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HomeMy WebLinkAboutUnion 19-11-01IN THE MATTER OF AN ARBITRATION BETWEEN PUBLIC HEALTH ONTARIO (the Employer) AND ONTARIO PUBLIC SERVICE EMPLOYEES UNION (the Union) Grievance Regarding Lead Logistics Operations: OPSEU # 2017-0545-005 and 2016-0545-0013 Hearings held in Toronto on March 2, July 13, November 13, November 15, November 27, 2018 March 4, April 1, June 18, and July 17, 2019 Arbitrator: Barry B. Fisher For the Union: Jesse Gutman For the Employer: Paul Meier AWARD 2 This case involves the determination of two issues: A) Whether the newly created position of Lead Logistics Operations should be in the OPSEU bargaining unit. B) If the answer to the above question is “no” then are there any restrictions on the duties that can be carried out by the Lead Logistics Operations at Resources Road. Background: This case was supposed to proceed primarily on the basis of an extensive Agreed Statement of Facts (ASOF) which is attached to this award. However, both parties spent considerable time and effort leading oral and written evidence about matters that were already referred to and agreed to in the ASOF. In writing this award I have therefore relied in most part on the ASOF as I found that the oral evidence largely supported what the parties had already agreed to. I will therefore not set out in detail in this award the underlying facts except where it is necessary to comment on the oral evidence that was also presented. Where I reference the ASOF, I will simply set out the paragraph number from the ASOF and do not repeat its contents. A) Whether the newly created position of Lead Logistics Operations should be in the OPSEU bargaining unit. The relevant Article in the Collective Agreement regarding the makeup of the bargaining unit contains the usual exclusion of “persons who exercise management functions “and “persons “employed in a confidential capacity in matters relating to labour relations”. However, the bargaining unit does include the position of Supervisor Mail and Warehouse ( “Supervisor”) In essence the Employer eliminated two Supervisor positions and replaced them with two Lead Logistics Operations (“ Lead”) who they claim are outside the bargaining unit. The ASOF sets out in great detail exactly where the parties agree the duties are similar and when they are different. They also set out where they cannot agree and, on these issues, I heard very extensive oral evidence. Here is my summary of those various categories: 3 SIMILAR DUTIES #42: Supervision of daily duties, work processes, daily work routines, input into preparation of budget, consult with clients, maintain service contracts, removal, participates in policies. #44 and 45: Skills and Knowledge #49: Communication/ Interpersonal Skills & Quality of Client/ Customer Service #50 and 51: Judgement/Problem Solving / Decision Making #65: Direction and Control of Day to Day Activities DIFFERENT DUTIES #36: Positions supervised # 37 to # 39: Managing and directing staff #40 to #41: Ensure compliance #46 to 48: Leadership and Coaching #53 and 54: Designated Authority Human Resources Authority #55 to 64: Hiring #66 to 70: Performance Reviews and Employee Training #78 to 83: Authorizing Overtime, Vacation and Leaves #84 to 89: Health and Safety and other Reporting Responsibilities #90 to 92: Discipline #93 Grievances 4 DISAGREEMENT #43: KPI and operational data. # 71 to 77: Assigning Staff and Directing the Work: On some of the Different Duties, there is a clear line between what the Supervisor could do as opposed to the Lead did or was authorized to do. In other situations, the differences were more subtle, meaning that the Supervisor could “recommend” or “participate “ while the Lead had the authority to do the task or give the approval themselves without the intervention or consent of their manager. I also heard extensive oral evidence from both parties as to the detail of the transactions and duties as already outlined in the SOF. Most of this evidence was focused on the few issues where the parties disagreed on the exact nature of the duties of the respective Supervisor and Lead. Obviously, there is a great overlap between the two sets of duties, especially in the area of day to day supervision of the work. I have concluded that if one were to simply add up the number of hours that the Supervisor spent doing the same or similar tasks of the Lead that this overlap would constitute the majority of their respective shifts. However, it is not just the quantity of time that one spends on a particular job task but also the character of the task that matters in determining whether or not the duties are managerial vs supervisory. For instance, one may spend less than 1% of their time disciplining employees, however the inclusion of that duty is very relevant to determining whether someone is a bargaining unit supervisor or an excluded manager. If one simply looks at the SOFs where the parties agree that there was a difference, one can instantly see that virtually all the differences focus on those duties traditionally viewed as being managerial, i.e. managing subordinates, designated authority regarding human resource issues, hiring, performance reviews, discipline and authorizing overtime, vacation and leaves. This is especially clear when one looks at Tab 16 of Exhibit 1 entitled “Delegation of Authority Human Resources” which sets out in detail “to define the limits of authority to specified positions of responsibility within PHO to conduct specific human resource functions for union and non-union positions”. The Lead is found within Level 6, the lowest level of authority. According to this document, the Leads can do the following things, none of which could be done by the Supervisors: Recruit staff position within budget. Determine area of search for recruitment 5 Make standard employment offers for both union and non-union positions Administer Oath of Office Deal with working condition grievances at stages 1 and 2 Deal with classification grievances at stage 1. Set performance standards and conduct performance appraisals Authorize and approve attendance Determine and approve hours of work Authorize and approve time credits while travelling Authorize and approve overtime and time in lieu Authorize and approve call back Authorize and approve On Call Duty Authorize and approve Stand-by time Authorize and approve day in lieu for working on a holiday or working overtime Ensure First Aid measures for unit Accident and Injury investigation Authorize bereavement leave up to 3 days, Personal Emergency leave , Family Medical Leave, Religious Observance , Pregnancy Leave, Parental Leave and other leaves Salary on Appointment Approve training courses and time off to attend up to 3 days Time off for PHO job interviews The few issues that the parties do not agree upon generally