HomeMy WebLinkAbout2002-2235.Union Grievance.04-02-23 Decision
Crown Employees Commission de ~~
Grievance Settlement reglement des griefs
Board des employes de la
Couronne
~-,...
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# 2002-2235
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
The ASSOcIatIOn of Management AdmInIstratIve and
ProfessIOnal Crown Employees of Ontano
(Umon Gnevance) Grievor
- and -
The Crown In RIght of Ontano
(Management Board Secretanat) Employer
BEFORE FelIcIty D Bnggs Vice-Chair
FOR THE UNION Mansa Pollock
Sack Goldblatt Mitchell
BarrIsters and SOlICItorS
FOR THE EMPLOYER DavId Strang
ActIng Associate DIrector
Management Board Secretanat
HEARING January 9 June 26 July 15 September 23
November 20 2003
2
DeCISIon
On June 27 2002, the ASSOcIatIOn filed a dIspute encompassIng three specIfic allegatIOns The
first was that vanous salary Increases and retroactIve momes OWIng as the result of the last
Memorandum of Settlement dated February 19 2002, were not paid In a tImely fashIOn. By way
of remedy Interest on those momes was requested In addItIOn to an order for prompt payment.
The second allegatIOn was that the Employer had not yet Implemented the Ment Pay Increases
AgaIn, prompt payment and Interest on momes OWIng was requested. FInally the AssocIatIOn
alleged that the Employer faIled to Implement the Pay for Performance bonuses
On, January 9 2003 the first day of heanng, the partIes agreed to attempt to resolve the dIspute
through medIatIOn. Unfortunately at the conclusIOn of that day the matters were not yet
resolved. AccordIngly further heanng dates were scheduled. However In the meantIme, the
partIes contInued In theIr efforts to resolve the outstandIng matters To that end a number of
scheduled heanng days were adjourned but the Board was asked to reconvene on June 26 2003
At that tIme It became eVIdent that the dIspute between the partIes was sIgmficantly narrower but
stIll somewhat complIcated. Indeed, the partIes had arrIved at a Memorandum of Settlement
resolvIng all but one of the outstandIng matters However In addItIOn to that remaInIng
outstandIng Issue there was a further allegatIOn from the AssocIatIOn that the Employer had
breached the recently negotIated Memorandum of Settlement.
In the Memorandum of Settlement sIgned May 28 2003 the partIes specIfically addressed the
unresolved Issue It was stated at paragraph 2, In part
The partIes agree that employees wIll be elIgIble to receIve pay for performance
payments under ArtIcle 45 2 for such proportIOn of the days In the prevIOUS year that they
receIved salary at the maXImum of theIr salary range
For clanty thIS IS deemed to Include elIgibIlIty for any part of the year In whIch an
employee was on approved leave of absence of not greater than three (3) months
IncludIng STSP and WSIB
The partIes dIsagree over how to treat employees In receIpt of EI top up for pregnancy or
parental leave It IS the ASSOCiatIOn's posItIOn that employees should be elIgIble to
receIve pay for performance payments under ArtIcle 452 for any penod of the year In
whIch an employee IS In receIpt of EI top-up for pregnancy or parental leave It IS the
Employer's posItIOn, that thIS should be cut off once an employee IS In receIpt of EI top-
up for pregnancy or parental leave for a penod of three (3) months Should the partIes faIl
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to resolve thIS Issue, the partIes agree that FelIcIty Bnggs, who IS seIzed wIth the above
named dIspute scheduled to be heard on June 26 2003 wIll determIne the matter The
partIes agree that thIS Issue wIll be argued on one of the four dates currently scheduled.
As can be seen from the above, the first dIspute concerned the applIcatIOn of Pay for
Performance for employees who were absent due to pregnancy and parental leave To further
complIcate the matter at the heanng It became apparent that the partIes dIsagreed upon the
process to be undertaken In order to resolve that dIspute It was the AssocIatIOn's VIew that the
partIes had agreed to gIve me the jUnSdIctIOn of an Interest arbItrator to determIne thIS dIspute
whIle the Employer asserted that I contInued to exerCIse only the authonty of a nghts arbItrator
In thIS regard It was the AssocIatIOn's posItIOn that the wordIng of the Memorandum of
Settlement was ambIguous and extnnsIC eVIdence of vanous dIscussIOns and draft proposals
dunng the negotIatIOns process would need consIderatIOn In order to decIde the matter of my
jUnSdIctIOn. The Employer took the OpposIte VIew It suggested that It was ImpoSSIble for thIS
statutory tnbunal establIshed to hear and determIne gnevance arbItratIOns can find Itself wIth the
jUnSdIctIOn of an Interest board of arbItratIOn.
The second area of dIspute was regardIng the InterpretatIOn of the "clanty note" In the mIddle
paragraph set out above The Employer took the posItIOn that the wordIng of the Memorandum
of Settlement IS clear and unambIguous and proVIdes that when an employee IS on a leave of
three months or less, the Pay for Performance IS unreduced. However If the leave of absence
contInues beyond three months, the Pay for Performance bonus IS prorated. The AssocIatIOn's
VIew was that the language of the Memorandum IS ambIguous EVIdence regardIng the
negotIatIOns was necessary to assIst In InterpretIng the language and would lead thIS Board to
find that for employees on a leave other than pregnancy or parental, only the penod of the leave
In excess of three months would be dIscounted In determInIng the Pay for Performance bonus
ThIS second dIspute comes before me as the result of paragraph 9 of the May 28 2003
Memorandum of Settlement whereIn It was stated
The partIes agree that these mInutes of settlement are enforceable as If they formed part
of the collectIve agreement, and FelIcIty Bnggs wIll remaIned seIzed to deal wIth any
Issues ansIng from the InterpretatIOn, applIcatIOn, ImplementatIOn, admInIstratIOn or
alleged vIOlatIOn of these mInutes of settlement. ThIS Includes any dIspute over the SIze
of the pay for performance envelope for each of the years under the collectIve agreement,
and determInIng the quantum of the remedy for any non-complIance wIth paragraphs 6
4
and 7 If FelIcIty Bnggs IS unavaIlable, the partIes wIll select an alternatIve arbItrator In
accordance wIth theIr normal practIce
It would be helpful at thIS pOInt to set out the relevant provIsIOns of the collectIve agreement. In
the most recent round of negotIatIOns the partIes agreed to Include ArtIcles 45 2 and 45 3 as
follows
For employees In AMAPCEO classIficatIOns who are at the maXImum of theIr salary
range
4521 EffectIve Apnl 1 2002, for employees who are at the salary maXImum on
March 31 pay for performance bonuses wIll be processed on Apnl 1 st each year based on
performance for the prevIOUS year
45 2.2 The pay for performance bonus shall be a re-earnable lump sum payment
and wIll not Increase the employee's base salary beyond the maXImum of the salary range
for any purpose
4523 The number of employees who receIve pay for performance bonuses
above a satIsfactory performance ratIng shall not exceed twenty percent (20%) of elIgIble
employees
45 24 The amounts of bonuses avaIlable under artIcle 45.2 shall be fixed at three and a
half percent (3 5%) for satIsfactory performance and SIX percent (6%) for above
satIsfactory performance
4525 There shall be no pay for performance bonus for employees whose
performance IS rated below satIsfactory The number of employees In thIS category shall
not exceed fifteen percent (15%) of elIgIble employees
4526 An employee must have earned the maXImum salary for hIS or her
classIficatIOn for at least twelve (12) months In order to be elIgIble for a full pay for
performance bonus For clanty an employee who IS at the maXImum salary for hIS or her
classIficatIOn on March 31 wIll remaIn elIgible for a pay for performance bonus In spIte
of the applIcatIOn of the Increases to the maXImum of the salary range under ArtIcles
441(b) 44.2(b) and 443(b) The performance bonus for an employee who has been
earnIng the maXImum salary for less than twelve (12) months wIll be pro-rated.
