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The overall question considered in examining the implementation of FCP is whether the FCP model is consistent with its objectives and effective in its implementation. This question was considered in terms of a wide range of issues, including the basic employment equity model; program parameters such as the thresholds for coverage; adequacy of staffing and other resources; and compliance activities. 3.1 Employment Equity Model Applied Under FCPGenerally, stakeholders indicated that the basic employment equity model of FCP — the set of 11 key criteria — was a good model, appropriate, and effective when fully implemented. Employers participating in case studies for the evaluation also generally indicated satisfaction with the employment equity model, although smaller employers wanted to see program requirements simplified. Further, Workplace Equity Officers noted that while the basic 11 criteria remain appropriate, they felt that the criteria needed to be better organized to reflect how employment equity should actually be implemented. No substantial changes in these criteria were suggested by stakeholders, employers, or FCP staff, with one exception — more consultation with unions was suggested as being a desirable objective. Further, it was recognized that a more simplified model would better suit smaller employers. Finally, where fully implemented, the employment equity criteria were found to be effective in achieving better workforce representation for designated groups (see Section 4 for related analyses regarding the positive impact of employers implementing the 11 key steps). 3.2 Equivalency of FCP with Legislated Employment Equity Program (LEEP)The Intent of Equivalency: While amendments to the Employment Equity Act called for the implementation of the FCP to be equivalent to the Legislated Employment Equity Program (LEEP), it appears that there has been no significant change to FCP since the requirement was outlined in the 1995 amendments. The relevant section (42.2) of the Act, reads: "The Minister is responsible for the administration of the Federal Contractors Program for Employment Equity and shall, in discharging that responsibility, ensure that the requirements of that Program with respect to the implementation of employment equity by contractors to whom the Program applies are equivalent to the requirements with respect to the implementation of employment equity by an employer under the Act." (emphasis added). In a number of key areas — i.e., consultation with unions, reporting and compliance — very substantial differences remain between FCP and LEEP. Specifically, differences between FCP and LEEP include the fact that LEEP covers casual employees while FCP does not, and LEEP requires consultation with unions while FCP does not (though FCP guidelines encourage such consultation). With respect to reporting, FCP employers do not have to report while LEEP employers do. While LEEP compliance is regulated through the Canadian Human Rights Commission (CHRC), Human Resources Development Canada (HRDC) is responsible for both consulting and compliance for FCP. Some stakeholders noted that FCP is viewed as more flexible than LEEP, a fact that is seen as being beneficial. They emphasized that while there is a desire to achieve equivalency this should be done without losing this flexibility. It has been almost five years since the Act was amended and equivalency is hindered by the lack of a clear definition by the Labour Program of "equivalency in implementation." While this includes the 11 steps of implementing employment equity, FCP headquarter staff do not have a clear interpretation as to whether this includes reporting and compliance and parameters such as thresholds. Thus this may be a key area for clarifying directions of the FCP for the future. 3.3 Reporting, Goals and TimetablesReporting and Related Issues: The possible need for FCP reporting, mandatory goals, and timetables was an important consideration for the evaluation, particularly in view of the new "equivalency" provisions in the Act. This was particularly so as currently FCP does not require any reporting by employers at all. Findings: The evaluation identified a number of factors favouring a new reporting regime, where almost all key stakeholders (designated groups, Workplace Equity Officers (WEOs) and other government key informants) felt that the FCP could not operate effectively without employer reporting. They indicated that without such reporting there is no way to assess or measure employer progress, and no way to measure program compliance or impacts. Indeed, most indicated that, if employers could not report on progress, then they were probably not doing employment equity at all. Employer Views: Only 16 percent of employers indicated that annual reporting would be a hindrance to achieving employment equity, a factor favouring the implementation of reporting. However, it is important to note that many stakeholders emphasized that reporting should not be too onerous on employers and should only require them to provide data which is needed to prepare employment equity plans (routine reporting in a simple format was noted by WEOs as a good way for employers to keep their representation statistics up-to-date). Other findings noted were that other contractors programs (LEEP, Quebec, U.S. program) all require some reporting. However, the type of reporting required, and maximizing its usefulness to employers, is a key issue. For example, a current frustration for employers is when