HomeMy WebLinkAbout1982-0440.Black.85-01-10IN THE MATTER OF AN ARBITRATION
Between:
Before:
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
.THE'.GRIEvANCE SETTLEMENT BOARD
For the Grievor:
For the Employer:
Hearings:
OPSEti (Co11 Black)
Grievor
-and- -'
The Crown in Right of Ontario
(Ministry of Revenue)
Employer
E.B. Jolliffe, Q.C. Vice Chairman
R. Russell Member
G.A. Peckham Member
M. Cornish
Counsel
Cornish & Associate'
Barristers & Solicitors
M. Simpson
Counsel
Legal Services Branch
Ministry of Revenue
January 12, 1984
February 16, 17 & 28,~ 1984
Karch 1, 2, 12, 14, 20, 21, 27, 28 & 29,
May 10, 1984
June 5, 6, 15, 19 & 20, 1984
July 9 & 10, 1984
August 9, 10. & 20, 1984
1984
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440/82
DECISION
Mr. co11 Black grieved that his "Employee
Appraisal" for the period from September 1, 1981, to
February 28, 1982 "does not reflect my true performance. It
contains unjustified criticisms."
The griever, who holds the C.G.A. qualification,
was employed by~the Ministry of Revenue from 1965 and became
a senior auditor in 1969. He served as a "group leader" in
the Retail Sales Tax Branch and was later assigned to other
duties, particularly the audit of large vendors, being
assisted at times by junior audito;s. He was classified
l,Tax~ Auditor 3," after being promoted in January, 1969.
The appraisal complained of, Exhibit A-2, was in'
respect of the period from September 1, 1981 to February 28,
1982, but bears the following notation, (signed by a super-
visor , Mr. John Haalboom) that "original copy received by
co11 Black on J~une 14/82." Another notation states: "Mr.
C. Black was not willing to sign." His grievance (Board
file 440/82) appears to have been presented on 'July 27,
1982, and was referred to arbitration..on September 22 of that
year:
Strictly speaking, this decision relates to one
particular grievance. It is, however, impossible to
overlook or ignore a context in which six other grievances
have been referred to arbitration. An earlier grievance
(which was never referred to this Board) had partial success
when the Deputy Minister required amendment of an E.P.A. We
have heard evidence at great length and considered numerous
documents, including audit files, in respect of the
griever's performance from 1979 to 1982, but not yet in
respect of the subsequent period. It is relevant to note
that this panel '.' of ~the Board is charged with the
responsibility of adjudicating other grievances, as follows:
(1) A grievance against the denial of one day's
vacation leave (Board file 4,39/82) dated August 13, 1982.
._
(2) A grievance dated August 27, 1982, against an.~~.
appraisal for the period from March 1, 1982, to May 31, 1982
(Board file 23/83). .~
(3) A grievance dated September 24, 1982, against
an appraisal for the period from June 1, 1982, to August 31,
1982 (Board file 266/83). .
(4) A grievance dated December 13,. 1982, against-
-a one-day. suspension without pay (Board file 267/83).
(5) A grievance dated January 27, 1983, against a
five-day suspension (Board file 594/83).
(6) A grievance dated March 29, 1983, against
dismissal (Board file 618/83).
It had been proposed at one time to hear all the
evidence before rendering a decision or decisions, of which
the most important would obviously relate to the dismissal
in 1983. Nevertheless, the evidence relating to. one
grievance and'ifs background has takenmany months and the
parties now request that the first decision be issued at
this time. This the Board has been reluctant to do, but a
useful purpose may be served if by any chance it should lead
to an early resolution by other means of the whole matter,
which appears to constitute a serious problem for both the
employer and the griever.
NO doubt the appraisa,l dated May 31, 1982 (three
months after the period reviewed),discloses the management
assessment of the griever's performance and sheds lig.ht on
subsequent events, which included other unfavourable
appraisals, two suspensions and finally a dismissal. Never-
theless, as previously stated, this decision must focus on
the appraisal dated in May, 1982, and determine whether or
h
not it meets Ministry standards of objectivity and fairness.
The appraisal consists of a rating sheet (Form B)
three and a quarter pages of "comments," single-spaced, and
three pages of "attachments," being two letters;
The rating sheet, reproduced on the next page
hereof, explains itself. It may be seen that management
rated the griever:
(1) Low Satisfactory for Reliability of Judgement,
(2) Low Satisfactory for.Technical Competence,
(3) Unsatisfactory for Organizing Ability,
(4) Low Sa&sfactory for Communication Skills:
For "Personal Factors," the griever 'received:
(1) In Capacity for Development, a rating of~.3 on
a scale of 5,
(2) In Adaptability, 5, being shown as "Poor,"
(3) In Initiative, 4, being a little better than
"Poor."
1~~ RELIABILITY OF JUDCEMENT
Consider ability to 6btain and to analyse
facts and to develop consistently sound
zonclusions.
i TECHNICAL CO.UPETE,VCE
!Lxnider the extnnt of the employee’s
lob knowledge.
1 ORCANIZI?IG .4B/LlTY’
Consider ability to ~1x1 his/her own work
znd:or effectively co-ordinete the work of
‘I-ask For&
Consider ability in verbal and written
communications to convey information
and recommendations to .support policy.
administrative decisions and legislation.
cl
cl
q
,.
The testimony of four management witnesses,
including Messrs. Haalboom and Lukassen, establishes that
the rating sheet accurately reflects their opinions about
._.
the griever's performance during the period under review.
To assess the validity of those opinions it is necessary to
-consider ..a11 their comments attached to the rating sheet --
and also of course their testimony and that of the griever.
The Board has reached certain conclusions about the *
appraisal complained of. These will be stated in due course.
It must be said, however, that there are 'limits to the
elaboration of our reasons. To thih point there have been
24 days of hearings, during which five witnesses testified
at length and counsel presented painstaking arguments. The
Board was asked to examine and consider several thousand
pages of documents, all of which are more or less relevant
to the performance issue. It is impossible to~summari-ze or
review such material adequately, except in a full-length
book, which this Board is not prepexed to undertake. Our .?
~view of the material can best be epitomized in assessing the
"comments" appended to the rating sheet.
The bulk of the evidence and the length of
arguments were doubtless inevitable. The management cause
against the griever over a three-year period was based on
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alleged unsatisfactory performance, and not (as in many
other cases) on one or more instances of misconduct calling
for disciplinary action. The result of relying on
"unsatisfactory performance" led to an examination --- at
times a microscopic examination --- of many files for which
the griever was responsible and which were' invariably
subject to review by his supervisors and sometimes by others
as well. ~~, .
Preliminary reference must be made to appraisals
prior to the appraisal dated in May; 1982.
Exhibit G33 is an appraisal for the 16-month period
from July 1, 1979, to October 31, 1980. In three categories
Mr. Black was rated Average Satisfactory. In the fourth ---
Organizing Ability --- the rating fell to Low Satisfactory.
The other ratings were: Capacity for Development --- 2, a
little below "Good;" in both Adaptability and Initiative --
3, which apparently means average on a scale of 5. Only one
page of comments was attached. Most were favourable or
highly favourable, but there was criticism of his use of
time.
The ratings in this appraisal were made by Messrs.
J. Peacock and EvertonClarke, and approved by Chief Audit
,
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Supervisor J.G. Coil. It was explained that "this
appraisal covers a period in which Mr. Black acted as
Senior Technical Auditor for large vendor audits for 13 l/2
months and as Group Leader responsible for an audit team on
retailer and hospitality audits for 2 l/2 months." Under
the heading of Technical Competence it was said: "Co11 has a
good knowledge of the Act, policy and procedures and of
accounting and auditing techniques. He continues to improve
his knowledge of the EDP environment." Mr. Clarke signed
this favourable appraisal, but in testimony before us was
highly critical of performance before October 31 as well as
after.
The next appraisal, Exhibit G32, for the lo-month
period from November 1, 1980, to August 31,'1981, was a
marked departure from the previous appraisal. Prepared by
Messrs. E. Clarke and J. Haalboom,' approved by the new
Chief Audit Supervisor, Mr. Paul Masse, and dated September _.
4, 1981, it gave an Unsatisfactory Rating in three cate-
gories and Low Satisfactory in the fourth, Communication
Skills. The three PersonalFactors were rated 3, 5 and 4
respectively.
Although Mr. Black had spent more than four months
of the period performing instructional~ and supervisory
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duties on a special project in the Retailer/Hospitality
Section (i.e. hotels, bars and restaurants) the Comments
explained that "the thrust of this appraisal is
concentrated within the period when Co11 operated as an
Auditor of large Vendors."
There was severe criticism of Mr. Black's
Reliability of Judgement, Organizing Ability and
Communication Skills. The longest comments were on his
"Technical Competence." While conceding his experience and
qualifications, it was said that "Co11 has consistently
failed to exploit these assets..." It was also said that
In he avoids following any given instructions which may;'
conflict with his opinions."
These strictures were of course protested by Mr.
Black. Five days later Chief Audit Supervisor ..,Masse wrote
him in Exhibit G28 vigorously confirming the appraisal and
concluding with these words:
As explained to you during the interview, your
Job Performance will be appraised again after the
three-month period ending November 30, 1981. If
during this period we do not see a significant
improvement in your work performance and attitude
it will be necessary to consider further
disciplinary action such as suspension, fines,
demotion or dismissal.
;.:
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The word "further" suggests a little confusion in
Mr. Masse's mind, since there had been no previous
disciplinary action unless an unfavourable appraisal be so
regarded, an incorrect view. A negative appraisal cannot
be construed as a reprimand.
Actually, there had been considerable
procrastination on the part of supervisors. -+On June 25 ,
1991, Mr. Masse had sent a memo, Exhibit G51, to Messrs
Haalboom and Clarke reminding them that "several.weeks ago"
he had asked for an appraisal. He did not receive it until
September. -a-
Mr . Black grieved aga'in st the appraisal of
September 4, 1981. On December~ 2, 1981, Deputy Minister
T.M. Russell wrote Mr .;~. Black in Exhibit G36, ,advising of
his investigator's report that "although nothing was brought
forward to show that the appraisal ias manifestly wrong,
management failed to produce evidence in support Oft the
unsatisfactory rating and comments on the Technical
Competence.- "factor," Accordingly, the Deputy Minister's
decision was that '8 your performance appraisal should be
amended to show an average satisfactory rating for Technical
Competence and the comments on this factor should be
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deleted. The remaining ratings and comments should remain
unchanged. A further EPA for the period ending February 28,
1982, is recommended."
