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HomeMy WebLinkAbout2018-2112.Chung.22-03-31 Decision Crown Employees Grievance Settlement Board Suite 600 180 Dundas St. West Toronto, Ontario M5G 1Z8 Tel. (416) 326-1388 Commission de règlement des griefs des employés de la Couronne Bureau 600 180, rue Dundas Ouest Toronto (Ontario) M5G 1Z8 Tél. : (416) 326-1388 GSB#2018-2112; 2019-1024; 2019-1025; 2019-2086; 2019-2531; 2020-2684 UNION#2018-0533-0005; 2018-0533-0010; 2019-0533-0007; 2019-0533-0013; 2020-0533-0001; 2021-0533-0002 IN THE MATTER OF AN ARBITRATION Under THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT Before THE GRIEVANCE SETTLEMENT BOARD BETWEEN Ontario Public Service Employees Union (Chung) Union - and - The Crown in Right of Ontario (Ministry of Government and Consumer Services) Employer BEFORE Janice Johnston Arbitrator FOR THE UNION Farnaz Talebpour Ryder Wright Blair & Holmes LLP Counsel FOR THE EMPLOYER Jonathan Rabinovitch Treasury Board Secretariat Legal Services Branch Counsel HEARING February 4, 10, 14 and 17, 2022 - 2 - Decision [1] There are six grievances at issue in this case. They deal with the following issues and read as follows: I. Grievance dated June 21, 2018: “I grieve that the employer has violated my rights with regards to but not restricted to Articles 2, 6, 9 & 8.1.1 of the OPSEU collective agreement.” Settlement desired: “Advancement to an SO7 level position.” II. Grievance dated December 5, 2018: “I grieve that my rights have been violated through articles 2, 3, and 21, as well as any other article, policy or legislation made known in the course of this grievance.” Settlement desired: “Full redress, including the removal of the letter of reprimand on file.” III. Grievance dated April 30, 2019: “I grieve that my rights have been violated through articles 2, 3, and 9, as well as any other article, policy or legislation made known in the course of this grievance.” Settlement desired: “1. Return to work and have equal rights as other staff members in the same unit and approve the accommodation requests by the doctor’s “return-to-work” medical questionnaire requested on Apr 9th. 2. Ensure development work is performed in a healthy working environment during the period of outstanding ongoing grievances. 3. Have access authorizations to all related servers, development, libraries, sources supported within the unit.” IV. Grievance dated October 23, 2019: “I grieve that the employer has violated my rights with regards to but not restricted to articles: Article 2 – Management rights Article 3 – No Discrimination – Employment Equity. Negative comment and option about griever mentioned by griever’s manager within the context of a grievance hearing dated September 11, 2019, at approximately 10:10am.” Settlement desired: “Retraction of comment and opinion plus any other applicable remedies.” V. Grievance dated January 9, 2020: “I grieve that the employer has violated my right with regards to but not restricted to articles: Article 2- Management rights Article 21 – Discipline and Dismissal. Lai Ping’s rights were violated when she was issued a Letter of Reprimand on January 9, 2020.” Settlement desired: “Retraction of Letter of Reprimand, issues to Lai Ping on January 9, 2020 and any other applicable settlement.” VI. Grievance dated February 19, 2021: “I grieve that my rights have been violated through articles 2,3, and 21 as well as any other any other article, policy or legislation made known in the course of this - 3 - grievance. Article 2: No proper workup to dismissal. No appropriately documented trail or advisory to employee. Article 3: Discrimination against the employee. Article 21.1 No just cause for dismissal.” Settlement desired: “Full Redress including a restoration to employment.” [2] The Grievor, Ms. Lai Ping Chung, has also filed an application with the Human Rights Tribunal of Ontario (File No. 2019-37873-I). The application asserts violations of the Human Rights Code that significantly overlap with the above- noted grievances. As such, the HRTO deferred the application pending completion of this GSB proceeding. [3] I heard from three witnesses in this case. Mr. Abraham Esedafe, the Manager of Citizens Services Transformation (“CST”) in the Ministry of Government and Consumer Services (“MGCS”) and Mr. Munish Sabharwal, Manager, Business Solutions, Digital Technology and Innovations Branch, Enterprise Digital Service Integration Division, GSIC. The Grievor testified on behalf of the union. [4] This case has a long history. The first day of hearing was April 1, 2019. The parties attempted to mediate on that day but were unsuccessful. Several other dates were set over the years and attempts were made to resolve the grievances but all proved unsuccessful. Ultimately, the parties concluded that arbitration was necessary. In an attempt to expedite the process, it was agreed that the evidence in chief of the three witnesses would primarily be via will-say with minimal verbal testimony and that cross-examination would be conducted in the normal course. As was noted at the outset, the hearing proceeded via Zoom video conference on February 4, 10, 14 and 17, 2022. [5] The Grievor became employed as a Senior Systems Analyst with MGCS in 1998. In 2001 as a result of a reorganization, the Grievor’s title was changed to Application Analyst/Developer and she held this position until her termination. Mr. Sabharwal was Ms. Chung’s manager from March 2016 until December 2019 when Mr. Esedafe became her manager. Mr. Esedafe was her manager up to her date of termination. [6] I was provided with a copy of the Grievor’s job description which as noted was Application Analyst/Developer. Under the heading Purpose of Position, it states that the position is to, “provide application development, support and maintenance services for a range of the GSC Cluster supported applications.” This means that programming or software coding is an essential and critical part of the job held by the Grievor. The job description also stated that anyone employed in her position should be proficient with Oracle, Java, Microsoft SharePoint, AS400, DB2, .NET - 4 - and Dynamics. Ms. Chung asserted that when she joined the team managed by Mr. Sabharwal, she was told that she would not be assigned any tasks which involved coding. Mr. Sabharwal denied this and pointed out on numerous occasions that coding was the main duty of the position held by the Grievor. [7] The Grievor was terminated on February 11, 2021. She was provided with the following letter of termination: Feb 11, 2021 E-mail & courier physical copy to employee home address Lai Ping Chung Dear Lai Ping, RE: Termination of Employment A meeting was held on Feb 11, 2021 at 1:30 PM with yourself, your Bargaining Unit Representative Kim Bailey, Manager, Abraham Esedafe, and myself. This letter is to confirm that as discussed at the meeting, your employment is terminated effective immediately as we have determined that you are incapable of fulfilling the basic duties of your position. In reviewing the matter and to make this decision, I have considered all of the relevant information available to me, including your job performance, the performance feedback and counseling that has been provided to you (orally and in writing), your years of service, your employment history, and the impact of your unsatisfactory job performance in the workplace. As you are aware, your manager has met with you on numerous occasions to discuss the level of job performance required of an Application Analyst/Developer and to provide you with directions and instructions to help you meet the expected standard of performance. In addition to these meetings, you have also received emails from your manager where you were provided with feedback and guidance concerning expectations and your performance. Your manager has expressed his concern that you are not meeting the job requirements. I have concluded that, despite these measures, you remain unable to meet the performance standards required of an Application Analyst/Developer to the extent that you are incapable of performing the basic requirements of the position. - 5 - I have concluded that despite the assistance and opportunities for improvement that you have been provided, your performance remains unsatisfactory. Accordingly, by the authority delegated to me under Section 44 of the Public Service of Ontario Act, I hereby dismiss you for cause in accordance with section 34 of the Act, effective Feb 11, 2021. You have the right to grieve your dismissal. Please return any MGCS assets in your possession immediately. The personal contents of your workstation will be collected and sent to you at your home address. Sincerely, Bhawnesh Sharma, A/Head, Business Solutions & Operations Branch Government Services Integration Cluster Ministry of Government & Consumer Services 222 Jarvis Street, 5th Floor Toronto, ON M5B 2B8 [8] As is made clear in the letter, the Grievor was terminated as the Employer felt that she was incapable of performing the basic duties of her position. Although the letter references that the Grievor was terminated for cause, in final argument counsel for the Employer characterized her termination as a non-culpable termination. The Grievor disputes that she is incapable of performing the basic duties of her position and attributes her termination to racial and age discrimination. She asserts that harassment by her managers created a poisoned work environment and made it impossible for her to do her job. [9] The Grievor’s will-say and supplemental will-say constitute a very lengthy document. It chronicles events commencing in December 2015 up until her discharge on February 11, 2021. Ms. Chung’s complaints during the early part of this time period involve allegations of unfair treatment, differential treatment and unfairly negative treatment by her manager, Mr. Sabharwal. I am not going to address each and every allegation raised by Ms. Chung in her will-say, as it is extremely detailed, but I will provide sufficient examples to illustrate the type of incidents that the Grievor views as evidence of harassment and discrimination by her managers. In support of her allegations, Ms. Chung refers to, amongst other things, many email exchanges she had with Mr. Sabharwal at various times. I have carefully reviewed these emails and what becomes clear is that what the Grievor considers harassment is simply the efforts of Mr. Sabharwal to manage the Grievor. [10] One of the examples raised by Ms. Chung, which she asserts to be evidence of discriminatory treatment, relates to the decision of Mr. Sabharwal to not allow her - 6 - to participate in the telework program in the summer of 2016. This program permitted employees to work from home three days per week. She provides as support of her allegation an email chain in which she questions the decision. Her tone in the emails is quite aggressive. She says things such as, “I totally disagree with you,” and, “I do not agree with your explanation which is irrelevant with respect to my eligibility as per the program guide.” It is very clear that Ms. Chung wanted to work from home and this theme comes up again later in her employment. [11] Ms. Chung also asserts as evidence of her discriminatory treatment at the hands of Mr. Sabharwal, an incident that occurred around the end of March 2017. At a Business Solution Branch meeting, she asserts that when giving credit for a project and asking staff to stand and receive recognition, that Mr. Sabharwal deliberately left out her name and did not invite her to stand up in front of the audience for recognition, as a contributor to the project. She takes the position that she was excluded discriminatorily and this exclusion constituted a reprisal due to an incident which happened with a client earlier in the month. [12] Mr. Sabharwal admitted that he inadvertently did not call out the Grievor’s name at the meeting and ask that she stand. He indicated that she was seated where he could not see her and that as he had been called upon by his director without any advance notice to recognize people, he simply missed her. He apologized to her afterwards and in fact nominated her to receive an award with the rest of the team. Ms. Chung does not reference in her will-say that she received an apology, nor does she mention that Mr. Sabharwal nominated her for the award. [13] Another example of the discriminatory treatment alleged by Ms. Chung was the fact that after she notified Mr. Sabharwal of her intention to take vacation from April 18, 2017 to April 21, 2017, Mr. Sabharwal informed the team about a 5-day Microservices hands on training at Global Knowledge offices which was scheduled to take place between April 19, 2017 and April 25, 2017. She asserted that as a result, she had to change her vacation plan in order to attend the training. She questioned whether Mr. Sabharwal purposely scheduled the training to subtly exclude her from the training or to cause her inconvenience and the need to adjust her vacation plan. [14] Mr. Sabharwal denied this allegation and stated that it was not true and incorrect. The training proposal came from an outside vendor and the dates selected were based on the availability of the instructor. The timing was outside of his control and it was not his decision. - 7 - [15] Ms. Chung suggests in her will-say that the fact that an individual named Mr. Rajul Bhatnagar was hired by Mr. Sabharwal as a project manager in November 2017 appeared to be a case of discrimination based on age/race. She suggests that she had been communicating to Mr. Sabharwal and another manager, her interest and desire to move to the project management position since she joined