important consIderatIOn.
WhIle some mIght argue "beauty IS In the eye of the beholder" (or at least the
pornographIc eqUIvalent of beauty), thIS IS only part of the Issue That IS because
the employee dISSemInatIng such matenal maIntaInS lIttle control over who the
beholder mIght be
An employer has a legItImate Interest In preventIng ItS employees from exposure
to matenals of thIS type ThIS exposure mIght occur as a result of It beIng sent to
a co-worker who contrary to the sender's expectatIOns, found It offensIve ThIS
mIght occur accIdentally or IndIrectly as It dId here where managers dIscovered It
or had to deal wIth It as part of theIr legItImate actIvItIes ThIS mIght also occur
by accIdent, as It IS not uncommon for e-maIl messages to accIdentally get sent to
the wrong recIpIent or even a lIst of recIpIents
Many VIew expenence of thIS type ofmatenal as a form of workplace harassment
partIcularly because of the degradIng manner It whIch It portrays women. The
Employer IS subJect to a legal duty to prevent such harassment, IncludIng that
whIch anses by umntended but aVOIdable exposure"
29
The fact that no one complaIned about havIng receIved the matenal dId not
Influence the arbItrator as he explaIns as follows
"the gnevor also relIes on the proposItIOn that no one complaIned and no one was
hurt by hIS havIng sent out these matenals ThIS IS basIcally a "we were all con-
sentIng adults" defense I accept as true that none of the dIrect recIpIents com-
plaIned. I also accept that the fact telus net was used In the e-maIl address,
although sIgmficant, IS of less Importance However I do not accept that no one
was affected by thIS dISSemInatIOn. The way the IndIVIduals In management came
across he matenal was qUIte legItImate, and It meant they were exposed to thIS
matenal, somethIng that they clearly wIshed they had not had to deal wIth. In
addItIOn, as noted above, the gnevor had no effectIve controls to prevent It
comIng Into the wrong hands The employee IS perfectly free to CIrculate such
matenal wIth other consentIng adults away from work, but I do not find that lIne
of defense persuaSIve In the workplace on company tIme and eqUIpment and
partIcularly In the face of an express warmng."
GIven hIS VIew of the senousness of the matter the arbItrator dId not conSIder It
a case for the applIcatIOn of progressIve dIscIplIne and he elected In the CIrcumstances not
to Interfere WIth management's decIsIOn to termInate the gnevor
In Re Consumers Gas v Communications Energy and Papen",orkers Union
(PnmIam Gnevance), [1999] O.L AA No 649 (KIrkwood) the gnevor was dIscharged
for reCeIVIng and dIstnbutIng pornographIc matenal USIng her computer at work. In
partIcular she was dIscharged for the storage and transmISSIOn of two A VI's, one marked
"awful" whIch was a vIdeo InvolvIng bestIalIty and the other marked "cokecan" whIch
Involved a half-nude woman USIng a "cokecan" for sexual purposes The gnevor
dIstnbuted "cokecan" to 3 people Internally and 12 people externally under the company
name The employer's InVestIgatIOn, whIch was ImtIated when messages sent by her
manager to the gnevor and others contaInIng the two vIdeos at Issue crashed the
employer's gateway resulted In approxImately 60 employees beIng dIscIplIned. The
30
gnevor was a short-term employee, apparently wIthout a dIscIplInary record. Although
the gnevor was unaware of the employer's polIcy prohIbItIng pornography the arbItrator
concluded that a reasonable employee would realIze that the storage and transmISSIOn of
sexual matenal was unacceptable and that the gnevor's use of the computer was well