WEOs ask for data to be reported which is not useful for the employers' achievement of employment equity, such as asking for national data when the employer recruits locally. Reporting also can enable employers who are committed to employment equity to assess how well they are doing in comparison to others, so a reporting regime should ideally include employer feedback. Goals and Timetables: Voluntary goals and timetables are currently required under FCP. Most case study employers did not favour mandatory goals, though a small number said they would not be problematic. Also, employers emphasized that achieving goals depends on the economy. Further, case study employers felt that numerical goals sent the wrong message about hiring the best-qualified people. While reporting was broadly supported by stakeholders, most stakeholders, including employers and WEOs expressed concern that reporting not be too onerous (i.e., such as under LEEP at this time). 3.4 Thresholds and Exemptions3.4.1 Organization SizeIs the 100 employees cut-off still valid? The evaluation considered whether the FCP is designed to target the appropriate-sized employers. The question was should FCP continue to focus only on employers with 100 or more employees or should a change be made in the threshold? A number of findings pointed towards the desirability of lowering the size threshold to include smaller employers. Designated groups felt strongly that thresholds should be lowered from 100 to 50 employees. Arguments for changing the threshold included the fact that many representatives of designated groups, particularly Aboriginal people, reported that they tended to be employed in small firms and that smaller firms were more typical of the regions where they live, so that the 100+ employees cut-off limited the reach of the program for them. Other stakeholders and the literature review also supported such a change. For example, the U.S. program — the original model for the FCP — requires an affirmative action plan from employers with 50+ employees. Stakeholders also expressed some concerns about the definition of "employees", suggesting that some employers have numerous contract staff and freelancers, resulting in the employer nominally having fewer than 100 employees. Discussion: Other considerations also affect the thinking about lowering the size threshold, and reflect the complexity of this matter. First, LEEP and FCP currently use the same size cut-off. Second, FCP is currently stretched in terms of staffing resources, as is shown later in this report. Lowering the size threshold would most likely — unless a very different delivery strategy were developed — create additional work for an already overworked and understaffed program. Finally, there are important differences in implementing employment equity in smaller firms, so that if the threshold was lowered or eliminated, it would be essential to consider how the program could be adjusted to take into account the very different needs of smaller employers. 3.4.2 Contract ValueThe evaluation considered whether the FCP should continue to focus only on employers with contracts worth over $200,000. Many stakeholders, particularly the designated groups, argued that the contract size cut-off should be lower to include more employers, with $50,000 or $100,000 levels being frequently suggested. The argument of designated groups was that including such contracts would extend the program and thus reach more employers and provide more aid to the designated groups. Additionally, designated groups argued that, as with suggested changes to the number of employees threshold, this change would improve regional coverage of the FCP. Other arguments which stakeholders noted are relevant to the practical operation of the program. First, a lower contract size cut-off would control for possible contract splitting, which it was suggested, is done sometimes by government departments to avoid contracts reaching the program threshold, or for other administrative reasons. Second, a lower cut-off could more effectively capture all contractors with a substantial business relationship with the Federal government and reduce the potential for employers moving in and out of the program as they start and end contracts. Third, participating departments and central agencies reported that cumulative contract value, which was considered as a possible program change, was not considered a viable alternative for contracting departments, because of the lack at this time of suitable information systems to monitor total contract activity. 3.4.3 ExceptionsA related issue for the evaluation was to consider if employers currently exempted from the program (particularly construction and legal services) should be included in FCP. A broad base of stakeholder opinion, particularly designated groups, favoured the removal of exemptions in FCP generally, and extension of coverage to all sectors. As well, many FCP employers who were surveyed favoured the removal of exceptions for construction (endorsed by 36 percent of employers surveyed), legal services (40 percent of employers), and organizations receiving grants (57 percent of employers). In key informant interview with employers, the factor in employers minds was fairness — that if they had to comply, others should as well. This issue of equity is, as noted, below a recurring one in this discussion. In 1989, the Bureau of Management Consulting review of FCP made the same case for including all major business sectors as it did for smaller and larger employers, mainly on the grounds