Mr. Sabharwal’s unit. She claims that she was disappointed that she was not made aware of the new position within the unit by Mr. Sabharwal who she asserts clearly had the intent to block her career advancement. [16] Mr. Sabharwal denied these allegations and pointed out that the individual in question had been hired through an open competition. Ms. Chung did not apply for the job. He asserted that he had no intention or desire to block the Grievor’s career advancement or the ambitions of anyone else in his unit. [17] Ms. Chung asserts, as an example of age discrimination, that in May 2018 Mr. Sabharwal criticized her for the fact that she was not able to set up a working development environment on her PC (personal computer) in two week’s time. The fact that he expected, based on his experience, that a senior developer/ programmer like Ms. Chung should be able to accomplish this task within one week was cited as an example of discrimination. She felt that he did not give her any support and did not accept her explanations for the barriers, such as insufficient space and slowness on her PC, that she encountered while performing the task. She felt that his remark was demeaning and appeared to be a case of age discrimination. [18] Mr. Sabharwal testified that this situation proved that the Grievor was incapable of performing her job. She cited space/storage issues as the reason she was not able to set up a working development environment on her PC. Any other developer or person at her level who encountered a space issue should be able to resolve it in a few hours. All she needed to do was to delete unwanted files or do a backup. The fact that she was unable to perform such a simple task illustrated and reinforced the position of the Employer that she was not capable of performing her job. [19] As the space issue had not been resolved, in June 2018 Mr. Sabharwal went to the Grievor’s cubicle in what she asserts as an impolite/rude/disrespectful manner. She suggests that he suddenly approached her cubicle and checked the disk space usages on her PC without notifying her in advance. She felt that Mr. Sabharwal did not believe the space issue that she had reported and was attempting to find fault with and to discipline her on the spot for being dishonest, if he could prove that he was right. After seeing the space issue himself, she suggests that Mr. Sabharwal just walked away without saying anything. The - 8 - Grievor felt harassed by Mr. Sabharwal’s invasion of her personal space and privacy. [20] Mr. Sabharwal completely denied the way Ms. Chung characterized this encounter. He denied being rude, impolite or disrespectful. He remembered going to her cubicle and asking her to show him what the storage issue was so that he could perhaps assist her in resolving it. He indicated that he checked the storage/file space issue and told her she simply needed to delete files/folders that she no longer needed to do her job. He denied walking away without saying anything. This incident and the conversation in May were the events that led to the filing of the first grievance on June 21, 2018. It appears that the space issue was eventually resolved by the purchase of a memory stick and the storage of some of Ms. Chung’s files on it. [21] On November 20, 2018, the Grievor received a letter of reprimand for what Mr. Sabharwal alleges was unprofessional/disrespectful conduct and for her failure to follow management direction. As examples of the conduct that gave rise to the reprimand Mr. Sabharwal described that: i. On Oct 3, 2018 I went to Ms. Chung’s desk to discuss a task that I had assigned to her. I had not received regular updates regarding the task. During that conversation, Lai Ping began to raise her voice in an aggressive and disrespectful way towards me in the presence of other colleagues. ii. Ms. Chung repeatedly declined my meeting requests without providing any reason. On August 03, 2018 at 3:58 PM Lai Ping declined a meeting request without providing any reason. At 5:32 PM on that same day she stated to me by email that she had not received any meeting invite. iii. I suspended Ms. Chung’s telework privileges from July 23, 2018 to Aug 20, 2018 as she was not able to complete a certain task despite having had two months to complete it. That task is usually completed by other employees with similar skills and experience in less than one month. Also, providing support to Ms. Chung while she was working remotely was proving to be onerous. She was informed by email dated July 17, 2018 that her telework would be suspended. She was also informed in person on Jul 24, 2018 and an email reminder was also sent on the same day. iv. Despite knowing that her telework privileges were suspended, on Jul 26, 2018 Lai Ping unilaterally and without authorization worked from home. On October 19th, 2018, Lai Ping also worked from home without seeking her manager’s prior approval, despite knowing that such pre-approval is required. - 9 - [22] Ms. Chung has a different view of these events. She suggests that when she attended a meeting with someone from HR and Mr. Sabharwal, he accused her of behaving inappropriately at work and failing to follow direction. She denied all these allegations. With respect to the November 20, 2018 letter of reprimand, the Grievor responded in her will-say as follows: a. I felt I was a victim of workplace harassment, the harasser being my immediate supervisor. Mr. Sabharwal always liked to find fault with me due to his prejudice. b. Under Mr. Sabharwal’s supervision, I felt I was treated as a prisoner in the office. Ms. Manjeet Bhoombla, the branch admin person, who sat next to my desk acted as a spy on behalf of Mr. Sabharwal, as she could easily monitor my work activities and hear my conversations, and gave signal to Mr. Sabharwal who just sat behind my desk in close proximity, separated by the space which occupied another desk plus little room that separated the seats at the two desks. c. Mr. Sabharwal had bad motive as he tried to justify his disciplinary action against me based on a number of isolated events. His action was inappropriate and did not have proper grounds. I felt I was unfairly treated which caused a significant impact to my ongoing health issues and led to my stroke and short term leave. [23] When she received the letter of reprimand, Ms. Chung also asserted that the employer had bad intentions and was trying to build a case to eventually terminate her employment or to discourage her from continuing with her employment by building a toxic workplace environment. She believed they took retaliatory action against her because of the ongoing grievances. [24] On November 12, 2018 her doctor, Dr. Sabanathan, wrote to Mr. Sabharwal outlining that he had advised her to take a leave of absence from work for three (3) months due to stress relating to her work environment. Ms. Chung went on a medical leave on December 3, 2018 and filed the second grievance before me dated December 8, 2018. [25] I would now like to address the allegations raised by Ms. Chung that the Employer failed to accommodate her based on disability. While Ms. Chung was on her medical leave, she alleges that she was periodically disturbed and harassed by management via emails and phone calls. She suggests that Mr. Sabharwal did not show any care and compassion about her health and that all he really cared about was just to get her to complete the health forms. She suggested that this put a lot of stress and pressure on her because Mr. Sabharwal was repeatedly chasing after her. - 10 - [26] Much of the communication between Mr. Sabharwal and Ms. Chung at this time was via email. I have reviewed all of the emails and it is clear from them that Mr. Sabharwal was not harassing the Grievor but merely doing his job and trying to get the necessary documentation for her sick leave from the Grievor. The tone of Mr. Sabharwal’s emails is polite and compassionate. It is very clear from the emails that Ms. Chung wrote in response that she did not understand the accommodation process. [27] In April 2019, Ms. Chung told Mr. Sabharwal that she was ready to return to work. Mr. Sabharwal indicated that as she had been off for a significant period of time, she needed to provide the employer with medical information. When Ms. Chung sought to return to work in April 2019 the employer wrote to her doctor, Dr. Sabanathan on April 8, 2019 requesting information regarding her current medically-based restrictions and limitations to enable them to provide the best workplace accommodation possible. The requested information was in the form of a series of questions for the doctor. I will set out the relevant ones and the answers provided: PLEASE ANSWER THE FOLLOWING QUESTIONS IN AS MUCH DETAILS AS POSSIBLE. Please note that we are not requesting diagnostic information. 1. Dr. Sabanathan, in the medical questionnaire you completed on March 9, 2019, you indicated Ms. Chung was unable to return to work. Is Ms. Chung currently able to return to her duties as an Application Analyst/Developer? - but NOT coding work. Yes  No ______ Date of Return ___________ 2. If the answer to Question 1 is yes, is Ms. Chung able to return on a gradual return to work schedule at this time? Please provide your recommended schedule. The patient & I agree she can work but we would like her to work from home x1 month of regular hours. 3. Please describe the medical restrictions and/or limitations that are impacting Ms. Chung's ability to attend work and/or perform her regular job duties as an application analyst. Miss Chung feels threatened at work and has an ongoing grievance issue she feels insecure doing coding work. 4. Please confirm whether the medical restrictions and/or limitations listed above are temporary or permanent in nature. If temporary, please indicate the expected duration. Temporary - 1 month 5. What is the current status of Ms. Chung’s medical condition(s)? Stable  Improving ______ Deteriorating ___________ Page 3 of 6 - 11 - [28] On April 9, 2019 Ms. Chung returned this completed medical questionnaire to her Employer. After finally providing the medical documentation, which the Employer had not had an opportunity to review, Ms. Chung asserts in an email sent to Mr. Sabharwal dated April 9, 2019 that, “As requested by my doctor for my accommodation, I shall work at home starting tomorrow.” [29] On April 15, 2019 Mr. Sabharwal rejected her request to return to work in accordance with her doctor’s recommended accommodation. On April 15, 2019, Mr. Sabharwal responded by email as follows: Hi Lai Ping, We have reviewed and assessed the doctor's response to the Medical Questionnaire. Based on the information provided there are significant medical restrictions that cannot be accommodated at this time by allowing you to work from home for the next month and not be assigned coding work or perform your regular duties as per your job description, as this is not operationally feasible. At this stage, you are advised to continue to be on a leave of absence due to sickness for another month as your physician has indicated that psychological/cognitive restrictions are temporary and are expected to last one month. We will follow up with another Medical Questionnaire by the end of April, to be completed and returned to the employer and the Disability Accommodation Specialist. To confirm, you are not authorized to work from home until you receive confirmation from the employer in consultation with the Disability Accommodation Specialist once a review of the Medical Questionnaire has been completed. Regards, Munish [30] Ms. Chung alleges that Mr. Sabharwal failed in his duty to accommodate her. She points to the fact that prior to her sick leave absence, Mr. Sabharwal approved all other permanent staff on his team to work at home for two days per week in accordance with the telework program. As she was not offered any similar work accommodation, Ms. Chung asserts that this is a case of disability discrimination. On April 30, 2019 Ms. Chung filed the third grievance before me. [31] It appears that Ms. Chung returned to work in late April or early May 2019. On July 17, 2018 Mr. Sabharwal met with the Grievor in the presence of a union steward - 12 - and Mr. Esedafe. Mr. Sabharwal sent Ms. Chung an email summarizing the conversation. It reads as follows: Hi Lai Ping, I would like to summarize the discussion of our meeting on July 17, 2019, in attendance was you, your union representative, Stephen Rode, Abraham Esedafe Manager and myself. We discussed your recent work performance on ONBIS, challenges and expectations of the duties you are assigned, and clarified the scope of your position and role. We also discussed a recent workplace incident involving misconduct. Work Performance • You provided an update on the tasks you have been working on during the month of June and July 2019. You indicated that you were testing ONBIS SO Account integration, and mentioned that she had limited knowledge of the application. When asked if you had developed a test plan and test cases to guide the plan, you indicated that you had not. Expectations: • Lai Ping to create Test Plan and Test cases to facilitate her testing of ONBIS. By writing the test cases, you will be able to better understand how the system works, as well as ensure better testing. • Lai Ping to provide list of areas where she needs help to fully understand ServiceOntario Account application/system. We (Munish and Lai Ping) will work together and create a plan going forward. I will arrange for resources to help you with these activities. • Lai Ping to make personal effort to learn ONBIS by walking through the system in the test environment. As your Manager and your Union