dealt with operational issues that would not materially affect this analysis. For instance, whether or not the Supervisor drafted Standard Operating Procedures would make little difference in deciding whether these duties took this job outside the bargaining unit. Moreover, the duties that the parties agree are similar are largely related to the day to day operations of the workflow, which are traditional supervisory or lead hand types of duties. I am satisfied that the duties performed by the Lead set out under DIFFERENT DUTIES are core duties of such a significant nature that they both constitute “persons who exercise management functions “ and, to a lesser degree, “persons employed in a confidential capacity in matters relating to labour relations”. They are not, as alleged by the Union, mere “paper duties” or “a sprinkling of management duties “. These new duties of the Leads flowed largely from a delegation downwards from duties previously performed by the Manager, Logistics Operation. It was done for the express purpose of insuring an on the ground managerial presence in a workplace which the Employer reasonably decided was necessary now that there were two separate physical locations and only one Manager. I therefore conclude that the Position of Lead Logistics Operations is not in the OPSEU bargaining unit as it falls within the managerial exemption. 6 B) Are there any restrictions on what duties the Lead Logistics Operations located at 81 Resource Road can do? As a direct result of the creation of the Lead position, there was a layoff of the Supervisor at the Resource Road location. That individual filed a grievance, which was then settled, and a Memorandum of Agreement was signed. That individual did not return to the employ of the Employer. Article 12.1.1 of the Collective Agreement reads as follows: Work of the Bargaining Unit Employees excluded from the bargaining unit shall not preform duties normally performed by employees in the bargaining unit which directly results in a layoff to an employee in the bargaining unit. Insofar as the Supervisor was laid off as a direct result of the Employer’s decision to create the Lead position, and given that many of the duties currently being performed by the Lead used to be performed by the Supervisor, is the Lead now prohibited from performing those bargaining unit duties? The reason that this issue only applies to the one position is because the change in the other location was done without any layoff. It is clear that: a) A significant amount of the work currently performed by the Lead at Resources Road is the same as the work previously done by the Supervisor. b) The only reason the previous Supervisor was laid off was because of the decision of the Employer to bring in the new position of Lead. The Union position is given these two facts, it flows from Art 12,1,1 that as the Lead is not in the bargaining unit, he cannot perform those overlap duties. The Union’s position is that this clause is not simply designed to protect the job of the incumbent but that the Union has an ongoing collective Bbrgaining interest in maintaining the integrity of bargaining unit work, even where the individually affected Grievor has resolved his layoff dispute and is no longer an employee. The argument of the Employer is that this Article only gives protected rights to the individual employee who is laid off and since he has resolved his individual grievance, which the Union agreed to, there are no further rights flowing from this Article. The parties cited a number of cases, however, I find the case decided by Arbitrator Petryshen in OPSEU v, MGS, GSB #201-011 to be the most relevant to our fact situation. 7 In that case the relevant Article read as follows: “5. Non- public servants, while in the workplace, shall not perform duties normally performed by employee in the bargaining unit if it directly results in the layoff of a bargaining unit employee.” This GSB case involved the situation where two bargaining unit persons were laid off while the Employer retained the use of outside consultants to do similar work. The Union was asserting that the employer should have been required to give that consultants’ work to the bargaining unit employees and the failure to do so resulted in a layoff. The arbitrator decided that the continued use of the outside consultants did not directly result in the layoff of the bargaining unit employees as the work they did was either discontinued or absorbed by other bargaining unit employees. However, the arbitrator also went on to comment on what the remedy would have been if he had found in favour of the Union. Paragraph 22. Even if there had been a violation of paragraph 5, I find that that section 20 of the Collective Agreement would not have any application in providing a remedy for the violation. If the Employer had contravened paragraph 5, the appropriate remedy would consist of a declaration that the Employer had contravened paragraph 5, with a direction to the Employer to return the SO to active employment and to compensate the SO for any losses. This is precisely the response of the arbitrators who found a similar contravention of a similar provision in the decisions relied upon by the Union. This remedial approach would be a sufficient response to a specific violation of paragraph 5. The Employer cites this paragraph of authority for their proposition that the only remedy is personal to the Grievor and that it cannot have an effect on the future work that the Lead can or cannot do. In all of the cases cited by both parties it is clear that the normal remedy is to order the displaced employee to be reinstated and provided with back pay. It is clear that if that were to happen and the next day the newly reinstated employee were to quit, the Employer would be free to have non-bargaining unit employees perform the tasks previously performed by the bargaining unit employee. In this case, the Supervisor settled his layoff grievance by giving up his claim to reinstatement, and instead accepted a monetary payment, This is akin to a situation where the employee is reinstated, gets his back pay, and then quits. As such I find that since the Supervisor in this case came to a financial settlement of his layoff grievance in exchange for a payment of money, it is the same situation as if he had voluntarily 8 resigned. It is clear that in that situation it would be perfectly legal for the Employer to assign some of his duties to a non- bargaining unit employee. it is therefore follows that the Resource Road Lead is permitted to perform those duties previously performed by the Supervisor, just as is the situation at the Employers’ other location. However, this does not mean that there is no remedy available because from the time that the Resource Lead was laid off until the time that he signed the Minutes of Settlement, the Employer was in breach of Article 12.1.1 of the Collective Agreement in that the Lead was performing bargaining unit work. The Union is therefore entitled to a declaration that the Employer breached Article 12.1.1 between the dates referred to above. The grievance is therefore allowed. Dated at Toronto this day of November 2019 Barry B. Fisher, Arbitrator 9 AGREED STATEMENT OF FACTS (ASOF) 10 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. AGREED STATEMENT OF FACT A. BACKGROUND Introduction 1. Public Health Ontario (“PHO”) is a Crown corporation dedicated to protecting and promoting the health of all Ontarians. PHO links public health practitioners, front- line health workers and researchers to the scientific intelligence and knowledge from around the world. PHO’s main clients are local public health units, government and health care providers and institutions. 