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HomeMy WebLinkAboutKenny 10-01-19 IN THE MA TIER OF AN ARBITRATION PURSUANT TO SECTION 49(4) OF THE LABOUR RELATIONS ACT, .R.S.O. 1995, c.L.2, AND ALL AMENDMENTS THERETO AND IN THE MATTER OF AN ARBITRATION ARISING OUT OF THE GRIEVANCE OF MICHAEL KENNY AGAINST CASINO NIAGARA PURSUANT TO A COLLECTIVE AGREEMENT BETWEEN: COMPLEX SERVICES INC. COB CASINO NIAGARA AND NIAGARA FALLSVIEW CASINO RESORT - and - OPSEU LOCAL 278 SOLE ARBITRA TOR: Richard L. Verity, a.c. FOR THE EMPLOYER: Richard Paris Ken Conhiser Counsel - Hicks Morley Hamilton Stewart Vice President, Legal Administration and Chief Compliance Officer Director of Security Security Manager, Casino Niagara Simon E. Mortimer Bruce Caughill FOR THE UNION: Tim Hannigan Jim Storin Michael Kenny Counsel- Ryder Wright Blair and Holmes Union Steward Griever HEARINGS: July 23, 2008 Niagara Falls,Ontario February 24, 2009 March 23, 2009 May11, 12, 13, 18, 19,20,2009 July 14, 2009 September 15, 28, 2009 Thorold, Ontario -2- A WARD Michael Kenny, aged 44, was hired as a security officer on September 10, 1996 in advance of the opening of Casino Niagara in Niagara Falls on December 17, 1996. His employment as a security officer was terminated on May 23, 2008 allegedly for just cause pursuant to article 11.05(a)(i) of the collective agreement in effect from April 1 , 2006 until March 31,2009. The employer (Falls Management Group L.P.) operates two separate facilities in Niagara Falls - Casino Niagara and Niagara Fallsview Casino Resort, both of which are covered by one licence and one collective agreement. Complex Services Inc. is the payroll provider for Falls Management Group. Complex Services Inc. is also a part of Falls Management Group. The reasons for termination are explicitly set out in a letter, dated May 23, 2008, which was signed by Casino Niagara Security Manager, Ken Conhiser. That letter (Exhibit 3) reads as follows: Re: Separation of Emplovment Please be advised that your employment with Complex Services Inc. is being separated, effectively immediately, for just cause pursuant to Article 11.05(a)(i) of the Collective Agreement. On May 19, 2008 at approximately 2:15pm, while assigned to the Escalator entrance, you permitted an 11 year old boy to enter the casino gaming floor. The boy entered unchallenged, as you made no attempt whatsoever to discharge any of your duties or responsibilities as a Security Officer. Your total disregard for established Security protocols constitutes a material breach of AGCO regulations. The incident is serious enough on its own merits to conclude that you are unable to responsibly continue in your role as a Security Officer. Your previous history of misconduct in the workplace further confirms this point. -3- Please return your security identification, AGCO Licence, SOP manual, uniforms, and all other company property to the Human Resources Department at the Montrose Associate Centre within the next three (3) days. A record of employment and final paycheque (if applicable) will be processed after those items have been received. Please note that you are prohibited from visiting any of the Niagara Casino properties for a period of six months effective the date of this letter. The letter set out above, signed by Security Manager Ken Conhiser, was written by Director of Security Richard Paris. In a grievance, dated May 27,2008, Mr. Kenny alleges that he was unjustly terminated by the employer in violation of article 4 of the collective agreement (Management Rights) and article 11 (Discipline, Suspension, Dismissal). By way of settlement, Mr. Kenny seeks reinstatement with full remedial redress. The relevant provisions of the collective agreement read as follows: 11.05 (a) Certain offences are of such gravity and importance that they shall be deemed to justify immediate discharge. Where the dismissal of an employee is made the subject of a grievance which proceeds to arbitration and the dismissal is for one or more of these serious offences, the Employer shall only be required to establish that the employee committed the offence. If it is established that the employee committed the offence then the dismissal shall be deemed to be for just cause and the arbitration board shall have no power to alter or substitute the penalty. The offences subject to the procedure outlined in this paragraph are: (i) material breach of AGCO regulations; -4- I am given to understand that although the first collective agreement between the parties came into effect on April 1 , 2003, this is the first time that the employer has relied upon article 11.05(a)(i) in terminating an employee at Casino Niagara. At the outset, it is helpful to address the wording of article 11.05(a)(i). In my opinion, the words used in that paragraph of the collective agreement are clear and unambiguous. Having said that, however, the arbitrator has not been given much latitude in terms of what the employer is required to establish and the remedy imposed. Article 11.05(a) specifies that "the Employer shall only be required to establish that the employee committed the offence". Once a finding is made to that effect the article goes on to provide that "the dismissal shall be deemed to be for just cause". Finally, under this provision, I have no authority "to alter or substitute the penalty". The second paragraph of article 11.05(a)(i) states that "specific offences" outlined therein are subject to the procedure described in the first paragraph. In the instant grievance, the specific offence relied upon by the employer is "material breach of AGCO regulations". Regulations are as set out in Ontario Regulation 385/99 pursuant to Gaming Control Act 1992. AGCO, the Alcohol and Gaming Commission of Ontario, is the "Regulator" which is responsible for the administration of the Liquor Licence Act and the Gaming Control Act in addition to other duties. The Ontario Lottery and Gaming Corporation (OLG) is the "Operator". In the Alcohol and Gaming Regulation and Public Protection Act, 1996, the Gaming Control Act, 1992 and Ontario Regulation 385/99 there ':'5- is a complex