beyond acceptable It IS clear from the decIsIOn that the nature of the matenal and the
gnevor's actIvIty IncludIng the dIstnbutIOn of "cokecan" externally contnbuted to the
senousness of the offence Because of the permISSIve culture In eXIstence at the
workplace, whIch Included management partIcIpatIOn, the lack of momtonng and
dIrectIOn of the workforce and the penaltIes gIven to others, the arbItrator substItuted a
one-month suspenSIOn for the dIscharge No relIance was made on the fact that no one
complaIned about the gnevor's conduct and no specIfic reference was made to the
pnncIple of progressIve dIscIplIne
In Re Greater Toronto Airports Authority and P S.A.C (GorskI) (2001) 101
L.AC (4th) 129 (Murray) the gnevor the presIdent of the local umon and an 18-year
employee, was dIscharged for VIeWIng pornographIc matenal USIng the Internet. A
female employee observed hIS actIvIty on at least one occaSIOn and a male secunty guard
observed the behavIOur at other tImes Samples of the matenal vIewed by the gnevor
consIsted of over 500 pages of photographs, "mostly of young adult women In vanous
stages of undress or exotIc dress, some engagIng In sexual actIvItIes of va no us sorts"
The VIeWIng and downloadIng of matenal occurred after normal workIng hours When
management was advIsed that the computer was beIng used Improperly although the
gUIlty party was unknown, management warned the day staff, IncludIng he gnevor
31
agaInst engagIng In such conduct. The employer eventually determIned that the gnevor
was the gUIlty party The arbItrator concluded that the gnevor was creatIng a pOIsoned
work envIronment by engagIng In the Inappropnate conduct over many months He also
determIned that the gnevor' s satIsfactory record and hIS long servIce were not sufficIent
mItIgatIng factors In the CIrcumstances The arbItrator concluded that reInstatement
would send an Inappropnate message to other employees and that bnngIng such
pornographIc matenal Into the workplace IS the type of conduct whIch cannot be
expunged by a lengthy suspenSIOn.
Counsel for the Employer submItted that these authontIes demonstrate that the
conduct engaged In by the gnevors warrants dIscharge In hIS VIew any other conclusIOn
would send the message that a lower standard eXIsts In the OPS and that a culture created
by the dIstnbutIOn of pornography IS "not so bad"
In the alternatIve, the Employer took the pOSItIOn that a conclusIOn that the
dIscharge of any of the gnevors cannot be sustaIned should not lead, In these
cIrcumstances, to the reInstatement of a gnevor In counsel's submIssIOn, thIS was the
type of case whIch necessItated a remedIal response other than reInstatement and he
referred to the folloWIng two deCISIOns In Re York Region Board of Education and
o SSTF (1999) 84 LAC (4th) 90 (ShIme) the gnevor a teacher for many years, was
dIagnosed WIth mamc depressIOn In 1987 and was prescnbed LIthIUm by hIS psychIatnst.
After he stopped takIng LIthIUm In 1994 the gnevor engaged In Inappropnate conduct
WIth students, a colleague and a parent, and he refused to Implement a markIng scheme
32
ThIS conduct ultImately led to hIS dIscharge After takIng Into account certaIn mItIgatIng
factors, IncludIng the gnevor's Illness, the arbItratIOn board concluded that there was not
Just cause for dIsmIssal However the gnevor's refusal to acknowledge any wrongdoIng,
hIS refusal of any help and uncertaInty about whether he would take proper medIcatIOn,
convInced the board of arbItratIOn that the gnevor would lIkely repeat hIS Inappropnate
behavIOur The gnevor was awarded 6 months compensatIOn, rather than reInstatement.