453 AdmInIstratIOn of Pay for Performance
45 3 1 EffectIve Apnl 1 2002 and on Apnl 1 st each folloWIng year a fixed envelope for
pay for performance wIll be establIshed. The envelope wIll vary from year to year and
wIll be calculated by
45 takIng twenty percent (20%) of the salanes of the percentage of employees In
AMAPCEO classIficatIOns (classIfied and unclassIfied), calculated as of Apnl 1 st of
that year who were earmng salanes at the maXImum of theIr salary ranges on
March 31st of that year and multIplYIng by SIX percent (6%) [example If 32% of
employees are earmng maXImum salanes, take 20% of theIr salanes and multIply by
6%]
46 takIng sIxty-five percent (65%) of the salanes of the percentage of employees
In AMAPCEO classIficatIOns (classIfied and unclassIfied), calculated as of Apnl 1 st
of that year who were earnIng salanes at the maXImum of theIr salary ranges on
March 31 st of that year and multIplYIng by three and a half percent (3 5%)
5
[example If 32% of employees are earmng maXImum salanes, take 65% of theIr
salanes and multIply by 3 5%]
(c) addIng together paragraphs l(a) and l(b) above
45 3.2 The admInIstratIOn of the pay for performance bonus plan under 45.2 IS totally
wIthIn the dIscretIOn of the Employer IndIvIdual employees' dIsputes over theIr
ratIngs and pay for performance bonuses wIll not be arbItrable An arbItrator's
jUnSdIctIOn IS lImIted to decIdIng whether or not the pay for performance
envelope as descnbed In artIcle 45 3 1 has been spent.
At the heanng I ruled that I would hear the extnnsIC eVIdence and reserve my rulIng regardIng
whether to admIt and consIder the extnnsIC eVIdence regardIng the negotIatIOns leadIng to the
Memorandum of Agreement. I made clear that I would make a determInatIOn after the
conclusIOn of the eVIdence and submIssIOns as to whether there IS a latent or patent ambIgUIty In
the language that would necessItate admIssIOn and consIderatIOn of the extnnsIC eVIdence to
assIst In InterpretIng the provIsIOns of the Memorandum of Settlement.
ImtIally turmng turn to the second dIspute regardIng the InterpretatIOn of the clanty note found at
paragraph 2 of the May 28 2003 Memorandum of Settlement. As set out earlIer It was the
Employer's VIew that the clear language of the Memorandum states that when an employee IS on
a leave of not greater than three months the Pay for Performance IS unreduced. However when a
leave extends even one day beyond three months the Pay for Performance IS prorated for the full
penod of the leave The AssocIatIOn, on the other hand, asserted that the language IS ambIguous
and extnnsIC eVIdence should be admItted and consIdered. Once the negotIatIng hIStory In thIS
regard was taken Into account, thIS Board would find that only the penod of any leave In excess
of three months would be dIscounted In the determInatIOn of Pay for Performance
In thIS regard I heard eVIdence from Mr Stephen Barrett, counsel for the AssocIatIOn and Ms
Deborah Anne Long, Corporate Staff RelatIOns Officer both of whom were Involved In the
negotIatIOn of the Memorandum of Settlement.
Ms Pollak, for the AssocIatIOn contended that the clanty note must be consIdered In context.
The partIes agreed In the first paragraph to take a proportIOnal approach to the tIme for whIch the
Pay for Performance IS to be applIed. The paragraph at Issue deems certaIn employees elIgIble
for the proratIng exerCIse However the ambIgUIty IS caused because It IS not clear whether It IS
tIme or compensatIOn that IS to be prorated That ambIgUIty leads thIS Board to admIt and
6
consIder the extnnsIC eVIdence of Mr Barrett and Ms Long regardIng the hIStOry of the
negotIatIOns leadIng to the sIgmng of the May 28 2003 Memorandum of Agreement.