registration regime which sets out various categories of registrants. Although the nomenclature differs between the Acts, relevant examples of registrants include "registered gaming assistant", "trade union", "suppliers", "operator", arid"gaming premises". Under the heading "Persons Prohibited from Playing Games of Chance", Falls Management Group relies upon s. 32(1) which reads "an operator of gaming premises shall not permit the following individuals to play games of chance at the premises: 1. Individuals under 19 years of age ...". The dispute between the parties focuses on the phrase "material breach of AGCO regulations". The parties agree that the word "material" means "important, and "substantial" within the definition of material as described in Blacks Law Dictionary 6th Ed., 1990. Counsel for the employer argues that material must mean that the employee's misconduct is material to the AGCO Regulation. An issue between the parties is whether or not the grievor is an "operator" within the meaning of s.32 of Ontario Regulation 385/99. The union contends that the grievor is not an "operator" and that accordingly, there has been no violation of the regulations. The employer argues that there has been a violation of the regulations and that the grievor when performing duties at a casino entrance is an operator or at least is acting as an operator. The following facts are helpful by way of background information. The importance of denying entry to underage patrons into gaming premises is an issue which is constantly broughtto the attention of casino employees in Niagara Falls. For example, on September 13, 2000 Jerry Cooper, Director of Legal Services and Deputy Registrar Alcohol and -6- Gaming Commission of Ontario sent the following fax to Commercial Casinos, Ontario Lottery and Gaming Corporation - Charity Casinos, Slot Machine Facilities and Great Blue Heron Charity Casino. The notice entitled "Underage Patrons in Gaming Premises" reads as follows (Tab 19 - Exhibit 6): The Alcohol and Gaming Commission of Ontario requires the operator of a gaming facility to provide incident reports to be filed each time an underage person (under 19 years of age) gains entry to the gaming facility. We appreciate that a large number of patrons pass through gaming facilities and the number of underage persons accessing the facilities is relatively small. However, we are in receipt of reports in which the first stage of security failed to check for identification of persons who were subsequently checked on the floor and determined to be under 19 years of age. Operators have a responsibility to prohibit entry to underage persons and to ensure they are not permitted to gamble. Security officers must be trained to as.k for identification (the general approach is to ask for ID for anyone who appears to be under 25 years of age) and operators must have sufficient security officers present at entrances to ensure that ID is requested from the appropriate persons. Also, gaming floor staff must be trained to monitor for potential underage persons. Also, gaming floor staff must be trained to monitor for potential underage persons on the floor and follow the gaming facility's procedures respecting detection of underage persons. We appreciate the efforts that have been made to date by many facilities to prevent entry by underage persons. At the same time, I want to emphasize the importance of keeping underage persons out of the gaming facility. We are monitoring the solution and take appropriate disciplinary action in situations where underage persons have been permitted to play games of chance in a gaming facility without being asked to produce identification. The grievor acknowledges that he has been trained to require identification from apparently underaged persons and that it had always been his practice to do so. AGCO requires the operator of a gaming facility to provide incident reports to be prepared each time an underage person (under 19 years of age) gains access to a gaming facility. -7- Under the Terms of Registration of Falls ManagementGroup LP (Tab 6 - Exhibit 5) the following wording appears: "WHEREAS under section 7(1) of the Gamino Control Act 1992, S.O. 1992, c.24, as amended (the "Act"), a registration is subject to such terms to give effect to the purposes of the Act as the Registrar of Alcohol and Gaming (the "Registrar") proposes and the applicant consents to, the board of the Alcohol and Gaming Commission imposes or the regulations prescribe; NOW THEREFORE, the Registrar proposes that the registration of the Falls Management Group L.P. ("FMG") shall be subject to th'e following terms and conditions, in addition to those terms and conditions prescribed under the Ontario Regulation 69/94 on the Registration of Suppliers and Gaming Assistants: Persons under the Age of Nineteen 1. (1 ) FMG shall not admit persons under the age of nineteen to the casino. (2) Notwithstanding s.1 (1), a registered gaming assistant or supplier who is eighteen (18) years of age shall be admitted to the casino for the purpose of his or her employment. (3) Notwithstanding s.1 (1), a casino operator may employ a person who is 18 years of age in a position that does not require registration provided that the duties of that position do not require the individual to access the casino floor. In the Security Plan, approved February 14, 2005 (Tab 9 - Exhibit 5) for Casino Niagara / Fallsview Casino and Resort the following appears: A. MINORS (a) Proof of Aqe The terms and conditions of the Falls Management Company's registration provides that individuals under the age of 19 cannot be permitted entry into the Casino unless the individual is a registered gaming assistant or supplier employed by the Casino and at least eighteen years of age. Any person entering or in the Casino whose appearance causes a question to be raised concerning their age will be confronted and requested to produce valid identification that establishes their age. Only valid government-issued photo identification is acceptable. (e.g. military ID, drivers licence, passport, Ontario health card, citizenship card, and any photo