HomeMy WebLinkAbout2022-8113.Wildman.24-06-27 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# 2022-8113
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Association of Management, Administrative and
Professional Crown Employees of Ontario
(Wildman) Association
- and -
The Crown in Right of Ontario
(Ministry of Natural Resources and Forestry) Employer
BEFORE Adam Beatty Arbitrator
FOR THE
ASSOCIATION
Marisa Pollock
Amy Chen
Goldblatt Partners LLP
Counsel
FOR THE EMPLOYER Felix Lau
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING March 20, October 20, December 6,
2023; January 8, January 11, February
22, and written reply submissions March
7, 2024
- 2 -
Decision
I. Introduction
[1] By way of email dated April 5, 2022, Joseph (Jody) Wildman (“the Complainant”)
requested an alternative work arrangement (“AWA”) pursuant to Article 47 of the
Collective Agreement. The Employer denied the Complainant’s request. The
Complainant grieved that decision.
[2] The Complainant is employed as a Program Coordinator in the Industry
Development Section (“IDS”) of the Ministry of Natural Resources and Forestry.
Starting in March 2020 all IDS staff (including the Complainant) worked remotely
five days a week because of the Covid-19 pandemic.
[3] The Complainant’s request for an AWA needs to be understood in context. Key to
this context are two memoranda issued by Ms. Michelle E. DiEmanuele, Secretary
of Cabinet (“SOC”) to all Ontario Public Service (“OPS”) staff (“the two SOC
memos”). On March 1, 2022, the SOC issued a memorandum that employees
would be expected to return to work three days a week beginning on April 4, 2022.
[4] On March 16, the SOC issued a second memorandum. The second memo scaled
back the return to work plans. According to the second memo, employees would
be expected to return to the office one or two days a week beginning on April 4,
2022 and a minimum of three days a week beginning on May 16, 2022.
[5] Article 47.1 is also key to understanding this grievance. It states as follows:
The OPS supports flexible work arrangements and building a flexible work
culture demonstrating flexibility in when, where, and how people work. The
purpose of the flexible arrangements is to respond to changing workplace
expectations of employees of all ages, boost employee engagement and
retain high-performing employees and demonstrate the Employer commitment
to being a modern Employer.
Alternative Work Arrangements (AWAs) may include but are not limited to:
compressed work week, flexible hours with fluctuating start and end times, job
sharing, pre-retirement part-time employment, and telecommuting/telework.
AWAs may be entered into by mutual agreement between an employee and
their manager. In considering any AWA, the manager will consider, in good
faith, both the employee’s request and the operational viability of the AWA for
the work site.
- 3 -
[6] AMAPCEO argued that when the Employer denied the Complainant’s requested
AWA, it applied the two SOC memos in a blanket fashion without considering,
either his request in good faith or the operational viability of the AWA for the
worksite. Accordingly, AMAPCEO argued that the Employer’s denial of the
Complainant’s request for an AWA violated Article 47.1 of the Collective
Agreement.
[7] For the reasons set out below, the Association’s grievance is allowed. The
Employer’s denial of the Complainant’s request for an AWA violated Article 47.1 of
the Collective Agreement. The facts show, unequivocally, that in denying the
Complainant’s request, the Employer did not consider his request in good faith. To
the extent that the Employer considered the operational viability of the AWA for the
worksite, the evidence establishes that the Complainant’s manager, Ms. Kristin
Fremlin, thought that the Complainant could do all of the requirements of his
position while working remotely. Put somewhat differently, Ms. Fremlin was
satisfied that the Grievor could work remotely without impacting the operational
viability of the worksite. Finally, the evidence also shows that the driving force
behind declining the Complainant’s request was the Employer’s interpretation and
application of the two SOC memos.
II. Background and Facts
[8] The parties entered their evidence by way of will-say statements. The witnesses
were then cross-examined on those statements. The will-say statements had a
number of exhibits attached to them. The Board was provided with an extensive
documentary record setting out, in considerable detail, the chain of events from the
Complainant’s request for an AWA to the ultimate denial of that request.
[9] This is a highly fact specific case. As such I have set out the relevant facts in
considerable detail.
[10] The Complainant emailed his request for the AWA to his manager, Ms. Fremlin, on
April 5, 2022. In his request, the Complainant noted the following:
• the AWA would not include a minimum number of days per week that he had
to attend at the workplace but he would agree to come in for meetings,
training, and at management’s discretion for events that required in person
attendance;
• the AWA would improve his work/life balance, reduce his carbon footprint,
improve his quality of life, health and fitness, and reduce his cost of living;
- 4 -
• working remotely during Covid had shown that working remotely could have
beneficial results for himself and the Employer; and
• his request for the AWA was consistent with the guiding principles of the OPS
Flexible Work Strategy Principles and Criteria (“the OPS flexible work
strategy”).
[11] Later on April 5th, 2022, Ms. Fremlin emailed Ms. Sarah White, a Human
Resources Advisor (“HRA”), requesting a meeting to discuss the Complainant’s
AWA request. That meeting took place on April 7, 2022. Ms. White also
responded to Ms. Fremlin by way of email dated April 13, 2022. In that email, Ms.
White noted the following:
• employees were required to return to the office unless there was a flexible
work arrangement, a medical reason or a family status accommodation;
• the Complainant was not relying on any extenuating circumstances in making
his request; and
• the Employer was not entertaining any permanent AWA’s at that time and the
direction of the SOC was that all employees return to the office.
[12] In her email, Ms. White indicated that those reasons (amongst others) were not to
be shared with the Complainant. Ms. White then concluded her email with a
suggested response, denying the Complainant’s request. Ms. White suggested
that Ms. Fremlin state as follows:
I have reviewed and considered the information which you have provided in
support of your request. However, based on the information you have
provided I do not find there to be personal or extenuating circumstances
preventing you from returning to the workplace. In consideration of the factors
you have outlined and consideration of employer’s operational requirements,
I’m unable to approve your request for a 5 day telework arrangement at this
time. Therefore, in the absence of additional information, you are expected to
attend the workplace on DATE.
[13] Ms. Fremlin had significant concerns with Ms. White’s suggested response. Ms.
Fremlin testified that she was not comfortable with the language suggested by Ms.
White. On April 27, 2022, she emailed her Director, Mr. Wayne Barnes and set
out her concerns. Specifically, Ms. Fremlin noted the following:
• the Complainant’s AWA request was thoughtful and genuine, he did not
embellish his reasons or disingenuously claim he could not return to the office,
rather he indicated that the AWA would be better for him;
- 5 -
• the Complainant pointed out that based on his experience he was able to
“perform all of required duties remotely” and “operationally he is able to
complete 100% of his work effectively remotely”;
• the HRA recommended that the Complainant’s request be denied even though
it is up to the “manager’s discretion”;
• Ms. White’s proposed response declining the AWA did “not reflect the true
reasons” and could confuse the Complainant because the rationale for the
denial was not responsive to the reasons he gave in requesting the AWA;
• approving the request was not aligned with SOC direction; and
• the HRA recommended the response to the Complainant be brief because of
an expectation that a grievance would be filed on this decision.
[14] Mr. Barnes responded to Ms. Fremlin two days later. He noted that he believed
that the denial of the Complainant’s request for an AWA complied with Article 47.