2. PHO provides expert scientific and technical advice and support relating to: 1. InfectiousDiseases 2. InfectionPreventionandControl 3. Surveillance and Epidemiology 4. Health Promotion, Chronic Disease and Injury Prevention 5. Environmental and Occupational Health 6. Emergency Preparedness and Incident Response 3. In carrying out its mandate, PHO operates its central public health laboratory, the Toronto Laboratory, at 661 University Avenue, occupying four floors of the MaRs West Office Tower. PHO employs approximately 400 employees in its Toronto Laboratory. 4. PHO also operates 10 regional public health laboratories across the province. 5. The Ontario Public Service Employees Union (“OPSEU” or the “Union”) represents over 155,000 employees in the public and para -public sectors across Ontario. Its Local 545 holds the certificate for bargaining rights for employees at PHO. 1 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. FORMER PHO ORGANIZATIONAL STRUCTURE 81 Resources Road – Pre- November 2014 6. Before November 2014, PHO’s Toronto Laboratory department was located at 81 Resources Road. At that time, the department included the corporate services that supported the Laboratory (e.g., finance, procurement, etc.). 7. PHO’s Mail Room Operations and its main Warehouse and Distribution Centre (“Warehouse Operations”) were also both located at 81 Resources Road. Staff in PHO’s Mail Room Operations and in its Warehouse Operations were members of 11 what used to be PHO’s “Public Health Laboratories / Procurement and Supply Chain” department. 8. PHO deployed five Stockroom Clerks in its Warehouse Operations and three Mail Room Clerks in its Mail Room Operations at 81 Resources Road. All of these Clerks were OPSEU-represented employees. 9. The Stockroom Clerks and Mail Room Clerks reported to the “Manager, Procurement and Supply Chain”. 10. The Manager worked onsite at 81 Resources Road. Her office was located on the building’s main level, directly above the Warehouse Operations floor. Under the heading “Key Responsibilities”, the Manager’s job description stated:1 Manages assigned Warehouse staff, congruent with the PHO's internal policies and procedures, professional standards, Collective Agreement requirements and other relevant standards, legislation or regulations, including: providing direction and leadership in the implementation of new techniques and standards; managing the assignment of staff and work/vacation scheduling; setting clear responsibilities and objectives and evaluating performance; ensuring training is provided, participating in recruitment/selection of staff; dealing with disciplinary issues and responding to grievances in conjunction with the PHO's Human Resources management programs; 1 See Tab 1: Manager, Procurement and Supply Chain job description dated May 16, 2014. 2 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. 11. PHO also deployed a “Supervisor, Mail and Warehouse” in respect of the 81 Resources Road Mail Room and the Warehouse Operations (hereinafter “the former bargaining unit Supervisor”). 12. This employee was a member of the Union’s bargaining unit and reported to the Manager. PHO REORGANIZATION AND RELOCATIONS Overview 13. Starting in November 2014, PHO began a major reorganization of its logistics operations. Under the new model, PHO split its operations into two separate Logistics Operations, each with its own core functions: 1. 661 University Avenue Logistics Operations (supporting PHO’s Toronto Laboratory and operating PHO’s centralized Mail Room); and 2. 81 Resources Road Logistics Operations (PHO’s Laboratory Operational Support Facility). 12 661 University Avenue Logistics Operations Toronto Laboratory Operations 14. Between November 2014 and up until March 2015, PHO moved its Toronto Laboratory (and related finance and procurement services) from 81 Resources Road to 661 University Avenue. As stated above, PHO’s new state-of-art Toronto Laboratory occupies four floors of 661 University Avenue’s West Office Tower. 3 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. 15. In undertaking this reorganization and relocation, PHO migrated logistics functions from 81 Resources Road to 661 University Avenue while simultaneously expanding its 661 University Avenue Logistics Operations to perform new functions that had not been performed previously at 81 Resources Road. For example, PHO transf erred lab-coats management and hazardous materials management activities, including two “Lab Attendants 1” FTEs,2 from 81 Resources Road to 661 University Avenue under the new Logistics Operations model. This transfer was made effective April 1, 2015. 16. The PHO also expanded its logistics functions at 661 University Avenue under the new model to include, inter alia, biomedical and sharp waste management, compressed gases management, and secured shredding management. 17. To meet the needs of its 661 University Avenue Logistics Operations, PHO established four “Logistics Clerk” positions at 661 University Avenue, updating and revising the former “Stockroom Clerk” job description.3 As PHO announced to its employees in July 2016: Over the past few months, we have been reviewing work processes in Logistics Operations following the move of Toronto laboratory operations to 661 University Avenue while continuing to work across the two sites. We have had an opportunity to review the roles in the Warehouse and Mail Room a nd have worked to realign some of the processes and tasks to better meet the needs of the department and assist with coverage for particular activities. As a result we have created a revised role titled ‘Logistics Clerk’. This role will continue with the same work as your current role as well as some additional duties such as the collection of bio-medical waste. This change will ensure that other staff are fully trained and able to provide coverage as required. These upcoming changes are designed to help us better integrate and deliver our services to support the Laboratories.4 13 18. PHO placed these positions in its new “Logistics and Supply Chain” Business Unit. PHO states that the new Logistics Clerk job descriptions removed the “compartmentalized approach” that had previously existed under the old 81 Resources Road model. Rather, in 2 “Full-Time Equivalents”. 