In Re Communty Living South Muskoka and o.p SE. U (Walla) (2000) 92 L AC (4th)
384 (Mikus) the gnevor engaged In a pattern of sexual harassment over a long penod of
tIme WIth the vIctIms remaInIng sIlent. Even though It apparently found that the
employer dId not have Just cause for dIscharge, the arbItratIOn board refused to reInstate
the gnevor because It was unlIkely the gnevor could successfully return to the workplace
In the CIrcumstances
As noted prevIOusly the Umon conceded that the gnevors contravened the IT
PolIcy and that they were deservIng of dIscIplIne but that dIscharge was not an
appropnate penalty In hIS submIssIOns, counsel referred to a number of matters whIch,
In the Umon' s VIew should lead to the conclusIOn that the dIscharge of the gnevors
cannot be upheld on the basIs of the Employer's best case Counsel emphasIzed the
Importance of consIdenng the folloWIng contextual matters In order to assess the conduct
of each gnevor The number of IndIVIduals InvestIgated represents a sIgmficant
proportIOn of the MNR staff and those dIscIplIned Include managers, OPSEU employees,
members of AMAPCEO Human Resources staff and a WDHP advIsor There eXIsted, In
the Umon' s VIew a workplace culture whIch encouraged and condoned the Inappropnate
33
behavIOur at Issue Employees who receIved Inappropnate matenal dId not find It
offensIve and employees who dIstnbuted Inappropnate matenal sent It to persons,
whether wIthIn or outsIde the MNR, who they belIeved were Interested In reCeIVIng the
Items and they dId not find them offensIve The IndIcatIOn from many of the persons
InvestIgated or dIscIplIned was that they dId not apprecIate at the tIme that they were
engagIng In senous mIsconduct. No one complaIned to the Employer about havIng
receIved offensIve pornographIc matenal Counsel argued that SInce the e-maIl abuse
had become so IngraIned as a part of the workplace culture, It was Inappropnate and an
over-reactIOn In the CIrcumstances for the Employer to sIngle out the SIX gnevors for
dIscharge
Counsel argued that the sIgmficant scope of the e-maIl abuse In the MNR
suggests that the message the Employer was attemptIng to convey wIth WDHP traInIng
was not gettIng through to a sIgmficant number of employees He noted that many
IndIVIduals had IndIcated that they would not have engaged In the conduct If they had
known that the Employer took the VIew that such mIsconduct was very senous Counsel
argued that the absence of any IndIcatIOn that the subJects of e-maIl abuse and the
Employer's VIew on the lInk between pornographIc matenal and a pOIsoned work
envIronment were addressed In WDHP traInIng IS a sIgmficant factor In thIS case
Counsel submItted that It would not necessanly be ObVIOUS to employees that the
dIstnbutIOn of pornography bye-mall could create a pOIsoned work envIronment and
consIdered so senous that It could subJect them to dIscharge In counsel's VIew the
34
faIlure of the Employer to so advIse employees IS relevant to asseSSIng the degree of theIr
culpabIlIty
Counsel for the Umon argued that the absence of a vIctIm or of an IndIVIdual
complaInIng about a matter covered by the WDHP PolIcy means that there has not been a
contraventIOn of that polIcy He noted that the provIsIOns of the WDHP PolIcy IndIcate
that It IS a complaInt dnven process and, In thIS Instance, no one complaIned that the
Inappropnate matenal offended or otherwIse affected them. Counsel also took Issue WIth
the Employer's posItIOn that the e-maIl abuse In thIS Instance resulted In a pOIsoned work
envIronment. Counsel submItted that there IS no IndIcatIOn that any of the employees
InvestIgated actually engaged In conduct toward another employee whIch contravened the
Code or that the e-maIl abuse that occurred here would ever lead to an overt
contraventIOn of the Code Counsel stated that the Employer could make the dIstnbutIOn
of pornography bye-mall a specIfic contraventIOn of the WDHP PolIcy but It has clearly
not done so Counsel argued that the Employer's relIance on a contraventIOn of the
WDHP PolIcy and ItS faIlure to establIsh such a contraventIOn should lead In thIS case to
a reductIOn In the gnevors' dIscharges, and In support of thIS posItIOn he relIed on Re
Western Star Trucks Inc and I.A.M Lodge 2710 (Demers) (1997) 69 L AC (4th) 250
(Bruce) In thIS decIsIOn the gnevor was dIscIplIned for vIOlatIng the employer's sexual
harassment polIcy Although he may have deserved some dIscIplIne, the arbItrator
concluded that the gnevor dId not engage In sexual harassment and that the faIlure of the
employer to show a vIOlatIOn of the relevant polIcy meant that the gnevance was allowed.