He also indicated that he would escalate the matter because he had concerns with
the proposed denial of the Complainant’s AWA request, including the following:
• telling the Complainant that his AWA was being denied because there were no
“personal or extenuating circumstances” was not responsive to his request;
• suggesting that manager exercised her discretion in denying the
Complainant’s request when that was not actually the case; and
• managers were not at liberty to give the real reasons for denying the AWA.
[15] In his will say, Mr. Barnes indicated that he was concerned with the Complainant’s
request because it amounted to a request to work remotely five days a week and
because it was fundamentally justified on the basis of lifestyle preferences.
[16] Ms. Fremlin responded to Mr. Barnes later the same day. She made the following
comments:
• the Complainant’s request was “operationally feasible in the sense that Jody
can do 100% of his work remotely (which he has demonstrated very well over
the last two years)” while also noting that it was not operationally feasible in
the sense that the OPS did not want all of its employees working entirely
remotely;
• the Employer was “not really considering AWA requests on a case by case
basis at manager’s discretion”;
• in her view neither the Collective Agreement nor the OPS flexible work
strategy spoke to limits on the number of days per week an employee could
work remotely; and
• that while she did not agree with the reference in the denial of the
Complainant’s request to “insufficient personal or extenuating circumstances”
- 6 -
this was the best she could come up in light of being told “not to use the “real”
reasons”.
[17] In cross-examination, Ms. Fremlin was asked about this last point. Ms. Fremlin
agreed when it was put to her that the “real reason” the Complainant’s AWA
request was being denied was because she was required to follow the SOC
memos.
[18] Following this feedback from Ms. Fremlin, Mr. Barnes sent an email to Sean
Maguire, Deb Weedon and Emma Root bringing the Complainant’s request to their
attention. Mr. Maguire is the Assistant Deputy Minister for the Ministry. Ms.
Weedon is a Director. Ms. Root is an HRA.
[19] In that email, Mr. Barnes noted that the request for the AWA was not based on
extenuating circumstances, but rather that the Complainant established over the
course of the pandemic that he could work effectively from home five days a week
and that both the Collective Agreement and the OPS flexible work strategy allowed
for it. Mr. Barnes also wrote that:
• managers were concerned by the perception they had more discretion than
they actually had and that they could not communicate the real reasons for
denying a request;
• a clear answer would involve telling employees that the Employer was being
flexible by not requiring them to return to the office five days a week and that
managers were not required to approve exactly what was requested but that
the HRA had advised these reasons were “not to be shared with the
employee”; and
• it would make managers’ jobs much easier if the Employer simply indicated
that it was not up to their discretion.
[20] Ms. Root responded to Mr. Barnes by “strongly” advising Ms. Fremlin to use the
language that Ms. White had originally recommended. Ms. Root indicated that:
• the language was developed by Employee Relations and was consistent with
the language being used across the OPS; and
• the AWAs were being discussed at the AMERC table and that it was important
a precedent was not set by approving this request that both Employee
Relations and the HRA advised against (having assessed the request using
the four-fold test)
[21] Mr. Barnes then forwarded Ms. Root’s email to Ms. Fremlin. This in turn lead to
another series of emails between Ms. Fremlin and Ms. White and Ms. Fremlin and
Mr. Barnes. In those emails, Ms. Fremlin indicated that she had concerns with the
- 7 -
wording proposed by Ms. White that suggested that she had reviewed and
considered the information the Complainant had provided in support of his request.
In her May 3, 2022 email to Mr. Barnes, Ms. Fremlin wrote that she was
uncomfortable with language that implied that she “reviewed the request entirely
on [her] own (i.e. without input/direction from HR/ER or my manager/ADM and only
[she] had input into the final decision).” According to Ms. Fremlin suggesting that
she was the only one who had input into the final decision was disingenuous.
[22] Mr. Barnes responded to Ms. Fremlin later the same day. He recommended that
she call Ms. White to explain her concern, follow up with an email, and “then use
the language” she was being directed to use.
[23] Ms. Fremlin then emailed Ms. White. She indicated that she had adopted the
language recommended by Ms. White despite her unease with it. She reiterated
that she was concerned that the email implied the decision to deny his request
was made entirely by her, which was not the case. She also noted that the
rationale for denying the Complainant’s request did not make sense because the
Complainant “did not claim there were any personal or extenuating circumstances
preventing him from returning to the workplace.” Finally she noted that the
response provided to the Complainant was “disingenuous” and went against her
“personal values of authenticity, honesty and integrity.”
[24] Ms. Fremlin then sent an email to the Complainant denying his request for an
AWA. She used the language approved by Ms. White. The email stated, in part,
as follows:
I have reviewed and considered the information which you have provided in
support of your request. However, based on the information you have
provided I do not find there to be personal or extenuating circumstances
preventing you from returning to the workplace. In consideration of the factors
you have outlined and consideration of the employer’s operational
requirements, I’m unable to approve your request for a 5 day telework
arrangement at this time. Therefore, you are expected to attend the workplace
at least one day per week until May 13th and starting the week of May 16th,
you are expected to attend the office a minimum of three days per week in
accordance with the temporary hybrid model that is currently in place.
[25] The Complainant responded on May 4, 2022. In his response, he raised several
issues, including the following:
- 8 -
• his request for an AWA was not based on “personal or extenuating
circumstances” preventing him from returning to the workplace as suggested
by the Employer’s denial;
• his request for an AWA was based solely on Article 47 of the Collective
Agreement;
• there were no operational requirements that he could not meet if he worked
remotely; and
• he requested that his AWA be reconsidered and that if it was denied a second
time due to “the employer’s operational requirements” that he be provided with
the specific operational requirements that could not be met by him working
from home.
[26] Later that day, Ms. Fremlin forwarded the Complainant’s response to Ms. White.
Ms. White asked her to draft a response that she could review prior to Ms. Fremlin
responding. Ms. Fremlin then responded asking for guidance before noting that
the Complainant’s email was “exactly the concern I had with the response I was
directed to give him.” Ms. Fremlin concluded her email by stating:
There are no operational requirements that can’t be met from him working
from home that I am aware of (with 2 years demonstrating just that). He is
willing to come into the office on an ad hoc basis for training or other needs as
they may arise.
[27] Ms. White responded to Ms. Fremlin by way of email dated May 6, 2022. In her
email, Ms. White stated that:
• it was important that Ms. Fremlin make her decision using the four-fold test
and that regardless of how she decided, HR would support her;
• the response provided was sufficient to advise the Complainant that
operationally it was not possible for him to have an AWA that would allow him
to work from home permanently; and
• operational feasibility is determined by the employer not the employee.
[28] Ms. White’s response lead to another series of emails between Ms. Fremlin and
Ms. White, and Ms. Fremlin and Mr. Barnes. Various draft responses to the
Complainant’s latest email were exchanged between the three of them. In Ms.
Fremlin’s initial draft she wrote that:
• AWAs were not being considered at that time unless there were personal or
extenuating circumstances that prevented an employee from attending the
workplace;
• the OPS was working on a standardized hybrid work model that they hoped to
roll-out in the fall;
- 9 -
• the OPS was providing flexibility by allowing employees to decide if they
wanted to work from home up to two days a week and the Complainant could
decide which two days he would stay home.
[29] Ms. White responded to Ms. Fremlin’s draft response with a number of suggested
edits. Mr. Barnes was copied on her email. Most significantly, Ms. White’s draft
removed the reference to AWAs not being considered in the absence of personal
or extenuating circumstances and inserted language indicating that the
Complainant’s AWA had been “reviewed and independently considered based on
the factors you [the Complainant] have outlined and the considerations of the
employer’s operational requirements”. Reference to there being “no personal or
extenuating circumstances” preventing the Complainant from attending the office
in person was left in Ms. White’s draft.