3 See Tab 3: Logistics Clerk and Mail Room Clerk job descriptions, as revised June 30, 2017. 4 See Tab 4: Letters to former Stockroom Clerks dated July 14, 2016, copying Shah Nawaz, OPSEU Local 545 President. 4 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. accordance with their new job descriptions, all Logistics Clerks rotate through “streams” every six months so that all of PHO’s Logistics Clerks can perform all of the various tasks and functions.5 Mail Room Operations 19. In addition to relocating the Toronto Laboratory, PHO also relocated all of its Mail Room Operations from 81 Resources Road. While it initially co nsidered co- locating its Mail Room with operations run by the Ministry of Health (“MOH”) at a MOH facility, PHO ultimately decided to move its Mail Room to 661 University Avenue effective June 30, 2016. 20. PHO deploys two Mail Room Clerk positions at 661 University Avenue under the new model. 81 Resources Road Logistics Operations 21. In undertaking its reorganization, PHO designated 81 Resources Road as its “Laboratory Operational Support Facility”, establishing the facility as a stand- alone distribution centre. Under the new model, the 81 Resources Road Logistics Operations now deploys three Logistics Clerks. 22. As part of ongoing operational plans, PHO is exploring opportunities to expand its 81 Resources Road Logistics Operations as it further centralizes certain warehouse and distribution functions on behalf of its 10 regional laboratories. 5 See Tab 5: for the work streams at 661 University Avenue and for 81 Resources Road (revision date: Feb 12, 2018). 14 5 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. NEW PHO MANAGEMENT STRUCTURE 23. By letter dated July 26, 2016, PHO advised the Union that “due to realignment of managerial functions of the Warehouse and Mailroom, we are elim inating the position of Supervisor”.6 24. As a result, PHO advised the Union that PHO “will be creating and posting two new management Team Leader positions to manage work-site issues including management of Human Resources and performance”.7 Accordingly, PHO introduced the Lead, Logistics Operations position to have a front -line management presence at both PHO locations (661 University Avenue and 81 Resources Road). 25. On October 4, 2016, PHO posted two “Lead, Logistics Operations” management positions: one Lead, Logistics Operations position for the 661 University Avenue location and another Lead, Logistics Operations for the 81 Resources Road location.8 26. As set out in PHO’s Delegation of Authority (Human Resources), the “Team Lead” is a designated managerial title amongst the organization’s six levels of management (i.e., Leads are at Level 6, along with PHO Managers). 27. On or about December 14, 2016, PHO offered Ms. Manuela Sudjito the Lead, Logistics Operations position for 661 University Avenue9 as the successful candidate in the above- noted job competition. 28. In her role, Ms. Sudjito has seven direct reports; four Logistics Clerks, two Mail Room Clerks and one Lab Attendant 1. All of Ms. Sudjito’s reports are OPSEU - represented employees. 6 See Tab 10: Letter from Catherine Green, Senior Advisor, Labour Relations to Shah Nawaz, President of OPSEU Local 545 dated July 26, 2016. 7 See letter at Tab 10. 8 See Tab 11: Job posting, Lead, Logistics Operations (2 positions), posted October 4, 2016. 9 See Tab 14: Employment Agreement dated December 14, 2016. 6 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. 15 29. On or about December 15, 2016, PHO offered Mr. Jack Vicente the Lead, Logistics Operations position for 81 Resources Road10 as the successful candidate in the above- noted job competition. 30. In his role, Mr. Vicente has three Logistics Clerks who report directly to him and who are all OPSEU-represented employees. 31. Both Lead, Logistics Operations positions report to the Manager, Logistics Operations.11 The Manager, Logistics Operations, is Ms. Katarina Goenadi. Ms. Goenadi has held this position since January 5, 2015. 32. Ms. Goenadi is a subject-matter expert in supply chain management and is assigned special Process Improvement Projects by Senior PHO management regarding same (e.g., opportunities to centralize PHO’s logistics functions). In addition to the two Lead, Logistics Operations reports (Ms. Sudjito and Mr. Vicente), PHO’s Supply Chain Coordinator position12 also reports to Ms. Goenadi. 33. Ms. Goenadi is located at 661 University Avenue. Given Ms. Goenadi’s responsibilities and job duties, Ms. Goenadi visits the 81 Resources Road location approximately four times per month. 34. Both Ms. Sudjito and Mr. Vicente are viewed as members of management by PHO’s senior management team, are privy to management -only information and attend management training courses. 35. The management role of Ms. Sudjito and of Mr. Vicente at their respective work locations is also repeatedly communicated to the PHO workforce. For example, as stated in PHO’s “In the Know @ PHO” newsletter (Winter 2018): 10 See Tab 15: Employment Agreement dated December 15, 2016. 11 See Tab 13: Logistics, Operations Manager dated November 25, 2015 (to be updated). 12 The position is currently vacant. 7 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. The team operates from 661 University Avenue, under the leadership of Manuela Sudjito, and from 81 Resources Road, under the leadership of Jack Vicente. While each site operates slightly differently, staff has the opportunity to rotate to work at the other location to gain a deeper understanding of the logistics processes at PHO.13 B. JOB DESCRIPTION COMPARISON Lead, Logistics Operations v. Supervisor, Mail & Warehouse Positions Supervised 16 36. The Lead, Logistics Operations job description -- under the heading “Positions Supervised” -- lists “Logistics Clerk” and “Mail Room Clerk” as positions supervised.14 No positions were listed as “positions supervised” in the former bargaining unit Supervisor’s job description.15 Key Responsibilities 37. Under the heading “Key Responsibilities”, the Lead, Logistics Operations job description states: Manages and directs staff , congruent with PHO’s internal policies and procedures, professional standards, Collective Agreement requirements and other relevant standards, legislation or regulations, including: providing direction and leadership in the implementation of new techniques and standards; assigning staff and implementing work/vacation schedules; setting clear responsibilities and objectives and evaluating performance; advising on training needs, participating in recruitment/selection of staff; dealing with disciplinary issues and responding to grievances in conjunction with PHO’s Human Resources management programs; 13 See Tab 7. 