Mr. Black replied on December
concluding with the following statements:
23, Exhibit G61,
'Ihe E.P.A. on which I have grieved was not prepared
with any reasonable criteria, i.e., the statements.
and ratings could. not be supported by specific
examples. It therefore has no validity and is
totally unacceptable to me.
Your recommendation for the resolution of the
grievance does not address these specific problems.
However, I respect you and your position and
believe your decision is in the best interest of
all concerned.
No further action will be taken by me in this
matter.
Mr. Black had made a number of suggestions in his
.I(.
letter to the Deputy Minister. As these seem to summarize
the position he takes (in his own defense) in relation to
appraisals, they may be worth quoting at this point:
I offer the following for consideration as
standards for the preparation of E.P.A.'s:
- There should be no surprises in the E.P.A.;
- All statements in the E.P.A. can be supported by
specific examples;
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- All negative statements in the E.P.A. are
supported by a previous discussion, during which
the supervisor has explained and shown the
employee that there is a valid area of concern;
- The ratings given must agree with the specific
examples ;
- Negative statements should not appear on the
E.P.A. until the employee has been allowed time
to correct the deficiency
It is obvious that the partial success in 1981 of
.?.
Mr. Black's first grievance did not enhance his standing in
the eyes of the younger men who were his supervisors.. The
amended appraisal is Exhibit G33.
The next appraisal (dire.cted by the Deputy Minis-~,
ter to cover the period ending February 28, 1982) was not
completed by supervisors until May 31, 1982, three months
later.
It must de kept in mind that neither of the two
appraisals described above are before this Board for
adjudication. They do, however, form part of the background
for the appraisals which followed in 1982 --- and the
dismissal in 1983.. Moreover, a great deal of detailed
testimony was given by Messrs. Masse, Clarke and Haalboom in
support of the ratings and comments in the appraisal. 05
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September 4, 1981. As a result the Board is obliged to
offer certain observations in respect of that testimony.
Many of the details related to several audit
files assigned to Mr: Black between February and May, 1980.
On these, it appears from Exhibit G38 and other documents,
he had not comple'ted his work by the end of September. In
August he had been assigned to full-time work in the Hospi-
tality Section under a different supervisor, Haalboom. In
January he returned~to audits of large vendors under the
supervision of Mr. E. Clarke. Even then there was delay in
completing audits begun in 1980, and Mr. Clarke sent an .
angry memo about two files to Mr. Black on March 2, 1981.
One of these audits, file V3, had required the assistance of
other district offices in Ontario and --- according to Mr..
Black --- their work was not all available. The other was
file VE, which had an extremely complicated history, of
which more will be said.
There were about 60 auditors in the District and it
is a little difficult to understand why the auditor in
charge of an audit as important as V8 would be transferred
-.-to other duties in an entirely~ different Section for a
period of four months or more. Clearly, there was a spill-
over of responsibility from one-group of duties to another
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---
and again a different type of spill-over when the audi-
tor returned to his work own large vendors. Perhaps some of
the work could have been completed on an overtime basis, but
not all of it because auditing of large vendors required
visits to their premises during business hours..
It is also difficult to understand why there was
not better co-ordination between the two supervisors
involved. For example, when Mr. Clarke wrote to Mr. Black
about his unfinished audits on October 31, 1980, he sent a
copy to Mr. Coil, Chief Audit Supervisor --- but not to Mr.
Haalboom, Mr. Black's supervisor at the time in the Hospi-
tality Section. Mr. Clarke claims he had told Mr: Haalboom
about the problem "orally and informally," but the latter
testified that he was not aware of it when he completed on
November 1 -2 I 1980, the appraisal which is Exhibit G33.
Our other comment must be that we have been given
no convincing~ explanation for the sharp change in manage-
ment opinions between November, 1980, and September, 1981.
What had been a favourable appraisal rather suddenly became
a highly unfavourable appraisal. This is most noteworthy in
one category: in the earlier appraisal Mr: Black's Tech-
; in the next it was severely nical Competen-ce was praised
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criticized, which did not escape notice by the Deputy
Minister's investigator. .,..
We turn now to the appraisal completed in 1981,
which, unlike the earlier appraisals, has been referred to
arbitration as 440/82. It related to the period between
September 1, 1981, and February 28, 1982.
General Comments were stated as follows: ..j
During the period of this appraisal, Mr. Black
acted as Senior Auditor in charge of the following
conglomerate vendor audits:
va , v9, v12, Vll, v14
It was his responsibility to-audit these vendors
and to resolve zy non-compliance encountered (with
the occasional assistance of Junior Auditors under
his direction). Mr. Black also participated in a
collection project wherein'he was responsible to
collect accounts and clear defaulted returns for 45
vendors.
It should be explained that numerous audit files
were admitted into evidence at hearings in this case. For
-purposes of anonymity the vendors' names were blacked out
and file numbers substituted. Thus files are identified as
V8, V9, etc.
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The reference to the accounts and defaulted
returns of 45 vendors was erroneous. Mr. Haalboom
eventually testified, as other evidence has shown, that only
31 were actually assigned to the griever. This matter is
referred to in subsequent comments.
As previously stated, the rating sheet placed the
griever at the Low Satisfactory level for Reliability of
Judgement. The comments under this heading begin as
follows:
Co11 displayed poor judgement during his conduct of
two audits:
W and VS
During the audit of 69, ti. Black discovered that
the vendor had not accounted for tax on own use of
certain electronic landing eguipnent on loan to the
Federal Department of Transport. Mr. Black had
made his decision that all of the loaned equipment
'should be taxable to W. He was very reluctant to
accept the direction.pf his supervisor to assess
only a portion of the equipment on.loan. Although
his supervisor explained the Branch position on the
taxability of the equipment to Wr. Black, Co11
could not accept the position. His supervisor,was
forced to assert his authority in order to gain Mr.
Black's acceptance of his supervisor's position - a
tactic which should not have been necessary to
efxsure a Senior Auditor's acceptance of the
direction of his supervisor.
The testimony in support of the above' statements
is that of Mr. Haalboom. There is, however, certain other
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-- evidence,~ including that of Mr. Black. The difference of
opinion as to taxability was not as simple or as clear-cut
as Mr. Haalboom suggested in his comment. Moreover, his
identification of his own opinio;n with "the Branch position"
is somewhat questionable, since there were other views in
the Branch. When questioned at our hearing, Mr. Black said
he now thinks the issue was a doubtful one which could be
'~decided either way; in cross-examination he indicated his
original opinion had not really changed.
When doing the audit of V9, the griever concluded
that the equipment in question was taxable. Mr. Haalbodm
has said he was not satisfied and consulted others in the
Branch, but he failed to name them. The result was his
decision that only a portion of the equipment "on loan"
~should be.assessed. He seems ~to have based his opinion on
~'
reading the contract between the vendor and the Federal
authority, about which he made notes although these probably
raise legal issues rather than-~ accounting .questions and
could well have been referred to the legal officers of the
Ministry. The griever had an opinion contrary to that' of
Mr. Haalboom, of which he made no secret. We think however,
that Mr. Haalboom was exaggerating when he wrote that he had
been forced to assert his authority. The griever had many
more years of experience in the Sales Tax Branch than Mr.
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Haalboom and was entitled to express his opinion on a rather
controversial point. Being a Senior Auditor he could not be
expected to serve as a "Yes-man." <
The acid tone of Mr. Haalboom's version can best
be explained by an incident which followed. Audit files are
regularly reviewed by supervisors, sometimes during an
audit, but normally on its completion. The V9 file also
went to a "reviewer" under a recently,established procedure.
Mr. Haalboom had made copious comments and queries, dated -..
December 24, on pages REV1 to REV3C of the file. In his
turn, the reviewer also made many comments dated January 18,
1982. On page REV-4b the reviewer, referring to schedule
547 in the file, raised the same question which had troubled
Mr. Black:
why have amounts for a total of $61.971.16 been
deducted as non-taxable? A scrutiny of invoices
for loaned eguipnent indicated that all equipment
loaned is taxable on sale or rental.
The reviewer again raised the issue at page REV-5
in "Further comments on Schedules J-47 and J-50" which he
underlined. He continued:
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According to file documentation the 7801 system
(value $61,971.16) is on loan to . . . . . on a no-
charge basis. In the opinion of the reviewer, V-9
is the consumer and must account for tax on the
l/36 method.
See copy of ruling dated July 11, 1979 from Head
Office in a similar situation.
Mr. Haalboom stood his ground in the following
reply, which appears opposite the reviewer's final comments:
,..
V-9 is the'consumer of a portion of the eguipnent
loaned to . . . . . that portion which will be returned
to V-9 upon delivery of the 7801. Thus tax is
assessed on this portion.
~_ v-9 is not the consumer of that portion of
eguipnent which is in effect delivered under the
contract of sale and on which "tax will be charged"
when the last installment billing is rendered to
. . . . . Thus tax is not assessed on this portion.
Mr. Haalboom found fault with the griever on the
ground that he had failed to give reasons for not assessing
tax. on ~a portion of the equipment, thus leading to a query
from the reviewer. On his part, the griever claimed he was
not familiar with the reasons.; the decision had been made by
Mr. Haalboom. It seems clear that the incident did much to
sour .- the relationship between the griever and his
supervisor, which ;as already somewhat strained. It must be
added that Mr. Haalboom's rather curt explanation quoted
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above did not fully clarify his position: for example it
failed to address the ruling cited by the reviewer or to
distinguish clearly between the facts in V9 and those dealt
with in the ruling.