Rep, Stephen Rode, encouraged you to build positive relationship with her colleagues as this will help create an environment for them to share knowledge with you and answer any questions you have. • You also indicated that you needed admin rights to Dev, UAT and production servers/databases. I advised you again that this was beyond the scope of your position requirements, and as such, does not require you to have such access. You were also advised that the entire process of deployment is automated, therefore, admin access is not required. Workplace Conduct Regarding the incident that took place in our team meeting on July 11, 2019, you admitted that your behaviour was inappropriate during this meeting when you made negative and inappropriate comments about your colleagues in a public space. During the meeting, your union - 13 - representative and manager explained to you how engaging in this type of behaviour is negatively impacting your relationship with your colleagues and creating a negative workspace. You agreed, and understood the advice that was provided for your best interest, and agreed to refrain from engaging in the same behaviour in the future. It is my sincere hope that you will take the advice provided to you during this meeting so that you improve your relationship with your peers and your performance in the workplace. As your manager, I am available to discuss any challenges you are experiencing with the work assigned to you as well as any issues you have with your colleagues. If you have any questions, or concerns, please feel free to contact me. Thanks and Regards, Munish [32] Ms. Chung responded to the email. She denied admitting that her behaviour was inappropriate and her response, in part, was as follows: I do not agree with your last comment concerning my behaviour. The group meeting is a public forum where each team member has the opportunity to exchange ideas and views openly on a particular issue. Each individual has his/her own unique personality. I happen to be one who likes to express my opinion and speak out for the best interest of the group such as to save resources within the OPS. [33] Ms. Chung testified that in her view she was further harassed, bullied and discriminated against in the meeting. [34] Mr. Esedafe testified that Ms. Chung struggled for multiple years with job performance prior to her termination. Since 2012, she worked on three of the six teams in her Branch. She reported to four different managers. Despite working on different teams and for different managers, she consistently underperformed and demonstrated that she could not do the work assigned to her. She was demonstrably unable to perform the core duties of her job, notably coding. After Ms. Chung returned to the workplace, the Employer tried to accommodate her and she was generally assigned work that did not require coding. Her assignments entailed setting up RFCs and CRQs, which are documents required to secure approval for software to be changed and installed. This type of work involves the lower skilled non-coding components of a developer’s job. Mr. Esedafe suggested that her previous managers (including Mr. Sabharwal) created work for her to do which otherwise would not have been done because it was not necessary. [35] Mr. Esedafe stressed that coding is the most critical and core part of Ms. Chung’s job description. Her inability to perform coding work caused significant workload - 14 - increases for her colleagues. In fact, some the team had to rely on one or more fee-for-service consultants paid about $750 per day to assist with the extra workload in her unit. By the fall of 2019, Mr. Esedafe testified that it became increasingly untenable for the Grievor to not do any coding, given her position. When her manager, Munish Sabharwal, encouraged her to resume coding, she simply refused, citing the medical note which had been provided in April. [36] In October 2019 the Employer asked Ms. Chung for additional medical information. The following letter was provided by Dr. Showraki. The relevant portions read as follows: I saw the above-named patient in consultation again on November 11, 2019 upon your referral. As you know the patient is a 65 years old married Chinese woman, in IT for Ontario provincial public services, living with her family in Richmond Hill. The patient who was seen and assessed in firs [sic] in January 2016, then twice in June and August of 2018, diagnosed with an adjustment disorder due to work stress and over-demand, and suggested to stay on her already started anti-depressant, Cipralex by you, has referred back. She reported that she has not been taking her cipralex and Quetiapine that was lastly suggested despite still struggling with anxiety, depression and more work stress. She has not yet been granted accommodation per medical recommendation and her job has been given to the younger employees, per her report. The patient also admitted to be anhedonic, lacking motivation and energy. She sleeps with difficulty and she has sleep disturbances, waking up a few times at night so not feeling restful in the morning. She has lost her appetite, eating and some weight. She has developed mild difficulties with her concentration and memory. She revealed feeling of hopelessness, but no suicidal thoughts, intentions or plans. ... In summery this patient with an adjustment disorder from work stress and overload is suggested to start her anti-depressant, Cipralex 10 mg AM again and Quetiapine 25 mg/hs for her insomnia. I have prescribed her one month supply of the above until she refers back to you for refill in a month. I also again recommend to her work not to overload her with difficult work project, specially code works and let her work with less stress for another few more years until her retirement as she is devoted to her work and still she needs to work financially. Thank you for referring this interesting, but unfortunate woman for consultation. Sincerely, - 15 - M. Showraki, M.D., FRCPC [37] This letter was provided to Swey Vishwanath the HR Advisor that Mr. Sabharwal had been working with and obtaining advice from. Mr. Vishwanath in turn forwarded it on November 28, 2019 to Bruce Dust, the Disability Accommodation Specialist (the “DAS”) dealing with Ms. Chung’s case. He responded to Mr. Esedafe by email indicating, “I have had a chance to review this specialist note. Because the specialist (psychiatrist) noted that Lai Ping was (mid November) non- compliant with their prescription medication, my advice is that there is nothing to add with respect to the accommodation plan. Where the physician speaks about letting her work “with less stress,” this is an entirely subjective assessment and outside the scope of health professionals. Are you finding it difficult to accommodate the ‘no coding work’ aspect within her Application Analyst/ Developer position? Would a quick call (approx. 30 minutes) be helpful?” [38] Mr. Esedafe testified that throughout this time, Ms. Chung performed almost no coding or software development, which constitute the core duties of her job. When she was assigned such work, her performance was unsatisfactory resulting in either missed project deliverables or other staff or consultants completing the work. This came at a significant cost, both financially and to team morale. Prior to Mr. Esedafe taking over as Ms. Chung’s manager, Ms. Chung and Mr. Sabharwal met with Mr. Esedafe in attendance to go through her performance development plan. [39] Mr. Esedafe suggested that throughout this meeting, Ms. Chung challenged every line item that Mr. Sabharwal raised regarding her performance plan or her actual performance. Mr. Sabharwal asked Ms. Chung to send him the soft copy of the performance plan and she refused. Mr. Sabharwal therefore typed the performance rating in an email to her, on which he was copied. In the email, Mr. Sabharwal stated that, “I have not received the soft copy of your PDLP after multiple requests” and then provided his feedback which followed up on an in- person meeting from the day prior. His feedback included: • “Results achieved are not indicative of any tangible outcome.” • “Task completion took longer than expected. The task was completed in almost 3 months whereas medium level skilled developer is expected to have a functional development environment in 3-4 weeks.” • “Overall Performance: Below Expectations” • “Lai Ping need to improve her technical skills. Lai Ping should take initiative and help herself by self-learning. Training can be arranged for specific areas as needed.” - 16 - • “Lai Ping should follow management direction and ask for clarification when needed as related to assigned tasks and duties.” [40] Mr. Esedafe pointed out that Ms. Chung then replied to the email by inserting her response in red font. Ultimately, this performance review was never concluded as she refused to cooperate. [41] Mr. Esedafe testified that Ms. Chung had a consistent approach when dealing with performance reviews (both formal and informal). He suggested that for example she: a. Includes work that she did not perform and accomplishments that she did not earn in the PDLP document; b. Argues aggressively with her manager during the reviews, especially when the manager seeks clarification of her work/accomplishments; c. Does not usually concur when her Union representative advises her to be respectful and cooperative. In the performance review meeting in October 2019 (which I attended), Lai Ping did not agree with her Union representative, who appealed to her to be more respectful. Throughout this meeting she challenged every line item in the review that her Manager discussed with her regarding her plan or her actual performance. At the end she did not send the completed review document to the manager; d. Stalemates the performance process to make it incomplete, for example, refusing to sign-off performance plans and performance reviews; e. She usually then follows up with grievances and emails to Assistant Deputy Ministers, Deputy Ministers, Secretary of Cabinet and sometimes the Premier. The contents of the letters/emails are usually unrelated to the performance meeting but rather target her colleagues and the Manager; f. Follows up with unsubstantiated allegations of discrimination. [42] Ms. Chung’s version of the meeting is very different. She alleges that Mr. Sabharwal quickly reviewed her PDLP document but did not recognize and recall some of the tasks that she had accomplished. She felt that his body language reflected his surprise, distrust and denial of her contributions and he did not show any empathy with her as someone going through a difficult period with ongoing mental health issues. She suggests that the review was short as Mr. Sabharwal wanted to hastily finish with her before his departure from the unit. Ms. Chung suggests that there was little discussion during the meeting and that in the end, Mr. Sabharwal did not sign the document. The next day, Mr. Sabharwal gave her a poor rating for her performance. - 17 - [43] Ms. Chung felt that the feedback provided by Mr. Sabharwal was subjective and one-sided as he did not give her any recognition or credit at all. She also noted that there was no indication that Mr. Sabharwal would consider and provide a plan to adjust her work performance expectations in line with her accommodation request. Ms. Chung felt that she was unfairly treated because of Mr. Sabharwal’s prejudice, stereotype and discrimination towards her, as he seemed to be quite determined to build up the grounds and set the stage for her job dismissal with just cause. [44] In her will-say, Ms. Chung describes her communication style as follows: My style of communication may be considered as always assertive because I spoke up for myself. During the reviews, I stood up for my beliefs, values and needs. I needed to defend my performance, as I was repeatedly under attack by Mr. Sabharwal who tried to lower/reduce and discredited my efforts and achievements. I would speak out if I had concerns instead of staying passive. Due to my mental health issue, it might be possible that I could not control my emotion if I were aggressively attacked by others. This would give Mr. Sabharwal the excuse to claim that I do not show respect to others from my psychological and mental reaction. I always respect others, but if it is the person’s intention to demean or harass me, I would not bend down but would fight back. [45] It was around this time that Ms. Chung filed the fourth grievance before me. On December 13, 2019, the Grievor was issued a written reprimand. It reads as follows: December 13, 2019 Lai Ping Chung Dear Lai Ping, RE: Letter of Reprimand This letter is a follow-up to the meeting held on Monday November 19, 2019, and your follow up emails dated November 19, 2019, where I met with you, your Union Representatives Kim Bailey and Steven Rode, and Swey Vishwanath, Human Resources Advisor, to discuss your inappropriate behaviour and failure to follow direction. Specifically, the meeting was to discuss the following allegations: - 18 - 1. You refused to follow my directions as it related to the work assigned to you; 2. You failed to follow my directions as it related to the unit's telework guidelines during week of Oct 14th - Oct 18th , 2019; 3. You failed to follow my direction to maintain a professional, positive and respectful behaviour towards others in the workplace; i. On October 23, 2019, you questioned the branch admin in the presence of the employee who you were seeking information about multiple machines stored at their desk. Your tone and behavior was aggressive and unprofessional. ii. On July 17, 2019, you were counseled in a meeting with me regarding similar