35
In determInIng whether the dIstnbutIOn of pornography bye-mall creates or
contnbutes to a pOIsoned work envIronment, counsel submItted that I should not admIt
the expert's report filed by the Employer In Re British Columbia (MinistlY of Attorney
General-Sheriffs) and B C G.E.U (1996),57 L.AC (4th) 391 (Greyell) after reVIeWIng
the relevant case law the arbItrator concluded that
" An expert OpInIOn wIll satIsfy the cntena of necessIty If the OpInIOn offered
by the expert would provIde InformatIOn "whIch IS lIkely to be outsIde the
expenence and knowledge of a Judge or JUry" (per DIckson, J In R. v Abbey
[1982] 2 S C.R. 24 (S C C )) or where the subJect matter of the eVIdence IS "such
that ordInary people are unlIkely to form a correct Judgement about It, If
unassIsted by persons WIth specIal knowledge"
In counsel's submIssIOn, the expert OpInIOn offered by the Employer does not satIsfy the
cntena of necessIty set out above
Counsel also argued that the Employer dId not appear to apply the concept of
progressIve dIscIplIne GIven that the gnevors had not been dIscIplIned for thIS type of
conduct, or at all for that matter counsel submItted that for thIS reason alone It was
Inappropnate to dIscharge the gnevors He argued that the type of offense In thIS
Instance IS not so senous that the concept of progressIve dIscIplIne can be Ignored.
Counsel noted that thIS concept IS a feature of both the WDHP PolIcy and the Employer's
general dIscIplInary approach. Counsel argued that the applIcatIOn of progressIve
dIscIplIne should have led to lesser penaltIes for the gnevors Counsel referred to the
folloWIng deCISIOns for theIr commentary on progressIve dISCIplIne Re Dupont Canada
Inc v Communication, Energy and PapelYf,orkers Union of Canada, Local 28-0 (Panter
Gnevance) [2001] O.L AA No 676 Re Westcoast Energy Inc and c.E.P Loc 686B
36
(Bourdon) (1999),84 L AC (4th) 185 The Union of Northern Workers and The Minister
Responsible for the Public Service Act (2002) unreported award of T JollIffe dated Apnl
25 2002, and Re Oshalta Foods Division and UF C W Loc 175 (Rushton) (1993),35
L.AC (4th) 31 (Starkman)
Counsel referred to some factors whIch should be consIdered when asseSSIng the
conduct of the gnevors, such as the subJectIve nature of determInIng the degree of
offensIveness of the Items In theIr accounts, the fact that some IdentIcal Items In dIfferent
accounts were labeled dIfferently because there were three persons Involved In eVIdence
gathenng and, further that Items whIch were sImply receIved and deleted were Included
as part of the Inappropnate matenal Counsel argued that the act of reCeIVIng
Inappropnate matenal and deletIng It IS not a dIscIplInary offense and he submItted that If
one dIscounted those Items whIch the gnevors sImply receIved and deleted, the conduct
of the gnevors would be vIewed as less senous
Counsel referred to a number of decIsIOns to Illustrate the approach arbItrators
have taken when asseSSIng dIscIplIne for thIS kInd of mIsconduct. In Re Dupont Canada
Inc v c.E.P Loca128-0 supra, the gnevor was termInated for Inappropnate computer
use on two days In December 2000 On the first day he downloaded at work at hIS wIfe's
request a newsletter contaInIng sexually explIcIt pIctures and text and transferred the
matenal to hIS Yahoo account. On the second occaSIOn, the gnevor transferred 24
pIctures descnbed as "sunshIne gIrlS" and not pornographIc to hIS Yahoo account through
hIS HotmaIl account. In October 1998 the gnevor had receIved a 10-hour suspensIOn for
37
accessIng Internet sItes at work. The gnevor's conduct dId not Involve dIstnbutIng
Inappropnate matenal to other employees and hIS actIvItIes were detected by a
momtonng system, not as a result of a complaInt. After consIdenng vanous mItIgatIng
factors and the doctnne of progressIve dIscIplIne, the arbItrator substItuted a four-month
suspenSIOn for the dIscharge The Umon also relIed on the comments relatIng to the
permISSIve culture and InCOnsIstent penaltIes made by arbItrator KIrkwood In the
Consumers Gas decIsIOn, supra. In Re Westcoast Energy Inc and CE.P Loc 686B
(1999), 84 L AC (4th) 185 (AlbertIm), the gnevor sent Inappropnate matenal
anonymously to a female employee on four separate occaSIOns whIch led to the findIng
that the gnevor dId sexually harass the female employee After consIdenng all of the
cIrcumstances, IncludIng the gnevor's 24 years of servIce and dIscIplIne free record, the
arbItrator substItuted a 6-month suspensIOn for the dIscharge and Imposed a number of
condItIOns In Re Ontario Polter Generation Inc and Polter Worker Union (Stewart)
an unreported decIsIOn dated June 26 2000 mne employees were Issued dIscIplIne
rangIng from a repnmand to a three day suspenSIOn for reCeIVIng and stonngJuvemle
"Jokes" of a sexual nature Some employees dIstnbuted the matenal to other employees
The gnevors were long servIce employees wIthout dIscIplInary records who expressed
remorse for theIr actIOns The arbItrator determIned that one employee should receIve an
oral repnmand and that those who faced suspenSIOn should receIve a wntten repnmand.