The. Retail Sales Tax Act and the regulations
thereunder give rise to many difficult questions which tax
auditors are obliged to resolve. As an example, we quote
'passages from the "Post-Audit Letter" sent to V9 over the
signature of Mr. Haalboom. The letter, which is part of a
massive V-9 file, Exhibit A-4, illustrates the complexity of
issues which may be encountered. Addressed to the Company's
Director of Taxation, the letter began by summarizing tax
iiability and certain credits. It then continued as
follows:
Future compliance with the Retail S-ales Tax Act
At the close of the audit we discussed with you the
deficiencies~ in your accounting system and the
required changes to ensure future compliance with the
Retail Sales Tax Act. You agreed that action would
be taken to institute new procedures or amend current
procedures in order to comply with.~the requirements
._ _ or of the Act. The areas brought to your attention are:
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Purchases For C&m Use
When goods purchased for own use are taxable the
purchase order should indicate to the supplier that
he is to charge the tax due. In cases when suppliers
do not charge the tax it is your rqsponsibility to
account for the tax on line 3 of your periodic
return. An example would be goods imported from
another country. Tax is calculated on the fair value,
which is equivalent to the laid down cost in Canadian
funds, and includes the value of goods in Canadian
funds, duty, federal sales and excise taxes, where
applicable, and delivery charges when the goods are
shipped F.O,B. destination. lbe liabililty for tax
results in the month the goods are received.
Loaned Equipment
When equipment is temporarily taken from inventory
for use in the conduct'of your business,. tax is due
on the formula, tax rate x I/36 cost of goods. This
formula is to be applied each month the goods are in
use.
Research and Development
Tax as required by the Act,& payable on all material
consumed in research and development projects. There
are no provisions to exempt taxable materials used in
research and development. However, when a prototype
is sold the tax paid on the materials may be claimed
back.
Printing for Own Use
We brought to your attention an error in your formula
calculation, i.e. manufactured cost of printing
plates and art and layout cost were not being
included in your calculation. Because of the small
amount of tax involved we have not assessed you. C&-
ruling on printing for own use is as follows:
hhen the produced value of printing exceeds $5,000 in
any year you are considered a manufacturer and tax
due can be caiculated on the-manufactured cost or
formula method.
The formula method is calculated as follows: Add the
cost of paper, imaged plate, ink, art and layout
work, calculate and add 220% of the total, add
Federal sales ~tax paid, then calculate the Retail
. ,,,.
I’
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Sales Tax on the total. Report the tax due on line 3
of your periodic return.
Real Property Installation Contracts
Vendors who enter into supply and install contracts
where the equipment, after installation, is attached
to real property, i.e. building, are responsible for
the tax due which is calculated on the vendors cost.
'Ihe vendor will not charge tax on his sales invoice.
Exemption Certificates
'Ihe Retail Sales Tax Act requires all vendors who
make exempt sales to obtain from their customers
purchase exemption certificates. @rtificates.are-to
be kept on file and renewed on their expiry dates.
Vendors who do not obtain certificates could be
liable for the tax not collected.
Post Audit Review
It is incumbent on you.to review your operations for
the period from September 1, 1981 to the present.and
to report any additional tax that is uncovered by
this review on your next return.
As discussed our auditor will be returning to your
'office in order to verify your reporting of any
additional tax.
We thank you for the assistance rendered to our staff
during the audit. Please contact this office if you
require any further information or assistance.
The next three paragraphs of comments on
"Reliability of Judgement".refer to the prolonged audit of
V8 and further illustrate Mr. Haalboom's unfavourable view
of the griever's performance. Whether they constitute fair
Or objective comments is another matter. The three para-
graphs are as follows:
:.:r; : ..
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During the audit of V8, Mr. Black seriously erred
in writing to V8 - asking the vendor to confirm our
agreement which the vendor states was never made.
The attached correspondence evidences that Mr.
Black wrote to V8 on September 11, 1981, asking LB
to confirm an agreement to perform an audit on
sales. V8 responded on October 6, 1981, informing
Mr. Black's supervisor that no such agreement had
been made. On March 10, 1982, Mr. Black wrote to
V8 (at his supervisor's direction) acknowledging
his error of September 11, 1981.
Mr. Black must learn to accept the direction of his
supervisor. Dictatorial action by a supervisor in
order to ensure Mr. Black's acceptance of. his
suprvisor's direction should not recur. __
Furthermore Mr. Black must not again write to a
vendor confirming agreements which do not exist.
Such actions call into question the honesty of the
writer .
-What exactly was said between Mr. Black and the .
V8 Supervisor of Commodity Taxes is not clear. The griever
-.-.I. undoubtedly suggested either an internal audit or review by
the vendor, which may or may not have been agreed to. There
may have been a misunderstanding or any assent given may
have been' ,. subject. ~to approval by another officer of the
vendor. What happened later is perfectly clear. The
griever wrote V8 asking, among other things,for confirmation
of what~had been agreed. This was a relatively innocent
request: +,t often occurs between solicitors when one writes
another seeking confirmation of an understanding thought to
have been reached in a previous conversation. When V8
denied an agreement, three possible explanations were open
to Mr. Haalboom:
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(1) 'Ibere had actually been an agreement, now
repudiated by Vz3;
(2) There had been an honest misunderstanding about
the conversation;
or
(3) NC-. Black stated dishonestly that agreement had
been reached, knowing otherwise.
Mr. Haalboom leaped to-' the third conclusion
immediately. The second alternative above would be most
charitable to both men concerned, but this does not seem to
have occurred to Mr. Haaiboom. Instead, he chose to accept
the version of the vendor against that of his own auditor.
His harsh comment was that "such action calls into question
the honesty of the writer." The comment was neither fair
nor objective. Moreover, :. .., Mr. Haalboom made clear that the
griever's acknowledgment of his error was written "at his
supervisor's direction." Mr. Haalboom had visited V8
together with the griever and seems to have been "ery
Ci"XlO"S to appease a vendor who was declining to conduct an
internal audit of its procedures. 'He testified that when he
visited V8 "they were not even willing to perform a review"
- which suggests that their attitude was subject to change.
It must be added that there may have been some
confusion between the terms "audit"-. and "review". I"
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writing Mr. Haalboom on October 6, 1981, V8 said:
As part of our ongoing commodity tax responsibil-
ities we have conducted periodic reviews of our
sales data originating at the various field admin-
istrative control terminals to ensure compliance
with Federal and Provincial tax requirement and we
intend to continue these reviews in the future to
ensure adequate controls and procedures' are being
followed in accounting for these taxes.
This is the only commitment we are prepared to
acknowledge at this time, however, any tax payable
arising from these reviews will be remitted with
our monthly returns in the usual manner.
Mr. Haalboom himself was not e'ntirely satisfied
with such "reviews." In his letter to V8 of March 10, 1982,
Mr.. Haalboom wrote:
During our discussion of the accounting system for
sales you. provided us with copies of your tax
directives that are issued to managers and
supervisors, they were found to be satisfactory.
You described the system for the accounting of tax
and pointed out that this is a relatively simple
operation with a minor amount of tax collected
therefore, your monitoring level was low. However,
internal audit procedures require checking of the
daily sales and cash and inventory reports. YOU
did not mention any checks to verify the correct
application of tax or that tax collected had been
properly.recorded.
We suggest the following be included in your
program to ensure that tax is correctly charged,
recorded and remitted: .
The internal audit procedure for checking the
daily sales and cash reports of service
stations and restaurants should include a test
check on the percentage of total taxable sales.
- 25 -
A program for the training of new staff on the
correct application of tax and recognition of
taxable merchandise should be implemented.
A guestionaire to evaluate the tax knowledge of
regular sales staff should be used by the
internal audit group during their visits to
service stations and restaurants.
'Ihe implementation of these suggestions should be
made as soon as possible.
The above "suggestions" which were to be
implemented "as soon as possible" sound very much like the
internal audit the grievor had been seeking some months
earlier. Mr. Haalboom seems to have assumed that the vendor
would comply.
Before lea~ving this topic, it must be said that the
V8 audit seems to have taken an inordinate amount of time.
Mr. Clarke, when he was supervising the "conglomerates"
(large vendors) had inquired about progress as early as
October 31, 1980, Exhibit G44, Schedule L6. In his letter
to Mr. Haalboom of October 6, 1981, the V8 Supervisor,
Commodity Taxes, referred to "Mr. Black's thirteen month
audit." .I
I
- 26 -
:
It is true that V8 was a very large company which
had been undergoing expansion and there were undoubtedly
some unusual problems. At one point in March, 1981, Mr.
Clarke ordered the grievor to finish it promptly, then
reported to Mr. Masse that "this file is basically un-
satisfactory as completed," and said "the file will be pro-
cessed as is." The assessment was then "Nil." This did not
satisfy the Audit Supervisor. In May, 1981, the audit was
resumed "with the objective of reviewing and assessing areas
of fixed assets and purchases indicated by Paul Masse in his
memo of May 5, 1981," Exhibit G55, REV-l. The result was a
new land bulky file known as V8, Part 2, which is Exhibit
G55. Another result was an assessment of $18,245.49. Mr.
Haalboom took an active role in this audit, as previously
mentioned, visiting the vendor together with the griever. He
blames the griever for the error; Mr. Black says it was an
. .
arithmetic mistake within the Company.
Even allowing for the fact that the grievor was
assigned to other full-time duties in the latter part of
1980, and was, away on vacation in April, 1981, the prolonged
and confused history of the V8 audit does not reflect credit
on the'grievor or his supervisors. It u-ndoubtedly contrib-
uted to Mr. Haalboom's exasperationwhen he assumed super-
vision over the auditing of large vendors. In testifying,
.~.
- 27 -
he went so far as to say he did not~think the grievor really
understood the V8 system of accounting. In any event, it
appears that tax in a considerable amount was due and
payable by the vendor. The previous "nil )( assessment
required correction because figures:previously given the
grievor were erroneous, as the vendor conceded.
The next group of comments appear under the heading
"Technical Competence," being the category in which t.he
previous rating and comments by Messrs. Clarke and Haalboom
had been overiruled by the Deputy Minister. ThYs time Mr.
Haalboom's comments were more cautious:
M&-. Black has demonstrated some improvement in his
documentation of his audit work. However much of
his improvement can be attributed to much-closer
supervision of his work during this period., For
Mr.'. Black to maintain a satisfactory rating over
his technical competence, he must demonstrate his
ability to maintain and improve his documentation
without close supervision.