card issued by the Alcohol and Gaming Commission of Ontario or the Liquor Control Board of Ontario under the Liquor Licence Act. The item of identification must include a photograph of the person and state his or her date of birth and must reasonably -8- appear to have been issued by a government. When a patron is refused entry, the Officer shall inform all Officers assigned to door positions of the description of the under age patron(s). (b) Minors Found on the Gamino Floor 1. Any individual under age 19 who is found on the gaming floor and/or gambling will be escorted to the Security Offices and be the subject of an incident report. Surveillance and the O.P.P. will be notified. All relevant information including the minor's personal information, details of his/her entry into the Casino, and details of any persons in the company of the minor will be recorded. (c) Sionaqe The Casino will have signage posted that will in a clear, concise manner spell out the policy of underage patrons in the Casino. The signage will be posted at all entrances to the Casino. Under Casino Niagara Security Department Standard Operating Procedures (Tab 10 - Exhibit 5), Policy A-4 the following General Rules of Conduct are specified: 1. Security Officer must maintain vigilance and alertness at all times while on duty. 2. Security Officers will maintain professional posture and look alert at all times regardless of area or duty assigned. No slouching or leaning against walls, tables or equipment. 4. Engage in conversation with customers and employees that are productive and deliver on our company's service commitments. Avoid unnecessary socialization that may interfere with your responsibilities while on duty. 6. Security Officers will not patrol with their hands in their pockets, chew gum or have toothpicks etc. in their mouth. 7. Maintain a constant lookout for underage guests and other suspicious persons. Check out same. -9- Similarly, under Casino Niagara Security Department Standard Operating Procedures, Policy A-6 at p. 8 (Tab 11 - Exhibit 5) reads: Z. MINORS GAMBLING/LOITERING 1. Proof of Age The Gaming Control Act of Ontario requires that any individuals be nineteen years of age or over to play games of chance in a Casino. Section 1 of the terms and conditions of the Falls Management Company's registration provides that individuals under the age of 19 cannot be permitted entry into the Casino unless the individualis a registered gaming assistant or supplier employed by the Casino and at least eighteen years of age. Any person entering or in the Casino whose appearance causes a question to be raised concerning their age will be confronted and requested to produce valid identification that establishes their age; specifically, Officers must request identification from anyone who . appears to be 25 years or younger. Only government-issued photo identification is acceptable (e.g. military ID, drivers licence, passport, Ontario health card, citizenship card, and any photo card issued by the Alcohol and Gaming Commission of Ontario orthe Liquor Control Board of Ontario under the Liquor Licence Act.) The item of identification must include a photograph of the person and state his or her date of birth and must reasonably appear to have been issued by a government. Student cards and bus passes are not acceptable. When a patron is refused entry, the Officer shall inform all Officers assigned to door positions of the description of the under age patron(s). The information is to be recorded on the refusal of entry form. 2. Found on the Gaming Floor 1. If a minor is found on the gaming floor, Surveillance is to be notified immediately of the location and description of the minor. 2. Contact the Security Shift Manager and Security Supervisor. 3. O.P.P. will be notified. 4. The minor will be escorted to the Security Office where an investigation will take place. -10- 5. If the minor is with a group, they will also be brought to the Security Office providing they are of age. The Security Shift Manager will decide whether to issue trespass notices to the members in the minor's party. 3. Signage 1. Casino Niagara will have signage posted that will in a clear, concise manner spell out the policy of underage patrons in the Casino. 2. The signage will be posted at all entrances to the Casino. Under the General Compliance 2007 documents for Casino Niagara (Tab 14 - Exhibit 5) the following provisions appear at p. 8: MINORS Patrons must be 19 YEARS OF AGE to enter Niagara Fallsview or Casino Niagara. The Gaming Control Act specifically prohibits those under the age of 19 from playing games of chance in a Casino. The Liquor License Act prohibits those under the age of 19 from purchasing or being served alcoholic beverages. Should Niagara Fallsviewor Casino Niagara not comply with the Terms and Conditions of their AGCO Registration or the conditions set out on the Liquor Licence, the Casinos: 1. Are in violation of the Gaming Control Act, and/or the Liquor License Act, 2. Are at risk of being charged with an offence, 3. May be subject to a Corporate fine of up to $500,000 4. May lose or have their Liquor License or Gaming License suspended Casino Niagara and Fallsview Security Compliance 2007 documentation (Tab 15 - Exhibit 5) under the heading "Minors" the following information is relevant: -11- Patrons must be 19 years of age to enter Niagara Fallsview or Casino Niagara. The policy of Niagara Fallsview/Casino Niagara is to request identification from all patrons who appear to be 25 years of age or under. - The Gaming Control Act specifically prohibits those under the age of 19 from playing games of chance in a Casino. The Liquor License Act prohibits those under the age of 19 from purchasing or being served alcoholic beverages. Compliance relating to minors is listed as a condition of Falls Management Company's Terms and Conditions of Registration, which states "the Operator (FMC) shall not admit persons under the age of 19 to the Casino". A condition of the Niagara Casinos Liquor License, further states that "no minors are permitted in the gaming areas of the premises". The facts of