misconduct/inappropriate behaviour during a team meeting (July 11, 2019), when you made comments questioning management's authority regarding the same employee in question; iii. You have previously received a letter of reprimand dated November 20, 2018 that counselled you on your disrespectful/unprofessional conduct and failing to follow management's direction. In response to failing to follow my directions as it related to the work assigned to you, you explained that there are ongoing medical concerns that are preventing you from completing the assigned coding tasks and shared with HR and myself medical information that speaks to your inability to complete the tasks involving coding. As such, I have reviewed this information and will continue to work with you and provide you with an accommodation as necessary and in accordance with the Disability Accommodation Policy. It is my expectation that you continue to work in a cooperative manner with me regarding any requests for clarification on medical information, accommodation and comply with directions provided to you regarding your work assignments. In regard to your failing to follow my directions as it related to the unit's telework guidelines during the week of October 14 - October 18, 2019, you explained that your request to switch your telework day was due to a scheduled medical appointment to complete a medical questionnaire that the Employer had requested of you. At the time you made your request, I agreed to you switching your telework day and had asked you to advise me an alternate day during the week that you would be able to attend the office instead. You responded to me in an email stating that - 19 - you did not believe you should compensate for switching the telework day. As you are aware, all employees in the unit are allowed two (2) telework days during the week. You indicated that you had worked on November 7, 2019 which was your regular telework day to make up for the time but failed to communicate or notify me that you were in the office that day. I explained that this was unacceptable as you cannot decide for yourself when you should or should not work from the office as you are required to make these arrangements with me in advance and with my approval as your manager. In regard to your behaviour towards your colleagues in the workplace, you explained that you were simply asking the branch admin a question about why there were several pieces of equipment stored at specific employee's desk, the same employee that you have previously raised questions regarding their qualifications to be employed with the OPS, inquiring about confidential details about their employment, including questioning management authority to hire this same individual. You have been previously counselled to cease and desist your behaviour targeting this specific employee. You are reminded that you were provided with a letter of reprimand dated November 20, 2018 regarding inappropriate behaviour and misconduct in the workplace. I have reviewed the information and materials you shared with me in response to the above-noted allegations at the November 19, 2019 meeting and have determined that as an employee of the Ministry of Government and Consumer Services, your conduct as it relates to allegation two and three were inappropriate and cannot be tolerated. Having given full consideration of the facts, your employment history, all other circumstances and mitigating factors, I have concluded that your actions are just cause for discipline. It is my decision to issue you this formal letter of reprimand. As an Application Analyst/Developer and a long-term employee in the OPS, we rely on you to be a positive brand ambassador and role model within the Delivery Citizen Services Transformation Unit, Digital Technology & Innovation Branch, Enterprise Digital Service Integration Division, Ministry of Government and Consumer Services. This requires that you demonstrate consistent professional and respectful conduct in the following areas: • Acceptance and completion of assignments, as directed by your manager. • Courteous, respectful treatment of colleagues and management. • Clear communication and cooperation with your colleagues and management. • Report to work on a regular basis at your office location. - 20 - • Should you require planned time off or work from home, prior approval or at least 24 hour prior notification is to be provided to me, as your manager. In future, it is my expectation that you will be respectful in the workplace and demonstrate immediate improvement in your professional conduct by interacting in a positive manner with colleagues. It is also my expectation that you will follow direction and ask for clarification, when needed and in order to complete tasks as assigned. It is also my expectation that you will follow the unit's telework guidelines and any changes to your schedules should be discussed in advance with your manager, and be carried out upon receiving explicit written approval. Please be advised that any further misconduct may result in further disciplinary action up to and including dismissal. A copy of this letter will be placed on your corporate personnel file. Please also be advised that you have the right to grieve this decision in accordance with the terms and conditions of your Collective Agreement. Sincerely, Munish Sabharwal Manager, Digital Technology and Innovation Branch Enterprise Digital Service Integration Division cc: Corporate File [46] On January 9, 2020 the Grievor filed the fifth grievance which is before me with regard to this letter of reprimand. [47] In December 2019, Mr. Sabharwal left the unit and moved to the Ministry of the Solicitor General. As noted, Mr. Esedafe took over as manager. [48] After meeting with the DAS with regard to Dr. Showraki’s letter dated November 11, 2019 Mr. Esedafe wrote the following email on February 13, 2020 summarizing the outcome of the meeting: NOTES AND PROPOSAL 1.Coding is an essential part of Ms. Chung’s Application Analyst/Developer position. Currently, all OPSEU positions in Ms Chung’s department are vacant and work continues to pile up and priorities are being deferred due to a lack of resources. 2.DAS confirmed that OPS staff are required to perform the work they are employed to as per the job description defined for the position within department that the staff works. - 21 - 3.DAS confirmed that OPS is not obliged to provide medical accommodation to staff to exempt them from performing essential duties, e.g. coding in the case of Ms Chung 4.A review of Ms. Chung’s note (psychiatric specialist) by DAS revealed that the psychiatrist noted that Ms Chung was (mid November) non- compliant with her prescription medication, so the DAS advised that: 5.There is nothing to add with respect to the accommodation plan. Where the physician speaks about letting Ms. Chung work “with less stress”, this is an entirely subjective assessment and outside the scope of health professionals. [Also, there is stress inherent in work, otherwise it would be a hobby.] 6.Ms. Chung needs to comply with her treatment plan by working closely with her doctor (psychiatric specialist) ... Previous Temporary Medical Accommodation Strategy OPS has provided temporary medical accommodation to Ms. Chung in most of 2019 by exempting her from coding duties, but this is not sustainable in 2020 due to a backlog of coding work. Prior to the medical report of November 11, 2019 by her psychiatrist, Ms. Chung has benefitted from: • OPS work accommodation – Temporary medical accommodation was granted to Ms. Chung and a performance plan created. Nonetheless, the performance review between the manager and Ms. Chung based on the accommodated work was stalemated as Ms. Chung vigorously contested the review of her performance by her manager. • Sick leave taken by Ms. Chung as per her STSP Proposed Final Medical Accommodation Strategy OPS is committed to treating staff compassionately, so it will extend Ms. Chung three additional months of temporary medical accommodation from March 1, 2020 to May 30, 2020 so that Ms. Chung can: 1. Work with her medical specialist to ensure compliance with her medical treatment plan while doing one or both of the following: 2. Refresh her coding skills to gain more coding proficiency during this period by attending coding technical training in coding programs sponsored by OPS in an Ontario public college 3. Take sick leave to enable her medical specialists to monitor her treatment compliance through more frequent medical monitoring by her medical professionals. 4. Based on the medical recommendations after May 30, 2020, OPS will evaluate the next steps for Ms. Chung. - 22 - [49] It appears that before the Medical Accommodation Strategy could be implemented COVID-19 intervened. On March 13, 2020 Mr. Steven Davidson, Secretary of the Cabinet, sent out a memo to all staff concerning COVID-19 with the recommendation that staff were to work remotely beginning March 16, 2020 through April 3, 2020 where operationally feasible. Ms. Chung therefore commenced working from home in March 2020 and did so until her termination on February 11, 2021. She worked from home after March 2020 and never came back to the office. Mr. Esedafe testified that he stopped assigning her work because it just wasn't worth the effort given that all efforts at performance management had no impact. Eventually the growing workload of the team, her lack of output and performance and the impact that this had on team morale and her managers made continued employment untenable. Ms. Chung was terminated on February 11, 2021. The sixth grievance before me pertains to the termination of Ms. Chung. [50] Up to and including the arbitration of this matter, Ms. Chung forcefully denies any inappropriate conduct in the workplace on her part. For example, when Mr. Sabharwal asserts that she, “raised her voice in an aggressive and disrespectful way towards me in the presence of others” Ms. Chung portrays her conduct as, “Mr. Sabharwal micromanaged and harassed me. I did not recall there were other colleagues present. I work for OPS for about 28 years, I am always respectful in the work environment, and I am not afraid to stand up and speak out. At the time, I had ongoing mental health issues, and was under a lot of stress at work. I might have spoken loud but I do not agree that my tone was aggressive.” [51] When the Employer asserts that Ms. Chung failed to perform work in a timely fashion her response is: I do not agree with the comments related to the longer task completion. For instance, if the person did not have any exposure to the particular set up beforehand, you would still need to rely on and follow the procedures in the related document provided to you. This has nothing to do with skill and experience. If the documentation provided were inaccurate and/or incomplete, then you might get stuck somewhere along the line and have no idea how to overcome this roadblock. This was what I had experienced. If I had received the correct instructions and everything went smoothly, I would expect that this might just be a few hours or a day’s job, depending on the space requirements and the actual installation run. I felt that Mr. Sabharwal had bad motive to make up a normal task completion time of about a month to mislead others that this type of work still requires fair amount of effort so he could not afford to direct an expert person to provide timely assistance as this - 23 - person had other tasks occupying their time. I was also faced with the environmental issue with my laptop not having disk space and performance slowness issues. These roadblocks needed to be addressed immediately in order to perform the actual development. Mr. Sabharwal had no intention to help me setup my computer and wanted to make me fail rather than helping me overcome these barriers in a timely manner. [52] Ms. Chung continually refers to the space issue on her computer as one of the main excuses for not completing tasks. [53] There is one final issue I must address. Ms. Chung in her will-say asserts: Through the years with OPS, I have observed the formation of a South Asian network which has diffused its people across the ministries of the Ontario government to expand and strengthen its power and influence in the workplace. Because of their ethnicity and cultural background, the South Asians work in unity and help one another within their own races. Once a South Asian manager gets a foothold in the company, he or she often makes an effort deliberately to provide help and support to a “fellow” in the areas of hiring, promotion and work arrangement. Of course, this might involve more than one members of the network that pull the strings behind the scenes as inconspicuously as possible in order to achieve its goals. This has led to a growing trend in our office environment which negatively creates potential bias and systemic barriers in recruitment, hiring and promotion. The encouragement of such practice would debase the OPS policy of equity which stresses on fairness in making sure everyone has what they need to succeed and removing barriers that disadvantage some groups over others. I have observed and believed that Mr. Sabharwal belongs to this South Asian network which would back him up against me. [54] Both Mr. Sabharwal and Mr. Esedafe strongly disagreed with this assertion. In Mr. Esedafe’s will-say he states: I understand that the Lai Ping considers herself to be a victim of Anti- Asian discrimination. I consider this allegation to be completely without merit. Firstly, the Application Development staff in most of the teams that she has worked for in the past decade is comprised of staff who are approximately 