Mr. Black is one of the most experienced auditors
in the Branch and is a.' p&fessionally qualified
accountant. As such he,is expected to display a
much improved level of technical competence. co11
can demonstrate such improvement by taking an
overall systems approach to the audit of
conglomerate vendors, limiting his time and testing
to critical points in the system. Co11 is expected
to put his expSrience and qualifications to good
use in his audits of conglomerates by, for example,
utilizing statistical sampling and computer
assisted audit techniques whenever feasible. .-.
.,..
- 28 -
The above paragraphs acknowledge "some improvement"
but attribute it to "much closer supervision." In other
words, if there had been an improvement, credit was due to
thee supervisor (Mr. Haalboom) rather than to the griever.
The two paragraphs give the impression of being an attempt
to justify the previous rating --- which had been over-
ruled.
The comments next appear under the heading
"Organizing Ability." There are eight paragraphs referring
to several different audits undertaken by the griever during
the review period.
on V12:
The first paragraph gives some credit to his work ::
As evidenced by his request for addditional time on
his audit of VU, Mr. Black has demonstrated that
he can, when he wants to, organize his audits so as
to minimize his audit time. Specifically Mr. Black
notes in his request that he has obtained the
vendor's assistance in preparing information and
working papers to support a tax liability over the
vendor's own use of eguipnent on loan and service
parts.
The comments continue with the following paragraph:
- 29 -
However several actions by Mr. Black have
demonstrated his unsatisfactory ability to
organize.
~The next paragraph refers to V9.
He failed to properly organize the work of an
assistant performing an analysis of the tax
liability account during the audit of V9. This
resulted in theassistant spending excessive audit
time with little contribution towards the audit.
This was one of a-number of cornplaints made from
time to time
that the griever failed to give adequate
guidance to juniors or students assigned~to help him. Some
of the complaints seem to be justified, aithough it must be
kept in mind that the auditornormally had several
audits
under way. at the same time, so that he could not watch
continuously the work of a junior. The nature of the work
often made it necessary to assign a particular task and then
leave the junior alone to carry it.out.
It is a cardinal rule that the auditor should
organize his file in s.uch a way that all the work and its
results can be readily understood by the supervisor nor
reviewerwho reads it. Thus the files include a great deal
of detail. Documents containing review comments and queries
- 30 -
together with the answers thereto are styled "REV I0 and
normally appear at the top of the file. Correspondence with
vendors and other letters are styled "L." Then appear a
series styled "T'I which give details of all hours spent on
the audit by the auditor and/or his assistant, if any,
together with memoranda relating to requests for time in
addition to the time originally allocated. The series
styled "A I, includes documents relating directly to
assessments calculated by the auditor --- ix. the
assessments of tax liability. These often include
directions given the auditor by his superiors --- and the
auditor's replies or explanations. The latter may consist of
many sheets and columns of figures derived from the vendor's
books, as well as hand-written explanatory memoranda. For
supporting documents the letters "C" or "J" or other letters
may be used.
In their testimony supervisors attached ,importance
to the "T" sheets which disclose time spent and requested.
This is summarily dealt with in the fo.llowing ,paragraph
under the heading of Organizing Ability. The .hours stated
in the original comments were not correct. They appear
below as corrected by representatives of the employer at the
hearings held by this Board:
- 31 -
Although Mr. Black was instructed to m.ake formal
requests for additional audit time and to submit :
his audit files for review upon reaching previously
approved time, he did not do so during the audits
of V12 and VllB. Gn VlZA he expended 65 l/2 hours
without approval while on Vll he has used 54
unapproved hours. It is further apparent from the
review of these files that Wr. Black's working
papers contain little evidence that Mr. Black has
planned the use of his time.
T’:
It is apparent that the griever was often late in
applying for more time. In some cases it was
inevitable
that mpre time would be required. The original .time
allocations were set arbitrarily by supervisors who could
not possibly foresee the problems that might arise,
particularly with vendors who had not been audited for
sever.31 years, or not audited at all 'in the past. The
griever's requests for more time seem to. have been approved
--- sometimes with an order to speed up the, job. Another
complaint by supervisors who testified was that the
griever's reports showed too much "fractured time," i.e.
work for an hour or two at two~or more different places on
the same day. The griever's answer is that this is often
necessary. The documents'he'needs to see or the person he
needs to interview may not be immediately available, in
I. ~',",
which case the auditor must move on to another vendor. The
result‘ is of course that a part of "working time" is
actually travel time.
- 32 -
No infotmation was offered __- in 24 days of
hearings --- as to the amount of additional time
requested
by other auditors. Indeed, with one exception, evidence
..:_-
regarding the performance of others (.or the content of their
files) was conspicuous by its absence. There is thus little
or no way of. knowing whether their productivity or effic-
iency wasany better than the griever's, i.e. whether his
performance was average or below average. What is clear
is that many features of his style of work irritated or
annoyed his supervisors.
The exception just mentioned arose in connection
with the next paragraph in Mr. Haalboom's comments. It is
as follows:
WI-. Black's results of his efforts to clear
defaults and collect accounts during the collection
project demonstrate further a serious inability on
his part to use his time effectively. Whereas
other audit staff~cleared between 51 and 88 percent
of the accounts assigned to them, Mr. Black cleared
only 18 percent. .His work over a four week period
resulted in only 8 accounts cleared - and those
were of the easiest types to clear.
Some ~of the statements above were~ not factual, as'
Mr. Haalboom was eventually persuaded to admit. He had
,
- 33 -
said at the outset of his comments that the griever had been
"responsible to collect accounts and clear defaulted returns
for 45 vendors," which is simply not so.
In November, 1981, ~Mr. Haalboom presided over a
project designed to assist collection officers in clearing
payments and returns in default. Auditors were asked to
concentrate on this project for three or four weeks. Mr.
Haalboom gave the griever 45 files. However, the Compliance
Office on the same day recovered 14 .files for its own
purposes. The grievor says he visited four 'or five
defaulters and made contact with all but two. Exhibit A-7
purports to be a statistical analysis of the results
obtained by four auditors, including the griever. For some
reason other auditors do not seem to have participated.
Attached to A-7 are more than 60 sheets of supporting
material, including many illegible entries and a number of
comments by Mr. Haalboom: "no work shown by Black."
Apparently he was not aware that the Compliance Office had
recovered 14 files, and there were other changes. He failed
to discuss the matter with the griever and in replying to
the grievance against the A-Z appraisal, Mr. Haalboom re-
fused to accept that there had been any change. When Exhi-
bit A-7 was found unsatisfac,toyy, Mr. Haalboom pro'duced a
revised analysis,, Exhibit A-16., reproduced on the next page
- 33A -
i
c. BLACK EPA SEPTEMBER 1, 198, - FEHRORRY 28, ,982
Collection Statistics
Auditor
C. Black TAXII
TAIII
TAII
TAII
ACCO""tS ACCOUIltS
Assigned with Cleared with
Debit Balances # Balances #
5 1
7 6
9 5
11 8
Account ACCO""t $ ACCo"nt Balance
% ACCOU"iS BalanCeS
Bal?i"CeS Collected to
Cleared Assigned $ Collected $ Assigne$
20 $ 2,478.05 $ 152.67 6
86 S 2.514.64 $ 2.388.29 95
56 $ 4.118.89 $ 1.454.94 35
73 $ 34,628.51 $ 11,493.29 33
Total/Average
Excluding Black 9 6 67 $ 13.754.0~ $ 5.112.17 37
Group~Total
Including Black
Group nverage
Including Black 8 5 63 10,935.02
$ 3.872.30 35
tax known to be due, and also those who had failed to make
the returns most vendors are required to make monthly. As
could be expected, defaults were in varying amounts --- as
low as $23.89 and as high as $50,141.05. Many of the
large accounts seem to have been taken back by the
i Compliance Office. Sheets CBla and CBZa in Exhibit A-7
showed that most accounts assigned to .the griever owed
nothing but were in default with their returns. One had a
,8(-R II
(credit) of $1,065.11, so that there was no money known
to be owing.
The griever's testimony is (as noted in his work-
sheets) that some of the smaller vendors to whom he spoke
claimed to be "out of business" or "bankrupt" or told tales
of a "cheque in the mail."
Exhibit A-16 does not indicate,outstanding success
on the part of the griever. It does show, however '(as does
A-7)i'that other auditors or the Compliance Office had been
given larger accounts. Moreover, according to A-16,' the
percentage of recovery for the other three auditors averaged
37 and, the percentage average for the group, including the
- 34 -
hereof. Changes produced a revised figure of 31
Defaulters included those who had failed to remit
_ 35 -
griever, was 35, which is not very different. On the whole,
the picture presented by A-16 is not the. same as the
impressioh given by A-7, which was part of the employer's
original case.
^_ The griever testified that "Mr. Haalboom received
my files when completed and I don't recall any file coming
._. back to me. The first criticism I had was on the E.P.A."
--- which of course was given to~~him six months later. At'
some point, however,;~.,Mr. Haalboom made many notes onthe
work-'sheets to the effect that work had not been done by‘the~
griever. A better course for a supervisor would be to
discuss the matter with the employee at once, not six months
later.
The next paragraph in A-2 relating to "Organizing
Ability" is as follows:
During the audit of W, Mr. Black did not follow
his supervisor's instruction to follow-up with
London District Office to ensure London's timely
completion of its' portion of his audit. Such
failure by Mr. Black could have seriously delayed
~the completion of the audit and resulted -in loss of
assessable revenue if his' supervisor had not
personally contacted London District Office and
ensured its' completion of work.
- 36 -
The griever admits that he faiLed to make the call
as instructed. He explains that being "in the field" he was
unable to call London on a direct line, and he had no reason
to suspect that London would neglect such an important
audit. Mr. Haalboom's was putting the worst possible
construction on the omission when he said that, .it "could ~,...:
have seriously delayed the completion of the audit and
resulted in loss of assessable revenue. 10 There is no
~evidence that the London office was a laggard.
There was considerable tes~timony about the crit-
icism levelled in the next paragraph:
Further, Mr. Black has failed to record daily his
location in the location book even though he was
instructed to do so in writing by memo on October
29, 1981.
The ~grievor admits he did not always. make the
.F_, required entries in the location book. The reasons he gave
in testimony were that (a) the office usually knew very well
where he was working, (b) until the switchboard was expanded
he often found it difficult or impossible to reach the
office by telephone. He gave the latter reason in a rather
irate memo tom his supervisor. On his part, Mr. Haalboom
said it was important for the office to know where an
auditor could be contacted.