[30] In response to Ms. White’s draft, Ms. Fremlin reiterated her frustration with relying
on the lack of personal or extenuating circumstances to justify denying the
Complainant’s request. Ms. Fremlin noted that she addressed this issue in her
first draft but that Ms. White had deleted that language (when she deleted the
sentence that AWAs were not being considered absent personal or extenuating
circumstances). Ms. Fremlin also indicated that she still did not understand what
operational requirements were not being met if the Complainant worked remotely,
and that she did not have a good answer for this question other than “it is SOC
direction and if we approve his request, we will have to do the same for others”.
Finally, Ms. Fremlin also offered the following comment:
As we discussed, I have no issue declining the request but I do have concerns
about being deliberately evasive with our response. I think we own [sic] our
employees a truthful rationale. Also, if we provide no rationale, I expect he will
respond back pointing out that we haven’t addressed his questions and again
requesting an explanation.
[31] After a little more back and forth, Ms. Fremlin, Ms. White and Mr. Barnes agreed to
the following language to use in responding to the Complainant’s questions:
I would like to clarify that your AWA request was independently reviewed and
considered based on the factors you outlined and in consideration of the
employer’s operational requirements. At this time, in the absence of
extenuating circumstances, I am not able to approve your request for a 5 day
telework arrangement. …
[32] In cross-examination, Ms. Fremlin indicated that she was never satisfied that her
emails to the Complainant provided a truthful explanation for why his request for
- 10 -
an AWA was being denied. Ms. Fremlin agreed with counsel for AMAPCEO when
it was put to her that it was not true that the Complainant’s request for an AWA
was independently reviewed. Ms. Fremlin stated that while his request was
considered on its own merits, she also understood, based on the two SOC
memos, that if there were no extenuating circumstances, such as a disability or a
need for accommodation, it would not be approved. Ms. Fremlin also agreed
when it was put to her that she disagreed with much of the content of the email
sent to the Complainant but that she agreed to do what she was told.
[33] The Complainant responded to Ms. Fremlin by way of email dated May 12, 2022.
He asked for clarification on what she meant when she wrote that his AWA request
was “independently reviewed”. He also asked for a list of the specific reasons why
his request would not be operationally viable.
[34] The Complainant’s email to Ms. Fremlin lead to another round of emails between
Ms. Fremlin, Ms. White and Mr. Barnes. By way of email dated May 18, 2022, Ms.
Fremlin responded to the Complainant by indicating that “independently” meant
that the Complainant’s request was reviewed on its own merits. In response to the
Complainant’s second question, Ms. Fremlin indicated that it was the Employer
who determined operational requirements and that the Employer was requiring
employees to be in the office three days a week. Ms. Fremlin also noted that the
leave request was denied because there were no personal or extenuating
circumstances.
[35] In cross examination, Ms. Fremlin agreed that here too she wrote what she was
told to write despite her own misgivings.
[36] The Complainant responded to Ms. Fremlin by way of yet another email later that
day. In that email, the Complainant raised a concern that someone other than Ms.
Fremlin had made the decision to deny his request. He also reiterated that his
request for an AWA should be considered under Article 47 of the Collective
Agreement and independently from the OPS return to work plan or any OPS
hybrid model that was being developed by the Employer. The Complainant
concluded by requesting a meeting with Ms. Fremlin and an AMAPCEO
representative. He stated as follows:
If you [Ms. Fremlin] are not able to provide any further details that would show
that my request was considered in good faith and without arbitrariness, that it
is not operationally viable for the type of work I do, that it was considered on
its individual merits and all relevant factors, and that you were able to exercise
your managerial discretion, I would request a meeting with you, my
AMAPCEO representative present, to try and resolve this issue.
- 11 -
[37] Ms. Fremlin reached out to Ms. White and proposed a response to the
Complainant’s email. Ms. White proposed a few edits to that response. During
this back and forth, the Complainant followed up with Ms. Fremlin renewing his
request for a meeting. Ms. Fremlin sought out Ms. White’s advice again. Ms.
White indicated that she was consulting with Employee Relations. Employee
relations proposed rejecting the Complainant’s request for a meeting and advising
him that the matter was now closed.
[38] Ms. Fremlin ultimately accepted Employee Relations’ advice and emailed the
Complainant, on June 7, 2022, telling him that she had reviewed his request for an
AWA and had made her decision and that another meeting would not be
productive because there was nothing left to discuss.
[39] The Complainant responded the next day. In an email dated June 8, 2022, the
Complainant took the position that Ms. Fremlin had not answered his questions.
The Complainant set out a number of questions that he felt remained unanswered
including the following:
• had Ms. Fremlin genuinely exercised her managerial discretion in denying his
request;
• how did Ms. Fremlin determine that the Return to Work hybrid model was an
operational need? And was the Return to Work hybrid model being
considered an operational need across the OPS or the Ministry?; and
• were there any other facts that made his requested AWA not operationally
viable
Finally, the Complainant repeated his request for a meeting with Ms. Fremlin and
an AMAPCEO representative.
[40] The next day, the Complainant emailed Ms. Fremlin again. The Complainant
attached a memo, dated August 1, 2017 to his email. He asked Ms. Fremlin to
review the memo in considering his request. In broad strokes, the August 1, 2017
memo reiterated the need to assess all AWA requests on their own merits and to
give proper consideration to the circumstances of each individual and to
operational needs.
[41] Ms. Fremlin sought Ms. White’s guidance on how to respond to the Complainant.
Ms. Fremlin attached the August 1, 2017 memo to her email and asked that Ms.
White review the memo in preparing her response. Ms. White suggested a
response to the Complainant that would indicate that his request had been
- 12 -
considered according to the principles set out in the AMAPCEO Collective
Agreement and that beyond that she had nothing else to say on the question.
[42] Ms. Fremlin responded by noting that, according to the August 1, 2017 memo, the
“Employer needs to provide actual examples where an AWA will impede
operational requirements”. Ms. Fremlin noted that if asked to do so, she did not
think they would be able to provide any such examples with respect to the
Complainant’s requested AWA. She asked Ms. White and Mr. Barnes whether
they needed to consider this issue before responding to the Complainant.
III. Arguments
a. Position of the Association
[43] AMAPCEO argued that Article 47 of the Collective Agreement limits the
Employer’s management rights. It imposes an obligation on an employee’s
manager to consider a request for an AWA in good faith. It also requires an
employee’s manager to consider the operational viability of the AWA for the
worksite. According to the Association, the decision of whether or not an AWA is
appropriate under Article 47 depends on local considerations.
[44] The Association relied extensively on the decision of the Board in AMAPCEO
(Roffey et al) and Ontario, 2024 CanLII 8294 (ON GSB) (Anderson) (“Roffey et
al.”). That case addressed the interplay between an office standard adopted by
the Toronto Regional Office of the Ministry of Children, Community, and Social
Services (the “TRO”) and the two SOC memos. Prior to the pandemic, the TRO
had implemented an “office standard” that allowed employees to work remotely for
up to three days per week. During the pandemic, the TRO announced that the
office standard would be changed, and that upon return to the workplace,
employees would be permitted to work remotely up to four days per week.