75% East Asian (e.g. Chinese, Vietnamese, Korean). As far as I know, none of her East Asian colleagues have complained of any anti-Asian discrimination. In fact, most of them have had upward progressive careers within and outside her Branch. I have never seen any behaviour that can in any way be construed as discriminatory towards Lai Ping. From what I have seen and based on conversations - 24 - I’ve had with her previous managers, none of the performance management has been in any way motivated by any prohibited ground of the Human Rights Code, including ethnic origin and disability. All of her managers, including myself, have received and continue to receive training in workplace discrimination, harassment, and maintaining respectful workplaces. [55] In his oral testimony, Mr. Esedafe stressed that the Ontario Public Service (OPS) culture does not tolerate discrimination or harassment. It is very inclusive and those who receive promotions do so based on merit. Mr. Esedafe disagreed completely with the Grievor’s suggestion that he had discriminated against her based on her age. He stated that the older folks are “our crown jewels” and are treasured and respected for their wealth of experience and knowledge. [56] Mr. Sabharwal testified that he has never discriminated against any employee or team members. He suggested that he is inclusive, open minded and always strives to create a safe environment for his team members. His team consisted of people from various ethnicities and backgrounds. He recruited people from all backgrounds and had a great deal of diversity on his team. The Grievor is East Asian and approximately fifty percent of the staff are also East Asian. No one has ever complained of discrimination and in fact most have had successful careers and promotions because of their excellent performance. [57] Mr. Sabharwal described Ms. Chung’s allegations as totally false, baseless and incorrect. As a manager he strives to follow principles of equality and equal opportunity for everyone. He adheres to the OPS policies and culture of inclusiveness. He stated emphatically that he treats people based on merit regardless of age or ethnicity. [58] Mr. Esedafe stated in his will-say that in his view the employment relationship has reached a point of complete breakdown and stated with absolute certainty that it is beyond repair. The Grievor’s long and demonstrated history of underperformance has had a genuine impact on the Branch. She occupied an important role which was meant to do important technical work. That fact that she could not do the work had a negative impact on her colleagues and her successive managers. Ms. Chung has been unable to contribute any added value to the workplace. She cannot do the basic parts of her job. In addition, she is unable to get along with her managers or her colleagues. He suggested that were Ms. Chung to return to the workplace, it would result in a steep decline in morale and productivity among the unit. He asserted that he was highly confident that it would result in multiple current staff leaving the unit. If Ms. Chung returned to work, it would seriously harm the business unit and the Ministry. - 25 - [59] In his oral testimony, Mr. Esedafe stressed that the work of the unit is very team based and that trust amongst the team is crucial. He felt that he could not depend on the Grievor to perform her work. When she failed to do her job, it resulted in timelines not being met and others on the team having to do her work. He characterized attempting to manage the Grievor as “exhausting and draining.” She continually refused to do coding work and claimed that it was too stressful. She would never admit that she could not perform coding work so was never willing to attempt to learn how to do it. In one case she felt that she knew more than the team lead she was working with and the individual left as he felt she was bullying him. She was very uncooperative, disrespectful and would not listen to any advice. Were the Grievor to be reinstated to the unit, Mr. Esedafe felt that other staff would also leave. Given the shortage of Application Analyst/Developers it would be easy for them to find work alternative work within the OPS. [60] Mr. Sabharwal also testified that in his view the employment relationship with Ms. Chung had completely broken down and he too stated with absolute certainty that it was beyond repair. Despite attempting to work with her and help her to perform her work the Grievor was incapable of adjusting her behaviour in the workplace. She was rude, disruptive, disrespectful to co-workers and managers and constantly made inappropriate comments in team meetings and in the one-on-one meetings he had with her. Her coworkers continually complained about her behaviour and the negative and poisonous work environment she created. They did not trust her and felt that her refusal to do her job meant that the team was continually short one member. Mr. Sabharwal testified that Ms. Chung refused to accept any criticism or change her behaviour. She was insubordinate, uncooperative, confrontational, aggressive and often even refused to meet with management. [61] The Grievor both in her will-say and evidence indicated that she was respectful of her coworkers and worked well with them. She testified that she had a good relationship with her coworkers. She claimed to be unaware of any problems or issues and maintained that she was not aware of any complaints from coworkers. She testified that she was “very surprised” to hear about this. She did not recall ever discussing these issues in her one on one meetings with Mr. Sabharwal. She also testified that she had forty years of experience and picked up knowledge very fast. She suggested that she was not offered training as Mr. Sabharwal did not want her to have a high profile and develop knowledge as he did not want her to get ahead of other team members and do a successful job. Ms. Chung asserted that Mr. Sabharwal did not mentor her but that she did not want to bring it up as he would then do negative things to her and tell people not to help her. She felt that - 26 - Mr. Sabharwal did not have the same level of technical knowledge that she did and did not know or follow OPS policies. Employer Submissions [62] Counsel for the Employer started his submissions with a summary of the evidence given in this case. I am not going to repeat most of it as I have already referenced much of it. However, counsel did ask that I draw certain conclusions from the evidence. He suggested that the inability and refusal of Ms. Chung to perform software coding, an essential and critical part of her job was not related to any medical condition. The medical documentation provided appears to simply state that she should not perform coding work. This restriction is not related to any medical condition other than that she found it stressful. The inability and refusal to code was clearly coming from the Grievor. [63] Employer counsel suggested that Mr. Esedafe, when addressing the Grievor’s allegations of discrimination, spoke as a visible minority, spoke from the heart and spoke as someone who understands discrimination – whether systemic or targeted to an individual. He made it clear that the folks who were promoted in Mr. Sabharwal’s team were Chinese. Counsel pointed out that it didn’t matter who the Grievor reported to, it was always the same allegations and alleged treatment. When she claims a poisoned relationship with all her managers, it is important to note that she is the common element. [64] When referencing the testimony of Mr. Sabharwal, counsel asked that I find him to be an even keeled, soft spoken, very genuine person who was always ready to help and ready to mentor. He was willing to help staff and let staff grow and he promoted staff that were competent. Mr. Sabharwal was a very patient leader who was committed to helping the Grievor succeed. Mr. Sabharwal was a diligent and attentive manager, who did his best in the face of very challenging circumstances. The same can be said for the Grievor’s prior manager, Anthony Zoutman, and her subsequent manager, Mr. Esedafe. Mr. Sabharwal was extensively cross- examined and he had complete answers for every question and thoroughly disagreed with the Grievor’s explanations and excuses. Counsel suggested that Ms. Chung’s excuses do not hold any water and her allegations are without any merit whatsoever. As a matter of credibility, he suggested that I should prefer the evidence given by Mr. Sabharwal and Mr. Esedafe over that given by the Grievor. [65] Employer counsel suggested that based on the evidence given by the Grievor, it is clear that she has no insight into her own behaviour in the workplace nor on her performance. She views her behaviour through rose-tinted glasses whereby everything was fine and everyone got along. That is simply not true and counsel - 27 - urged me to prefer and accept the testimony of Mr. Sabharwal and Mr. Esedafe. With the Grievor, everything is someone else’s fault, her managers are incompetent and her colleagues don’t know what they are doing. In her will-say she alleges that various emails sent to her by Mr. Sabharwal constitute harassment. The opposite is true. Mr. Sabharwal’s emails are calm and professional and respectful. Counsel referenced a number of specific emails and asked that I review these emails. When I do so, he suggested that I will find that not only do these emails not constitute harassment by any measure, they actually cast Mr. Sabharwal in a good light as a manager doing his best to provide guidance and manage the office effectively. [66] In Ms. Chung’s will-say and in her oral evidence, she raised allegations about an alleged South Asian network and suggested that she thinks Mr. Sabharwal is racist and that he “takes care of his people” more than others. Counsel pointed out that in cross, he asked the Grievor whether, after hearing Mr. Sabharwal’s and Mr. Esedafe’s testimony denying discrimination, her feelings had changed in any way. She said no and reiterated that she feels that her South Asian managers don’t respect her. Counsel stressed that I should not put someone back who firmly believes – despite the lack of any evidence – that the South Asians in her workplace are racist. It will poison the workplace to put her back. Ms. Chung has not changed her behaviour and she is incapable of changing her behaviour. Her evidence makes it clear that she still feels victimized and still feels that South Asians are untrustworthy and out to get her. [67] Turning to the jurisprudence, counsel referred first to Ontario Public Service Employees Union (Mohamed) v Ontario (Attorney General), 2021 CanLII 127098 (ON GSB) and Ontario Public Service Employees Union (Solomon Smith et al) v Ontario (Children, Community and Social Services), 2019 CanLII 126475 (ON GSB) both of which speak to the definition of harassment in the workplace. I will come back to these decisions later as I agree they provide a helpful analysis. By the standard articulated in these cases counsel argued that the conduct complained of by the Grievor does not constitute harassment. [68] In counsel for the Employer’s opinion, the test for a non-culpable termination has been satisfied. Therefore, the termination grievance should be dismissed. In the alternative, counsel asked that should I uphold the termination grievance, I should conclude that the only appropriate remedy in this case is damages in lieu. This is not a case where the Grievor should be reinstated to her position. He pointed out that it was management’s evidence that the employment relationship is beyond repair. - 28 - [69] Counsel suggested that I heard extensive evidence from Mr. Sabharwal and Mr. Esedafe about the fact that the employment relationship is beyond repair and their evidence was credible, consistent and persuasive. The Grievor refused to accept the decisions of management. She was disruptive, insubordinate, confrontational, not trusted by her managers to do her job, unable to get along with colleagues, managers, or clients. And importantly she is incapable of adjusting her behaviour to permit the continuation of the employment relationship as nothing is ever her fault. In counsel’s view, her reinstatement would cause significant problems in the workplace. [70] In support of this position counsel referred to: Alberta Union of Provincial Employees v. Lethbridge Community College, 2004 SCC 28 (CanLII), [2004] 1 SCR 727; Ontario Liquor Boards Employees' Union (Massa) v. Ontario (Liquor Control Board of Ontario), 2000 CanLII 20493 (ON GSB); Ontario Public Service Employees Union (Massa)v. Ontario (Liquor Control Board of Ontario), 2000 CanLII 20494 (ON GSB); Labour Community Services of Metropolitan Toronto Inc. v United Steelworkers, Local 7536, 2020 CanLII 88997 (ON LA); Canadian Union of Public Employees Local 1487 v The Scarborough Hospital (Meyer grievance) 2013 CanLII 16383 (ON LA); and Custom Control Panels Inc. v The Communications, Energy and Paperworkers Union of Canada (C.E.P.), LOCAL 546 2013 CanLII 41906 (ON LA). [71] In conclusion, Employer counsel asked that I dismiss all of the grievances before me and find that the test for a non-culpable termination has been satisfied. In the alternative, counsel requested that I conclude that damages in lieu of reinstatement is the appropriate remedy in this case. He then asked what should the damages look like? The cases often speak to the Grievor taking, in effect, an early retirement and compensation is assessed on that basis. Arbitrators often award compensation on the basis of one month’s wages for every year of seniority, together with a 15% payment for loss of fringe benefits. Were I to