- 37 -
The concluding paragraph in this group of comments
is as follows:
If Mr. Black is to obtain a satisfactory rating for
his organizing ability he must make major
..improvements. None of the above noted actions can
recur. -.~~
This was obviously.designed to put the griever on
notice that his position was in jeopardy. Mr. Clarke had
said the same thing in a letter to the griever some months
earlier.
The next group of comments are under the heading of
"Communication Skills," for tihich the griever was rated Low
Satisfactory. It is very briefs, but the Board considers it
is probably more importan t than many of the other complaints
made by supervisors:
Mr. Black continues to demonstrate poor commun-
ication skills in his documentation of audit files.
Although instructed by his supervisor to keep his
audit working papers up-todate and to complete his
documentation of sections of the audit as he works
on them, Mr. Black's work-in-process files on '411
and VlZ still lack neatness, clarity,. dates and
sources of information.
Mr. Black must strive to improve his written
communication skills in his preparation of audit
working papers.
- 38 -
The Board has bee" obliged to examine and consider
a number of the voluminous files for which the griever was
responsible, such as V2. V3, V5, V6, VT, V8, parts 1 and 2,
v9 I Vll, V12A and V12B. Necessarily, much of the work done
0" a file is hand-written, as are the'queries and comments
of reviewers. The kindest thing that can be said about
these documents is that they are not easy to read. The
griever's calligraphy is deplorable. Mr. Haalbdom's writing
is often difficult to decipher and his language is almost as
cryptic as the grievor's. On the other hand, Mr. Clarke's
legible writing reveals that he was not schooled in Canada
and his thinking is clearly expressed,.~ but his decisiveness
in closing the V8 audit prematurely (and without consulting
the grievor).,was unwise.
AS previously stated, the cardinal rule,,about audit
files is that they be so intelligible that they can be read
and understood by a reviewer. This means that the problems
encountered m"5t be explained as well as the reasons for
decisions taken about tax liability, with copies of support-
ing material derived directly or indirectly from the
vendor's books and other information yielded by the vendor.
.I" the case of a conglomerate --- a very large vendor like
V8 --- the material used can be massive.
- 39 -
It is standard procedure for the reviewer ---
whether a supervisor or the reviewer in the Standards Office
--- to write comments and queries on the left side of a
page. He may also give instructions and, if need be,
express his disagreement with a decision reached by the
auditor. It is then the duty of the auditor to write his
replies or explanations on the right side of the page. In
view of the criticism levelled at the griever's files, the
Board asked for a file considered to be a model of Its
kind. We were given V28, prepared in 1974. It has been
noted that this file has two pa~ges of comments, the .first .
being "overall file is very good." However, at least two
corrections were required, and regrettably certain of the
reviewer's comments.are illegible. Some of the supporting
material is also illegible. On the whole it appears
relatively neat and a well-organized file. Unfortunately,
the samd:cannot be said,of the griever's files.
Mr. Haalboom's very rational view was that an
auditor should systematically build his file while the audit
is in-progress, so that when the work is.,complete and he
returns to the office there is little left to do except to
draft the post-audit letter to the vendor. He cri'ticized
the griever for a':,habit of assembling and completing a file
after returning to the office.
- 40 -
It is not clear to what extent the griever complied
with instructions. He gives the impression that after many
years of experience he prefers to do the work his Own way
and is not really convinced that his supervisors could do it
a*Y better. The impression is fortified by the brevity of
the written re-plies and explanations he often gave when
answering queries or comments.
The griever's unwillingness or inability to give
.full and clear explanations undoubtedly irked Mr. Haalboom.
It led to difficulties with the reviewing officer in the
Standards Office. .b.' \ An example hasalready been given in the
case of V9 'and the equipment which Mr. Haalboom considered
was taxable only in part --- at least at the time.
Other examples are to be found in V8 - Part 2.
This file was reviewed by a Standards Officer, Mr. F.
Mascarenhas. He made the.following sta~tement at,page 2 of
his review commknts:
I am in agreement with the auditor's contention
that all the taxable spare parts included in the
total of $1.027.173 transferred from the Project
A/C to the Inventory A/C should have been assessed
rather than just taxable parts purchased during the
audit period.
., - 41 -
Obviously annoyed, Mr. Haalboom added his own
comment, directed to the griever.
co11 - you must objectively describe the
considerations taken into account in reaching this
decision. If this were done this review comment
would not appear. .,..
On
the very next page is evidence of a.~ similar
problem. The reviewer wrote:
Sch. m-62 indicate taxable carts wrchased for the
Lube Plant modification project, bn which charging
of tax of $75,855 has been delayed. Sch. AB-62
indicates tax of $52~,600.estimated as unpaid on
materials for the same project. It has been
documented by the auditor that neither the interest
on the delayed payments nor the unpaid tax has been.
assessed on decision of Paul Masse.
Mr. Haalboom again rebuked the griever:
co11 - you m&t objectively describe the
circumstances and considerations which led to the
decision to forego revenue. If this were done no
review comment would appear here.
Mr. Haalboom's assumptions were that if his
~.'
decision and Mr. Masse's decision had been explained more
convincingly by the griever, they would not have been
challenged by the reviewer. These are only assumptions but
they cast all the blame for disagreement on the griever.
‘~ - -. - 42 -
It is apparent from these and other entries that
supervisors found fault with the griever when he failed to
explain fully the reasons for decision~s taken by himself or
his supervisors. This was particularly disturbing if the
reviewer in the Standards Office happened to agree with the
griever rather than with Mr. Haalboom or Mr. Masse. super-
visors felt that the griever was too stubborn or un- . .~.
cooperative to set out reasons for opinions he did not'
share.
The griever is inclined to give a short answer when
the long one can be avoided. His failure to organize his
files and write his answers in a form satisfactory to his
supervisors helps 'to explain his strained .relations with
them. It is unfortunate that he did not make sufficient
efforts to meet their requirements in these areas.
As previously mentioned, Exhibit A-Z, the E.P.A.
complained of by Mr.. Black's grievance, had a fifth category
entitled "Personal Factors." In it there are three factors.
The second is "Adaptability," for which he' received the
lowest possible rating, a 5, meaning "Poor."
/
”
- 43 -
In this connection there were many references in
testimony to changes in the policies of the Branch, coupled
with assertions that the griever had either failed to accept
such changes or had manifested reluctance to do so.
Although Messrs. Clarke and Haalboom had little or
no experience in supervising auditors prior to 1980, they
insisted that standards for documentation had always been
the same. Reference was made to such Exhibits as G-5,
entitled "Guidelines For Documentation in Audit Files,"
issued by Mr. B.B. Gallop (then "Acting Chief Audit
Supervisor") to "all auditors" on March 23, 1976. It was
followed by Exhibit G-20, a memorandum on "Revised Audit
Forms," issued on March 31,1977, by Mr. T. Benson, at that
tim,e Manager - Field Operations. The latter was more
detailed than the.former, but both gave rather .general
instructions.
Exhibits GlO, G14, G15 and GlE~.include-.-most of
three chapters~in the Ministry Mannual. Chapter 3, "Audit
-..
Report and Working Papers," goes into details,about
documentation, but appears to have been substantially
amended. None of the extracts or the amendments are dated.
It must be said that most instructions therein relate to the
- 44 -
,conduct of an audit rather than to documentation.
The grievor testified that for many years
,: supervisors tended to accept without question the~results of
his work and that theirreviews were somewhat cursory. With
the arrival of Messrs. Clarke and Haalboom in '1980,
reviewers became much more demanding: they were inclined to
require meticulous documentation and often questioned the
griever's judgement. This was a new experience for him, and
it is obvious that he did not adapt successfully to the new
order. There is no evidence that Mr. Peacock --- the
grievor's supervisor for some time prior to 1980 --- ever .z
found fault with his documentation, which is not without
significance. Mr.Haalboom has conceded that Mr. Peacock's
evaluation of the grievor was "positive," as shown by his
contributionto the favourable appraisal for the period from
July 1, 1979; to October 31, 1980,~ Exhibit G33, which was
discussed early in this decision.
The new emphasis on documentation was clearly
signalled initially in a memorandum from Mr. Benson to "Dis-
trict Managers," dated May 31, 1979, which stated, however,
that "this material is an interim policy on file
_.
documentation" Exhibit G6. It seems likely that it inspired
new and relatively inexperienced supervisors, such as
Messrs. Clarke and Haalboom, to adopt very strict standards
when reviewing audit files. It was not until March 4, 1982,
however, that Mr. Paul Masse, Chief Audit Supervisor in the
Toronto District, issued a memorandum, Exhibit G58 to "all
audit supervisors" in which he said:
On March 2, 1982, the attached documentation policy
was accepted by our audit management group for
immediate implementation at the Toronto District.
The policy represents a concise restatement of
existing Branch documentation policies. This
policy should serve as both a training and
reference guide as we continue~to enhance our pro-
fessional image.
As discussed the policy should~ be presented,
discussed and implemented by each audit section no
later than March 19, 1982. Romero Dias -
Supervisor Standards, is available to Bttend
section meetings as necessary to provide background
in this matter. Please make those arrangements
directly with Romero.
Please let me know the arrangements you have made _
to.discuss this documentation policy with your
audit staff.
The instructions attached to G58 on three pages
were ~concisely stated and'~clearly designed to facilitate the
work of a rev~iewer. On the fourth,page appears only the
following paragraph --~- worthy of note by the griever:
- 46 -
NEATNESS AND LEGIBILITY
Neatness in working papers inspires the confidence
of the taxpayer and the reviewer and reflects well
on the auditor who prepared them. It is essential
that all documentation be legible and capable of
being copied.
It must be pointed out, however, that the memor-
andum quoted above was issued four days after February 28,
1982. Thus it was not available during the~period between
September 1, 1981, and February 28, 1982, the period of the
appraisal which is the subject of this grievance. The very
fact that Mr. Masse found it necessary to issue such a
memorandum on March 4, 1982, suggests that the new emphasis
on documentation had not been adequately communicatea to
auditors prior to that date.