14 See Tab 12: Lead, Logistics Operations Job Description, “new” as of September 13, 2016. 15 See Tab 2: Supervisor, Mail and Warehouse job description dated June 19, 2014. 8 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. 38. The parties agree that the “manages and directs staff” responsibility was not contained in the former bargaining unit Supervisor’s job description. 39. The parties agree that the “manages and directs staff” responsibility of the Lead, Logistics Operations position uses very similar language to the language contained in the job description of the former Manager at 81 Resources Road. As set out above, under the heading “Key Responsibilities”, the former Manager job description stated:16 Manages assigned Warehouse staff, congruent with the PHO's internal policies and procedures, professional standards, Collective Agreement requirements and other relevant standards, legislation or regulations, including: providing direction and leadership in the implementation of new techniques and standards; managing the assignment of staff and work/vacation scheduling; setting clear responsibilities and objectives and evaluating performance; ensuring training is provided, participating in recruitment/selection of staff; dealing with disciplinary 17 issues and responding to grievances in conjunction with the PHO's Human Resources management programs; 40. The Lead, Logistics Operations job description states also under the heading “Key Responsibilities: Ensures compliance with relevant PHO policies, standards, and guidelines and legislative requirements; 41. The parties agree that the above-noted “ensure compliance” responsibility language was not contained in the former bargaining unit Supervisor’s job description. 42. The parties agree that most of the remaining key responsibilities described in the Lead, Logistics Operations job description are similar to the responsibilities described in the former bargaining unit Supervisor job description: Supervises/Leads Warehouse: “Supervises/Leads the work processes and workflow priorities of the Logistics/Warehouse and Distribution Centre...” versus “Supervises the day to day operations of the PHOL Warehouse and Distribution center...”; 16 See Tab 1: Manager, Procurement and Supply Chain job description dated May 16, 2014. 9 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter.  Supervises/Leads Mail operations: “Supervises/Leads the work processes and workflow priorities for the provision of mail” versus “Supervises day to day the provision mail...”;  “Coordinates the daily work routines for Logistics Operations staff...”  “Provides guidance and direction to external contracted Courier staff”;  “Provides input to preparation of the warehouse budget”;  “Consults with staff and client groups to establish and implement the appropriate procedures and services to respond to client needs”;  “Ensures that all service related equipment is properly used, maintained and repaired”;  “Facilitates removal/disposal of records, chemical waste and assets as required as per approved procedures”; and  “Participates in development and implementation of internal policies and procedures and makes recommendation on meeting client needs”. 18 43. The parties disagree about the following changes, added to two key responsibilities in the Lead, Logistics Operations job description:  “Develops and supervises various KPI and performance measures for Logistics Operations...” versus “Analyzes and produces a variety of inventory reports for product use rates, forecasting of future demand levels, reorder levels etc...”; and  “Develops and maintains effective and useful operational data, (e.g. staffing, equipment, supplies for analysis and decision making process by management staff)” versus “Maintains operational data...” 10 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. Skills and Knowledge 44. The parties agree that the “Skills and Knowledge” required for the Lead, Logistics Operation position and the former bargaining unit Supervisor position are similar. 45. As described in some greater detail below, the parties have a dispute regarding following addition to the Lead, Logistics Operations job description: ... to revise/create SOP [“Standard Operating Procedures”] and generate standard reports, Q-Pulse to support and assist with revision/generation of SOP and Quality Assurance forms as required; Leadership and Coaching 46. Under the heading “Leadership and Coaching”, the Lead, Logistics Operations job description states: Manages and directs the unit staff . Provides coaching, guidance and feedback, to develop the skills and performance of team members within the Logistics Operations team. 47. The parties agree that the “manages and directs staff” leadership requirement contained in the Lead, Logistics Operations position is very similar to the former 81 Resources Road Manager’s requirement.17 17 See Tab 1, p. 3, “Leadership and Coaching” 11 19 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. 48. The parties agree that the “manages and directs staff” leadership requirement was not contained in the former bargaining unit Supervisor’s job description. Under the heading “Leadership and Coaching”, the former bargaining unit Supervisor job description stated: Provides day to day leadership to the warehouse team including Mail Clerks and Shipper, Receiver and Stockroom Clerk including assigning / reassigning priorities and assignments to meet client needs; Ensures all labour relations matters are escalated to the Manager for resolution. Communication/Interpersonal Skills & Quality of Client/Customer Service 49. The parties agree that the “Communication/Interpersonal Skills & Quality of Client/Customer Service” required for the Lead, Logistics Operation position and the former bargaining unit Supervisor position are similar. Judgement/Problem Solving/Decision Making 50. The Lead, Logistics Operations job description contains three items that were absent from the former bargaining unit Supervisor’s job description: o Ensures prompt addressing of client concerns / complaints and the implementation of the necessary corrective procedures to ensure that no repeat incidences occur (improper filling of orders, incorrect shipping destinations, and reports mailed to incorrect addresses etc.). o Responsible for maintaining and establishing storage and inventory management and scheduling/rescheduling and tracking of shipments of general supplies to meet their testing needs; o Ensures value for service or goods procured by the warehouse and discusses any discrepancy and inefficiency with the Manager. 51. The parties agree that these items fell within the former Supervisor’s Judgment/Problem Solving / Decision Making capacity. 