the Victoria Day incident on Monday, May 19, 2008 are relatively straightforward. On that day the grievor worked the day shift beginning at 8:05 am. At approximately 2:15 pm, the grievorwas performing security officer duties working alone at Casino Niagara's escalator entrance known as "Echo I". That posting is located in a noisy area which contained both the escalators and waterfalls. Video surveillance tape at the escalator post recorded that at 2: 15 pm the grievor waved through three people including a minor, without challenging the minor to produce identification to establish age. Subsequent events established that the minor was an 11 year old boy dressed in a bulky winter coat and fishing hat. The two persons accompanying the minor were his mother and an unidentified male. Approximately five minutes after gaining access to the casino, the minor was observed and challenged by a casino employee near pit 2 on level 3. The mother and her son were detained and subsequently the minor was identified by Shift Manager Kelly Harriman as an 11 year old child. There was no dispute that the mother and the unidentified adultmale were overthe age of 25 years. Subsequently, an Underage Patron Report was prepared (Tab 15 - -12- Exhibit 6), as was a Security Report (Tab 16 - Exhibit 6) and a series of reports from numerous witnesses on the gaming floor. Shortly after 3:00 pm, the grievor was brought to Shift Manager Harriman's office arid asked to prepare a handwritten report. That report (Tab 18 - Exhibit 6) reads as follows: At approx 1505 hrs I was called into the security officer [sic] by s/m Harriman where I was notified that I apparently let a minor into the casino. I have no recollection of any minor giving [sic] access through my post. The grievor was promptly sent home by the shift manager pending an investigative suspension. That suspension lasted until Friday, May 23 at which time the grievor was instructed to return to the workplace at 8:35 am. At 8:45 am on May 23, the grievor attended the video surveillance room in the presence of Union Steward Jim Storin and Security Manager Ken Conhiser where they viewed the video tape which showed the entry of the minor and two adults. The grievor reviewed the video tape four times. At 8:50 am, Mr. Conhiser escorted the grievor and Union Steward Storin to his office where he allowed them to meet for several minutes. Finally at 8:55 am, Mr. Conhiserterminated the grievor's employment by giving him a copy of the termination letter (Exhibit 3). The grievor was escorted out of the casino by Union Steward Storin at approximately 9:00 am on Friday, May 23,2008. -13- Essentially there were two principal witnesses called by the employer - Bruce Caughill, Vice-President, Legal Administration and Chief Compliance Officer, Richard Paris, Director of Security for both Niagara Casinos, Both Messrs. Caughill and Paris testified that each viewed the video surveillance evidence, the video surveillance reports and supporting documentation and separately concluded that termination of the grievor's employment was the appropriate remedy. In addition, Mr. Caughill in Exhibit 7 reviewed three incidents, two in 2001 and one in 2003 in which charges were laid in the Ontario Court of Justice (Provincial Offences) and substantial monetary fines ($106,250.00; $112,505.00; $62,505.00 respectively) were imposed by the Courts against Niagara Casino for individuals under the age of 19 being allowed to play games of chance. According to Mr. Caughill, as few as seven and as many as 20 minors a year gain access to the gaming floor at the Niagara Casinos and although termination was not a common occurrence, it did occur occasionally. At the hearing on February 24,2009, the union made a production request for a list of unchallenged minors who had gained entry to the gaming floor. The list was prepared ~ J.h h' ~V1 h 2'"' 2001"> d J. d' r- h'b'J. 8 M C h'I' J. J.'~' d J. h' lor lei eanng on I larcl 0, :::1 an enlere as eX I il . I r. augl Illeslllle as LO IS knowledge of 30 incidents of the 35 listed between 2001 and 2008 in which security officers received a one day, three day or five day suspensions. These included six incidents in which termination was found to be the appropriate remedy, Mr. Caughill testified that in circumstances where there were mitigating factors present, the practice was to substitute a period of suspension in lieu of termination. -14- According to the testimony of Mr. Caughill, there were no mitigating factors present in the instant grievance. The second principal witness for the employer was Director of Security Richard Paris. He was appointed to that position on October 21,2001, after his predecessor had been terminated because of minors gaining access to Casino Niagara. When the new casino opened in 2004, Mr. Paris was given the added responsibility of Security Director at Niagara Fallsview Casino Resort. Mr. Paris reviewed the security structure in place for both casinos and in particular the duties of a security officer. He went on to testify that a security officer works an 8% hour shift with two half hour breaks. Mr. Paris was involved in the first set of negotiations leading to the first collective agreement for the period April 1 , 2003 to March 31, 2006. He was involved in the second collective agreement from 2006 to 2009. Similarly, he was involved in the last set of negotiations for the current collective agreement which has now been resolved. The Director of Security reviewed the legislation affecting all employees at the casinos - the Gaming Control Act, 1992, Ontario Regulation 385/99; Liquor Control Act, Liquor Licence Act and the terms of registration of Falls Management Group LP. In addition, Mr. Paris reviewed the specific duties of a security officer outlined in the Casino Niagara Security Department Standard Operating Procedures - General Rules of Conduct, (Tab 10 - Exhibit 5), the Casino Niagara Security Department Standard Operating -15- Procedures (Rules, Regulations and Policies) (Tab 11 - Exhibit 5), Casino Niagara Security Department Standard Operating Procedures -Identification, Policy G-31 (Tab 