It was the Employer's VIew that the partIes agreed In the Memorandum of Settlement that
employees on short leaves of absence ought not to be dIsadvantaged for the purposes of the Pay
for Performance bonus A balance was struck dunng negotIatIOns and the clanty note IS the
resultIng compromIse In the overall scheme the partIes agreed to Ignore short term absences but
eventually leaves of absence become long enough to affect the abIlIty to achIeve performance
goals ObvIOusly the partIes agreed that In the admInIstratIOn of the program It would be unfair
to rate one employee who had supenor performance for SIX months the same as an employee
who had a supenor performance for twelve months
Clearly It was asserted by the Employer the partIes decIded that some cut off penod was
appropnate and three months was the agreed tIme The language IS clear and there can be no
purposIve reason for stretchIng the ordInary and clear words found In the Memorandum of
Settlement. The Employer submItted that the AssocIatIOn IS askIng thIS Board to read Into the
agreement that the first three months of any leave, IrrespectIve of ItS length, IS protected. SImply
there IS nothIng In the Memorandum of Settlement that can be Interpreted as suggested by the
AssocIatIOn. Mr Strang said that whIle, as the AssocIatIOn suggested, the cut off of three months
mIght seem an arbItrary number there would be a cut off date In any event wIth people fallIng on
eIther sIde of that date lIne That alleged unfairness IS merely a necessary delIneatIOn between
acceptable penods of absence and those absences whIch are too long to allow for proper
assessment of the Pay for Performance bonus
In thIS regard the Employer relIed upon Re University of Manitoba and Canadian
Educational Workers, Local 9 (1990) 11 L.AC (4th) 353 (Freedman) and Re Strait Crossing
Joint Venture and International Union of Operating Engineers/Iron Workers (1997), 64
L.AC (4th) 229 (ChnstIe)
As was asserted by both partIes, the Issue of ambIgUIty and the resultIng use of extnnsIC
eVIdence has been consIdered by many boards of arbItratIOn. It IS tnte but true that each case IS
fact dependent. However a reVIew of the junsprudence IS helpful ArbItrator Freedman
conducted such a reVIew In Re University of Manitoba (supra) In that case the Umon was
7
seekIng a declaratIOn regardIng the InterpretatIOn of an artIcle In the collectIve agreement
concernIng lImItatIOns on the hours of work. The artIcle at Issue was lengthy and It was the
Umon's assertIOn that there was a latent or patent ambIgUIty so as to reqUIre the admIssIOn of
extnnsIC eVIdence to assIst WIth ItS InterpretatIOn. In consIdenng the matter ArbItrator Freedman
stated, at page 357
The arbItral authontIes make clear that It IS appropnate to dIStIngUIsh between
"ambIgUIty" In the legal sense and the possIbIlIty of dIfferent constructIOns of a
document (see Re Int'l Nickel Co of Canada Ltd. and US W (1974) 5 L.AC (2d) 331
(Weathenll) I have no dIfficulty In understandIng the language used In cl 14 9 3 and
there are no references thereIn whIch render comprehensIOn dIfficult. I agree wIth the
VIew of the board In the Int'l Nickel case (pp 333-4) where It was Said
It may be that the provIsIOns of the collectIve agreement here In Issue pose a
problem of constructIOn, so that they may be said to be "of doubtful meamng" In
that very general sense In our VIew however the InterpretatIOn of the notIOn of
"latent ambIgUIty" to Include generally all cases of doubtful meamng or
applIcatIOn" should not be, and was not Intended to be taken so far as to open
the door to admIssIOn of extnnsIC eVIdence wherever a dIsagreement as to the
constructIOn of a document anses If that were allowed, the strength of a
document such as a collectIve agreement would be greatly reduced, and the well-
establIshed rules respectIng the admIssIOn of extnnsIC eVIdence would be
meamngless
In my judgment the questIOn before me IS one of constructIOn or contract InterpretatIOn In
the normal sense, and IS neIther more nor less than that. I do not find the provIsIOns In cl
14 9 3 ambIguous In the sense of eIther latent ambIgUIty or patent ambIgUIty as those
terms are used In the authontIes and It IS not necessary for me to resort to extnnsIc
eVIdence to Interpret the Agreement.
The prescnbed task for me IS to construe and Interpret the Agreement accordIng to the
IntentIOn of the partIes, whIch IntentIOn IS denved from the words they have used, unless
there IS an ambIgUIty of the nature and to the extent that would warrant the admIssIbIlIty
of extnnsIC eVIdence to aid In the InterpretatIOn of the Agreement. As IndIcated, I have
found no such ambIgUIty
ArbItrator Freedman also dIscussed the "cardInal presumptIOn" that the partIes are assumed to
have Intended what they have said. He also consIdered an occaSIOnally held arbItral VIew that
collectIve agreements are, for a vanety of reasons, ImpreCIse documents that mIght well reqUIre
extnnsIc eVIdence to properly Interpret. In thIS regard ArbItrator Freedman said at page 360
With respect, I take a dIfferent VIew of the degree of Integnty that should be accorded to
collectIve agreements To hold that collectIve agreement language wIll be InevItably
ImprecIse would be to permIt arbItrators at any tIme and In any case to read Into language
actually used by the partIes, language that was not used. It would permIt arbItrators at any
tIme and In any case effectIvely to rewnte or amend collectIve agreements (a practIce that
8
vIrtually every collectIve agreement proscnbes) In my expenence, collectIve agreement
language IS not generally ImprecIse
That IS not to say that In an appropnate case, where patent or latent ambIgUIty eXIsts
In the language used, extnnsIC eVIdence ought not to be admItted, because In such a case
It IS proper to admIt and consIder such eVIdence The arbItrator's task IS to determIne the
real substance of the matter In dIspute and the arbItrator ought to fulfill that role, where
he can, by readIng and construIng the language whIch the partIes themselves have
negotIated In the case before me I am able properly to construe the Agreement wIthout
reference to extraneous eVIdence
I agree wIth that VIew and have found It useful In my consIderatIOn of ambIgUIty The dIspute
between these partIes IS whether employees who are absent on approved leaves of absence for
longer than three months have the first three months of theIr leave taken Into account for the
purposes of Pay for Performance It IS somewhat Iromc that the very sentence that gIves nse to
thIS dIspute begIns wIth the phrase "for clanty" In any event, the provIsIOn states that elIgIbIlIty
Includes "any part of the year In whIch an employee was on approved leave of absence of not
greater than three (3) months IncludIng STSP and WSIB" After consIdenng the submIssIOns of
the partIes, the junsprudence and the very language of the Memorandum of Settlement I am led
to the InevItable conclusIOn that there IS neIther a latent nor patent ambIgUIty As stated by
ArbItrator Freedman In Re University of Mamtoba, "I have no dIfficulty In understandIng the
language used" and "there are no references thereIn whIch render comprehensIOn dIfficult" The
language IS clear on ItS face and supports the Employer's VIew of thIS matter Indeed, to have the
meamng proffered by the AssocIatIOn, the partIes would have had to expressly state that when
leaves of absence are greater than three months, only that tIme In excess of the first three months
IS not Included for the purposes of entItlement to pay for performance compensatIOn.