12 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. C. WORK DUTIES – LEAD, LOGISTICS OPERATIONS 20 52. The following responsibilities / duties are set out below:  Delegated Human Resources Authority  Hiring  Direction & Control o Managing Performance o Assigning Staff and Directing the Work o Determining Vacation, Overtime and Premium Pay for Employees o Making Decisions regarding Leaves of Absence  Health & Safety and Other Responsibilities  Discipline  Grievances Delegated Authority Human Resources Authority 53. In accordance with the PHO Delegation of Authority, Human Resources (“HR DOA”), Ms. Sudjito and Mr. Vicente are responsible and accountable for decisions affecting their employees within the terms of the applicable collective agreement, PHO’s human resources policies and relevant legislation.18 54. The parties agree that pursuant to the PHO HR DOA, the unionized supervisor role was not included in the ranks of management. Hiring 55. Ms. Sudjito and Mr. Vicente have the authority to approve and have approved the recruitment of staff positions, both permanent and temporary. Ms. Sudjito and Mr. Vicente 18 See Tab 16: PHO Delegation of Authority, Human Resources dated July 10, 2017. 13 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. have the authority to interview and do interview job applicants. Ms. Sudjito and Mr. Vicente have the authority to make job offers and do make job offers to successful candidates. 56. For example, with respect to a permanent Logistics Clerk position at 661 University Avenue: 21 o on October 4, 2017, Ms. Sudjito, as the “Hiring Manager”, approved the recruitment as being within her Unit’s approved budget;19 o Ms. Sudjito, together with Mr. Vicente, developed interview questions to ask candidates for the position; o on November 23, 2017, Ms. Sudjito interviewed candidate Alex Pellettieri, asking the candidate six questions with a total possible score of 40 marks. Based on his interview answers, Ms. Sudjito scored the candidate as 34.5 marks out of 40. Mr. Vicente was also on the interview panel;20 and o on November 24, 2017, Ms. Sudjito extended an offer of employment to Mr. Pellettieri, asking him to sign back the job offer if he accepted its terms and conditions by November 26, 2017 (which he did).21 57. As another example, Ms. Sudjito determined that she needed to hire an employee on a temporary basis at 661 University Avenue because a full -time employee in her Unit continued to be absent from the workplace on an extended unpaid leave. Accordingly, on November 29, 2017, Ms. Sudjito extended an offer of temporary full-time employment to 19 See Tab 17: Approval Form, October 4, 2017, “Approved by Manuela Sudjito”. 20 See Tab 18: Interview Questions – Logistics Clerk, dated November 23, 2017. 21 See Tab 19: Employment Offer letter dated November 24, 2017. 14 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. Ms. Melissa Scott, asking her to sign back the job offer if she accepted its terms and conditions by December 1, 2017 (which she did).22 58. In February 2018, Ms. Sudjito, again as the “Hiring Manager”, approved an extension of Ms. Scott’s temporary employment. 59. Ms. Sudjito also signed off on revised Logistics Clerk and Mail Room job descriptions in 2017, stating as “Manager”: “I certify that the foregoing is an accurate description of the position[s]”.23 60. Mr. Vicente, as the “Hiring Manager”, also hires for permanent and temporary positions. For example, with respect to a permanent Logistics Clerk position at 81 Resources Road:   22  on October 4, 2017, Mr. Vicente, as the “Hiring Manager”, approved the recruitment as being within his Unit’s approved budget; Mr. Vicente, together with Ms. Sudjito, developed interview questions to ask candidates for the position; on November 23, 2017, Mr. Vicente interviewed candidate Jason Leung, asking the candidate six questions with a total possible score of 40 marks. Based on his interview answers, Mr. Vicente scored the candidate 39 out of 40 marks. Ms. Sudjito was also on the interview panel; on November 24, 2017, Mr. Vicente extended an offer of employment to Mr. Leung, asking him to sign back the job offer if he accepted its terms and conditions by November 26, 2017 (which he did); and Tab 20: Job offer to M. Scott dated November 29, 2017. job descriptions at Tab 3. 22 See 23 See 15 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. Mr. Vicente’s completed the ECO Form (as “Manager”), confirming Mr. Leung into the permanent position dated November 27, 2017 as well as the “Employee Life Cycle Request” form (Mr. Vicente entered as the “Hiring Manager”).24 61. Ms. Sudjito and Mr. Vicente also have the authority to approve and certify bargaining unit employee job descriptions. For example, for the Logistics Clerk position (revised) and the Mail Room Clerk (revised) dated June 30, 2017, Ms. Sudijito, as “Manager Position Title (Lead, Logistics Operations)”, signed “Approval: I certify that the foregoing is an accurate description of the position” for both positions.25 62. The parties agree that former bargaining unit Supervisor was involved in several job competitions for both permanent and temporary positions and, in doing so, developed questions in tandem with management; scored candidates as part of the panel; and formed part of the interview and selection process. 63. The parties agree that former bargaining unit Supervisor never assumed the role of Hiring Manager and did not sign off on job descriptions, as Manager or otherwise. 23 64. The Supervisor did not approve or make offers of employment to successful candidates. Direction and Control 65. In their role, Ms. Sudjito and Mr. Vicente are responsible for and do direct and control the day-to-day activities and working conditions of the employees who report to them. 24 See Tab 21: authorizing hiring for a permanent position dated October 4, 2017; Mr. Vicente’s Interview Questions and scoring of the candidate dated November 23, 2017; Mr. Vicente’s offer of permanent employment to the candidate dated November 27, 2017; ECO form and “Employee Life Cycle Request”. Also see Tab 22: Employment Offer Letter to Pat Porco dated November 24, 2017. 25 DOA, HR at Tab 16; Tab 3. 16 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. Managing Performance 66. Ms. Sudjito and Mr. Vicente set performance standards and conduct performance appraisals. 67. For example, if performance standards are not met in Ms. Sudjito’s determination, she conducts coaching meetings with the employee at issue. On February 3, 2017, Ms. Sudjito met with a Logistics Clerk to review her expectations regarding his waste management duties.26 On December 14, 2017, Ms. Sudjito met with another Logistics Clerk after he received and accepted damages items.27 68. Ms. Sudjito28 and Mr. Vicente29 also conduct formal performance appraisals of their respective reports, determining whether the employee has “achieved” or “not achieved” the PHO’s minimum work performance standards (e.g., “delivering on key responsibilities”, “delivering on other activities that may be assigned”, “attendance and punctuality” and “demonstrating PHO values”). 