do that in this case, I would arrive at a number that is very significant. [72] In this case, the Grievor has stated her intention to retire and she currently qualifies based on her age and years of service for an unreduced pension. This distinguishes the situation before me from those where damages are assessed based on an “early retirement” or the fact that the employee will be receiving a “reduced pension.” Neither are true in our case. Counsel suggested that an appropriate damages award would be to order the Employer to pay her twelve months salary at her base rate, plus an award of damages up to fifty thousand dollars. Union Submissions - 29 - [73] Counsel for the Union also provided me with a summary of the evidence given by the Grievor in this in this case, which in counsel’s view, supports a finding that all of her grievances should be upheld. Again, I am not going to repeat most of it as I have already referenced much of it earlier in this award. [74] Counsel suggested that the Employer’s decision to terminate the Grievor was tainted by reprisal in relation to the Grievor’s prior grievances and Human Rights Tribunal of Ontario (“HRTO”) Application. On this basis alone, the termination should be set aside in its entirety and the Grievor should be paid general compensatory damages for the Employer’s violations of her rights. This case is about an Employer, that could not, and chose not to tolerate the fact that the Grievor sought to vindicate and enforce her rights under the Collective Agreement and the Human Rights Code. [75] The Employer has attempted to paint the actions of Mr. Esedafe, when he became the Grievor’s interim manager, as fair. This is inaccurate and unfair. It is clear that the Employer was fed up with the Grievor and unable to accept any challenges to their managerial authority, including the Grievor’s efforts to vindicate and exercise her rights. [76] This is a termination case. The Employer and management had obligations to the Grievor in relation to disciplinary procedures it had to follow, including giving the Grievor sufficient warning that her performance was not acceptable and the consequences that may flow, as well as the benefits of progressive discipline. Instead, Mr. Esedafe and the Employer abused their managerial authority and terminated the Grievor without just and sufficient cause and because she had exercised her rights under the Collective Agreement and the Human Rights Code. [77] Union counsel asserted that the Employer has also not satisfied the test for non- culpable termination in this case. She referred to Maritime Telegraph & Telephone Co., Ltd. and International Brotherhood of Electrical Workers, Local 1030 (Cotter decision) (1984) 16 L.A.C. (3d) 318 (“the Maritime Telegraph Case”) at paragraph 47, which outlines the elements which the Employer must satisfy before it may legitimately terminate an employee for non-culpable inability to perform the job. These elements are: 1. Has the employer identified in objective terms the nature of the work to be performed and the standard expected?; 2. Has the employer established that the grievor was made aware of the standard?; 3. Has the employer established that the grievor’s work performance was below that standard?; - 30 - 4. Did the employer provide supervisory direction to the employee to assist him to achieve the standard?; 5. Did the employer take reasonable steps to move the employee into other work within the bargaining unit that was or might have been within his qualifications and competence?; 6. Did the employer bring home to the grievor the fact that the performance was unsatisfactory and that dismissal might result from a continued failure or inability to meet the standard?; 7. Did the employer afford the grievor a proper opportunity to challenge its assessment of his work by grievance?; 8. Does the evidence support the inference of a continuing inability on the part of the employee to meet the standard? [78] This approach was endorsed by the Grievance Settlement Board and adopted by Vice-Chair Mikus in Ontario Public Service Employees Union (Ng) v Ontario (Government Services), 2012 CanLII 6214 (ON GSB) at paragraph 94. Counsel argued that the Employer has failed to establish the 5th, 6th and 8th elements of this test and as result, the Grievor was inappropriately terminated from her position. [79] Regarding the 5th element, the Union submits that the Employer did not take reasonable steps to move the employee into other work. Mr. Sabharwal testified that he suggested QA work to the Grievor which she rejected. In her testimony, the Grievor explained that she was not aware of Mr. Sabharwal’s reasoning and based on her experience on the team, she felt that this was Mr. Sabharwal’s way of pushing her out of his team so he did not have to deal with her again. It is the Grievor’s position that Mr. Sabharwal never properly explained why he wanted her to take the position or why she was not meeting the requirements of the team. [80] Regarding the 6th element, it is the Grievor’s position that the Employer and her manager failed to bring home the fact that her performance was unsatisfactory and that dismissal might result from it. The Grievor testified that she was unaware of any complaints from her co-workers and that the senior leads were happy with the proofs she was providing of her coding work. [81] With respect to the 8th element, Counsel referred to the comment by the Adjudicator in Maritime Telegraph Case at paragraph 56 where it was noted that: “… cases involving non-culpable termination require arbitrators to assess the prospect of rehabilitation of the terminated employee. In particular this requires an assessment of whether there is a reasonable possibility that the employee can, in the foreseeable future, achieve a satisfactory performance level.” - 31 - [82] Union counsel suggested that the Employer’s evidence does not support the inference of a continuing inability of the Grievor to meet the required standard. As she testified to, the Grievor would be willing to try coding again if accommodation could be implemented for her. The Grievor’s will-say also provided evidence of the technological and access issues that she experienced in her role that prevented her from completing the required tasks. If the Employer provides the Grievor with the proper support as she requested, it is her position that she would be able to meet the standards of the role. [83] Counsel for the Union argued that the Employer has failed to establish that the employment relationship is not viable. She suggested that should I find that there was not just case for termination, the usual remedy of reinstatement should follow. In her view, only in “exceptional circumstances” should damages in lieu of reinstatement be ordered: A.U.P.E. v. Lethbridge Community College, 2004 SCC 28, at paras. 50-57. Damages in lieu of reinstatement, “is not and ought not to be a proxy for progressive discipline. It does not and should not provide an opportunity for an employer to, effectively, sever the employment relationship and to deny an essential collective bargaining remedy in circumstances where the application of progressive discipline may have been less than complete.” See PEGO v. Ontario (Shannon) (2005), 143 L.A.C. (4th) 193 (Herlich), at paragraph 122 (“the PEGO Case”) . [84] It is the Grievor’s position through her evidence that while she had a history of disagreeing with Mr. Sabharwal and asserting her rights, she also ultimately complied with management’s directions and did her work to the best of her ability. In cross-examination of the Grievor, the Employer tried to point to the Grievor’s prejudice to those of South Asian race in support of its arguments that the employment relationship is not viable. Those arguments are without merit. The Grievor in her oral testimony clearly stated that her issues were with Mr. Sabharwal and his treatment of her. She testified that she likes her co-workers, believes she can work well with them and would not have a problem reporting to anyone of South Asian race going forward. [85] In any case where a terminated employee is ordered reinstated through an arbitrator’s order, it may of course be “uncomfortable” for the manager, the team and that employee to work together after the employee is reinstated. Notwithstanding this, the overwhelming arbitral consensus is that reinstatement is the usual remedy where an arbitrator determines there was not sufficient cause to warrant termination. Arbitrators have held that, “any mere concern about possible friction in the workplace should not be sufficient to warrant denying reinstatement,” (see the PEGO Case at paragraph 117), and that reinstatement should follow notwithstanding the fact that arbitration proceedings may have, “generated a - 32 - certain amount of friction” in the relationship (See in this regard Tenant Hotline (1983), 10 L.A.C. (3d) 130 (MacDowell), at paragraph 32). [86] In conclusion, Union counsel asserted that the Grievor must not be deprived of the same protections as any other employee in terms of having the right to adequate disciplinary warnings, as well as the benefit of progressive discipline and the opportunity to modify or correct alleged problematic behaviour. [87] The Grievor has filed grievances in which she asserts harassment, bullying and discrimination on the basis of her race and age. These grievances and the arbitration process have had a very real impact on the Grievor emotionally, mentally and financially. The cumulative impacts of management’s actions in relation to the Grievor as outlined by her oral evidence and in the Grievor’s will- says have had a tremendous negative impact on the Grievor. The employer’s actions have poisoned the Grievor’s work environment and as a result, her work record has been tarnished, her achievements belittled and she has been treated like a burden by her team and managers. Since joining Mr. Sabharwal’s team in 2016, the Grievor has felt under attack by her manager. The Grievor takes great pride in her work and is very serious when it comes to work. She strives to do her best work but the lack of support and the bullying, harassment and discrimination she experienced as a result of her race and age at the hands of the Employer created a poisonous work environment for the Grievor and made it very difficult for her to do her role properly. Mr. Sabharwal’s treatment of the Grievor worsened her ongoing health issues, causing her to go on medical leave. In support of her argument that the Grievor was harassed and discriminated against, Union counsel relied upon the following cases: Toronto Transit Commission v. Amalgamated Transit Union (Stina Grievance), [2004] O.L.A.A. No. 5O65, 132 L.A.C. (4th) 225 (Ont. Arb) (Shime); Children’s Hospital of Eastern Ontario v. Ontario Public Service Employees Union (Labrecque), [2015] O.L.A.A. No. 342 (Parmar); Seguin v. Great Blue Heron Charity Casino, 2009 HRTO 940 (CanLII) [reported 69 C.H.R.R. D/325]; and Arunachalam v. Best Buy Canada 2010 HRTO 1880 (CanLII). [88] The Union in this case seeks the following remedies: • Allow the grievances • A declaration that the Employer has breached Articles 2, 3, 8.1.1, 9 and 21 of the Collective Agreement as well as other relevant articles; • A declaration that the Employer has violated the Ontario Human Rights Code; • A declaration that the Employer wrongfully terminated the Grievor in February 2021; - 33 - • An order for the Grievor to be reinstated immediately; • An order that the Grievor be made whole and given full redress, which includes: compensation for all lost wages; compensation for all lost benefits and the restoration of lost pension benefits & seniority; that the Grievor be granted authorizations to all related servers, development, libraries, sources supported within the unit; that the Grievor be advanced to a S07 position; and an order of damages in respect of the harassment and discrimination the grievor has suffered. This last order would include: general damages in excess of $15,000 to compensate for the injury to her dignity, feelings and self-respect associated with the experience of discrimination; special damages for the salary differences between her current position level (SO4) and deserved position level (SO7) which amounts to $289,034; and such other relief as seems just to this Board. Employer Reply [89] Employer counsel objected to any assertion that management had engaged in any type of reprisal against the Grievor for the filing of grievances or Human Rights complaints. There is absolutely no evidence to support such a finding and it is purely subjective speculation. The Union asserted that the Employer did not give the Grievor sufficient warning that her performance was not acceptable and the consequences that may flow and engage in progressive discipline. Although this is not a progressive discipline case, the Employer did in fact issue two written reprimands to the Grievor. Therefore, it is not factually correct to assert that the Grievor had no discipline on file. Counsel also clarified and stressed that when he suggested an award of damages as a potential remedy, the damages were being paid in lieu of reinstatement and were not “human rights” damages. The Employer does not agree that it has in any way violated the Human Rights Code. Decision [90] I found Mr. Sabharwal and Mr. Esedafe to be credible witnesses who did their best to manage, work with and assist Ms. Chung. Ms. Chung on the other hand made accusations and assertions about her treatment in the workplace which are not credible. She saw attempts by Mr. Sabharwal and Mr. Esedafe to supervise or manage her as harassment. When she was treated differently than other