I also agree wIth ArbItrator Freedman that an arbItrator's role IS to "determIne the real substance
of the matter" That role IS, when possIble, to be carrIed out by consIdenng and InterpretIng the
language agreed upon by the partIes In my VIew In thIS Instance I am able to fulfill that role
wIthout consIdenng extnnsIc eVIdence The language has neIther a latent nor a patent ambIgUIty
Moreover I am of the VIew that the language of the partIes does "clanfy" the first paragraph of
sectIOn 2 of the Memorandum of Settlement. The first paragraph refers to when "employees wIll
be elIgIble" The next paragraph does clanfy that employees who are on leaves of absence of
"not greater than three months IncludIng STSP and WSIB" are "deemed" to be elIgIble
9
I wIll return now to the first dIspute As set out above, the partIes dIsagree as to how the Pay for
Performance bonus IS affected when employees are on pregnancy and parental leave It IS
appropnate to first consIder the Issue of my jUnSdIctIOn In thIS regard.
The AssocIatIOn took the posItIOn that the partIes have agreed to bestow upon me the jUnSdIctIOn
of an Interest arbItrator whIle the Employer asserted that no such agreement ever eXIsted and, In
the absence of such accord, I contInue to hold only the authonty of a nghts arbItrator
Ms Pollak suggested that the partIes have been creatIve and somewhat non tradItIOnal In the area
of dIspute resolutIOn as can be seen by a reVIew of the collectIve agreement. For example, ArtIcle
18 6 contemplates unfair competItIOn complaInts, ArtIcle 15 9 2 provIdes for classIficatIOn
dIsputes and ArtIcle 32 consIders the handlIng and resolutIOn of dIsputes InvolvIng demal of
benefits ObvIOusly she suggested, these partIes are flexIble and creatIve WIth respect to dIspute
resolutIOn mechamsms Therefore It IS not surpnSIng that the partIes would Include In one
Memorandum of Agreement two separate methods of dIspute resolutIOn, that IS, Interest
arbItratIOn for the determInatIOn of the matter of parental and pregnancy leave and gnevance
arbItratIOn for the Issue of InterpretIng the clanty note regardIng what three months means for
employees on leaves other than parental and pregnancy leave
Treatment of employees on parental and pregnancy leave IS consIdered under paragraph 2 of the
Memorandum of Settlement whIle the determInatIOn of the Issue of other leaves comes to thIS
Board as a result of paragraph 9 The AssocIatIOn stressed that the fact that the two provIsIOns
were IndIVIdually consIdered In separate paragraphs IS tellIng and must lead me to find that the
partIes would not have used dIffenng words In separate paragraphs If they Intended to utIlIze the
same dIspute resolutIOn mechamsm
Further the AssocIatIOn asserted that the partIes recogmzed there were two very dIstInctIve tasks
beIng asked of the Board. RegardIng the matter of the leaves of not greater than three months, I
can only Interpret the agreement of the partIes However for the Issue of the parental leave, the
partIes agreed that I would determIne that matter That phrase, "determIne the matter" IS classIc
Interest arbItratIOn phraseology There were no constraInts added such as "In accordance wIth the
collectIve agreement" However In the event that there IS any ambIgUIty regardIng thIS phrase,
10
the AssocIatIOn's eVIdence, IncludIng that of the dIscussIOn about "final offer selectIOn"
supports ItS VIew The partIes wanted somethIng other than a constructIOn of the language found
In the CollectIve Agreement. Rather they wanted thIS Board to render a decIsIOn based upon the
relatIve ments of the Issue
The Employer's contentIOn was, sImply put, that there IS nothIng on the face of the
Memorandum of Settlement that grants thIS Board the jUnSdIctIOn to act as an Interest Board of
ArbItratIOn. The partIes entered Into a Memorandum of Agreement leadIng to the Instant
collectIve agreement. After the partIes ratIfied the Memorandum of Agreement, gnevances were
filed concermng, amongst other thIngs, the payment of pay for performance bonuses As set out
above those matters were resolved but for one Issue The outstandIng matter IS now before thIS
Board for determInatIOn In accordance wIth the normal path of nghts arbItratIOn and there has
been no agreement to alter that course
Mr Strang took Issue WIth the AssocIatIOn's contentIOn that the phrase "determIne the matter" IS
code for or more appropnate to Interest arbItratIOn. Indeed, SectIOn 49(4) of the Labour
Relations Act provIdes that a nghts Board of ArbItratIOn shall "hear and determIne the matters"
In dIspute between the partIes
After consIdenng the submIssIOns of the partIes, I must find there IS no ambIgUIty In the
Memorandum of Settlement regardIng my jUnSdIctIOn. I agree wIth the Employer that I have
jUnSdIctIOn of a nghts arbItrator to hear and determIne the dIspute between the partIes
At paragraph 2 of the Memorandum of Settlement It was stated that, "should the partIes faIl to
resolve thIS Issue the partIes agree that FelIcIty Bnggs, who IS seIzed wIth the above named
dIspute scheduled to be heard on June 26 wIll determIne the matter" I find nothIng unusual
about the use of the phrase "determIne the matter" In the context of gnevance arbItratIOn."
Indeed, at ArtIcle 15 11 3 of the collectIve agreement between these partIes provIdes that "all
complaInts anSIng under ArtIcle 15 that are referred to arbItratIOn shall be determined by the
Chair or a Vice-Chair of the GSB SIttIng alone" (emphasIs mIne) There IS nothIng to have me
find that "determIne the matter" IS a phrase peculIar to Interest arbItratIOn.
11
Further there IS no language In the Memorandum of Settlement that persuades me that I have
somethIng other than the jUnSdIctIOn I was gIven by the partIes at the begInmng of thIS dIspute,
that IS, the jUnSdIctIOn of a nghts arbItrator floWIng from a complaInt filed under the collectIve
agreement. In my VIew for me to decIde that I have the jUnSdIctIOn of an Interest arbItrator clear
and uneqUIvocal language would be necessary Such a provIsIOn IS not present In the Instant
matter To the contrary I am of the VIew that the Memorandum of Settlement clearly provIdes
that I have the jUnSdIctIOn of a nghts Board of ArbItratIOn. Indeed, the very language of the
Memorandum of Settlement IS stnkIngly sImIlar to that provIded In the arbItratIOn provIsIOn set
out at ArtIcle 15 of the collectIve agreement.