[45] As set out above, prior to the return to the workplace, the two SOC memos were
issued. The TRO interpreted the two SOC memos as permitting it to continue to
allow employees to work remotely three days per week because it constituted an
existing AWA in place prior to the pandemic. However, the TRO also concluded
that the increase of up to four days of remote work per week was not permitted
under the two SOC memos because that increase was announced during the
pandemic.
[46] The Association grieved the TRO’s decision to reverse the four days per week of
remote work announcement as a violation of Article 47. In that case, the
- 13 -
Association argued that under Article 47 local management is charged with making
decisions with respect to remote work and the two SOC memos amounted to an
impermissible fettering of that discretion.
[47] The Board allowed the Association’s grievance in Roffey et al. The Board held
that Article 47 was a restriction on management rights and that the Employer could
not fetter the discretion granted to managers under Article 47 to consider requests
for days of remote work in excess of the office standard. The Board concluded
that the TRO interpreted and applied the two SOC memos in such a way as to
fetter the manager’s discretion to consider any AWA that went beyond the three
days of remote work in place prior to the pandemic. According to the Board in
Roffey et al. the evidence established “that following the SOC Memos, the
Employer had adopted a rigid policy of not agreeing to AWAs for more than three
days per week of remote work.”
[48] In the current matter, the Association advanced the same argument. The
Association argued that the evidence showed that the Employer interpreted and
applied the two SOC memos in such a way as to fetter Ms. Fremlin’s discretion to
consider the Complainant’s request.
[49] The Association also argued that the Employer did not comply with the fourfold
test when it denied the Complainant’s request for an AWA. The parties agreed
that the fourfold test was first set out in Kuyntjes and Ministry of Transportation
and Communications (1984), GSB No. 513/84 (Verity) and that it sets out the
standards for the exercise of management discretion. The fourfold test is as
follows:
1. The decision must be made in good faith and without discrimination.
2. It must be a genuine exercise of discretion power, as opposed to a rigid policy
adherence.
3. Consideration must be given to the merits of the individual application under
review.
4. All relevant facts must be considered and conversely irrelevant considerations
must be rejected.
[50] The Association argued that none of the factors in the fourfold test were met by the
Employer. According to AMAPCEO, the manager was not allowed to exercise her
discretion and was told to respond in a manner that was neither responsive to the
Complainant’s request nor truthful. In those circumstances the decision could not
have been made in good faith. Nor was there a genuine exercise of discretion by
Ms. Fremlin (despite her best efforts). The Association argued that she was told
what to do in order to comply with the two SOC memos. This amounted to “rigid
- 14 -
policy adherence” according to the Association. Consideration was not given by
Ms. White, or those above her, to the merits of the Complainant’s request.
AMAPCEO argued irrespective of what the Complainant said the Employer rigidly
adhered to the two SOC memos. Finally, the Association also argued that the
fourth factor was not met. The Association noted that where the first three factors
are not met the fourth factor also will not be.
[51] Applying the fourfold test to Article 47.1, the Board in Roffey et al. held that a
manager “must consider factors relevant to the employee’s request and to the
operational viability of the work site. Other factors are irrelevant”. The Board went
on to hold as follows:
67. Factors relevant to an employee’s request are inherently individual: they
require consideration of the employee’s circumstances. Factors relevant to the
operational viability of an AWA for a work site may include consideration of the
work site in a larger context. OPS-wide factors, such as a direction from the
SOC, may be relevant to what is operationally viable for a work site. They
cannot, however, trump other relevant factors, including purely local factors.
This is because, as stated by Arbitrator Parmar in McMurrich Sprouts Daycare
and CUPE, Local 4400 (Szwaj),Re, 2013 CarswellOnt 18633 (Ont. Arb.) at
para. 33: “Focusing on a single fact is akin to applying a blanket policy as it
allows the Employer to ignore relevant information.
[52] The Board then noted that whether discretion was improperly fettered was a
matter of fact. Turning to the two SOC memos, the Board concluded that under
the two SOC memos managers could not approve new AWAs that provided for
three or more days per week of remote work. The Board noted that employees in
the TRO understood, based on the two SOC memos, that AWAs that called for
four or more days of remote work per week would not be approved. The evidence
also established, according to the Board, that the decision not to allow four or
more day of remote work was not made by the TRO.
[53] The Board concluded that Article 47 was breached to the extent that the direction
to managers not to consider AWAs that included more than three days of remote
work per week removed the obligation of managers to consider such requests.
The Board held that it was “the direction to managers not to consider requests for
an AWA in excess of three days of remote work per week which is in breach of
Article 47.”
[54] By way of remedy, the Board ordered the Employer to advise the TRO managers
that they must in good faith consider requests for AWAs in excess of the office
standard (i.e. three days a week of remote work).
- 15 -
[55] The Association argued that the evidence in the current matter was more
compelling than the evidence before the Board in Roffey et al. The emails
between Ms. Fremlin and Ms. White (and others) showed, conclusively according
to the Association, that the decision to deny the Complainant’s request was not
made by the Complainant’s manager Ms. Fremlin.
[56] The Association argued that the Employer in effect imposed a blanket rule. The
only issue the Employer considered was whether the AWA requested by the
Complainant’s complied with the two SOC memos. According to the Association,
by proceeding in this manner the Employer ignored relevant information and
violated the Collective Agreement. The Association noted that Arbitrator
Steinberg reached a similar conclusion in Toronto District School Board and CUPE
(Hamilton), 2016 CarswellOnt 7214 (Steinberg).
[57] Similarly, in PEGO and The Crown in the Right of Ontario, 2016 CanLII 7448, the
Board concluded that the Employer failed to consider a number of relevant factors
when it decided to eliminate compressed work weeks. The Arbitrator concluded
that there was no evidence to support the Employer’s conclusion that compressed
work weeks needed to be cancelled. As such, the Board found that the
Employer’s decision was arbitrary and unreasonable and therefore a breach of the
collective agreement. The Association argued that the same conclusion should
apply.
[58] The Association argued that in the instant case, the overwhelming reason the
Complainant’s request for an AWA was denied was because it did not comply with
the two SOC memos. The two SOC memos had little to no regard for local
considerations, and in the words of the Association, “usurped” Ms. Fremlin’s
discretion. The Association noted, as set out above, that part of the rationale for
denying the Complainant’s request for an AWA was that it would be inconsistent
with what the Employer was doing elsewhere in the OPS. As such, according to
the Association, the Employer had not satisfied its obligations under Article 47 of
the Collective Agreement.
[59] The Association argued that Ms. Fremlin’s evidence was clear. She believed that
in light of the SOC memos the Employer was not issuing AWA’s unless there were
extenuating circumstances or an accommodation was required. The Association
noted that, as described above, in an email dated April 13, 2022, Ms. White wrote
as follows:
- 16 -
• The employer is not entertaining any remote work agreements (AWAs)
permanently at this time and the direction provided by SOC is that all
employee return to the office space.
• We as the employer also have to remember that we are providing flexibility to
employees by not having them return to the office 5 days per week. Currently
the flexibility being offered is the 1-2 days per week and then May 16, 2022 to
have employees return 3 days per week. The employer is being flexible by
not having them return full time (5 days per week).
[60] According to the Association, this email demonstrates that from the outset, the
Employer was not considering the Complainant’s request pursuant to the
requirements of Article 47. The Association argued that in this email the Employer
plainly stated that it would not consider the personal circumstances of the
individual or the operational requirements of the workplace as required under
Article 47. Rather, the Association noted that the Employer was taking the position
that it was already granting employees a generous amount of time to work
remotely and that was sufficient. The Association also pointed to comments Ms.