12 - Exhibit 5); and Casino Niagara Security Department Standard Operating Procedures - (Rules, Regulations and Policies), Policy A-6, (Tab 13 - Exhibit 5) together with general compliance documents for Casino Niagara and Fallsview (Tab 14 - Exhibit 5) and Security Compliance Documents 2007 (Tabs 14 and 15 - Exhibit5). Mr. Paris made particular reference to page 56 of the Security Compliance 2007, which clearly stated that patrons must be at least 19 years of age to enter Niagara Fallsview or Casino Niagara. The policy of both casinos is to request identification for all patrons who appear to be 25 years of age or under. Mr. Paris testified that the Gaming Control Act specifically prohibits those under the age of 19 from playing games of chance in the casino and the Liquor Licence Act prohibits those under the age of 19 from purchasing or being served alcoholic beverages. Compliance relating to minors is listed as a condition of the Falls Management Company's Terms of Registration which states "the operator (FMC) shall not admit persons under the age of 19 to the casino". A condition of the Niagara Casino's liquor licence further states that "no minors are permitted in the gaming areas of the premises". Reference was made to the fact that should Niagara Casinos not properly comply with the terms and conditions of their AGCO registration or the conditions set out in the Liquor Licence, the Casinos · are in violation of the Gaming Control Act and/or the Liquor Licence Act · are at risk of being charged with an offence · may be subject to a corporate fine of up to'$500,000 -16- · may lose or have their liquor licence or gaming licence suspended According to the testimony of Mr. Paris, he received a telephone call within minutes of the Victoria Day incident, from Casino Security Manager Ken Conhiser. He looked at the Victoria Day 2008 Incident Report and the surveillance video tape, the report of Supervisor Ray Frigault (Tab 10 - Exhibit 6), the report of dealer Aaron Fritz (Tab 11 - Exhibit 6), the report of Pit Manager Sandra Lane (Tab 12 - Exhibit 6), the incident report of Table Games Shift Manager Tino Trinci (Tab 13 - Exhibit 6), Shift Manager Kelli Harriman's incident report (Tab 14 - Exhibit 6), Surveillance Department Underage Patron Report (Tab 15 - Exhibit 6), Security Report (Tab 16 - Exhibit 6), Ken Conhiser's report (Tab 17 - Exhibit 6) and Michael Kenny's report (Tab 18 - Exhibit 6). In addition, Mr. Paris reviewed the grievor's file and looked at all disciplinary matters currently on file. In the words of Director of Security Richard Paris, the incident in question "was a complete failure (on the part of the grievor) to exercise the functions of a security officer. In Mr. Paris's opinion, the grievor failed to comply with standard operating procedures and general rules of conduct. He failed to maintain vigilance and alertness on the job at the escalator entrance, he failed to maintain professional posture in the sense that he was slouching and leaning against the equipment, his hands were in his pockets, and he failed to maintain a constant lookout for underage guests. After watching the surveillance video at the escalator entrance, Mr. Paris concluded that the grievor did not appear to have made ey.e contact with the minor. In Mr. Paris's own words "I see no reason whatsoever for (the grievor) not to see that child and to have questioned him in the -17- usual fashion". Mr. Paris testified that, as a security officer, the grievor is expected to look at all people as they enter the casino and ask for identification in the form of proof of age, if appropriate. Mr. Paris was satisfied that the grievor's actions on the day in question constituted "a total disregard of his duties". Mr. Paris stated that there is no automatic termination of employment for allowing a minor to gain access to the casino floor, in that each case is looked at on its merits. When assigned to work a casino entrance/exit the prime responsibility of the security officer is to assume responsibility to monitor people entering the casino. In cross- examination, Mr. Paris admitted that the underaged guest did not gamble nor did he attempt to do so. Neither did he, the underaged guest, consume alcohol nor attempt to do so. The grievor testified that at 2:15 pm on May 19, 2008, Victoria Day, he was assigned to the escalator entrance (Echo I). Initially Echo I was a two person post with one security officer being responsible for the "ins" and a second security officer being responsible for the "outs". However management decided to reduce the staffing from two to one security officer. In the grievor's opinion, there should have been two security officers on duty on May 19 because it was "busy and it was a holiday". On the day in question the grievor was assigned to work the day shift at Casino Niagara from 8:05 am to 4:35 pm. He was assigned to work as usual at various locations each of approximately 45 minutes duration. -18- The grievor recalled seeing a female entering the casino at about 2: 15 pm who appeared to be at least 25 years of age and who was carrying and pointing an umbrella. According to the grievor, he was distracted by the umbrella. He remembers seeing an unidentified male who was well over the age of 25 years. Surprisingly, the grievor does not recall seeing a third person, the minor, until his memory was refreshed by viewing the video tape on March 23, 2008. In the grievor's words - "I feel terrible", "it should not have happened", "I regret it", "I made a mistake". At about 3:00 pm that afternoon the grievorwas told by shift manager Kelli Harriman that he had let a minor into the casino some three-quarters of an hour earlier. At the request of the shift supervisor, the grievor wrote a short statement of his recollection of the event (Tab 18 - Exhibit 6) to the effect that he had "no recollection of any minor gaining access through my post". After giving his statement, he was instructed by Shift Manager Harriman to go home pending investigation. The grievor was critical of management for not asking him for a second statement and for not allowing him to view