It IS true as asserted by the AssocIatIOn, that these partIes have been relatIvely creatIve In the
vanous dIspute resolutIOn mechamsms consIdered In theIr collectIve agreement. However I
cannot find that because these partIes are prepared to agree In theIr collectIve agreement to
vanous methods of resolvIng dIsputes It IS more lIkely In thIS Memorandum of Settlement that, In
the absence of clear language so provIdIng, the partIes gave me the jUnSdIctIOn of an Interest
arbItrator
The AssocIatIOn referred to the fact that the Issue regardIng the affect of parental leaves IS set out
at paragraph 2 whIle paragraph 9 consIders my jUnSdIctIOn to resolve the dIspute regardIng the
clanty note It was suggested that havIng those two provIsIOns In separate paragraphs must lead
me to find eIther that the partIes Intended dIffenng jUnSdIctIOns or In the alternatIve, that an
ambIgUIty resulted. Of course, such an ambIgUIty would cause me to admIt and consIder extnnsIc
eVIdence In thIS regard,
There IS no ambIgUIty created by dIfferent dIsputes beIng consIdered In separate paragraphs
Paragraph 2 consIdered the dIspute that the partIes knew was at Issue at the tIme they sIgned the
Memorandum of Settlement. At the same tIme, at paragraph 9 they provIded for my jUnSdIctIOn
In the event there were future dIsputes floWIng from the ImplementatIOn of the Memorandum
Such a provIsIOn IS not uncommon and makes good labour relatIOns sense In my VIew the
partIes provIded for dIfferent types of dIsputes, not dIfferent types of jUnSdIctIOn.
The AssocIatIOn relIed upon Re Dominion Citrus Ltd. and Teamsters, Local 419 (2001) 98
L.AC (4th) 11 (E Newman) In that case, the arbItrator agreed over the ObjectIOns of the
12
Employer that she had the jUnSdIctIOn of an Interest Board of ArbItratIOn. However the matter
was substantIally dIfferent as IS eVIdent at page 18 whereIn It was Said
ShIfts, start tImes and the defimtIOn of the workweek are negotIated elements of thIS
contract, and the partIes have expressly preserved the character of these elements In the
contemplatIOn of change They have, In effect, agreed to reopen thIS artIcle of the
collectIve agreement dunng the currency of the contract, In order to negotIate changes
I am of the VIew that the matter before me IS dIstIngUIshable Here the partIes negotIated a new
provIsIOn to be Included In the collectIve agreement regardIng Pay for Performance bonuses An
AssocIatIOn dIspute was filed on February 11 2003 allegIng vanous breaches that the collectIve
agreement. The dIspute came before the Gnevance Settlement Board for determInatIOn In
accordance wIth the procedure found at ArtIcle 15 6 of the collectIve agreement. Much of the
dIspute was resolved between the partIes and a Memorandum of Settlement was entered Into on
May 28 2003 The first paragraph of the Memorandum sets out ItS purpose It states, "ThIS
memorandum of settlement IS In relatIOn to an AssocIatIOn polIcy dIspute dated February 11
2003 respectIng ment pay and pay for performance (p4p) bonus, and an AssocIatIOn dIspute
dated June 27 2003 respectIng faIlure to Implement salary Increases, ment pay adjustments and
pay for performance bonuses In a tImely manner" In the thIrd paragraph of the Memorandum of
Settlement It was agreed, "should the partIes faIl to resolve thIS Issue, the partIes agreed that
FelIcIty Bnggs, who is seized with the above-named dispute, scheduled to be heard on June
26 2003 wIll determIne the matter" (emphasIs mIne) In my VIew that sentence clearly states
that I, who am seIzed of the ongInal AssocIatIOn dIspute regardIng, amongst other thIngs the Pay
for Performance bonus, wIll contInue to act In my capacIty as nghts arbItrator and determIne the
matter To broaden the scope of the dIspute from a nghts dIspute to an Interest dIspute would
reqUIre much more specIfic language There IS nothIng In the Memorandum of Settlement that
would have me find my jUnSdIctIOn to determIne the matter was altered by agreement of the
partIes
For those reasons, I find I am actIng as a nghts arbItrator In determInIng the Issue of how to
"treat employees In receIpt ofEI top up for pregnancy or parental leave"
AccordIngly the final area of dIspute IS "how to treat employees In receIpt of EI top up for
pregnancy or parental leave" As stated In the Memorandum of Settlement, It was the
AssocIatIOn's posItIOn that "employees should be elIgIble to receIve pay for performance
13
payments under ArtIcle 45.2 for any penod of the year In whIch an employee IS In receIpt ofEI
top-up for pregnancy or parental leave" It was asserted by Ms Pollak that a reVIew of the
collectIve agreement reveals the partIes' IntentIOn that employees on pregnancy or parental leave
would not be dIsadvantaged In any way as the result of theIr leave
ArtIcles In the collectIve agreement referred to In thIS regard were
Article 2 - No Discrimination/Harassment
2 1 There shall be no dISCnmInatIOn or harassment practIced by reason of race, ancestry
place of on gIn, colour ethmc on gIn, cItIzenshIp creed, sex, sexual on entatIOn, age,
mantal status, famIly status, same sex partnershIp status, or handIcap as defined In
sectIOn 1 O( 1) of the Ontano Human Rights Code (OHRC)
Article 16 - Seniority/Continuous Service
162 1 An employee's semonty/contInuous servIce shall accumulate from the date
determIned In ArtIcle 16 1 and shall Include the penod of servIce dunng whIch an
employee
(a) IS In receIpt ofLTIP or WCB benefits, or
(b) IS absent on pregnancy or parental leave or
( c) IS absent on any authonzed leave wIthout pay of thIrty (30) calendar days or less
Article 24 - Pregnancy Leave, Parental Leave and Employment Insurance Top-Up
24 1 In thIS ArtIcle,
"weekly pay" In respect of an employee on a leave of absence referred to In ArtIcle 24
means weekly pay at the rate actually receIved by the employee on the last day of work
and also Includes any salary Increase that IS granted after the last day of work to take
effect retroactIvely on or before the last day of work.