69. The signatures of Ms. Sudjito30 and Mr. Vicente31 are also required on all Employee “Training/Competency Forms”, as “Managers”, to verify whether or not any employee in training who reports to them is “competent”. 70. Ms. Sudjito and Mr. Vicente decide whether to approve training courses and are authorized to release employees from their duties for up to 3 days for learning and development. For example, Ms. Sudjito and Mr. Vicente approved their respective employee groups for a course, “Transportation of Dangerous Goods: Logistics and Warehouse”, in January 2018. 24 26 See Tab 23: PHO Meeting Record dated Feb 3, 2017. 27 See Tab 24: PHO Meeting Record dated Dec 14, 2017. 28 See Tab 25: three PHO “Performance Discussion Templates – OPSEU”, all signed by Ms. Sudjito as “Manager”. 29 See Tab 26: example “Performance Discussion Template – OPSEU” dated February 22, 2018, signed by Mr. Vicente as “Manager”. 30 See Tab 27: e.g., PHO Training / Competency Form signed by “Manager”, Ms. Sudjito, on January 16, 2018. 31 See Tab 28: example “Training / Competency Form” dated January 30, 2018. 17 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. Assigning Staff and Directing the Work 71. Ms. Sudjito and Mr. Vicente determine the daily duties, responsibilities and time schedules for their reports, including break times and lunch. For example, Mr. Vicente promulgates a “81 [Resources Road] daily duties and responsibilities and time schedule,” including set times for employee breaks and lunch.32 He also publishes schedules, directing employees to perform duties on a rotating basis.33 72. Ms. Sudjito and Mr. Vicente also manage the rotation and transfer of Logistics Clerks between the 661 University Avenue location and the 81 Resources Road location so that staff can gain experience in all of the various tasks and functions.34 73. To initiate these employee changes, Ms. Sudjito and Mr. Vicente complete Employee Change Order (“ECO”) forms as the written authorization necessary to make the changes within PHO. As stated on PHO’s ECO forms, Ms. Sudjito is the “Direct Supervisor” at 661 University Avenue and Mr. Vicente is the “Direct Supervisor” at 81 Resources Road and Ms. Goenadi is their “Department Head”.35 74. Ms. Sudjito and Mr. Vicente are responsible for developing and maintaining various Key Performance Indicators (“KPI”) to ensure the effective and efficiency operations of their respective Operations. 75. Both Ms. Sudjito and Mr. Vicente dedicate a significant portion of their work day to production planning and to the daily reporting of KPI results. For example, Mr. Vicente sets production schedules for his Logistics Operations36 and makes daily productivity reports (e.g., reporting on orders entered, stock received, shipments and kits produced).37 32 See Tab 29: e.g., daily duty schedule for November 20, 2017. 33 See Tab 30: “DynaCare – email and print out of daily manifest” duty rotation. 34 See Tab 31: e.g., email from Mr. Vicente to two Logistics Clerks regarding their rotation schedule dated February 8, 2018. 25 35 See Tab 32: Sample ECO forms, signed by “Manager”, Ms. Sudjito. 36 See Tab 33: e.g., Master schedule for month of Feb 2018; Kit Assembly Production Reporting (Nov 2017). 37 See Tab 34: See daily KPI report summary spreadsheet for March 2018. 18 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. 76. Ms. Sudjito and Mr. Vicente provide direction and leadership in the implementation of new techniques and standards. For example, for the 81 Resources Road Logistics Operations, Mr. Vicente has initiated new processes including new techniques to validate client orders, control inventory (receiving), manage back orders etc.38 77. Ms. Sudjito39 and Mr. Vicente40 set the agenda for and conduct team meetings for their direct reports. As stated by Ms. Sudjito while reserving the meeting date with her team, “please ensure that you prioritize your work” to permit attendance. Determining Vacation, Overtime and Premium Pay for Employees & Making Decisions regarding Leaves of Absence 78. Ms. Sudjito and Mr. Vicente authorize and approve employee attendance and manage vacation and “float day” credit balances for their respective groups. In doing so, Ms. Sudjito41 and Mr. Vicente42 are provided with employee credit balance reports from PHO Payroll. 79. Ms. Sudjito43 and Mr. Vicente44 determine whether or not to approve employee vacation requests. 80. Ms. Sudjito45 and Mr. Vicente46 approve overtime, paid at a premium rate or accrued as banked time, for their reports. 38 See Tab 35: pictures demonstrating new processes. 39 See Tab 36: as an example, “Team Meeting Agenda” for February 1, 2018 and Meeting Minutes re same, including Ms. Sudjito’s determination of rotating schedules for employees between 661 University Avenue and 81 Resources Road. 40 See Tab 37: example Meeting Agenda and Meeting Minutes dated February 5, 2018 by Mr. Vicente. 41 See Tab 38: email from PHO payroll to Ms. Sudjito re “Vacation, float and COC balances as of November 19, 2017” 42 See Tab 39: email from PHO payroll to Mr. Vicente re “Vacation, float and COC balances as of August 27, 2017”. 43 See Tab 40: See “Vacation/Float Request Forms” dated May 4, 2017, July 24, 2017 and August 1, 2017, Part B “To be completed by Manager”, signed by Ms. Sudjito. 44 See Tab 41: See “Vacation/Float Request Forms” dated December 6, 2017 signed by Mr. Vicente. 45 See Tab 42: See “Attendance Records” listing “Premium Hours” and signed by Ms. Sudjito. 46 See Tab 43: See “Attendance Records” listing “Premium Hours” and signed by Mr. Vicente. 26 19 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. 81. Ms. Sudjito and Mr. Vicente are also authorized to approve other Collective Agreement premium payments and allowances including Call Back (Article 18.4), Stand-by time (Article 18.5), On-Call Duty (Article 18.6), Time Credits While Traveling (Article 18.11) as well as to approve a compensating day off in lieu of working on a holiday. 82. Ms. Sudjito and Mr. Vicente are authorized to grant and manage leaves for their groups, including bereavement leaves,47 Personal Leaves,48 Family Medical Leaves,49 leave with or without pay up to 5 days, employee time off work for religious observance, Pregnancy Leaves and Parental Leaves,50 Special Leaves for special or compassionate purposes,51 Jury and Witness Duty leaves52 and Military and Reservist leaves.53 83. Ms. Sudjito and Mr. Vicente are authorized to manage and do manage short term sickness plan (“STSP”) credit usage by their employee groups.54 Health & Safety and Other Responsibilities 84. Ms. Sudjito and Mr. Vicente enter into accommodation plans and return to work (“RTW”) plans with their employees.55 85. In their role, Ms. Sudjito and Mr. Vicente complete and sign off on PHO Laboratory Accident / Incident Reports. For example, Ms. Sudjito investigated injuries in January and in February 2017 and made recommendations to prevent re-occurrences of the incidents or accidents.56 47 Article 15.4 of the Collective Agreement. 