Fremlin made in response to an email from Mr. Barnes on April 29, 2022 (as set
out above) where she noted that by applying the SOC memos the Employer “was
not really considering AWA requests on a case by case basis at managers’
discretion.”
[61] The Association also noted that during her cross examination, Ms. Fremlin agreed
that she believed that employees could not work from home beyond what was
permitted by the SOC unless the employee already had an AWA in place. Ms.
Fremlin also agreed that the only flexibility provided to employees (unless there
were extenuating circumstances or a pre-existing AWA) was the flexibility
contemplated by the SOC memos.
[62] The Association also relied on the email from Ms. Root on May 2, 2022 to Mr.
Barnes (and subsequently forwarded to Ms. Fremlin). As set out above, in that
email, Ms. Root “strongly advised” that Ms. Fremlin use the language originally
provided by Ms. White. Ms. Root noted that the language originally provided was
consistent with wording being used across the OPS and that AWA’s were being
discussed by the labour-management employee relations committee. Ms. Root
noted her concern about the possibility of setting a precedent if the request was
approved. The Association argued that this email constituted further evidence of
the Employer’s failure to apply an individualized approach as required by Article
47.1 of the Collective Agreement.
[63] The Association argued that Ms. Fremlin’s evidence was clear that the
Complainant’s request was not denied because of anything inherent to the request
- 17 -
or because of the operational viability of his request. The Association did not
dispute that the Complainant’s request was based on his personal preferences
and was not the result of personal or extenuating circumstances. In particular, the
Complainant was clear in his will-say and during cross-examination, that the AWA
he requested would improve his quality of life, his work-life balance, it would allow
him to live a healthier lifestyle, and would reduce his carbon footprint. The
Association noted these factors were consistent with those listed in the OPS
flexible work strategy. The Association also noted, as set out above, that in an
email to her Director, Ms. Fremlin wrote that the Complainant’s request was
“thoughtful and genuine.” Ms. Fremlin also indicated that based on her
understanding of the OPS flexible work strategy, the OPS claimed to support AWA
for all the reasons the Complainant was relying on.
[64] The Association noted that the Complainant’s evidence also established that he
viewed his request to work remotely five days a week as an opening position and
an invitation to continue discussing the appropriate amount of time to spend at the
office. The Complainant was clear that he anticipated further conversations to
determine what was reasonable. The Association noted that the Complainant
stated in his will-say that he was willing to come in when required by the Employer.
The Association emphasized that the Complainant also indicated during cross-
examination that he thought giving the Employer flexibility in terms of when he
needed to be in office would be beneficial to the Employer. However, those
conversations never took place because the Employer simply refused his request.
[65] The Association argued that the evidence was even more emphatic when
considering the issue of the operational viability of the Complainant’s request. The
Association stated that the evidence unequivocally established that the
Complainant could carry out all the functions of his position remotely. Ms. Fremlin
noted, in several emails, that the she did not think the Complainant’s request
raised any concerns regarding the operational viability of the worksite. For
example, in an email dated May 4, 2022, Ms. Fremlin wrote to Ms. White that there
were “no operational requirements that can’t be met from him working from home
that I am aware of (with 2 years demonstrating just that).
[66] The Association also pointed to an email from Ms. White to Ms. Fremlin dated May
26, 2022, where the Employer makes reference, for the first time, to the idea that
working together in the office allows for greater “collaboration, innovation,
relationship and team building”. The Association argued that this explanation for
turning down the Complainant’s request came late in the day and was little more
than a stock response.
- 18 -
[67] The Association also noted that the Complainant’s evidence established that the
Complainant’s position involved a considerable amount of “telework” prior to the
pandemic. The Complainant spoke about his colleagues working in three different
offices. Important weekly and by-weekly meetings took place by way of
conference call. As such, according to the Association, the idea that the
Complainant was required to be in the office to facilitate team building and
collaboration was not supported by the facts of this specific worksite.
[68] To the extent that Ms. Fremlin raised concerns in her will-say statement that
allowing the Complainant to work remotely five days a week would open the
floodgates, or that that the Complainant’s requested AWA fettered her discretion,
or that there were team-building and cohesion benefits to having the Complainant
come into the office at least occasionally, the Association argued that that
evidence should not be given any weight. The Association noted that there was
no contemporaneous evidence of Ms. Fremlin having concerns about any of these
issues. The Association suggested that these issues amounted to a belated
attempt by the Employer to bolster its case.
[69] In light of all of the foregoing the Association urged the Board to conclude that
absent the two SOC memos the Complainant’s request would have been
approved. The individual considerations of the request are those that, according
to the Association, should have led to the request being granted. Similarly, the
operational requirements were also met. The Association argued that as such and
pursuant to Article 47 the Complainant’s request should have been approved.
More importantly, because the denial of the Complainant’s request, was based on
the two SOC memos, it violated the Collective Agreement.
[70] In terms of remedy, the Association argued that the nature of the request and the
operational viability of the request both favoured granting the Complainant his
requested AWA as opposed to remitting the matter to his manager to be
considered in good faith. In the alternative they asked for the manager to make a
decision within two weeks.
b. Position of the Employer
[71] The Employer argued that the Complainant’s request for an AWA was
extraordinary. The Employer noted that the request would effectively mean that
the Complainant worked remotely five days a week. Such a request represents,
according to the Employer, a significant intrusion into its management rights that is
not supported by Article 47.
- 19 -
[72] The Employer noted that Article 47 does not entitle an employee to an AWA.
Article 47 provides only for a procedural right. It requires a manager to consider,
in good faith, an employee’s request and the operational viability of the request.
Nothing more. The Employer contrasted the procedural right under Article 47 to
other provisions in the Collective Agreement where employees’ requests cannot
be unreasonably denied. Under Article 47, the Employer argued that arbitrators
cannot second-guess an employer’s decision if the decision is reasonable.
Relying on Simcoe (County) District School Board v. O.P.S.E.U., Local 330, 2022
CarswellOnt 2761 (Davie) the Employer noted that it is required to consider
relevant factors and that it cannot rely on extraneous considerations.
[73] The Employer argued that it is not required to provide reasons for denying a
request for an AWA. In OPSEU (Neeb) and Ministry of Finance, GSB No. 2002-
1438 (Abramsky), the Board held that while it may be preferable for the Employer
to provide reasons there is no requirement to do so. As such, whether the
Employer failed to provide the Complainant with the “true reasons” for the denial is
a separate question from the issue of whether the Complainant was entitled to the
requested AWA.
[74] The Employer also argued that the focus of this grievance, and therefore any
decision issued by the Board, should be on how the Complainant’s manager
responded to his request for an AWA. The grievance is not, according to the
Employer, about the two SOC memos. The Employer claimed approaching this
matter in this way is consistent with approach the Board took in Roffey et al.
[75] Turning to the Complainant’s actual request, the Employer argued that it did
consider the Complainant’s request for an AWA in good faith. The Employer noted
that the request was reviewed in depth and the Complainant had multiple
opportunities to follow up with his manager. In so far as AMAPCEO emphasized
the role of Ms. White, the Employer notes that as an HRA her role is to provide
“advice and recommendations” to managers but that she did not make the ultimate
decision to deny the Complainant’s request.