the video tape until some three or four days later on Friday May 23, the day that he was teiminated. AccOiding to the giievoi, he was "in disbelief' that he was being terminated in these circumstances. He testified that he had "many sleepless nights" overthis incident and what had hurt him the most was the fact that no one from management had asked for his side of the story. After viewing the surveillance video tape" the grievor acknowledged, without hesitation, that the minor should have been subject to identification and stopped from -19- entering the casino. The grievor agreed that he was not sufficiently busy at the relevant time to use the stension ropes that were available for crowd control. Once the grievor saw the video tape, he recognized the lady carrying the umbrella and testified that he had been distracted by the umbrella. The grievor acknowledges that had been spoken to on more than one occasion by management about leaning against the podium and having his hands in his pockets. In cross-examination, when shown Casino Niagara Security Department Standard Operating Procedures (Tab 10 - Exhibit 5), the grievor agreed that, on the day in question, he had not been vigilant, that he had not been alert, that he had not maintained a professional posture, that he had his hands in his pockets, that he had not maintained a constant outlook for underaged guests, that he failed to request production of identification of a minor, that he had failed to follow proper identification procedures described in (Tab 12 - Exhibit 5) and that he had failed to use a list of identification aids. ~ On day 6 of the hearing, at the request of the parties, I took a view of Casino Niagara. Both the employer and the union agree that in the complex legislative structure applicable to casino's, the grievor as a security officer at Casino Niagara was best described as a "registered gaming assistant" within the definition of the Gaming Control Act, 1992. -20- The employer's submissions are as follows. Falls Management Group LP operates the two casinos in Niagara Falls and is the licensee and holds and operator's registration. Under s. 32(1) of the Ontario Regulation 385/99 an operator of a gaming premises shall not permit the following individuals to play games of chance at the premises "1. Individuals unde~the age of 19". Similarly under s.30(1 0) of the Liquor Licence Act",no person under nineteen years of age shall enter or remain on premises in which the sale of liquor is authorized if the person knows a condition of the licence or permit for the premises prohibits the entry of persons under nineteen years of age". The employer contends that the grievor's actions on May 19, 2008 allowing a minor to gain admission to the gaming floor, without challenge, is a material breach of the AGCO regulations contrary to s.11.05(a)(i) of the collective agreement. According to counsel for the employer, Simon Mortimer, the only issue is whether or not the offence happened and if so, the arbitrator's authority is limited to making that finding. Simply stated, counsel argues that under article 11.05(a), the arbitrator has no authority to alter or substitute the penalty. On these facts, the employer contends that the eleven year old minor improperly gained access to the casino floor in the absence of any challenge by the grievor. Counsel contends that there is no excuse for the grievor to say that he did not see the minor. Counsel m"aintained that the grievor had no justification for not asking for identification of proof of age. Counsel contends that on the day in question, the grievor in admitting a minor, made no attempt to perform the duties of his position as a security officer and in these circumstances there were no mitigating factors. Mr. Mortimer argued that article 11.05(a)(i) was conclusive. -21- In the alternative, the employer had just cause having regard to the grievor's disciplinary record, a three day suspension for irate and aggressive behaviourtowards Shift Manager Kelli Harriman (on December 22,1999) and a five day suspension for irate and aggressive behaviour towards another security officer (on September 12, 2003) together with several other written and oral reprimands. Counsel Mortimer relied on the evidence of his two principal witnesses, Bruce Caughill and Richard Paris, both of whom testified that there were no mitigating factors present for the employer to justify the substitution of a lesser penalty. Finally, the employer contends that the single incident on May 19, 2008 was sufficiently serious to justify termination. The union contends that there was no violation of AGCO regulations by the grievor. The union acknowledges that the grievor did not see the eleven year old minor enter the escalator entrance on the day in question. The union acknowledges, however, that the child should not have gained access to the casino. The thrust of the union's position was that there was no reason, in the absence of any gambling and/or alcohol consumption by the minor, to terminate the grievor's twelve year career. The union relied upon the list prepared by the employer entered. as Exhibit 8 of unchallenged minors who gained entry to the gaming floor. Of the 30 entries reviewed in Exhibit 8, the vast majority of penalties involves suspensions of one, three or five days and only six incidents involved the termination of casino employees. -22- The union argues that past practice can be used as an aid to interpretation. In these circumstances, it has been common practice to deal with the infraction by way of progressive discipline rather than summary dismissal. The principal argument of the union was that article 11.05(a)(i) did not apply in these circumstances. Further, the union argues that there is no significant breach by the grievor to constitute a material breach. Union counsel argues that a breach of the employer's policies and procedures does not mean that it is a breach of the AGCO regulation. The union acknowledges, however, that if the breach was intentional it may be deemed a material breach. Union counsel Hannigan stated that a minor accessing the gaming floor