48 Article 15.1 of the Collective Agreement. 49 In accordance with the ESA, 2000. 50 Articles 15.6 and 15.7 of the Collective Agreement. 51 Article 15.2 of the Collective Agreement. 52 Article 15.5 of the Collective Agreement. 53 Article 15.8 of the Collective Agreement. 54 Article 16 of the Collective Agreement. 55 See Tab 44: Return to Work plan signed by “Manager”, Ms. Sudjito and dated June 27, 2017. 56 See Tab 45: PHO Laboratory Accident / Incident Reports signed by Ms. Sudjito 20 27 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. 86. While the former bargaining unit Supervisor would have contributed to such reports in his role, his Manager would had to have signed off on any report before it went to PHO’s Safety Office. In contrast, as demonstrated in the reports at Tab 45, Ms. Sudjito signed off on the reports in her own right as a manager. 87. Ms. Sudjito and Mr. Vicente manage and oversee Workplace Safety and Insurance claims related to their respective groups together with PHO’s Health, Safety & Wellness Unit. 88. Ms. Sudjito and Mr. Vicente are also “supervisors” for the purposes of the Ontario Occupational Health and Safety Act (“OHSA”) given that they have “charge of a workplace” (i.e., broad control over the planning of work and how it is carried out) and “authority over a worker” (i.e., can exercise specific powers to ensure a worker’s compliance with directions). As result, they have specific OHSA obligations including the identification of workplace hazards and regarding work refusals. 89. Ms. Sudjito and Mr. Vicente are also tasked with managing privacy breaches, completing the necessary reports (e.g., Part B of the form states that it must “be completed by manager”). For example, see the PHO Privacy Report from February 2018 that Ms. Sudjito became engaged in. Again, as management, Ms. Sudjito and Mr. Vicente are empowered to get to root cause of the problem and can implement effective corrective action.57 Discipline 90. Ms. Sudjito and Ms. Vicente are authorized to issue letters of reprimand (i.e., disciplinary, not simply letters of counsel) and will make effective recommendations concerning the imposition of more severe discipline including suspensions, demotions and dismissal, as applicable. 57 See Tab 46: PHO Privacy Report updated February 8, 2018. 21 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. 91. In dealing with any employee discipline matter, Ms. Sudjito and Mr. Vicente would handle the allegation meeting, the disciplinary meeting, as applicable, and would sign off on all communications to the employee related to the discipline matter. 92. The former bargaining unit Supervisor did not have any disciplinary p owers. 28 Grievances 93. Ms. Sudjito and Mr. Vicente are the management representatives at the “Complaint Stage” (as the Collective Agreement states: “...it is understood that an employee has no grievance until he has first given his or her immediate supervisor the opportunity of adjusting his or her complaint”).58 Ms. Sudjito and Mr. Vicente are also authorized to respond to formal grievances, including hearing the grievance at the “Step 2” level if the grievance involves a working condition. This responsibility includes providing the Union “with a written response to the grievance by the end of the 20th working day following the date of the filing of the grievance” if the Step 2 process does not resolve the grievance. 94. The former bargaining unit Supervisor did not have any involvement in the processing of employee grievances. THE INSTANT GRIEVANCES AT ARBITRATION 95. On July 28, 2016 and February 3, 2017, the Union filed the instant Grievances (OPSEU# 2017-0545-0005) in conjunction with several other grievances. 96. On October 17, 2017, the parties settled the individual matters relating to the layoff and other grievances of an employee, Mr. Thomas Nicholson, pursuant to a Memorandum of Settlement (“MOS”). 97. In the preamble of the MOS, the parties noted: 58 Article 9.4 of the Collective Agreement. 22 Solely and exclusively for the purposes of the arbitration before Arbitrator Fisher in the matter of OPSEU v. PHO, Grievance Nos. 2017-0545-0005 (February 3, 2017) and 2016-0545-0013 (July 28, 2016) [“PHO Inclusion/Exclusion matter”]. The Employer and the Union reserve their respective rights to call viva-voce evidence in this matter. WHEREAS the Grievor filed the above-captioned grievances alleging, among other things, that he had been dealt with contrary to legislation including the Ontario Human Rights Code and the Collective Agreement; WHEREAS reinstatement was a possible outcome of the grievances and the grievor hereby relinquishes his right to reinstatement in consideration for the following terms; WHEREAS the Employer denies that it has violated any of the Grievor’s rights, including any rights under legislation including the Collective Agreement and the Ontario Human Rights Code; WHEREAS, notwithstanding the above, the parties are desirous of resolving all outstanding grievances and differences between the parties; 29 98. Mr. Nicholson signed a full and final release, stating: The Grievor hereby releases and forever discharges the Crown in Right of Ontario and the Employer, its servants, agents and directors of and from all actions, applications, causes of action, grievances, claims, differences, complaints and demands of every nature and kind arising out of, as a result of the grievances and the circumstances giving rise to the grievances, including but not limited to all claims under the Collective Agreement, the Employer’s Workplace Discrimination and Harassment Prevention Policy, the Ontario Human Rights Code, the Public Service of Ontario Act, the Occupational Health and Safety Act, the Labour Relations Act, the Employment Standards Act and the common law. 99. The parties agreed that the central remaining question – whether the Leads, Logistics Operations perform managerial duties and must therefore remain outside of the bargaining unit -- could proceed before Arbitrator Fisher as follows: The Union agrees that, within 30 days from the execution of this agreement, it shall advise the Employer whether it intends to pursue grievances 2016 -020 and 2017-008. These grievances are deemed to be withdrawn if the Union does n ot contact the Employer by that time. Arbitrator Barry Fisher shall be seized with carriage of these grievances should they proceed. 23