[76] The Employer emphasized that the requested AWA was rejected, at least in part,
because of the lack of compelling reasons to justify such an extraordinary request.
The Employer noted that the Complainant justified his request on the basis of a
number of “generic reasons” including the following:
• he preferred to work out of his home office;
• it was hard to move his office equipment back and forth between his home
and the Employer’s workplace;
- 20 -
• working from home would improve his work life balance;
• working from home was more environmentally friendly;
• working from home would allow him to exercise more; and
• working from home would allow him to remain more actively involved in the
community.
[77] The Employer noted that in her will-say statement, Ms. Fremlin indicated that the
reasons given appeared to be generic and that most of them would likely apply to
the majority of employees. The Employer argued that none of the reasons
provided by the Complainant established that he needed to work remotely five
days per week. At most, his request reflected his personal preference and nothing
more.
[78] According to the Employer, Ms. Fremlin was also justified in turning down the
Complainant’s request for an AWA because of the impact his request would have
on management’s ability to determine when his attendance in the workplace was
required. In her will-say, Ms. Fremlin noted that she was concerned that granting
the Complainant’s requested AWA would fetter her ability to determine when his
attendance at the office was required. Ms. Fremlin also noted that she was
concerned that the Complainant’s requested AWA implied that his consent or
agreement was required before he could be asked to come into the office. Ms.
Fremlin also expressed a concern in her will-say statement that the Complainant’s
requested AWA would require the Employer to establish the bona fides of a
request to reduce the number of days the Complainant was working remotely,
even though there is no such requirement in the Collective Agreement.
[79] The Employer noted that Article 47.3 of the Collective Agreement permits the
cancellation of an AWA with 30 days notice. The AWA implied that the
Complainant’s consent would be required to any changes to the AWA. Ms.
Fremlin also indicated in her will-say statement that she was concerned that the
Complainant’s requested AWA was inconsistent with the AWA template
agreement in the AMAPCEO collective agreement.
[80] Finally, Ms. Fremlin also noted in her will-say that she was concerned that the
Complainant’s requested AWA would have a wider impact on the other employees
who worked with the Complainant (and other employees in the OPS more
broadly). In short, Ms. Fremlin raised the concern that if the Complainant’s
request was approved, out of fairness she would have to grant similar requests
from other employees.
[81] The Employer argued that the decision to deny the Complainant’s request for an
AWA was consistent with applicable jurisprudence. In particular, and relying on
- 21 -
the decision in Simcoe (County) District School Board, the Employer argued that it
was appropriate for the Employer to consider the following factors:
• whether approving a request for an AWA could open the floodgates to other
requests from other employees (including employees not represented by
AMAPCEO); and
• the duration of the request.
[82] According to the Employer, and as set out above, Ms. Fremlin was concerned that
if she approved the Complainant’s request to work remotely five days per week
she would have to approve similar requests from other employees. She was also
concerned, again according to the Employer, that it appeared to her that the AWA
requested by the Complainant was open ended and could operate indefinitely.
The Employer argued that it was appropriate for Ms. Fremlin to take these factors
into account when rejecting the Complainant’s request.
[83] The Employer also argued that declining the request due to deficiencies within the
request itself was consistent with a number of cases including: Stewart and
Canadian Nuclear Safety Commission, 2017 CarswellNat 8496 (Chankasingh) and
Wire Rope Industries Ltd. and United Steelworkers, Local 3910 (1982), 4 L.A.C.
(3d) 323 (Chertkow); and Nova Scotia Union of Public and Private Employees,
Local 2 v. Halifax Regional Centre for Education, 2019 NSSC 333.
[84] The Employer argued that Ms. Fremlin properly considered the impact the
Complainant’s requested AWA would have, if granted, on the operational viability
of the worksite. As described above, the Employer was concerned that the AWA
would fetter its ability to determine when the Complainant would be required to
attend at the worksite. The Employer was also concerned that if the
Complainant’s request was granted, many other employees would make similar
requests and it would have to grant those requests as well. Both of those
concerns, according to the Employer, had potentially significant implications for the
operational viability of the Complainant’s request on the worksite.
[85] The Employer also took the position, more broadly, that a manager must consider
factors relevant to the employees request (as set out above) and operational
viability. According to the Employer, granting a request for an AWA simply
because it was operationally viable would be inconsistent with the language in
Article 47.1. The Employer argued that deficiencies in the request, such as those
referred to above (the lack of a compelling reason for the request and the potential
fettering of the Employer’s ability to require the Complainant to come into the
workplace).
- 22 -
[86] The Employer also noted that Ms. Fremlin raised a concern in her will-say
statement that being in the office provides a better opportunity for collaboration,
innovation, relationship and team building.
[87] In terms of remedy, the Employer also argued that if the Board determined that the
Employer violated Article 47, the appropriate remedy would be to remit the matter
back to the Employer so that it could exercise its discretion properly. According to
the Employer, this outcome would be consistent with the Board’s remedial
approach where the exercise of the Employer’s discretion is at issue. The
Employer noted that this remedy was consistent with the following decisions:
O.P.S.E.U (Taylor et al) and Ministry of Community Safety and Correctional
Services, GSB No. 2012-2926; O.P.S.E.U. (Germotte) and Ministry of the Solicitor
General), GSB No. 2019-1524 and O.P.S.E.U. (White) and Ministry of the Solicitor
General), GSB No. 2017-2911.
[88] Applying these cases to the current grievance, the Employer argued that the
Complainant is not entitled to a specific AWA (or any AWA at all). In addition, the
Complainant stated in his evidence that his request was intended to initiate a
conversation with the Employer. It was not the intended to be a “take it or leave it
offer”. In the circumstances, if the Board concludes that the Employer improperly
exercised its discretion, the appropriate remedy would be to remit the matter to the
Employer so that it can exercise its discretion appropriately.
[89] In addition, the Employer argued that it would not be appropriate to require the
Employer to exercise its discretion within a stipulated period of time. The
Employer noted that Article 47 does not include any specific timelines, there are no
other decisions where a timeline has been imposed, and imposing a timeline may
hamper the parties’ ability to have fulsome discussions regarding the requested
AWA.
[90] The Employer also noted that the remedy it was proposing (in the event the Board
concluded that there was a breach of Article 47) was consistent with some of the
decisions cited by the Association. In Roffey et al., PEGO, and Ontario
(Workplace Safety and Insurance Board) and CUPE Local 175, (2015) 255 L.A.C.
(4th) 223, the GSB declined to grant specific orders being sought. Rather, as set
out above, in Roffey et al, the Board declared a breach and ordered the Employer
to direct the TRO managers to exercise their discretion in good faith. In PEGO
and Ontario and CUPE Local 175, the issue of remedy was remitted to the parties.
c. Association Reply
- 23 -
[91] In its reply, the Association argued that in Roffey et al., the Board concluded that
Article 47 is a restriction on management’s right. It prescribes what the Board
must consider when an employee requests an AWA. The Association argued
there was no reason to depart from the Board’s decision in Roffey et al.
[92] The Association emphasized that the evidence supported the conclusion that the
Employer failed to consider the Complainant’s request in good faith and instead
declined the request because of the two SOC memos. The Association noted that
Ms. Fremlin raised a number of concerns in her will-say regarding the
Complainant’s request that were not found in any of the contemporaneous emails.
The Association argued this evidence should not be given any weight.