In Re Hydro One Ne~orks Inc and Polter Workers Union (Stewart), an unreported
decIsIOn dated August 27 2001 the gnevor was termInated for USIng the Internet to
access pornographIc sItes whIle at work. Some of these sItes depIcted scenes of rape and
vIOlence towards women. The gnevor dId not cIrculate the matenal to anyone and hIS
38
actIvItIes were dIscovered when the employer conducted a reVIew of Internet usage
among employees TakIng Into account the gnevor's nearly 20 years of servIce, hIS
acknowledgement of wrongdoIng and hIS SIncere apology at the heanng, the lIkelIhood
that he would not repeat such conduct and the fact that another employee was suspended
for five days for conduct somewhat sImIlar to the gnevors, although the matenal accessed
by the gnevor was more egregIOus In nature, the arbItrator substItuted a 15 day
suspenSIOn for the dIscharge
Counsel for the Umon also submItted that I should not accept the Employer's
alternatIve posItIOn WIth respect to reInstatement. He argued that the CIrcumstances In
thIS case are unlIke those In the decIsIOns referred to by the Employer In counsel's
submIssIOn, the CIrcumstances here do not IndIcate that the employment relatIOnshIp
between the gnevors and the Employer has been Irrevocably broken or that the gnevors
could not successfully return to the workforce
In addressIng the Issue of whether the dIscharges can be upheld on the basIs of
the Employer's best case, havIng regard to the conduct of the gnevors, It IS Important to
agaIn note what matters are not before me at thIS stage of the proceedIng. SInce the
partIes agreed that the Issue of mItIgatIOn IS not before me at thIS tIme, factors such as
semonty the recogmtIOn and acknowledgement of wrongdoIng and an assessment of
whether It IS lIkely a gnevor wIll engage In sImIlar conduct In the future If reInstated, are
not now relevant. The one exceptIOn to thIS general approach IS that I can consIder the
dIscIplInary records of the gnevors In order to deal wIth the Issue of progressIve
39
dIscIplIne Although counsel for the Umon made submIssIOns on condonatIOn, the partIes
also agreed that thIS Issue IS for the next stage These matters whIch are not now before
me, of course wIll be relevant In determInIng whether the dIscharges can be sustaIned or
what penalty should be substItuted for the dIscharges If reInstatement IS an optIOn.