24 12 In respect of the penod of pregnancy leave, payments made accordIng to the
Supplementary Employment Benefit Plan wIll consIst of the folloWIng
(a) for the first two (2) weeks, payments eqUIvalent to mnety-three (93)% of the
actual weekly rate of pay for her classIficatIOn and shall also Include any
Increases In salary that she would have attaIned had she been at work dunng the
leave of absence as they are, or would have been Implemented, and
(b) for each week, up to a maXImum of fifteen (15) addItIOnal weeks, payments
eqUIvalent to the dIfference between the sum of the weekly Employment
Insurance benefits the employee receIves for the week and any other salary earned
by the employee dunng the week, and mnety-three percent (93%) of the actual
weekly rate of pay for her classIficatIOn and shall also Include any Increases In
salary that she would have attaIned had she been at work dunng the leave of
absence as they are, or would have been Implemented, and,
14
( c) for each week up to a maXImum of fifteen (15) addItIOnal weeks, where the
employee elects to take Parental Leave In accordance wIth ArtIcle 24 7 payments
eqUIvalent to the dIfference between the sum of the weekly Employment
Insurance benefits the employee receIves for the week and any other salary earned
by the employee dunng the week and mnety-three (93%) percent of the actual
weekly rate of pay for her classIficatIOn, and shall also Include any Increases In
salary that she would have attaIned had she been at work dunng the leave of
absence as they are or would have been, Implemented.
24 14 Payments under the Supplementary Employment Benefit Plan wIll not apply to
leave that contInues after fifty (52) weeks folloWIng the day the chIld IS born or comes
Into the custody care and control of the parent for the first tIme where Employment
Insurance benefits do not apply NotwIthstandIng any other artIcle In thIS agreement,
vacatIOn credIts and semonty contInue to accrue dunng pregnancy leave (ArtIcle 242)
parental leave (ArtIcle 24 7) and extended leaves (ArtIcle 24 17 and 24 19) ContInuous
servIce for severance accrues dunng pregnancy and parental leave for a bIOlogIcal father
and adoptIve parent.
24 20 An employee returmng to work after pregnancy leave, parental leave or extended
leave referred to In ArtIcles 24 19 or 24.22 shall be reInstated to the posItIOn the
employee most recently held wIth the Employer on a regular and not a temporary basIs, If
the posItIOn stIll eXIsts, or to a comparable posItIOn, If It does not.
24 21 The Employer shall pay a reInstated person salary that IS at least equal to the
greater of
(a) the salary the employee was most recently paid by the Employer or
(b) the salary that the employee would be earnIng had the person worked throughout the
leaves of absence referred to In ArtIcle 24 2, 24 7 24 19 or 24 22
Article 31 - Benefit Plans for Full Time Employees
31 3 Dunng leaves of absence wIth pay full benefit coverage wIll contInue The
Employer and employee wIll contInue to pay the applIcable premIUms
31 4 Dunng pregnancy and parental leave, an employee who partIcIpates In any Benefit
Plan may contInue to do so unless he or she elects In wntIng not to do so Unless an
employee gIves the Employer thIS wntten notIce, the Employer and the employee shall
contInue to pay the applIcable premIUms
Article 45 - Merit Pay and Pay for Performance Bonus
45 1 Ment Pay
For employees In AMAPCEO classIficatIOns who are not at the maXImum of theIr salary
range
45 1 1 A ment Increase for a twelve (12) month work cycle COIncIdIng wIth the
employee's anmversary date shall be processed In any amount of 0 - 5% of hIS or her
15
salary at the dIscretIOn of the Employer An employee's ment Increase for satIsfactory
performance shall be three and a half percent (3 5%) of hIS or her salary
45 1.2 Where an employee's performance ratIng results In a ment Increase that wIll cause
hIS or her salary to exceed the maXImum salary for hIS or her classIficatIOn, the amount of
the ment Increase In excess of the maXImum salary wIll be paid out as a lump sum bonus
Such lump sum bonus wIll not Increase the employee's base salary for any purpose
The provIsIOns for Pay for Performance found at ArtIcles 452 and 45 3 are reproduced earlIer In
thIS decIsIOn.
As stated earlIer the AssocIatIOn submItted that the collectIve agreement provIdes that those
absent on pregnancy and parental leave would not suffer losses as the result of theIr absence
Those employees return to the same salary or the salary they would have been earmng If they
had worked throughout the leave TheIr semonty and servIce contInues to accumulate and they
contInue to earn vacatIOn. ArtIcle 23 entItled "Leaves of Absence" contemplates vanous types
of leaves, both paid and unpaid. Included In those leaves are JUry or wItness duty leave, mIlItary
leave specIal & compaSSIOnate leave and bereavement leave The AssocIatIOn stated that It IS
worthy of note that pregnancy and parental leaves are not found In ArtIcle 23 There IS a separate
provIsIOn In the collectIve agreement found at ArtIcle 24 that consIders the terms and condItIOns
for those employees on pregnancy and parental leaves Clearly the partIes Intended that these
employees would be treated dIfferently from employees on other leaves, that specIal treatment
Includes the proVISO that they would not be finanCIally dIsadvantaged because of theIr absence
It was argued by the AssocIatIOn that the collectIve agreement must be construed so as to find
that "salary" Includes the Pay for Performance bonuses There are specIfically defined terms In
artIcle 24 for employees on pregnancy and parental leaves, such as weekly pay whIch refers to
the rate actually receIved on the employees last day pnor to theIr leave IncludIng any salary
Increase that IS granted after theIr last day wIth retroactIve applIcatIOn. ObvIOusly thIS
underscores the concept of earnIng salary In absentIa. That defimtIOn, read In conjUnctIOn wIth
ArtIcle 24 12 regardIng Supplementary Employment Benefit Plan, sIgnals the agreement
between the partIes that weekly pay and salary are dIfferent and further that salary Includes the
Pay for Performance bonus Further It IS to be remembered that both Ment Pay and Pay for
Performance are added to employee's earmngs
16
The ASSOcIatIOn argued that the fact that the Pay for Performance bonus IS based on an appraisal
does not change the charactenzatIOn of "salary" As part of salary the bonus cannot be reduced
because of absence on pregnancy and parental leave
AddItIOnally the AssocIatIOn took the posItIOn that the treatment of AssocIatIOn dues buttresses
ItS VIew that the Pay for Performance bonus IS salary AccordIng to ArtIcle 1001 the Employer IS
oblIged to deduct dues from "the salary/wages" of every employee There was no dIspute that
AssocIatIOn dues are deducted from the Pay for Performance bonuses and therefore that levy IS
an Employer acknowledgement that the Pay for Performance bonus IS part of salary
Ms Pollak referred to ArtIcle 45 2.2 whIch provIdes that the lump sum payments resultIng from
Pay for Performance bonus "wIll not Increase the employee's base salary" "Base salary" IS used
for the calculatIOn of pensIOnable earmngs "Salary" unqualIfied by the term "base" must Include
allowances and bonuses As such, the Employer cannot wIthhold any part of the Pay for
Performance bonuses to any employee absent due to pregnancy or parental leave
The ASSOCIatIOn remInded the Board that the Employer had conceded that Pay for Performance
IS "wages" as that term IS found In the Employment Standards Act, S 0 2000 c 41 The Act
provIdes, at SectIOn 53 that employees returmng to work after such leaves must be reInstated at
a rate that IS equal to the greater of the rate In affect at the begInmng of the leave or the rate that
the employee would have earned had she worked throughout the leave Clearly the Act provIdes
that an employee IS to receIve what they would have receIved but for theIr absence due to
pregnancy leave Therefore, employees returmng from pregnancy or parental leave must get the
full amount of the Pay for Performance bonus
Not surpnsIngly the Employer took a much dIfferent VIew Mr Strang descnbed the newly
negotIated Pay for Performance bonus as an amount of money It agreed to put "Into a pot" to
dIstnbute to a relatIvely wIde number of members of the bargaInIng umt. It VIews thIS bonus as a
program that wIll serve as an InCentIve to enhance the performance of the most semor members
of staff The Pay for Performance bonus IS a backward lookIng benefit, that IS to say that It IS a
lump sum bonus granted at the end of a penod of work already completed. Therefore, It would
be surpnsIng If employees absent on pregnancy or parental leave had access to the bonus
because they were not performIng work.