can happen and does happen from time to time which is the reality of the situation of working in a casino. On the other hand, in the event of a finding that a material breach had occurred, union counsel argues that I have the power to look at the exercise of discretion in applying article 11.05(a)(i). Further, the union maintains that I can review the exercise of discretion conducted by the employer if it involves bad faith or if the discretion has been exercised in a discriminatory fashion. For the union, Mr. Hannigan accuses the employer of lack of good faith in comparing how the grievor's case was dealt with in comparison with others cases where suspensions have been given. Mr. Hannigan claims that the grievor's treatment under article 11.05(a)(i) is discriminatory and that the employer did not turn its mind to all of the circumstances. Union counsel argues that management's handling of the grievor's fate has had a terrible affect on a twelve year senior employee in difficult economic times. -23- Union counsel made reference to the following precedents, Blacks Law Dictionary 6th Ed. definition of "material"; Re United Steelworkers of America. Local 3257 and The Steel Equipment Co. Ltd. [1964] O.L.AA No.5, 14 L.AC. 356 (Reville); John Bertram and Sons Co. Ltd. and I.A.M.. Local 1740 [1967] 18 L.AC. 362 (Weiler); OPSEU (Pieter B. Ku vn ties) and Ministry of Transportation and Communications G.S.B. (unreported December4, 1984) (Verity); and Siemens Canada Ltd. v. NationalAutomobile. Aerospace. Transportation and General Workers Union of Canada - CAW-Canada. Local 1941) (Norman Grievance) (1999), 84 L.AC. (4th) 340 (Snow). At the outset of my award I wish to make several comments of a general nature. Having heard evidence over 10 hearing days, I am satisfied that this is not a case of discrimination or bad faith on the part of the employer. As a result of a production request by the union, a list of approximately 35 unchallenged minors who gained entry to the casino was introduced as Exhibit 8. The list involved security officers whose inattentiveness in allowing minors to gain access to the gaming floor and who were given minor suspensions and some six security officers who were terminated for their misconduct. Bruce Caughill, Vice-President and Chief Compliance Officer was questioned by the parties as to his knowledge of the circumstances of some 30 incidents referred to in Exhibit 8. -24- It is hardly surprising that the facts of none of the 30 incidents about which Mr. Caughill testified were identical to the facts of the instant grievance. Perhaps the closest parallel involved the termination of Security Officer Mike Wilson (Exhibit 24) for an incident which occurred on May 7,2005 where his dereliction of duty allowed an eleven year old boy accompanied by his parents to gain access to the casino. The minorwas in the casino for less than three minutes before he was noticed by casino staff and, as might be expected, there was no gambling and no consumption of alcohol by the minor. Security Officer Wilson had three years seniority and one prior incident of discipline for his inattentiveness. The circumstances of the Wilson discipline and the fact that the misconduct was not lodged under article 11.05(a)(i), in my opinion, does not establish discrimination. While it is true that the grievor before me has no prior incident of discipline for inattentiveness, he did have five prior incidents where discipline was imposed, including a three day suspension on December 22, 1999 for irate and aggressive behaviour and uttering profanity towards Shift Manager Harriman and a five day suspension on September 12, 2003 for irate and aggressive behaviour and uttering profanity towards another security officer. The grievor was critical of management's decision in reducing the entrance staff from two security officers to one security officer at the escalator entrance. I do not accept that this criticism has merit. -25- Further, the grievor testified that May 19, 2008, being a holiday - Victoria Day - it was a busy time. The video surveillance tape would dispute that claim as does the grievor's testimony that the number of people using Casino Niagara had "reduced significantly" after the opening of Niagara Fallsview Casino Resort in 2004. The grievor testified that he was distracted by the child's mother pointing her umbrella on entering the casino as the reason for not seeing the minor. I find that explanation difficult to accept. Management made no request to obtain a second statement from the grievor after his initial statement on May 19, 2008. I sympathize with the grievor on this issue, however, it is unlikely, given the video surveillance tape, that a second statement would have advanced the grievor's case. Finally, the grievor was critical of management for failing to ask for his version of events. Cases of this nature are slow to evolve and, accordingly, criticisms in this regard are not unusual. One further matter remains - I did not find the case law submitted by the union helpful in determining this grievance. For that reason, I make no reference to the case law submitted. -26- On the evidence adduced, I am satisfied that on May 19, 2008, the grievor seriously misconducted himself by failing to ask for identification of proof of age, thereby allowing an 11 year old minor to gain access to the gambling floor of the casino. It is readily apparent that few issues are of greater importance to the employer than prohibition of minors gaining access to the casino. The grievor acknowledges that he is well aware of the requirements to ask for valid identification of proof of age. Similarly, the grievor acknowledges that he is well aware of the employer's practice to ask for identification from anyone who appeared to be under 25 years of age or younger. The evidence established that the written "Terms of Registration" of Falls Management Group L.P. and the employer's extensive policies and procedures require that persons under the age of 19 years shall not be admitted to the casino, with two exceptions contained in the Terms of Registration - (1) "a registered gaming