staff, she considered it to be discrimination. She was completely incapable of accepting any responsibility for her lack of performance and always blamed others. Accordingly, I prefer the evidence given by Mr. Sabharwal and Mr. Esedafe over that given by the Grievor. - 34 - [91] I agree with counsel for the Employer when he notes that, based on the evidence given by the Grievor, it is clear that she has no insight into her own behaviour in the workplace, nor on her performance. She testified that everything was fine and everyone got along. It seems that she believes that when things go wrong it is never her fault but is always someone else’s fault because her managers are incompetent and her colleagues don’t know what they are doing. I do not accept that as true and I prefer and accept the testimony of Mr. Sabharwal and Mr. Esedafe. [92] I have carefully reviewed the medical documentation provided in this case. I have concluded that the inability and refusal of Ms. Chung to perform software coding, an essential and critical part of her job, was not related to any medical condition. The medical documentation provided by her family doctor in April 2019 states that she is capable of returning to her duties and then simply states, “but not coding work.” This restriction is not related to any medical condition. No rationale is provided for this key restriction. The doctor goes on to state that “we” would like her to work from home for one month and the reason given is that she feels threatened at work and has an ongoing grievance issue. The doctor notes that she “feels insecure” doing coding work. It is clear from this note that the Grievor told her doctor she did not want to do coding work and wanted to work from home and he was merely endorsing what he had been told. The inability and refusal to code was clearly coming from the Grievor and her inability to code is not tied to any specific disability. [93] In the specialist’s letter written in October 2019, he too notes, “I also again recommend to her work not to overload her with difficult work project, specially code works and let her work with less stress for another few more years until her retirement as she is devoted to her work and still she needs to work financially.” Although the doctor does not say that the Grievor cannot perform any coding work, he recommends that she not be overloaded “with difficult work project, specially code works.” I am satisfied that not only did the Employer not overload Ms. Chung with work, they barely assigned her any work particularly at the time this letter was written by Dr. Showraki. She told the specialist that she was overworked and he accepted this. However, I am satisfied that it is not true. He finds that she suffered from anxiety and depression and prescribes medication to help her with this. She did not take it. No explanation was provided by her for this failure to follow her doctor’s recommended treatment. [94] I do not doubt that Ms. Chung found her work to be very difficult and challenging. Instead of admitting that that was the case and that she was lacking the necessary skills to perform her job and asking for help, she blamed everyone else around her, including her managers. It was their fault she couldn’t do her job. She claims - 35 - to need accommodation based on a disability, but I do not accept that the medical documentation provided establishes this. Ms. Chung either lacked the skills to do the coding work or simply did not want to do it. [95] The Grievor claims harassment, bullying and discrimination in the workplace on the basis of age, race and disability. In the Mohammed Case Arbitrator Petryshen sets out a review and analysis of some of the jurisprudence which addresses the test for a finding of discrimination or harassment. Beginning at paragraph 6 he states: [6] There is no dispute about the legal principles that apply in this case. I adopt the principles and tests that are referred to in the following decisions. With respect to an allegation of discriminatory treatment, Arbitrator Dissanayake in Ontario (Ministry of Transportation) v. OPSEU (Brydges et al), supra, set out an excerpt in Moore v. British Columbia (Education), (2012) 351 D.L.R. (4th) 451 (S.C.C.) in which Abella J. described the requirements to be met to establish prima facie discrimination as follows: As the Tribunal properly recognized, to demonstrate prima facie discrimination, applicants are required to show that they have a characteristic protected from discrimination under the Code; that they experienced an adverse impact with respect to the service; and that the protected characteristic was a factor in the adverse impact. Once a prima facie case has been established, the burden shifts to the respondent to justify the conduct or practice, within the framework of the exemptions available under human rights statutes. If it cannot be justified, discrimination will be found to occur. [7] In Ontario (Ministry of Finance) v. OPSEU (Fortin), Arbitrator Luborsky had before him allegations of bullying and harassment made by an employee against certain managers. In this decision, he provides a thoughtful analysis of the considerations and tests that are relevant when addressing a workplace harassment complaint. The following features of the decision are worth noting, beginning with his consideration of what the words bullying and harassment mean. 161. Article 3.3 of the collective agreement provides that the parties: “are committed to a workplace free from workplace harassment, including bullying, by other employees, supervisors, managers, and any other person working or providing services to the Employer in the workplace, clients or the public, in accordance with the law.” The term “workplace harassment” is defined in that article as “a course of vexatious comment or conduct against an employee in the workplace that is known or ought reasonably known to be unwelcome”, which is substantially the same as the statutory definitions of employment or workplace harassment in - 36 - sections 10(1) of the Code and 1(1) of the OHSA. 162. The word “vexatious” is defined in The New Shorter Oxford Dictionary (Claredon Press, Oxford: 1993) as “causing or tending to cause annoyance, frustration, or worry” and in law it denotes, “an action or the bringer of an action that is brought without sufficient grounds for winning, purely to cause annoyance to the defendant”. Applied in the context of labour relations, “vexatious comment or conduct against an employee in the workplace” by a supervisor or person in authority as that phrase appears in article 3.3 of the parties’ collective agreement, refers to words or actions without sufficient grounds or bona fides purposes other than to cause annoyance, frustration and/or worry to an employee, constituting a form of bad faith. This must be distinguished from the words or actions of a supervisor, which the supervisor reasonably knows is unwelcome by the employee, but is nevertheless part of the legitimate exercise of the supervisor’s right to manage the enterprise in the good faith application of the power expressly conferred under article 2 of the collective agreement (and any residual prerogatives), “to manage the business and direct the workforce”, which is not “vexatious” in itself. 163 The word “bullying” describes a spectrum of conduct related to the improper use of power that one person has over another, “to coerce or intimidate weaker persons” (per The New Shorter Oxford Dictionary, supra). In the Board’s opinion, “bullying” is a form of an “abuse of power” in the workplace, which includes conduct by a person in a relative position of authority against an employee that a reasonable person would find hostile or offensive causing or having the potential to cause physical or psychological harm or adverse employment consequences to the employee, such as: (a) repeated infliction of verbal invective or maltreatment in the form of derogatory remarks, foul language and/or insults; (b) verbal or physical conduct that a reasonable person would find threatening, intimidating or humiliating, including yelling and physical displays of aggression and/or any form of violence; (c) deliberate sabotage or undermining of an employee’s work performance; (d) whether as part of a pattern of repeated misconduct or even where it occurs on a single occasion that is especially severe. … 165 The foregoing concepts and the appropriate evidentiary tests for determining whether harassment or bullying has occurred in the workplace have been considered by arbitrators and adjudicators in a variety of employment contexts. For example, in Toronto Transit Commission v. - 37 - A.T.U., Arbitrator Shime defines “abusive conduct” and “harassment” as follows at paras. 248-9: 248 Abusive conduct includes physical or mental maltreatment and the improper use of power. It also includes a departure from reasonable conduct. 249 Harassment includes words, gestures and actions which tend to annoy, harm, abuse, torment, pester, persecute, bother and embarrass another person, as well as subjecting someone to vexatious attacks, questions, demands, or other unpleasantness. A single act, which has a harmful effect, may also constitute harassment. [8] Arbitrator Luborsky then proceeded to provide further examples of the tests that arbitrators have adopted when evaluating allegations of harassment and abusive conduct. I will set out excerpts from some of the decisions he referred to. In Nunavut v. P.S.A.C., 2006 CarswellNat 4671 (CAN ARB) (Knopf), the arbitrator wrote as follows: 33 An allegation of harassment is a serious matter. It cannot be taken lightly, and the onus of proof lies with the Union. A finding of harassment can only be made if there is objective evidence to support its claim. The fact that [the grievor] honestly felt that she was being harassed, and the fact that she suffered greatly, is not enough to make this claim succeed. Nor can it succeed if the evidence showed that the harassment came solely from the community. The grievance is against the Employer. This grievance can only succeed if the objective evidence supports a finding that there has been abusive conduct as a result of improper use of power or a departure from reasonable norm… [9] In Fanshawe College of Applied Arts and Technology v. OPSEU (Read), 2016 CarswellOnt 6614 (ON ARB) (Bendel), the arbitrator commented as follows: In my view, a prerequisite for a finding of harassment is that the conduct about which the complaint is made be “a departure from reasonable conduct”. This was the conclusion of arbitrator Luborsky in Re Cara Operations, supra, drawing on language used by arbitrator Shime in Re Toronto Transit Commission, supra. An employee that complains about behaviour that is within the realm of reasonable conduct will be unable to satisfy an arbitrator that there has been harassment, regardless of the effect that behaviour might have had on the employee. I should add that it seems obvious to me that a decision on the reasonableness of the impugned conduct has to take account of the particular work situation… - 38 - [96] I would start by agreeing with the observation that an allegation of harassment is a serious matter. The onus of proof lies with the Union and a finding of harassment can only be made if there is objective evidence to support its claim. In the case before me, I am satisfied that all of the conduct the Grievor claims to have been harassment or discrimination was simply her managers trying to manage her performance. As was noted by Arbitrator Luborsky, “the words or actions of a supervisor, which the supervisor reasonably knows is unwelcome by the employee, but is nevertheless part of the legitimate exercise of the supervisor’s right to manage the enterprise” does not constitute harassment. All of the conduct by her managers complained of by the Grievor, was simply the efforts and reasonable conduct of management attempting to direct her in the performance of her duties. There is simply no objective evidence of harassment or discrimination on the basis of age, race or disability in this case. [97] In the Solomon Smith Case Arbitrator Anderson commented as follows: 14.Whether Code based or not, harassment or bullying is concerned with conduct, comment or other action. The question is not whether a complainant believed she was the subject of bullying or harassment. The question is whether a reasonable person, informed of all relevant facts, would conclude the impugned behaviour would constitute harassment or bullying if the perpetrator knew or ought reasonably to have known that it was unwelcome: Grievor at para. 48; Cara Operations Ltd. at para. 17 - 20; and Kinark Child & Family Services, Syl Apps Youth Centre v. Ontario Public Service Employees Union, Local 213, 2012 CanLII 97669 (On LA) (Marcotte) pp. 15-17. See also Gauntlett at paras. 18 - 20, holding that statements of belief by the grievor and others as to the motivations of members of management were to be given no weight on a non-suit motion. ... 