17
The Employer submItted that accordIng to artIcle 45 3 2, the admInIstratIOn of the Pay for
Performance bonus IS "totally wIthIn the dIscretIOn" of the Employer It was conceded that there
are certaIn restnctIOns put upon that dIscretIOn. For example, a specIfied percentage of those
employees at the maXImum of the salary range wIll receIve a SIX per cent bonus However none
of the express restnctIOns assIst the AssocIatIOn In ItS quest to have employees on pregnancy and
parental leave paid the same performance bonus as those employees who remaIn In the
workplace
It was asserted by the Employer that It IS In ItS Interest to compensate employees for posItIve
work performance Surely It IS ObVIOUS that the assessment of performance IS dependent on work
actually beIng done That evaluatIOn can only be undertaken when employees are performIng In
the workplace and not absent on any type of leave IncludIng pregnancy or parental leave In
order for the Pay for Performance program to be successful there has to be an orderly process for
settIng and asseSSIng performance goals AgaIn, It IS easIly apparent that the actual process of
evaluatIng employees IS a complex exerCIse Indeed, the partIes recogmzed that fact when they
agreed to gIve the Employer total dIscretIOn to run the program.
It IS explIcItly stated at ArtIcle 45 2 6 that an employee "must have earned" the maXImum salary
range for at least twelve months to be elIgIble Further If the employee has "been earmng the
maXImum salary for less than twelve months" the Pay for Performance bonus IS to be prorated.
WhIle It was the AssocIatIOn's VIew that thIS provISIOn means that an employee merely has to
have reached the maXImum range In the salary gnd to get the full Pay for Performance bonus, the
Employer suggested that It means precIsely and clearly what It says that IS, that an employee
must "have earned" the salary The partIes can and dId use clear language when they wanted to
conSIder employees at the top of the salary range ArtIcle 44 l(e) states
Any employee who on or after Apnl 1 2001 and pnor to ratIficatIOn, receIved no ment
Increase solely because he or she was at the maXImum salary rate of hIS or her
classIficatIOn, shall have hIS or her salary adjusted based on satIsfactory performance up
to the reVIsed maXImum salary rate of hIS or her classIficatIOn, effectIve as of hIS or her
anmversary date
The Employer argued that the faIlure to utIlIze those words In the Pay for Performance bonus
provISIOns IS tellIng and should lead thIS Board to find for the Employer
18
Employees on leaves of absence are not "earnIng" a salary They mIght be on paid leaves of
absence for a vanety of reasons However they are not "earnIng" salary Therefore the
Employer IS entItled to prorate the Pay for Performance by takIng Into account the employee's
faIlure to earn salary for the penod of the leave
Mr Strang contended that the AssocIatIOn dId not press strongly any suggestIOns of
dISCnmInatIOn because It knew that any such assertIOn IS groundless Employees returmng from
pregnancy or parental leaves are not the subject of dISCnmInatIOn because they do not receIve the
full Pay for Performance bonus The proratIng of the Pay for Performance bonus does not reduce
any benefit they had pnor to or after theIr leave Indeed, they are not prejudIced In any way
regardIng theIr performance before or after theIr leave In thIS regard the Employer relIed upon
Re Regional Municipality of HaUon and Ontario Nurses' Association (1995),48 LAC (4th)
301 (Burkett) and, Re Regional Municipality of Durham and Canadian Union of Public
Employees, Local 132 (1995), 48 L AC (4th) 135 (Craven)
In reply the AssocIatIOn stated that nothIng In the collectIve agreement makes the actual receIpt
of wages dependent upon the concept of "earnIng"
As stated above, my jUnSdIctIOn to determIne thIS matter anses from the collectIve agreement
and the Memorandum of Settlement the partIes sIgned on May 28 2003 After consIdenng the
submIssIOns of the partIes, I am of the VIew that the Employer's VIew of thIS final Issue must
prevaIl
The AssocIatIOn would have me find that the Pay for Performance bonus IS part of salary As
such, those on pregnancy and parental leave shall not have the bonus prorated. I dIsagree In my
VIew the partIes specIfically addressed thIS Issue and agreed otherwIse ArtIcle 45 2.2 states that
the bonus "shall be a re-earnable lump sum payment and wIll not Increase the employee's base
salary beyond the maXImum of the salary range for any purpose" ThIS provIsIOn makes two
Important elements of the Pay for Performance bonus clear FIrst, the bonus IS earned and "re-
earnable" In the context of a performance bonus such earmng would be achIeved through work
performance I cannot find that It would be earned whIle absent from work on pregnancy or
parental leave The second aspect of thIS artIcle IS that the partIes agreed the bonus does not
Increase the employee's base salary If the bonus does not Increase the salary It IS not part of the
19
salary The reference In ArtIcle 45 2.2 to "base salary" does not elevate the Pay for Performance
bonus to the status of salary
Further ArtIcle 45.2 6 whIch contemplates elIgIbIlIty for the bonus, provIdes that an employee
must "have been earnIng" the maXImum salary for at least twelve months Those words are clear
and unrestncted. There IS nothIng In thIS artIcle or any other artIcle that I could find In the
collectIve agreement that would lead me to find that "earnIng" In thIS context does not reqUIre
attendance at and performance of work. If the partIes had Intended to say that all employees who
had reached the maXImum of the salary range for at least twelve months are entItled to the full
and un-prorated bonus they could have and should have said so clearly It IS to be noted that
ArtIcle 44 l(e) dealIng wIth Ment Pay contemplates a group of employees who are "at the
maXImum of the salary range" I cannot find those two dIffenng phrases to have the same
meamng as was urged by the ASSOCIatIOn. To do so would effectIvely read the words "have been
earmng" out of the collectIve agreement.