of equity — that is, if firms in manufacturing or similar sectors must comply with FCP, other sectors such as construction or legal services should also have to comply. Additionally, it was noted in the international review component of the evaluation that other programs (particularly the U.S. contractors program) covered all sectors, including construction.9 3.4.4 Sub-ContractsThe question of whether sub-contractors should be included in the program was considered, and while some other contractors programs include sub-contractors, it is not clear how easy it would be to implement such a requirement. Sub-contractors are covered by Quebec's contractors program, which requires the primary contractor to comply with employment equity initiatives and oversee what the sub-contractors do. Similarly, the U.S. program includes sub-contractors. However, it is not clear from the evidence available exactly what the conditions are to make this work well. For example, the Quebec treatment of sub-contractors was reported to be ineffective and reports from the U.S. suggest that their treatment of sub-contractors may also be somewhat problematic. Also, as was emphasized by one FCP staff member, sub-contractors do not make the decision to do business with the federal government as do the primary contractors, but on the other hand sub-contracts can provide a method for contractors to avoid their obligations of employment equity. This is an important issue in this era of outsourcing and downsizing (see Bureau of Management Consulting, 1989). 3.5 Internal FCP Information SystemsInformation Systems: An examination of FCP's internal information systems found that systems were extremely inadequate and insufficient to support good program management and accountability and that they were a source of inefficiency in the work of WEOs and managers. These internal information systems did not provide reliable data on either the progress of employers, or the activities of WEOs, thus preventing strategic management or allocation of resources. Also, most WEOs (85 percent) reported that the lack of information system resources was a major factor causing stress on the job. Impacts on Reporting and Accountability: Partly as a result of the lack of good information, regular progress reports are not produced for the FCP, and the FCP has not produced a public report — such as an annual report — on its overall work since 1994. These factors appear to have contributed to the low visibility of the program within HRDC and to the lack of awareness of the program outside of HRDC. The problems with administrative and internal information systems suggest that there is a need for substantial improvement of the internal program information systems, linking employer data to both WEOs regional data and to Headquarters to support strategic reporting and planning efforts. Ideally, the information systems would provide the main information for an annual report on FCP. 3.6 Staffing Resources for FCPStaffing Resources: The evaluation examined the adequacy of FCP resources and deployment. FCP was, even in 1992, already deemed to be under-staffed (see Evaluation of the Federal Contractors Program, EIC, 1992), suggesting that the program has been understaffed since its inception. Even so, the program staffing was drastically cut in the mid-1990s — with much deeper cuts, stakeholders indicated, than occurred across HRDC generally. Overall FCP staff resources were reduced (total combined NHQ and regional staff complement working on FCP) dropping from 26 FTEs in 1994/95 to 13 FTEs in 1998/99, limiting the capacity of the program for field efforts, both in education/consultation and in compliance reviews. Regional staff dedicated to FCP has dropped from 14 in 1994/95 to 7.5 in 1999 (communications from Workplace Equity). Thus the total staff complement for FCP dropped from 26 FTEs in 1994/95 to 13 FTEs in 1998/99. Thus in 2001, the current number of FTEs allocated to FCP are insufficient to fully implement the program as it is designed. This is reflected in the low level of compliance activity under the program, and low level of contacts with employers. Organizational Changes: Organizational changes have also been a concern for the program, as seen by a number of HRDC stakeholders, and may also have exacerbated workload problems. Until 1993, there was a separate compliance unit located in Ottawa. When compliance was moved to the regions, no additional staffing resources were added. At the time of the evaluation, the headquarters view was that in the regions, WEOs are frequently re-directed to work in Part II or Part III or general labour standards administration (see Section 3.13 for a full treatment of organizational issues). Other Work-Load Factors: LEEP employer demands for informational support have also been substantial in this time period and have increased since the last revisions to the Act increased the profile of LEEP. Because LEEP is legislated and annual reports are required, LEEP employers are often given priority over FCP employers. As well, following the new legislation in 1996, WEOs were given new responsibilities (e.g. pay equity) in the same time period. Need for more staff for FCP was also indicated by the large number of FCP employers who reported not hearing from a WEO for years (resulting in the program losing its apparent significance, and giving the impression that the program is not really going to be applied); and the majority of FCP employers who identified having "more access to FCP staff" as a factor that would aid implementation