The Issues now before me can be framed by the folloWIng questIOns Is the
conduct of the gnevors so senous that dIscharge could be an appropnate response? At
the conclusIOn of the May 2001 conference wIth the managers, the Employer concluded
that some of the Inappropnate matenal In each of the gnevors' Outlook accounts was
very offensIve and that theIr Inappropnate e-maIl actIvIty was senous enough to warrant
dIscharge If I conclude that thIS assessment was Incorrect for any of the gnevors, then
reInstatement becomes an optIOn. A second questIOn for consIderatIOn IS whether the
Employer has been consIstent In ItS applIcatIOn of dIscIplIne In thIS sItuatIOn. IrrespectIve
of how senous the conduct of the gnevors may be, reInstatement may stIll be an optIOn If
the other IndIVIduals who were dIscIplIned engaged In sImIlar conduct to the gnevors, but
were only suspended. In the course of addressIng these Issues, I wIll deal wIth those
matters referred to by counsel In theIr submIssIOns
HavIng made reference In some detaIl to the decIsIOns relIed on by the partIes, I
note that the result, of course In each of the decIsIOns IS determIned by theIr partIcular
facts However they do provIde some general approaches to addressIng the Issues
related to e-maIl abuse I also note that In dealIng the matters before me I have taken Into
40
account the fact that the adJudIcatIOn of the dIscharges and the other gnevances IS not
complete
When determInIng the senousness of an offense of the sort engaged In by the
gnevors, the arbItral Junsprudence clearly IndIcates that It IS appropnate and necessary to
consIder the degree of offensIveness of the matenal Rather than put all Inappropnate
matenal, IrrespectIve of how offensIve It IS, In the same category arbItrators take Into
account the nature of the Inappropnate matenal when determInIng the senousness of the
conduct at Issue Although some of the Umon' s submIssIOns appeared to suggest
otherwIse, thIS approach has consIderable ment. For example, the dIstributIOn of chIld
pornography bye-mall at work and the dIstnbutIOn of pIctures of naked women are both
Inappropnate but It IS ObVIOUS that the dIstnbutIOn of the former matenalIs consIderably
more senous than the latter and generally would warrant a more severe dIscIplInary
response
The Employer determIned that the gnevors engaged In senous mIsconduct
because It concluded that many Items In theIr Outlook accounts were very offensIve It
appears that the Employer made an effort to assess the matenal based on obJectIve
cntena so as to lImIt subJectIvIty Although some of the concerns raised by the Umon
about how the matenal was classIfied and how each gnevors' conduct was categonzed
are valId, they do not alter the essentIal nature of the e-maIl abuse engaged In by the
gnevors What IS not tenable, In my VIew IS the Umon's posItIOn that the mere receIpt
and deletIOn of Inappropnate matenal cannot be the subJect of dIscIplIne In these
41
CIrcumstances I agree wIth the posItIOn of the Employer that when asseSSIng the
Inappropnate e-maIl actIvIty of these gnevors, the act of reCeIVIng and deletIng offensIve
Items was not a paSSIve actIvIty whIch can be Ignored when aSseSSIng culpabIlIty The
gnevors, and others, explIcItly In some Instances and certaInly ImplIcItly InvIted the
receIpt of Inappropnate matenal The sItuatIOn In thIS case IS not one where an employee
receIves pornographIc matenal bye-mall, deletes It and then advIses the sender not to
send such matenal agaIn. Once the InVItatIOn IS made, the recIpIent has no control over
what matenalIs sent and how offensIve It IS
After reVIeWIng the matenal In the gnevors Outlook accounts at the heanng and
agaIn after the heanng, It IS my conclusIOn that the Employer correctly assessed some of
the Inappropnate matenal as very offensIve The demgratIOn and vIOlence towards
women as contaIned In the DIrty Sanchez vIdeo IS partIcularly offensIve Although the
Inappropnate matenal In the gnevors' accounts Includes some relatIvely Innocuous Items,
they also Include Items of bestIalIty oral sex, pIctures of nude obese and elderly women
and pIctures of sexual actIvIty that are degradIng and vIOlent to women. When
companng the Inappropnate matenal the gnevors receIved or dIstnbuted, where It IS
possIble to do so to the Items whIch led to dIscharges or lengthy suspenSIOns In the
decIsIOns referred to by the partIes, many of the Items In the gnevors' accounts are
generally more offensIve and the volume of actIvIty generally IS greater The gnevors
dIstnbuted matenal not only to persons wIthIn the MNR, but also to persons outsIde the
MNR and the OPS thereby creatIng the potentIal for consIderable embarrassment for
themselves and the Employer One of the Items In the Chrysler ComplaInt ongInated
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WI th Mr HastI e The receIpt and dIstnbutIOn of thIS type ofmatenal does have human
nghts ImplIcatIOns and they contnbute to a culture InCOnsIstent WIth the obJectIves of the
Code The offensIveness of the Inappropnate matenal In the gnevors' Outlook accounts
and the senousness of theIr mIsconduct IS not altered by the fact that they dId not find the
matenal offensIve or the fact that no one complaIned about the matenal The
Inappropnate conduct of the gnevors In the decIsIOns I was referred to was not detected
because someone complaIned, but for other reasons The faIlure of anyone to complaIn
dId not Influence the arbItrator's VIew of the senousness of the conduct.