16.The objective test for harassment is reflected in the following comment by Arbitrator Misra in Ontario Public Service Employees Union (Cross et al.) v Ontario (Ministry of Community Safety and Correctional Services), 2015 CanLII 60421 (ON GSB), at para. 46: The arbitrator in [UFCW Local 1518 v. 55369 BC Ltd., 2007 CarswellBC 3880 (D.L. Larson)] noted that harassment normally involves an element of persistent conduct or a course of activities that involves hostility, importuning, badgering, intimidation or bullying that causes a person distress that is inimical to a safe and positive work environment (para. 31). The exercise of normal management rights does not excuse harassment, and giving directions, evaluating performance and disciplining employees should not be considered harassment in the normal course of events provided that such activities are not carried out in a manner that is abusive, demeaning or hostile, and has a legitimate workplace purpose (para. 33). Not every “employment bruise” should be - 39 - treated as harassment, and Arbitrator Larson noted that it would be unfortunate if a harassment process was “used to vent feelings of minor discontent or general unhappiness with life in the workplace, so as to trivialize those cases where substantial workplace abuses have occurred” (para. 34). [98] I completely agree with the reasoning of Arbitrator Misra when she states: “...giving directions, evaluating performance and disciplining employees should not be considered harassment in the normal course of events provided that such activities are not carried out in a manner that is abusive, demeaning or hostile, and has a legitimate workplace purpose”. In my view, what occurred in the case before me was the exercise of normal management rights and Mr. Sabharwal and Mr. Esedafe were merely trying to direct the Grievor, assign her work, evaluate her performance and correct inappropriate behaviour. They were never “abusive, demeaning or hostile” in their interactions with the Grievor and their actions had a legitimate workplace purpose. [99] Counsel for the Employer noted that in her will-say, Ms. Chung alleges that various emails sent to her by Mr. Sabharwal constitute harassment. Counsel referenced a number of specific emails and asked that I review these emails. He asked that I find that not only do these emails not constitute harassment by any measure, they actually cast Mr. Sabharwal in a good light as a manager doing his best to provide guidance and manage the office effectively. I have reviewed the emails referenced and I agree that Mr. Sabharwal’s emails are calm, professional and respectful and are in no way harassing. As the tone of them is professional and very similar to the letters and emails set out earlier in this award, I have determined that it is not necessary to set them all out and add to this already lengthy award. [100] There is also no evidence, other than the subjective and highly speculative evidence given by the Grievor, to support any finding whatsoever of a South Asian network. The allegations raised by Ms. Chung are not supported by any objective evidence and are frankly offensive. The Grievor is incapable of acknowledging any deficiencies in her performance or behaviour in the workplace. The assertion that there is some sort of network or conspiracy that is preventing her from getting ahead and is instead supporting South Asians in hiring, promotion and decisions pertaining to work arrangements, is without merit and is simply not borne out by the evidence in this case. [101] Accordingly, for all of the reasons stated, the first five grievances filed by the Grievor, which are based on allegations of harassment, discrimination and that she was inappropriately disciplined in a manner that was not for just cause, are hereby dismissed. - 40 - [102] Counsel for the Union suggested that the Employer’s decision to terminate the Grievor was tainted by reprisal in relation to the Grievor’s prior grievances and Human Rights Tribunal of Ontario (“HRTO”) Application. On this basis alone counsel suggested that the termination should be set aside in its entirety. She argued that this case is about an Employer that could not and chose not to tolerate the fact that the Grievor sought to vindicate and enforce her rights under the Collective Agreement and the Human Rights Code. With all due respect, I disagree. There is no evidence before me to support a finding of reprisal. [103] Counsel for the Employer suggested that the test for a non-culpable termination has been satisfied and asked that I dismiss the termination grievance. In the alternative, counsel asked that should I uphold the termination grievance, I should conclude that the only appropriate remedy in this case is damages in lieu. Should I conclude that damages in lieu of reinstatement is the appropriate remedy in this case, counsel argued that I should not follow the normal pattern for the assessment of the quantum for the damages owed. He pointed out that the cases often speak to the Grievor taking, in effect, an early retirement and compensation is assessed on that basis. Arbitrators often award compensation on the basis of one month’s wages for every year of seniority, together with a 15% payment for loss of fringe benefits. Were I to do that in this case I would arrive at a number that is very significant. [104] In this case, the Grievor currently qualifies based on her age and years of service for an unreduced pension. This distinguishes the situation before me from those where damages are assessed based on an “early retirement” or the fact that the employee will be receiving a “reduced pension.” Neither are true in our case. Counsel suggested that an appropriate damages award would be to order the employer to pay her twelve months salary at her base rate, plus an award of damages up to fifty thousand dollars. [105] Counsel for the Union asserted that the Employer has not satisfied the test for non-culpable termination in this case. She referred to Maritime Telegraph & Telephone Co., Ltd. and International Brotherhood of Electrical Workers, Local 1030 (Cotter decision) (1984) 16 L.A.C. (3d) 318 (“the Maritime Telegraph Case”) in support of this position. Although I have already set out the list of factors considered in that case, for ease of reference, I will set them out again. Employer counsel did not dispute that the Maritime Telegraph Case outlines the elements which the Employer must satisfy before it may legitimately terminate an employee for non-culpable inability to perform their job. These elements are: - 41 - 1. Has the employer identified in objective terms the nature of the work to be performed and the standard expected?; 2. Has the employer established that the grievor was made aware of the standard?; 3. Has the employer established that the grievor’s work performance was below that standard?; 4. Did the employer provide supervisory direction to the employee to assist him to achieve the standard?; 5. Did the employer take reasonable steps to move the employee into other work within the bargaining unit that was or might have been within his qualifications and competence?; 6. Did the employer bring home to the grievor the fact that the performance was unsatisfactory and that dismissal might result from a continued failure or inability to meet the standard?; 7. Did the employer afford the grievor a proper opportunity to challenge its assessment of his work by grievance?; 8. Does the evidence support the inference of a continuing inability on the part of the employee to meet the standard? [106] As noted, this approach has been accepted by the Grievance Settlement Board and was specifically adopted by Vice-Chair Mikus in Ontario Public Service Employees Union (Ng) v Ontario (Government Services), 2012 CanLII 6214 (ON GSB) at paragraph 94. Union counsel argued that the Employer has failed to establish the 5th, 6th and 8th elements of this test and as result, the Grievor was inappropriately terminated from her position. [107] With respect, I do not agree that the Employer in this case failed to bring home to the Grievor the fact that her performance was unsatisfactory and that dismissal might result from a continued failure or inability to meet the standard (the 6th element). I’m not certain that the Grievor ever believed that termination was a possibility because she refused to admit or accept that there were any legitimate issues with her performance and with her interactions with her fellow workers. However, management tried over and over to correct deficiencies in her performance and her behaviour. The written warning issued to the Grievor on December 13, 2019 ends by stating that any further misconduct may result in further disciplinary action up to and including dismissal. I am also satisfied that the 8th element has been satisfied. The Grievor either will not or cannot perform coding work at a level that is even close to the standard required and her attitude on this issue has not changed. The evidence clearly supports the inference of a continuing inability on the part of Ms. Chung to meet the standard required for her position. - 42 - [108] However, I do have a concern with regard to the efforts made by the Employer to move the Grievor into other work within the bargaining unit that was or might have been within her qualifications and competence as required by the 5th element. There was some evidence that Mr. Sabharwal did try to assign Ms. Chung other duties that were somewhat connected to her position. But there is no evidence before me that establishes that management made any efforts, let alone reasonable efforts, to find other work for her to perform and made it clear to her that she faced dismissal if she did not accept a different position within the Ministry or the OPS. The Employer did not take reasonable steps to move the employee into other work within the bargaining unit that was or might have been within her qualifications and competence. They never sat down with the Grievor and gave her an ultimatum. It was never put to her that she was being reassigned to another job and had to accept it. Given how intractable and difficult the Grievor is, I am not sure how such a meeting would have gone, but nevertheless the Employer is obligated to try. Accordingly, because of this failure, the Employer has not satisfied the test for non-culpable termination as provided for in the Maritime Telegraph Case in the case before me and the termination grievance is upheld, subject to what I have concluded with regard to remedy. [109] Counsel for the Union argued that the Employer has failed to establish that the employment relationship is not viable. She suggested that should I find that there was not just case for termination, the usual remedy of reinstatement should follow. In her view, only in “exceptional circumstances” should damages in lieu of reinstatement be ordered and that damages in lieu of reinstatement should not provide an opportunity for an Employer to, effectively, sever the employment relationship and to deny an essential collective bargaining remedy. I agree with counsel that damages in lieu of reinstatement should only be ordered in exceptional circumstances. [110] Before determining that this exceptional approach is appropriate, I must be satisfied on the evidence before me that the employment relationship is beyond repair. I agree with counsel for the Employer that I heard extensive evidence from Mr. Sabharwal and Mr. Esedafe about the fact that the employment relationship is beyond repair and I agree that their evidence was credible, consistent and persuasive. The Grievor refused to accept the decisions of management. She was disruptive, insubordinate, confrontational, not trusted by her managers to do her job, unable to get along with colleagues, managers, or clients. She is incapable of or unwilling to perform a fundamental part of her job and is unwilling to admit this fact. And of crucial importance, the evidence is clear that because she feels she is the victim and has done nothing wrong, were I to reinstate her, her behaviour will - 43 - not change. Nothing is ever her fault and she has indicated no willingness to change. [111] If I believed that the Grievor understood and accepted her performance deficiencies and was willing to do everything suggested by the Employer to improve her job performance I might have been willing to give her another chance. But the fact that she does not do so and will not change, coupled with the behaviour issues identified by the Employer and flatly denied by her, leads me to conclude that this is the “exceptional circumstances” case in which damages in lieu of reinstatement, as opposed to the usual remedy of reinstatement, should be ordered. I do not come to this conclusion lightly but have carefully reviewed the evidence and have concluded that it is the right answer in this case. [112] In this case, the Grievor currently qualifies based on her age and years of service for an unreduced pension. I agree with Employer counsel that this distinguishes the situation before me from cases in which damages were assessed and ordered based on the theory that the employee is in effect taking an “early retirement” or the fact that the employee will be receiving a “reduced pension”. Neither are true in this case. However, I must also take into consideration that the Grievor is a very long service employee. [113] Arbitrators often award compensation on the basis of one month’s wages for every year of seniority, together with a 15% payment for loss of fringe benefits. Were I to do that in this case would arrive at a number that is very significant and would constitute a windfall to the Grievor. Counsel suggested that an appropriate damages award would be to order the employer to pay her twelve months salary at her base rate and up to $50,000 as damages. After careful consideration I have determined that it is appropriate to award the Grievor 1.5 years of salary which amounts to approximately $135,000 minus deductions and $45,000 as damages for the loss of her bargaining unit position. [114] Accordingly, the termination grievance is upheld in part. In the event that the parties have any difficulties with regard to the interpretation or implementation of this decision I shall remain seized. Dated at Toronto, Ontario this 31st day of March 2022. “Janice Johnston” Janice Johnston, Arbitrator