assistant or supplier who is eighteen (18) years of age shall be admitted to the casino for the purpose of his or her employment" and (2) "a casino operator may employ a person who is 18 years of age in a position that does not require registration provided that the duties of that position do not iequire the individual to access the casino floQi". Neithei exception applies to the facts of the instant grievance. The issue before me is whether or not it may be said that the grievor's misconduct constitutes a "material breach of AGCO regulations" within the meaning of article 11.05(a)(i). The first question is whether there is a regulation that was breached and the second question is whether or not it was a material breach. -27- There is agreement between the parties that the grievor as a security officer is a "registered gaming assistant". Under the Gaming Control Act, 1992, a registered gaming assistant is defined as ilan individual registered as a gaming assistant under this Act". Under Regulations 385/99 to the Gaming Control Act, 1992, an "operator" is defined "as the Ontario Lottery and Gaming Corporation or a registered gaming-related supplier who operates a gaming premises that is a casino, charity casino, slot machine facility or the premises used for a prescribed lottery scheme under contract with the Ontario Lottery and Gaming Corporation". There is also agreement between the parties that the AGCO (Alcohol and Gaming Commission of Ontario), created under Alcohol and Gaming Regulation and Public Protection Act, 1996, is the "Regulator" while the OLG (Ontario Lottery and Gaming Corporation), created under the Gaming Control Act 1992 is the "Operator". Under the Liquor Licence Act, 1990, s.30(1) states "no person shall knowingly sell or supply liquor to a person under nineteen years of age". That Act also provides in 8.30(10) that "no person under nineteen years of age shail enter or remain on premises in which the sale of liquor is authorized if the person knows that a condition of the licence or permit for the premises prohibits the entry of persons under nineteen years of age". On the other hand, the Gaming Control Act, 1992, prohibits individuals who are under the age of nineteen from playing games of chance. Unlike the Liquor Licence Act, -28- the Gaming Control Act, 1992, however, contains no prohibition of access to a casino for those persons under age nineteen. I would agree with the employer's argument that the "Terms of Registration" of Falls Management Group LP (the Licencee) is incorporated by reference into their registration. The Terms of Registration of Falls Management Group L.P. states "FMG shall not admit persons under the age of nineteen to the casino". My rationale to a complex series of legislative requirements is as follows: Under s.5(1) of the Gaming Control Act, 1992, it states that "no person shall, for consideration, participate in or facilitate in any manner the playing of a game of chance unless (a) the person is registered as a gaming assistant ...". Under s.21(2) of the Act "a registered supplier who provides gaming premises shall ensure that the premises is operated in accordance with this Act, the regulations and the terms of the suppliers registration and the licences for gaming events held on the premises". Under s.21 (3) of the Gaming Control Act, 1992, "a iegistered gaming assistant who is managing gaming premises shall ensure that the premises is operated in accordance with this Act, the regulations, the terms of registration of the supplier of the premises and the terms of the gaming assistant's registration and the licences for gaming events held in the premises". -29- Of particular importance to the issue before me is the fact that it is a condition of the Terms of Registration of Falls Management Group LP that "FMG shall not admit persons under the age of nineteen years to the casino". I would venture to suggest that because the grievor's services as a security officer facilitated the playing of games of chance-, this employee was registered as a gaming assistant. As a security officer, in my view, he is managing the premises for the operator. Therefore, under s.21 (3) of the Gaming Control Act, the grievorwas under a duty to ensure that the premises were operated in accordance with FMG's Terms of Registration which in turn places upon the grievor a duty to prevent a person under nineteen from gaining access to the premises. The grievor appears to have made no attempt to perform his job on the day in question by failing to prohibit an 11 year old boy from gaining access to the casino floor. By his own admission, he did not see the minor enter the casino at 2: 15 pm. I would agree with the testimony of both Bruce Caughill and Richard Paris that there were no mitigating factors in the instant giievance to justify a reduction of the penalty from termination to a suspension. I would agree with the words of Director of Security Richard Paris in describing the grievor's lack,of action, "it was a complete failure to exercise the function of a security officer". While it may be said that the grievor was an honest and likeable witness, it may also be said that he was unrealistic in advancing numerous criticisms of his employer's actions. -30- In the absence of any mitigating factors there can be no justification for the employer to reduce the penalty from a termination to a period of suspension. This is a clear case of non-performance of the ~uties of a position which, in my view, justifies summary dismissal. On th evidence adduced, I am satisfied that the employer has properly applied article 11.05(a)(i) of the collective agreement to the facts of theJnstant grievance. I find that the grievor has committed a material breach of AGCO regulations as alleged by the employer. In the particular circumstances of this case, I have no power to alter the penalty imposed. In the result, therefore, the instant grievance is dismissed. DATED at Brantford, Ontario, this 19th day of January, 2010. ~~. / ~ /~~qY A~ 4;h .......: ....... .,:...................;............ ..,7............. RICH L. VERITY, Q.C. SOLE ARBITRATOR