The Umon argued that the absence ofWDHP traInIng on the appropnate use of
computers and e-maIl and on the lInk between the receIpt and dIstnbutIOn of pornography
bye-mall and a pOIsoned work envIronment are factors whIch should have the effect of
negatIng the penalty of dIscharge Generally an employer should advIse employees
about what behavIOur wIll result In dIscIplIne and how severe the dIscIplIne mIght be
Employers commonly satIsfy thIS oblIgatIOn by ISSUIng rules and a range of penaltIes for
a vIOlatIOn of a rule But there IS some conduct whIch any employee should recogmze as
unacceptable even wIthout a rule or some other notIce from the Employer In the Telus
Mobility and Consumers Gas decIsIOns, albeIt In dIfferent contexts, the arbItrators
decIded that reasonable employees would understand that reCeIVIng and sendIng
pornographIc and other Inappropnate matenal to employees or to others would be
unacceptable to the Employer It IS a reasonable extensIOn of thIS approach to suggest
that a reasonable employee, wIthout the benefit of notIce or traInIng, would also
understand that the more offensIve the matenal, the more senous the offence and
43
consequences In thIS Instance, the Employer has clearly IndIcated to employees through
the IT PolIcy and the warmngs on the computer system that the use of e-maIl for non-
busIness purposes IS unacceptable and could lead to dIscIplIne HavIng been warned not
to engage In such conduct and that dIscIplIne may result If they dId, It IS not open to
employees to complaIn that they were unaware about what kInd of offensIve matenal
dIstnbuted bye-mall could result In dIscharge or that such conduct created a pOIsoned
work envIronment. I note that under the references to unacceptable actIvIty In the IT
PolIcy a connectIOn IS made wIth the storage and dIsplay of offensIve matenal, a
pOIsoned work envIronment and the WDHP PolIcy Although not related to WDHP
traInIng per se, the Deputy's memorandum advIses employees that the presence of
pornography or other offensIve matenal wIll not be tolerated at the workplace and wIll
result In dIscIplInary actIOn, up to and IncludIng dIscharge In my VIew It would be
dIfficult to conclude that the MNR employees were preJudIced by a lack ofWDHP
traInIng relatIng to computer usage In the face of the message contaIned In the Deputy's
memorandum
I also find It dIfficult to accept that the dIstnbutIOn of pornographIc matenal by e-
mall, by Itself, cannot create or contnbute to a pOIsoned work envIronment and that there
cannot be a contraventIOn of the WDHP PolIcy wIthout a complaInt or wIthout specIfic
conduct by an employee agaInst another employee In relatIOn to the Code's prohIbIted
grounds I agree wIth the Umon that the expert OpInIOn proffered by the Employer to
establIsh that pornography In the workplace contnbutes to a pOIsoned work envIronment
does not meet the test of necessIty However I agree wIth the Employer's posItIOn that
44
the detnmentalImpact of pornography In the workplace IS a common sense proposItIOn
denved from general expenence In my VIew the dIstnbutIOn of matenal In the
workplace bye-mall or some other means whIch obJectIfies and demgrates women, and
whIch depIcts acts of vIOlence agaInst women does pOIson the workplace, whether
someone complaIns about the actIvIty or not, and such conduct fits wIthIn the defimtIOn
of pOIsoned work envIronment contaIned In the WDHP PolIcy Whether someone
complaIns about the Inappropnate actIvIty does not change the nature of the mIsconduct.