[93] The Association also sought to clarify that the failure to provide the Complainant
with the true reasons for denying his requested AWA was evidence that the
request was not considered in good faith as required by Article 47. In short, the
Association argued that Ms. Fremlin was told she could not communicate the true
reasons for denying the request. As a result of this direction, the Association
argued that Ms. Fremlin was not able to consider or respond to the Complainant’s
request in good faith.
[94] Finally, the Association argued that in the circumstances of this case, the relief it
had requested should be granted.
III. Analysis and Decision
[95] There is no dispute that subject to the provisions of the Collective Agreement, the
Employer has the right under Article 3 to direct the workforce, including the right to
determine work methods, the location of the workplace and the right to make
reasonable rules and regulations. Article 47 limits how the Employer can direct the
workforce when faced with a request for an AWA. Pursuant to Article 47, the
manager is required to consider an employee’s request for an AWA. The manager
is required to consider in good faith, both the employee’s request and the
operational viability of the AWA for the work site.
[96] Based on the evidence before me, I have concluded the Employer did not
consider, in good faith either the Complainant’s request or the operational viability
of the AWA for the work site. As such, the decision to deny the Complainant’s
request for an AWA violated Article 47 of the Collective Agreement. Accordingly,
the grievance is allowed.
a. The Complainant’s request not considered in good faith
- 24 -
[97] The evidence shows that the Employer did not consider the Complainant’s request
in good faith. As set out in detail above, by way of email dated April 13, 2022, Ms.
White indicated that employees were required to return to the office unless there
was a pre-existing flexible work arrangement, a medical reason or a family status
accommodation was required. Ms. White also stated that the Employer was not
entertaining any permanent AWA’s at that time and that the two SOC memos
required all employees to return to the office.
[98] In the April 13 email, Ms. White also told Ms. Fremlin that these reasons could not
be shared with the Complainant. Later, Ms. Fremlin was told not to disclose the
real reasons for denying the Complainant’s request because there was a concern
that a grievance would be filed once he was told his request had been denied.
[99] At the end of her email to Ms. Fremlin, Ms. White provided a draft response. That
response is reproduced again here for convenience:
I have reviewed and considered the information which you have provided in
support of your request. However, based on the information you have
provided I do not find there to be personal or extenuating circumstances
preventing you from returning to the workplace. In consideration of the factors
you have outlined and consideration of employers operational requirements,
I’m unable to approve your request for a 5 day telework arrangement at this
time. Therefore, in the absence of additional information, you are expected to
attend the workplace on DATE.
[100] Again, as discussed above, Ms. Fremlin indicated that she had grave concerns
with the proposed response. Ms. Fremlin noted that the Complainant’s request
was thoughtful and genuine. Ms. Fremlin also noted that the proposed response
was not responsive to the Complainant’s request because it did not address the
reasons the Complainant gave for requesting the AWA. In cross-examination, Ms.
Fremlin agreed that the “real reason” the Complainant’s AWA request was being
denied was because she was required to follow the two SOC memos.
[101] Following the April 13, 2022 email, there was a series of emails between Ms.
Fremlin, Ms. White, Mr. Barnes, and Ms. Root. Throughout these emails, Ms.
Fremlin reiterated various concerns with the Employer’s proposed response. Ms.
Fremlin continually raised concerns that the communication with the Complainant
was not providing the real reason for the denial. She noted repeatedly that the
Employer’s proposed response was not responsive to the issues the Complainant
had raised. She also indicated that the Employer’s proposed response gave the
impression that she alone was deciding the Complainant’s request when that was
- 25 -
not the case. Finally, and crucially, Ms. Fremlin noted that it was her
understanding that the Employer would not accept any AWAs that went beyond
what was being permitted under the two SOC memos.
[102] The parties agreed that the fourfold test sets out the standard for the Employer’s
exercise of discretion. Based on all of evidence presented, I am satisfied that the
Employer did not meet any aspect of the fourfold test. As argued by the
Association, the Employer took active steps to avoid disclosing the true reason for
denying the Complainant’s request. It provided responses that were
unresponsive. The Employer continually referred to the lack of “personal and
compelling circumstances” for the Complainant’s request despite both Ms. Fremlin
and the Complainant, repeatedly advising that his request was not based on
personal or compelling considerations. Ms. Fremlin raised her concerns with Ms.
White and Mr. Barnes. Mr. Barnes shared Ms. Fremlin’s concern that managers
were not at liberty to tell employees the real reasons for denying a request for an
AWA. The decision not to advise the Complainant of the true reasons for denying
his request is indicative of a process that was clearly inconsistent with making a
decision in good faith.
[103] I also agree with the Association that Ms. Fremlin was not permitted to engage in a
“genuine exercise of discretion”. To the contrary, she was told from the outset by
Ms. White that the Employer was not approving AWAs that included remote work
beyond that contemplated in the two SOC memos. Similarly, Ms. Root “strongly
recommended” that she use the language proposed by Ms. White in responding to
the Complainant’s request. In an email to Mr. Barnes, Ms. Root noted that the
language proposed by Ms. White “was developed by Employee Relations” and
was consistent with wording being used across the OPS in similar cases.
[104] Nor did the Employer give consideration to the merits of the Complainant’s
application. Ms. Fremlin noted that the request was “thoughtful and genuine”.
Many of the reasons given for his request were taken directly from the OPS
flexible work strategy. However, other than noting that the Complainant’s reasons
were mere “preferences”, and not “especially compelling”, the Employer failed to
engage with the Complainant’ specific request. Rather, it applied the two SOC
memos and used those memos as the basis for denying his request. As such,
there is no evidence that supports the conclusion that the Employer satisfied this
aspect of the fourfold test.
[105] Finally, the evidence established not only that the Employer failed to consider all of
the relevant facts but also considered irrelevant factors. Primary amongst the
- 26 -
irrelevant factors the Employer considered were the two SOC memos. The Board
in Roffey et al addressed this issue and stated as follows:
Of particular note is the requirement to consider all relevant facts and reject
irrelevant considerations. Article 47.1 states: “In considering any AWA, the
manager will consider in good faith both the employee’s request and the
operational viability of the AWS for the work site.” Thus, a manager must
consider factors relevant to the employee’s request and to the operational
viability of the work site. Other factors are irrelevant.
Factors relevant to an employee’s request are inherently individual: they
require consideration of the employee’s circumstances. Factors relevant to
the operational viability of an AWA for a work site may include consideration of
the work site in a larger context. OPS-wide factors, such as a direction from
the SOC, may be relevant to what is operationally viable for a work site. They
cannot, however, trump other relevant factors, including purely local factors.
This is because, as stated by Arbitrator Parmar in McMurrich Sprouts Daycare
and CUPE, Local 4400 (Szwaj) Re, 2013 CarswellOnt 18633 (Ont. Arb.) at
para: 33 “Focusing on a single fact is akin to applying a blanket policy as it
allows the Employer to ignore relevant information.”
As a result of the SOC’s March, 2022 Memos, the TRO changed its “office
standard” for remote work from the anticipated four days a week to three days
a week. To the extent this constituted a change in the direction which the
Employer was giving to its managers as to the number of days of remote work
to which they should agree in a requested AWA, it was a permissible exercise
of management rights. If, however, it also constituted a direction not to agree
to more than three days per week, it was in contravention of the obligation of
managers under Article 47 to consider such requests in good faith.