Another comment may be in order. In any
compendium or commentary embodying detailed and difficult
documentation, it would not be difficult -to discover
discrepancies or defects, major or minor. This would be so
whether it were a scientific treatise, an'audit file or even
an arbitration decision. It becomes even easier to find
fault when the reader is a sceptical critic, l.acking
confidence in the judgement of the writer. Objectivity on
the part of a reader his more difficult to achieve than
I
!
- 47
niatness or legibility on the part of a writer. An auditor
usually works under time .limitations; he may be criticized,
as the grievor was, for taking too much time to do his job.
On the other hand, the reader --- a reviewer --- may be
frustrated or exasperated by an untidy file, since. his time
is also limited.
There was another~ change of emphasis to which
Messrs. Clarke and Haalboom attached great importance. They
.-
testified that the griever failed to.accept the change ---.
or at least failed to adapt to its requirements. :
According to the supervisors, Branch policy in 1981
and 1982 called for emphasis on gaining "future compliance"
by an erring vendor, rather than on levying the
"appropriate". assessment for unpaid taxes. Supervisors
thought the griever continued to strive for assessments and
ought to have shown more interest in ensuring "future
compliance". There is an element of mystery about the whole
matter of assessments. The Retail Sal&s Tax g&he;ates about
18 per cent of provincial revenues, ranking second to
personal income taxes. There are many thousands of
retailers and manufacturers who are required to hold permits
to collectsales tax and to remit it---- as well as returns
- 48 -
--- to the R.S.T. Branch. It would seem important to bring
in all revenue due from such an important source. Mr. Masse
testified, however, that a staff of about 60 auditors in the
Toronto office has been reduced by almost one half. The
staff is so small that no more than three per cent of
vendors are audited. It is impossible to believe that the
other 97 per cent invariably pay all that is due. This does
not mean that~most are cheating.the Treasury. Audits have
shown that defaults are often caused by defective accounting
procedures, untrained staff or genuine misund~erstanding ~of
the Act and the Regulations thereunder. These include many
complex-requirements as well as not a few exemptions ---
which may change from time to time.
In earlier years, according to the griever, there &
was much emphasis on "time."- An auditor was expected to
gene,rate more than sufficient money to justify the cost of
his salary. On the other hand, according to supervisors, I
the recent thrust of Branch policy is to educate and'skrve
vendors, and above all to persuade them to adopt techniques.
likely to facilitate "'future compliance." This, they argue,
is more important thancollecting unpaid back taxes ----'or
the interest thereon.
- 49 -
Mr. Haalboom said the grievor "concentrated on the
past --- dollars rather than prospects." He explained that
"the Branch has changed. There's a new emphasis on future
compliance... He has not adapted."
.In cross-exam~ination, Mr. Haalboom said the could
not recall any written directive on the change of emphasis
from assessment to ensuring future compliance. '
The Board was referred to Exhibit G22. That
document, however, was not addressed to auditors. Dated
June 17, 1980, it was addressed by Mr. Benson (in his
capacity as Manager - Field Operations) to "District
Managers." Moreover, there was no mention of a "change of
emphasis." The guidelines attached were explained as
follows:
. .,- _ :.
The procedures outlined in the guidelines are
designed to assist in determining the reason(s) for
a vendor's non-compliance and establishing a course
of action for resolution of the problem. This will
require, at times, the involvement of Group
Leaders, Supervisors and Districts Managers as well
as Auditors.
Further, far from~ down-grading the importance of
assessments, the forms 'provided included a space for
"Recommendations," and a note explaining that:
- 50 -
This area willbeused only when an assessment is
to be raised. The auditor will briefly describe the
course of action he intends to take to raise the
assessment and will estimate the additional time
required. This must be approved by the Group
Leader, Audit Supervisor and District Manager.
Incidentally, the forms attached have a heading:
"Analysis-of Assessment -from Audit and Resolution." There
is nothing in G22 or any ,ofher document we can find
authorizing emphasis on "future compliance" at the expense
of assessments. The latter are not only authorized, they
are required by law: the Retail Sales Tax Act, R.S.O. 1980,
chapter 454, particularly Sections 16 and 17 and of course
the Regulations under that Act.
On his part-, the gr.ievor said he considered-both
assessments and future compliance to be important. He
denied neglecting the latter and claimed to have suc,h~good
relations with vendors that he could get their co-operation.
The only evidence to the contrary is his "misunderstanding"
with an officer of V8.
-The supervisors' enthusiasm for the new "emphasis"
led to unfortunate differences of opinion.- For example,
when the grievor was completing the second stage of auditing
~8, he proposed not only a substantial assessment butalso
interest on taxes unpaid.
- 51 -
As other evidence has shown, and,as authorized by
law,interest is chargeable on arrears of taxes. In the case
of V8, Mr. Haalboom ruled that interest should not be
charged. He considered (after his interviews with V8) that
future compliance could be expected and held that it would
not be "appropriate" to charge interest. This d~ecision was
questioned by the reviewi~ng, officer in the Compliance Stan-
dards office, and Mr. Haalboom then rebuked the grievor for.
having failed to place an adequate explanation on the file.
As previously mentioned, he wrote: "Co11 -- you must objec-
tively describe the circumstances and considerations which
led to the decision to forego revenue..." In his testimony,
Mr. Haalboom gave this as an "example" of the grievor's
"inflexibility." Mr. Black had failed to disguise his own
opinion that interest was due and payable.
The Board was troubled by Mr. Haalboom's insistence
that "it is a supervisor's responsibility to assess or not
assess." Whether to forego, i.e. forgive, revenue owing to
the Crown is a very serious decision and it is questionable
that any public servant has any right to make that decision.
As a general principle, no person ;-- not even a public
servant --- can perform any act on behalf of the Crown in
Right of Ontario unless directly or indirectly authorized to
do so by 'an Act of ~the Legislative Assembly or ~.
.:
- 52 -
by a Regulation duly adopted~ thereunder. :Mr. Haalboom and
the representative of the Ministry were invited more than
once to cite any provision of the Act or the Regulations
enabling any person to forgive a debt due to the Crown, but
no such citation.was forthcoming. It is sometimes forgotten
that al:1 citizens, including public servants, are subject to
the rule of law rather than the discretion of individuals,
whether or not such individuals believe their exercise of a ..~
non-existent discretion to be "appropriate."
The E.P.A. complained of by the present grievance
concluded. with three paragraphs underthe head ing "Other
Comments." The first paragraph was as follows:
Mr. Black will receive another formal evaluation of
his performance for the three months ending May 31,
1982. Furthermore, Mr. Black will attend monthly
meetings with his supervisor wherein his
performance will be discussed. Due to the lateness
in preparing this evaluation the first such meeting
will occur in day, 1982. '
The above paragraph, must havebeen written
carelessly (as Mr. Lukassen ought to have noticed) because
the E.P.A. itself, purporting to cover the period from
September 1, 1981, to February.28; 1982, was not completed
until May 31, 198,2; and was given to the grievor on June'l4,
as appears on its face.
- 53 -
The second paragraph read:
Mr. Black is a graduate certified professional
accountant. He has completed many postgraduate
seminars in computer systems,economics, et cetera.
He has over 12 years audit experience with the
Branch.
The "12 years" --- another example of carelessness
--- should be corrected to read "almost 17 years."
The third paragraph was:
These factors lead to two conclusions; firstly, to
the expectation of much more from Mr. Black than he
.currently offers In his work, and secondly that Mr. ..
Black is capable of improving his performance.
Reference must.tiow be ma,de to the gualifications
and experience of the five witnesses.
Mr. D.H. Lukassen, a C.G.A. since 1972, joined the
Branch in September, 1967, after some years of.experience
with trust companies and other employers in the private
sector. OnMarch 19; 1982, he assumed the duties of
Regional Manager in the Toronto office. Thus he was not
there during any of the period between September 1, 1981,,
and February 28, 1982. Neverthel~ess, he approved the
-
- 54 -
appraisal, obviously relying on the judgement of Mr. Masse
and Mr. Haalboom. He said he was "very interested" in
E.P.A.'s and wanted recognition of "both merits .and
.,.'I. I;
deficiencies." He had discussed drafts of the appraisal
with supervisors and thought the final version was "fair and
accurate." In cross-examination, he said he could not agree
"that this is a particularly negative appraisal." He also
said the delay incompleting the E.P.A. occurred because
"Mr. Haalboom was seconded urgently to another office;"
Mr. Paul Ma~sse also joi:led the Branch in 1967.
Like all the other management witnesses, he has moved
frequently from one position to another. In 1975 he became
a C.G.A. and in 1978 was promoted to a head office position
in a training capacity. In 1981 he was Chiefs Audit
Supervisor in the Toronto office, then became Assistant
Manager, but later in 1982 h,e took a Quality Control
position and then went to the Peel District Office as
Manager. When ,he testified in February, 1984, he was
Manager in Mississauga. Points he emphasized were that
taxes collected from purchasers are trust moneys until
remitted to the Branch, and that penalties can be assessed
against the vendor for failure to collect.
Mr. Masse was Chief Audit supervisor when he
- 55 -
directed that the V8 audit be reopened in May, 1981. He was
the author of several letters and memoranda to the grievor
criticizing his work. In one meeting with the grievor a
"personality conflict" (apparently with Mr. Clarke) was
"discussed and assessed." An E.P.A., he said, "should or
can be both positive and negative," and an unsatisfactory
E.P.A. should be "followed up." A supervisor should spend
40 per cent of his time with auditors, but the auditors
spend 80 per cent of their time with~vendors.
Mr. Masse had approved G32, the appraisal for the
period from November 1, 1980, to August 31, 1981, and he
rejected the ensuing grievance. That appraisal was amended
in part by decision of the Deputy Minister some months
later. There is no doubt Mr. Masse's opinion was'somewhat
affected by the history of the V8 audit, during which he
reversed Mr. Clarke's decision to terminate it. However, by
the time the second V8 audit was completed he had gone to
other duties. His experience with the griever was only in
1981 and part of 1982.
_.
;, .>-.
Mr. Everton Clarke was not yet a C.G.A. when he
testified in March, 1984, but he had completed most of the
course. After an education in civil engineering he came to
- 56 -
Canada in 1961 and joined the Branch the following year. He
rose rapidly from being a Clerk 2. to the level of a Tax
Auditor 3, in 1973. From 1975 he func.tioned as a "Tax
Specialist$and fin'-May, 1980, went to the Toronto District
Office as an Audit Supervisor, but a year later became a . .