The Umon conceded that the Employer could make It clear In the WDHP PolIcy that the
dIstnbutIOn of pornography bye-mall would contnbute to a pOIsoned work envIronment.
Although the matter IS not specIfically addressed In the WDHP PolIcy the Employer
accomplIshed the same result when It dIstnbuted the Deputy's memorandum whIch
makes the lInk between the dIstnbutIOn of pornography a pOIsoned work envIronment
and the WDHP PolIcy It IS my conclusIOn that the conduct of the gnevors at Issue does
contravene the WDHP PolIcy
I agree that the pnncIple of progressIve dIscIplIne need not necessanly be
abandoned when dealIng wIth senous offences of the kInd commItted by the gnevors
GIven that the manager's chart for each gnevor refers to the employee's dIscIplInary
record, It would appear that some consIderatIOn was gIven to progressIve dIscIplIne
ProgressIve dIscIplIne would have been one factor among many others, the managers
consIdered when decIdIng the Issue of penalty In my VIew It IS dIfficult to apply the
concept of progressIve dIscIplIne In IsolatIOn when the conduct at Issue constItutes a
senous matter In these sItuatIOns the practIce of arbItrators IS to consIder all of the
45
factors, IncludIng progressIve dISCIplIne, In order to determIne whether dIscharge IS
appropnate or whether there IS a basIs for subStItutIng a lesser penalty Therefore, rather
than addressIng the Issue of progressIve dISCIplIne now It IS appropnate to consIder the
Issue along wIth the Issues of mItIgatIOn and condonatIOn, and any other factors relevant
to the Issue of reInstatement.
The Umon asserted that It was unfair and Inappropnate to dIscharge 6 employees,
havIng regard to the scope of the problem concernIng e-maIl abuse and the creatIOn of a
culture whIch encouraged and condoned thIS behavIOur As prevIOusly noted, the
condonatIOn element IS not now before me The fact that a sIgmficant number of
employees engaged In e-maIl abuse, by Itself, does not necessanly assIst the gnevors
Unless It can be shown that the Employer was In some way responsIble for the culture or
was aware of the problem but turned a blInd eye to It, the gnevors and the employees
who were dIscIplIned wIll not be able to aVOId complete responsIbIlIty for theIr conduct.
Even though the mIsconduct of the gnevors IS senous, the Employer must be
consIstent In ItS dIscIplInary approach. If the conduct of other employees was sImIlar to
the conduct of the gnevors and they were suspended, the Employer would be precluded
from treatIng the gnevors dIfferently The Employer appears to have made consIderable
effort to ensure consIstency In the applIcatIOn of dIscIplIne In thIS Instance In assessIng
the nature of the actIvIty of the gnevors and the offensIve nature of the matenal In theIr
Outlook accounts as compared to employees and managers who receIved lengthy
46
suspensIOns, I am satIsfied that the gnevors' conduct IS more senous than the conduct of
the IndIVIduals who were suspended.
In summary It IS my conclusIOn, on the basIs of the Employer's best case, that the
dIscharge of the gnevors mIght be an appropnate response In CIrcumstances where the
gnevors engaged In senous mIsconduct due to the receIpt or dIstributIOn of very
offensIve matenal bye-mall, where employees had been warned that dIscharge could
result from such conduct and where the Employer applIed dIscIplIne consIstently It IS
dIfficult to conclude at thIS pOInt that the dIscharges could not be upheld. SInce I have
decIded that It would not be appropnate to reInstate a gnevor at thIS tIme, It IS
unnecessary to deal wIth the Employer's alternatIve posItIOn on reInstatement. Perhaps
CIrcumstances relevant to thIS Issue may anse dunng the next phase of thIS proceedIng.
The heanng of the gnevances shall contInue on the days prevIOusly scheduled.
Dated at Toronto thIS 23rd day of January 2003