[106] In this matter, I am satisfied that the two SOC memos were interpreted, and
applied, as a prohibition on agreeing to an AWA that included more than two days
of remote work per week. As noted repeatedly in the Employer’s emails set out
above, the flexibility contemplated by the two SOC memos was that employees
would not be required to come into the office five days a week and employees
could choose the days of the week they worked remotely. However, beyond that,
there was no consideration of allowing employees to work more than two days per
week at home (let alone five as requested by the Complainant). In that sense, the
Employer interpreted the two SOC memos in the exact same fashion that the
Board found to be a contravention of Article 47 in Roffey et al.
[107] In short, the evidence is overwhelming that the Employer did not consider the
Complainant’s request in good faith. To the contrary, the Employer deliberately
- 27 -
mislead the Complainant when it denied his request, refused to provide the “true
reasons” for its decision, and applied the two SOC memos without regard to the
merits of his request. In so doing, the Employer breached Article 47 of the
Collective Agreement.
b. Operational viability of AWA for the work site
[108] The Employer also failed to consider the operational viability of the Complainant’s
request for the worksite. The evidence was perhaps more conclusive with respect
to this aspect of the test under Article 47.
[109] The Complainant indicated that he had worked remotely throughout the pandemic
and had had no problems fulfilling the duties and responsibilities of his position.
To the contrary, the Complainant believed that he was more effective, and more
efficient, working from his home office. There was no evidence that contradicted
the Complainant’s belief in this regard.
[110] Similarly, Ms. Fremlin noted repeatedly in her emails with Ms. White and Mr.
Barnes, that she believed the Complainant could carry out 100% of his job working
remotely. Ms. Fremlin noted that the Complainant had done so for approximately
two years during the pandemic.
[111] The evidence also demonstrated that important aspects of the Complainant’s
position had been fulfilled remotely prior to the pandemic. There was no dispute
that IDS employees worked out three different locations: one in Sault Ste. Marie,
one in Thunder Bay, and one in Sudbury. Prior to the pandemic IDS employees
held weekly meetings with individuals in Thunder Bay and Sudbury joining by
teleconference. Similarly, larger branch meetings, involving employees working
out of Sault. Ste. Marie, Thunder Bay, Sudbury, Peterborough, Timmins and
elsewhere in Ontario, were held on a bi-weekly basis. Here too, individuals
working outside of Sault Ste. Marie joined those meetings by teleconference. Both
the weekly and bi-weekly meetings continued by way of videoconference during
the pandemic.
[112] Ms. Fremlin did raise a number of concerns about the operational viability of the
Complainant’s requested AWA in her will-say statement. Ms. Fremlin indicated
that she was concerned that the Complainant’s requested AWA would fetter the
Employer’s ability to determine when in-office attendance was required. She also
indicated that she was concerned that the Complainant’s requested AWA ran
counter to the AWA template agreement in the AMAPCEO collective agreement.
She was also concerned about the possibility of a “floodgates” whereby, in light of
- 28 -
the somewhat “generic reasons” the Complainant provided for requesting the
AWA, she would be required to approve other similar requests in the future.
[113] However, these concerns are either absent in the contemporaneous record before
the Board, or only raised in passing. In addition, Ms. Fremlin confirmed in her
cross-examination that she believed the Complainant could fulfill all the
requirements of his position remotely. The only conclusion that can be drawn from
Ms. Fremlin’s evidence was that she was overwhelmingly confident that the
Complainant could perform all the duties and responsibilities of his position while
working remotely and that the requested AWA was operationally viable for the
worksite.
[114] One final point on the issue of the operational viability of the AWA for the worksite.
The Employer called some evidence, including one of Ms. White’s initial emails,
regarding a concern that granting requests such as the Complainant’s would have
a negative impact on team building and cohesion.
[115] While, perhaps a concern, I have not given this evidence very much weight for the
following reasons. First, as set out above, Ms. Fremlin’s evidence clearly
established that the Complainant’s ability to work remotely outweighed any other
considerations. Second, as also set out above, employees in the IDS worked in
separate offices before the pandemic. In the circumstances, I am satisfied that the
effect on the Complainant’s request on the operational viability of the worksite, and
in particular on “team cohesion” is significantly reduced. Third, there was no
evidence regarding the specific effects granting the Complainant’s requested AWA
would have on team cohesion or team building. In the context of the evidence as
a whole, this concern appeared to be more of a template response in the event of
a requested AWA (such as the Complainant’s) as opposed to a bona fide, thought
out, response to a specific request. Fourth, Article 47.3 of the Collective
Agreement permits the cancellation of an AWA with 30 days’ notice. Should it
become apparent that granting requests such as the Complainant’s are having a
negative impact on team building and cohesion, the Employer may give notice of
cancellation of the Complainant’s AWA.
c. Remedy
[116] For all of the reasons set out above, I am satisfied that the Employer’s response to
the Complainant’s request for an AWA breached Article 47 of the Collective
Agreement. The Employer did not consider, in good faith, the Complainant’s
request or the operational viability of the requested AWA for the worksite.
- 29 -
[117] As set out above, the Association seeks to have the Complainant’s AWA
approved. In the alternative, the Association has requested that I direct the
Employer to re-assess the Complainant’s request for an AWA in a manner that
complies with the Collective Agreement. The Association further requests that I
direct the Employer to do so within a limited period of time. The Association
suggests that two weeks would be appropriate.
[118] The Employer submits that if the Board finds a violation of Article 47, it would not
be appropriate for the Board to grant the Complainant’s requested AWA. Doing so
would effectively usurp the Employer’s authority to manage the workplace,
according to the Employer. Rather, the Board should remit the matter back to the
Employer so that it can consider the request once again. Remitting the matter
back to the Employer is consistent with the Board’s approach in other matters
where the Employer’s exercise of its discretion has been challenged.
[119] The Employer also submits that no time-limit should be imposed on the Employer
in re-considering the Complainant’s request for an AWA. The Employer noted that
imposing such a time-limit cannot be justified on the basis of the language of
Article 47. Nor is there any precedent for doing so. Finally, the Employer submits
that applying such a timeline could hamper the parties’ ability to meaningfully
discuss the Complainant’s request.
[120] In the circumstances of this case I am not prepared to direct the Employer to grant
the Complainant’s requested AWA. I agree with the Employer that doing so would
usurp its discretion. Rather, the request should be remitted for the Employer to
reconsider in a manner consistent with the Collective Agreement and this decision.
[121] I am also not prepared to direct the Employer to decide the Complainant’s request
within a stipulated amount of time. There is no basis for such a direction at this
point in time. There is no evidence that the Employer dragged its feet in anyway in
considering the Complainant’s request. That being said, my hope would be that
this award will provide the Employer with guidance on the factors it should
consider in making its decision (and those that it should not). I would also note
that in certain circumstances a failure to consider, and respond to, a requested
AWA within a reasonable amount of time could be evidence of a failure to consider
that request in good faith. And of course, I will remain seized of any issues arising
from the implementation or enforcement of this award.
[122] Accordingly, and for all of the foregoing reasons, the grievance is allowed. The
Employer’s conduct in declining the Complainant’s request for an AWA violated
Article 47 of the Collective Agreement. The Complainant’s request for an AWA is
- 30 -
remitted to his manager Ms. Fremlin to be considered in a manner that complies
with the Collective Agreement.
Dated at Toronto, Ontario this 27th day of June 2024.
“Adam Beatty”
_________________________
Adam Beatty, Arbitrator