"Service Supervisor."
Mr. Clarke supervised the griever from May to
August, 1980, Andy from January, 1981, until his departure
three month,s later, when he was succeeded in the Large
Vendors Section by Mr. Haalboom. Thus he supervised the
grievor for a total of only about six months. Despite his
rather limited experience in supervising auditors, Mr.
Clarke had a great deal to say about the griever's work. In
particular; he found fault with documentation, pointing to
many of his very critical review comments, and he had no
faith in the griever's judgement. His own judgement in
terminating the V8 audit was quickly reversed by Mr. Masse.
His strongest criticism was that the grievor sometimes
failed to follow his instructions --- one..~of which was to
terminate V8 immediately. It is significant that Mr. Clarke
had a part in preparing the app~raisal for the lo-month
period from November 1, 1980, to August 31 , 1981. His only
experience with the griever in that period was from January
to April, 1981, but he'considered.that in earlier months
- 57 -
(from August to December, 1980) when the grievor was away in
the Hospitality Section, there had been neglect of audits
previously assigned to the grievor,in the early part of
1980. Mr. Haalboom, then in charge of the Hospitality
Section, said instructional duties there had priority, but
also said older files usually have priority. These incon-
sistencies do little to strengthen the case against the
grievor. Obviously, it is inefficient to hold an employee
responsible~to two different supervisors at the same time.
For that anomaly, management rather than the grievor was
responsible. Hs could not leave Toronto and continue the
audit of V8 when he had full'time instructional and review
duties with the junior auditors in the Hospitality Section,
nor could he effectively super" i
who did considerable work at V8
se his assistant, Mr. Pitel,
Mr. John Haalboom is one of few (if any) in the
Branch to be a C.A. as well~as holding a B. Comm (1975) and
an M.B.A. (1983). There is no question a,bout his youthful
energy, or his intelligence,and ability. Thus it is not
surprising that he has advanced rapidly since being
recruited in January, 1979, after some experience with a
large accounting firm in the private sector. In 1982, he
had, however, very limited experience in supervising Branch
auditors. .:
- 58 -
Having supervised the griever throughout the whole
of the period from September 1, 1981, to February 28,~1982,
Mr. Haalboom became the principal authorof the appraisal
now before us, Exhibit A-2. His testimony was given in
great detail and cannot be discussed fully, but certain
passages are worthy of comment. because they reflect,his
attitude towards the grievor and also his understanding-of.
the E.P.A. proces~s.
Mr. Haalboom said that experience in auditing one
large retailer can be useful in auditing others. The
grievor is of the same opinion and considers that his long
experience gives him an advantage in any audit.
When heading the large vendors' section in 1981i82,
Mr. Haalboom supervised from six to~eight tax auditors, each
of whom would normally be responsible for several audits at
one time. The supervisor selected firms to be audited and
made the original allocation of time. .There would be a
natural tendency to assign the most senior and ,expkrienced i
auditor,the grievor, to large and important companies such
as V9.
Mr. Haalboom thought the grievor was "reluctant to
follow instructions," referring of course to their
- 59 -
disagreements about the V9 assessment~and the forgiveness oft- I
interest at V8. He insisted that documentation ought to
have explained the reasons for such decisions. According to
him, the grievor "did not think he should explain others' "
decisions." The grievor's answer on this point was that Mr.
Haalboom failed to explain such decisions clearly to him and
gave rulings rather than explanations;
The witness strongly criticized the griever's use
of time and thought he was "out of control." Hereferred to
the missing sentries in the 'location book and considered (as
Mr. Clarke had thought) that requests for additional time
were both belated and excessive. Mr. Haalboom having had
no experience in auditing~large vendors himself, it is not.
clear how qualified he was to judge the.time required
Like Mr. Clarke, Mr. Haalboom was inclined to
reject the grievor,'s explanati.on~s without.sufficient
inquiry. For example, notwithstanding the griever's
denials, he persisted in believing that 45 accounts had been
assigned to ttie griever in the collection project until some
time after the second stage ins the grievance.procedure.
The witness thought Mr. Clarke's views in connec-
tion with earlier appraisals were stronger than his own, and
remarked: "Mr. Clarke.does make.absolute statements."
- 60-
cross-examined, Mr. Haalboom was not Certain ;..
,,,hether the griever had been made aware of his shortcomings
during the appraisal period --- apart from review comments
and queries. . It is revealing, however, that he proposed on
or wafter May 31 to do another appraisal for the period ~from
March 1 to May 31. It would be physically impossible to
discuss shortcomings during a~period which was already in ,
the past. Mr.Haalboom did not seem to be aware at the time
that the proposal was inconsistent with the Ministry's
E.P.A. standards.. In cross-examination, however, he
admitted that "the Ministry requires advice before an E.P.A."
Mr. Haalboom also conceded that some of the
criticisms he made in his testimony had not been mentioned
to the grievor "until now."
The witness defended his decision not to assess
interest against V8. He even said Mr. Black "could have
recommended a write-off, but he didn't." He himself thought
the vendor would be "upset" by an interest assessment, and
he felt "it was appropriate not to assess because they were
complying." This appears to- be a reference to future
compliance, and its relevance is obscure.
. .
- 61 -
Mr. Haalboom made a curious statement which appears'
to confuse this appraisal with a previous appraisal by Mr.
Clarke. Referring to the grievor's failure to document
adequately reasons for his rulings, he said: "That
occurrence and others with Clarke resulted in an
Unsatisfactory rating for Judgement. Alone, it would not
have had that result....if this were the only occurrence."
Later, he also said: "I can't divorce myself from Clarke's
opinions."
Such statements tend
impression that principally by ta
to confirm the Board's
king to each other Messrs.
-Masse, Clarke and Haalboom arrived at a common opinion which
was highly unfavourable to the grievor. There is
insufficient evidence that they spent much. time talking to
the griever or attempting to improve his performance. There.
are many Indications of a failure to communicate betwee'n
them and the older man. Moreover,, there is no sign that
they recognized his long experience or thought he might have
something of value to offer as they assumed new .
responsibilities. Mr. Haalboom in testimony did, however,
acknowledge that the grievor "had 17 years of.experience as
'of 1982," and that he himself had "no experience in
commodity auditing of large vendors"~ when he took over that.
section in April, 1981.
- 62 -
Mr. Haalboom was candid enough to admit an
unfortunate rapport with the grievor: "I f.elt an
undercurrent --- he felt I was not a capable supervisor ---
but he never made such a statement. It was the feeling I
had throughout a .two-year period. It's reflected in the
E.P.A."
It should be added that the grievor did not say in
his testimony that any of the supervisors lacked capacity,
but it is clear that he did not always agree with them ---
and failed to hide it --- which was certainly resented by
Mr. Haalboom. The latter said, referring to the V9 problem:
"I got the impression he was reluctantly following my
instructions." This eventually led to rather extravagant
language in the E.P.A. that !'his supervisor was forced to
assert his authority." Sudh language is an expression of
insecur~ity rather than certainty on the part of a
supervisor.
There was also some strong. language in Mr.
Haalbbom's testimony. Referring to the V9 assessment, the
witness said the grievor's failure to place reasons on.the
file '!.sabotaged my position." If he had explained his
reasons fully to the grievor, and asked the grievor to put
those reasons on the file, his statement might be justified.
,’
- 63 -
Instead it appears that (as he said) he "asserted his
authority."
Mr. Haalboom conceded that "I felt he communicated
well orally but I didn't say .so in the appraisal." He
further agreed that there were both positive and negative
aspects of the work on.V9. He was satisfied, however, by
review comments on the V8, Part I file that the grievor's
documentation was "poor."
Mr. Haalboom deserves some 'credit for his candor.
He did not pretend to be an impartial witness. He made
clear that he regarded the grievor, whatever his experience
and qualifications, to be an nnsatisfactory employee.
The grievor himself was not a very articulate
witness, being in the position of defending himself against
countless criticisms, but he carefully refrained from
attacking his critics. On occasion he admitted fault ---
for example in spending "additional time" on Ann audit before
asking authority to do so. Its is clear he had difficulty in
adjusting his habits.to the new order being introduced by
inexperienced supervisors who came and went.:with remarkable
frequency.
- 64 -
It may be well to summarize the griever's
experience. After wartime service in the British Merchant
Marine he came to Canada in 1948. For the next two years
he was a teller.with the Bank of Comme.rce. From 1950 to
1961,he served with Canada Railway News, first a&a book-
keeper and then as accounting supervisor. He took a
business equipment course with I.B.M.-.and then had a series
of accounting jobs in supervisory positions with Cities _. _,
Service, Canadian Admiral, the T. Eaton Insurance Company
and the Toronto Board of Education.
The griever was employed by the Ministry of.Revenue
from October, 1965, first as a Tax Auditor 2, winning
promotion to Ta.x Auditor 3 in January, 1969. At that time
he was auditing a variety of vendors while a separate group
audited the large vendors. From 1979, however, he was
assigned to the large vendors, sometimes known as "conglom-
erates" and also as "jumbos." From 1965 to 1979 he was
designated as a "Group Leader," freque,ntly training and
assigning duties to junior auditors. This included the
preparation of a number of appraisals;:.He described the
supervisors' role in those days as "consultative."
- 65 -
After several years of correspondence courses, the
grievor became a C.G.A. in 1974. Thereafter he took courses
at Seneca in E;D.P. programming and language, as well as
systems analysis and microcomputers, thereby updating his
previous I.B.M. course. He also took several Government
courses in periods ranging from two days to one week. In
his spare time he also acted as Treasurer of a ski club
(which claims 3,000 members) and designed and installed a
book-keeping system which may become computerized.
In 1979 or later the so-called ."Group Leader"
designation was "phased-out" and the grievor became known as
a "senior auditor." However, his assignment to the
Hospitality project in 1980 involved the work of a Group
Leader or instructor because, instead of going out into the
field, he taught juniors how to evaluate vendors in the
light of information supplied by the L.C.B.O. as to the
volume of liquor sold to retailers of that commodity.