of the program. Some Comparisons: In the U.S. literature, effective enforcement was shown to be strongly dependent upon adequate staff resources. In particular, the U.S. program was strongly staffed in its initial years, when program expectations were being institutionalized with employers. To draw a key comparison within the Canadian federal jurisdiction, about 13 Workplace Equity FTEs currently implement FCP for over 800 firms. In contrast, the enforcement component of LEEP at CHRC has a current staff complement of 30 for some 400 federally regulated employers, federal departments and agencies. Were FCP to be resourced at the same level as LEEP enforcement, staff complement would be more than doubled. Summary: Stakeholder and employer responses also point to a need to rebuild the staff resources of this program, if it is to be delivered as designed, and its goals achieved.10 Some key stakeholders noted, however, that program goals are not achieved simply by "throwing bodies" at the problem. Rather, some new methods may need to be considered such as a new information-communications strategy and partnering, both of which could be key drivers for more effective and efficient FCP delivery. 3.7 Compliance ActivitiesCompliance Issues: The evaluation examined the adequacy of the FCP compliance strategy, including guidelines, compliance reviews and related factors. This analysis revealed that FCP compliance activities are a major weakness of the program. This was seen in FCP employer survey results which indicated that less than half of FCP employers were implementing key FCP steps.11 This was also strongly shown in administrative data that indicated that from 1992-95, the number of FCP compliance reviews completed ranged from as low as 121 to as high as 217 per year. Overall, the number of completed reviews has dropped considerably, between 1993 and 1999, going steadily downward from 217 closed in 1993 to 33 closed in 1999 (see Display 3 below).
Possible Reasons for Decline in Compliance: While compliance reviews can prompt employers to implement employment equity activities, compliance reviews, as currently undertaken, have only modest impacts. This is because they often only result in employers beginning the employment equity process, they are infrequent and drawn out over a long time period, and they are not linked to potential penalties if compliance is poor. Historically, the FCP compliance review process typically involved many extensions (e.g., because the person managing employment equity leaves or other organizational changes occur), and can take more than a year to complete. One of the reasons for the decrease in compliance reviews appears to be the elimination of a separate compliance unit, this activity having been given to the regions in 1995. A number of FCP employers also felt that compliance reviews are potentially important as a motivator. A few case study employers found the compliance review process helpful since a compliance review can help management identify and correct gaps and weaknesses. But other employers who participated in case studies indicated that the expectations were unclear and the process was time consuming relative to the benefits.12 Survey responses suggest that employers know what to expect from compliance reviews with the majority of employers indicating that the process was clear. However, the FCP employer survey indicated that only 26 percent of employers found the compliance review process helpful and only 25 percent were satisfied with this process (see Section 4.6 for details on employer satisfaction with FCP). While the Workplace Equity Officers' (WEOs) dual role of consultation and compliance was seen as problematic by some, the fact that WEOs reported that they only spend about 7 percent of their time on FCP compliance reviews significantly contributes to the weakness of the FCP compliance process. Designated groups and other stakeholders suggested that this dual role creates a conflict of interest for WEOs. Some employers also indicated that having the same person educate them on employment equity and conduct the compliance review does not give the compliance process enough clout.13 It appears that the very definition of "compliance" is problematic. In FCP today, "compliance" effectively is defined as not refusing to do employment equity, rather than the stated requirement in the U.S. where "good faith effort" is defined and treated as actually making progress. A related problem for compliance reviews is that there is no way to distinguish between different levels of involvement/commitment to employment equity. This suggests that a compliance "continuum" — a range of compliance tools or procedures — would help. Such a continuum could be linked to a range of penalties rather than just the ultimate penalty of disbarrment. 