The ASSOCIatIOn suggested that pregnancy and parental leave has a separate and dIStInCt status
under thIS collectIve agreement. WhIle It IS true that these leaves are conSIdered In a dIfferent
artIcle In the collectIve agreement from other leaves of absence, that separatIOn IS not sufficIent
for me to find that access to Pay for Performance IS untouched by the penod of the absence
It was submItted that because vacatIOn pay IS earned whIle an employee IS absent from the
workplace on pregnancy and parental leave, attendance at work IS not a necessary cntena for
earmng Pay for Performance I admIt thIS argument has some superficIal attractIOn. However I
am of the VIew that the Pay for Performance bonus IS not akIn to vacatIOn pay Indeed, there are
sIgmficant dIfferences between vacatIOn entItlement and the Pay for Performance bonus First,
vacatIOn IS not a bonus Second, unlIke the Pay for Performance bonus, the Employer does not
have "total dIscretIOn" regardIng the applIcatIOn of vacatIOn entItlement. ThIrd, the partIes
speCIfically addressed how vacatIOn IS to be accrued. ArtIcle 302 states that an employee IS
entItled to vacatIOn credIts when they are at work as well as when they are on leaves of absence
wIth pay ThIS benefit IS reInforced at ArtIcle 24 12 There are no sImIlar provISIOns for the
payment of the Pay for Performance bonus dunng pregnancy and parental leave The fact that
vacatIOn entItlement contInues to accumulate for employees on pregnancy or parental leave IS
not determInatIve
20
The Issue of whether the proratIng of the Pay for Performance bonus for employees absent due to
pregnancy or parental leave constItutes dISCnmInatIOn was raised. AgaIn, after consIderatIOn I
thInk not. There has been much arbItral consIderatIOn of adverse Impact dISCnmInatIOn as It
relates to pregnancy and parental leave It IS generally accepted that employees on pregnancy and
parental leave shall not lose accrued nghts and benefits More specIfically arbItrators have
consIstently found that semonty contInues to accrue dunng such leaves In part, thIS has been
determIned because faIlure to accrue semonty dunng these leaves would lead to employees not
reCeIVIng contractually provIded annual wage Increases at the appropnate tIme That result
would vIOlate the provIsIOns of the Employment Standards Act. The legIslatIOn provIdes that
employees returmng from pregnancy leave should be reInstated to the "wages that the employee
would be earnIng had the employee worked throughout the leave" In the Instant matter I am not
presented wIth employees who faIl to move up the salary gnd because of theIr absence on
pregnancy or parental leave The Issue at hand IS whether those employees who have earned the
maXImum salary for at least twelve months receIve a full annually applIed bonus for performance
or whether the bonus should be prorated takIng Into account the penod of pregnancy and parental
leave
In Re Regional Municipality of Halton (supra) It was determIned that nurses absent from work
on pregnancy leave were not entItled to vacatIOn pay because vacatIOn pay was condItIOnal on
tIme actually worked. It was said to be a "work dnven" and not a "servIce dnven" benefit. In thIS
regard ArbItrator Burkett said, at page 1 0
There IS a surface attractIOn to the notIOn that because an employee on pregnancy
leave suffers a reductIOn In vacatIOn pay and because only females can become pregnant
there has been adverse Impact dISCnmInatIOn WIthIn the meamng of the above defimtIOn.
However If thIS analysIs IS correct as It pertaIns to vacatIOn pay that IS earned through
attendance at work It would support a claim for wages whIle absent on pregnancy leave
because, for purposes of such a claim a benefit based on hours worked IS not dIfferent
than wages There IS no suggestIOn In any judgment or award of whIch we are aware than
an employee absent on pregnancy leave suffers dISCnmInatIOn because of not reCeIVIng
her wages whIle absent from work. Indeed, If such a wIthholdIng of wages constItutes
dISCnmInatIOn It would have been an easy matter for the legIslature, In puttIng ItS mInd to
the dISCnmInatory Impact of pregnancy leave and stIpulatIng the wage rate to be paid
upon return from pregnancy leave to have made contInUatIOn of wages a statutory
reqUIrement of any pregnancy leave In the absence of any such reqUIrement, the better
VIew IS that loss of a work dnven benefit that IS avaIlable to all employees on the basIs or
hours worked, by reason of absence from work for whatever reason, pregnancy or
21
parental leave, does not constItute a penalty or restnctIve condItIOn wIthIn the meamng of
adverse Impact dISCnmInatIOn.
A bonus that IS awarded for performance reqUIres attendance In the workplace Absent
employees cannot be rewarded for a full year's performance IrrespectIve of whether theIr
absence resulted from a pregnancy leave or due to another type of leave Pay for Performance IS,
In the words of ArbItrator Burkett, a "work dnven" bonus Therefore, the proratIng of the Pay for
Performance IS not dISCnmInatory
FInally a consIderatIOn of thIS matter based on a purely pragmatIc and sImple approach
buttresses my VIew In order to be paid a bonus for performance, ongOIng performance of work IS
necessary It makes no sense that an employee would be rewarded for twelve months of
satIsfactory or supenor performance If they had actually been at work for only two months of
that year One cannot be rewarded wIth a bonus for work not performed IrrespectIve of the
reasons for the absence from the workplace I am of the VIew that the partIes agreed to that
pnncIple wIthout exceptIOns at artIcle 45.2 6
F or all these reasons I find that the Employer's VIew as set out In the thIrd paragraph of sectIOn 2
of the May 28 2003 Memorandum of Settlement IS correct.
Dated III T/onto tlus 23~ day of February 2004
.