In his early experience, the griever said,
supervisors relied on the judgement,of their auditors and
emphasized that comment should be kept to a minim-urn. He
acknowledged that from.1980 there was a demand for more
detailed information in files. Standard forms were.devised
to save time in some audits, but this was-not possible in
- 66 -
auditing large vendors. -From 198Lthere was more stress on i
standardizing-documentation, which he attributed to "new
staff," but he asserted that not all supervisors were
consistent about it.
There were mixed results, the griever said, when
resorting to the aid of computers because some systems'were
not compatible with others, and a ve~ndor would not always
agree to it because an auditor's intervention could disrupt
its own programming.
As for his relations with Mr. Clarke, the griever
said communication between them was minimal. He discussed a
number of incidents compl~ained of by Mr. Clarke.and gave his
own explanations, undoubtedly in more detail than Mr. Clarke
'was willing to hear. It is clear the're wars a~personality
conflict which the grievor discussed with Mr. Masse.
Similarly, Mr. Black gave his version.of incidents
involving Mr. Haalboom, several of.,which have already been
described. The griever said he was seldom questioned by Mr.
Haalboom about problemson which Mr. Haalboom had a great
de'al to say in his testimony. It is regrettable that much
of what was discussed in testimony before the Board does not mu
- 67 -
seem to have been discussed by the two men in 1981 and 1982.
Again, there was a breakdown of communication between them.
With more effort on both sides it is probable that some
problems at least could have been solved at the time and it
would not have become necessary for this Board to hear evidence
and argument for 24 days.
.I
Before stating our conclusions in this case, it is
necessary to offer a melancholy observation. It is apparent
that all the witnesses have admirable expertise in their chosen
field, which is accounting and auditing, but they have demon-
strated a remarkable lack of competence in the important area
of human relations. The effective leadership of others is an
essential ingredient of good management. Unfortunately, it is
not evident in the appraisals which have been placed before us.
As for the griever, his failure to satisfy supervisors seems to
have arisen in part at least from a certain reluctance.to make
those compromises and special efforts which.~many employees have
found necessary in similar situations.
It now becomes necessary to state conclusions arising
from the vast body of evidence which we,have attempted to
summarize. Many of the reasons for our conclusions have al-
ready been indicated.
- 68 -
CONCLUSIONS
By Section 18(2) in the Crown Eniployees Collective
Bargaining Act it is provided as follows:
In addition to any other rights of grievance under
a collective agreement, an employee claiming,
. . . . . .
(b) that he has been appraise&contrary to the
governing principles and standards
. . . . . .
. . . may process such matter in accordance with the
grievence procedure provided in the collective
agreement, and failing final determination under
such procedure, the matter may be processed in
accordance with the procedure for final determ-
ination applicable under section 19. . .
Section 19 provides for reference to arbitration
and a final and binding decision by the Grievance Settlement
Board.
Thus the issue to be decided is whether the
appraisal of the grievor for the period from September 1,
1981, to February 28, 1982, was "contrary to thee governing
principles and standards."
- 69 -
Entirely reasonable and proper principles and stan-
dards have been eYstablished in Exhibit G37, part of the
Ontario Manual of Administration and also in Exhibit G13, a
lengthy document adopted by the Ministry of Revenu.,e and
entitled "Performance Appraisal System." These need not be
set out in full, but there.are certain significant passages.
The Manual of Administration defi.nes the'process as
follows:
Performance appraisal is a three-step process
whereby a manager and an employee:
1) define the performance that is expected .:.,.
of the employee during the next review
period;
2) discuss performance on anongoing basis
during the review pericd:.andd-~.
3) evaluate job~performance at the end of
the review period.
On the next page the-Manual sets out the "Primary
Purpose" as follows:
The primary purpose of performance appraisal .-- is to:
improve performance; and/or
maintain high performance levels.
- 70 -
The "objectives" are then stated:
The objectives of performance appraisal are:
to attain high performance levels by
ensuring that employees know and are
committed to achieving what is expected
of them:
. to assist employees to develop in their
jobs through coaching, counselling and
training;
. to improve communications and work
relationships between employees and
managers; and
to provide for a better understanding of
organizational objectives. ,.
Then there are the "Guidelines" in the Manual. It
will be noted that they call for day-to-day discussion
throughout the period...;. While this may not be always
;
possible, it underlines the need for continuing contact
between supervisor and supervised,--- and not merely an
appraisal every few months.
The following performance appraisal guidelines are pre-
sented to assist in the development and implementation
of effective performance appraisal programs:
1. &fine performance expectationswhich are:
. set by manager and employee at the beginning of
each review period:
. re-examined during the review period'and revised
where appropriate:
. specific to each job;
. consistent with the position description;
. results oriented;
. measurable.
2. Discuss actual performance with the employee on a day-
to-day basis throughout the review period.
3. Base the evaluation at the end of the review period
on the employee's work performance and
acccmplishments.
4. Discuss the performance evaluation at the end of the
review period with the employee and where the
appraisal is written, provide the employee with a
copy.
5. Includein the performance evaluation at the end of
the review period a summary rating of the employee's
performance so that the employee has a clear
understanding of whether overall performance has
exceeded, met or not met the expectations of the job.
6. Indicate, where performance expectations have not
been met, what is required to meet these
expectations and whether improvement has been
demonstrated during the review period.
7. Include in the appraisal of managers, their operation
of the performance appraisal program.
The Ministry of Revenue in Exhibit G13 has in .
effect reaffirmed the substance of the Manual's Guidelines.
Two paragraphs in the Introduction are worthy of note:
The Employee Performance Appraisal System.is to
provide an assessment of an employee's work
performance during a specific period of time, for
the purposes offeedback from management to the
employee, and as a tool for manpower development.
- 72 -
The assessment is to be objective, stating both
strengths and weaknesses as shown by an employee's
performance. It will emphasize skills and personal
qualities which will be considered in regard to
promotional opportunities, supervisory development,
management training and rotation of staff from area
to area for the expansion of desirable skills. .
A significant statement appears at page 7:
A vital consideration is the fact that it is
unlikely that an individual can be completely
outstanding in all factors or completely useless in
all factors. In other words, all employees are
complex individuals having both strong points and
weak points, and this should-be reflected in the
rating. Accordingly, itis expected that a
staggered pattern will emerge in the degrees
column, and any straight line pattern should be
lodked at skeptically.
Referring to the appraisal of employees performing
at a professional level, it is said at page 11:
The factors used for assessingthe performance of
such employees are not inherently different from
the fundamentals of any other performance appraisal
system. However, the bias varies. More than any
other, the completing of this form calls for a
judgmental process.
The conclusion si?a,ted at page, 13, is the following: ~.
1
- 73 -
Ratings should be carried out because:
1) The employee has a right to know how he is
doing.
2) Management must assess its staff to determine
how best to develop the potential of. the human
resources in its organization.
Following a 1978 Audit Supervisors Conference, Mr.
T. Benson issued a memorandum to "Distr.ict Managers,"
Exhibit G12, attaching an abbreviated transcript of the
proceedings and also a copy of a paper apparently written by
Mr. Ian Percy, a management psychologist. In it he expanded
on the interaction between employees and appraisers and-made
the following points:
To complicate this interaction effect, a
-performance appraisal is almost as much a comment.
on the apppraiser as on the appraisee/'lhis means
that the employee's personality, task and situation
also interact with the same three variables on the
part of the appraiser.
We all know of an employee who, when assigned to
Partner A, received consistentl:y negative
appraisals. When reassigned to Partner B, however,
the appraisal report was always positive. It is
not likely chat the employee's personality changed,
nor is it likely that he. or she was assigned a
radically different task. Rather, the difference
indicates that when the employee interacted with
Partner B positive things happened. The difference
lies in the interaction between two individuals.
- 14 -
Among the points mentioned in Mr. Benson's record
of the Conferene were the following:
1) E.P.A.'s are used to develop employees.
. . . . .
3) Comments on E.P.A.'s must be supported by
facts...
. . . . .
8) An E.P.A. must be honest.
9) The contents of an E.P.A. must not be a
surprise to the employee. Ongoing discussions
with the employee will ensure he knows where he
stands.
Clearly, the last point means that a deficiency of
importance to the appraiser should not be mentioned to an
employee for the first time six months later--- or at an
arbitration hearing two years later.
Exhibit Gil is a Ministry directive issued on March ._
30, 1979, -reiterating some of the previous ..advice and -
emphasizing that when performance is deemed unsatisfactory,
a number of detailed steps should be taken,~ including
interviews with the employee, full discussion, a commitment
by the employee to make correction, all of the same to be
fully documented. In other words, the Sup.erViSOr'S
- 75 -
i:
responsibility is greater than merely composing a series of
unfavourable appraisals.
It is the conclusion of this Board that the
appraisal now referred to arbitration was framed in ratings
and language contrary to the principles and standards set
out in the Manual of Administration and the Ministry of
Revenue Guidelines. It is almost completely negative and
reads more like an indictment than an E.P.A. I~f its was
intended to "build a case" against the grievor, then that
purpose was duly served.
At the same time, the Board is of the opinion that
there was fault own both sides. The uneasy interaction
between employee and appraiser required lubrication. As
already indicated; the grievor did not make sufficient
e~fforts to meet demands which were new to him. On their
part, supervisors (doubtless preoccupied by new responsibil-
ities) made no serious effort to establish a good
relationship with a very senior employee or to benefit from
his long and varied experience. Speaking bluntly, all fhe
witnesses before us displayed a substantial egotism, and
there is ample evidence of personality conflicts. They were
all given to "inflexibility," including the griever... who
should learn the meaning of compromise.
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For reasons hereinbefore stated, the appraisal
which is Exhibit A-2 must be set aside and removed from the
grievor's record as invalid.
opinion
arbitrati
Nothing s,aid herein should be 'construed as an
in respect of any other grievance.referred to
on and not,,yet heard, each of which ,must be decided
on its own merits.
T.he~ Board wishes to acknowledge the patient,
thorough an~d very competent efforts of Ms. Simpson and Ms.
Cornish in assisting us to decide this diffic-ult case. ;.
Dated at Toronto th ,i S
10th day of January ‘I .J985
Vice Chairman
. R. Russell
Member A
/ G.A. Peckham
Member
EBJ:sol