3.8 EnforcementNeed for Enforcement: When examining the adequacy of FCP enforcement, multiple evaluation data sources (administrative data, surveys of employers, case study interviews and surveys of WEOs) indicated the need for stronger enforcement of FCP. Given that employer compliance tends to be weak, especially given the lack of real penalties for unresponsive employers, and the fact that the existing enforcement mechanism (disbarrment from contracts) is very rarely used is a problem. This weakness of the FCP enforcement process was seen by stakeholders as greatly limiting the program's impact. Indeed, the evaluators noted reports that only eight contractors had ever been disbarred. However, stakeholders reported that as a rule, no employers have recently been prevented from bidding on a new federal contract because of non-compliance, although many employers — stakeholders noted — do little or nothing to fulfil their FCP commitments. Key stakeholder and administrative data both point towards a need for a new process and —if the program is to be effective — significant repercussions for employers who fail to fulfil their FCP commitments. In the course of the evaluation, a variety of suggestions were put forward by stakeholders which could be alternatives for the future, such as requiring the filing of the employer's most recent employment equity report to FCP when bidding on new contracts. Such requirements could ensure that employers are "up-to-date" on their employment equity efforts; or an employment equity holdback on contracts could be implemented with the holdback being rebated only when a "good faith effort" has been made by the employer. 3.9 Tools and SupportsTypes of Tools and Supports: The evaluation assessed the usefulness of a wide range of FCP supports such as Regional staff, and tools (such as guidelines, statistics, and educational materials). This assessment was somewhat hampered because tools for employers are difficult to access from the HRDC website. While most of the FCP material that is available can be found on the FCP web site, not that much is available in print and the web site is difficult to find. Many of the case study employers did not know that there was a web site and much of the material referred to on the web site is old, not written in a user-friendly manner and does not use the current language of employment equity. FCP employers are encouraged to use LEEP guidelines but since the programs currently differ, this can be frustrating for FCP employers who may unnecessarily do work needed for LEEP that is not required for FCP (e.g., reporting). Employer Assessments: Employers reported that they find the data collection and analysis process time-consuming and were concerned about accuracy. For example, some case study employers suggested that not all designated groups self-identify themselves in the workplace surveys that employers conduct. Additionally a number of these employers reported that the data analysis was difficult and time-consuming and many also noted that National Occupational Codes did not fit their industry. FCP employers were asked about a variety of specific tools or measures which might help implement FCP (see Display 4, below). A substantial number of the responding employers indicated that various new tools materials or supports would help with their implementation of FCP. For example, most indicated that they would benefit from sample material they could adapt (80.3 percent); better software/tools from the federal government (77.8 percent); more information on employment equity for employers (72.5 percent); feedback on how their firm is doing relative to their industry (71.1 percent); and worksheets which would calculate gap once employer data was put in (76.9 percent) would help them in their efforts to comply with FCP requirements. Other supports such as annual reporting of representation to the federal government (31.1 percent); better recognition for Award winners (31.3 percent); and more information about the FCP (36.7 percent) were areas where fewer FCP employers identified as potentially helping implementation. Importantly as well, few of these alternative approaches were regarded as potential hindrances by employers. For example, annual reporting was assessed as a potential hindrance only by 18 percent of employers, and the only items rated as substantial hindrances were "separating sub-groups" (35 percent regarded as a hindrance), and "enforcement of the FCP by the CHRC" (37 percent regarded as a hindrance). In the same vein, all of the WEOs surveyed (100 percent) supported the idea that employers would be helped by having more access to FCP staff and tools. They indicated that employers would be aided generally by more information on employment equity and "how-to-do-it" kits; sample materials that employers could adapt; better recognition of award winners and more information about the program generally, for example, by providing an annual report. Also, WEOs noted that a number of strategies could be used to improve program delivery and compliance, including increased staff resources (100 percent); more compliance activities (92 percent); better information systems (91 percent); increased educational efforts for employers (85 percent); and periodic reporting from employers (85 percent).14
3.10 Information-Communications StrategyCommunications in FCP: Does the program communicate effectively and efficiently with employers? Do such communications build relationships, partnerships, and broader support for employment equity goals? Findings: The survey of FCP employers suggested that many employers have not been contacted by FCP for periods of a year or much longer (most employers were contacted by FCP staff only every 3-5 years). Often when contact is made regarding compliance reviews, only then do employers begin their employment equity activities. A majority of employers suggested that they wanted more contact with FCP staff. This suggests that more contacts and better partnering with employers could be aided by a stronger information-communications approach as an overall strategy to better develop employment equity in FCP workplaces. Other problems noted included the lack of a clear explanation of FCP at the bidding stage, and what the employment equity process could involve. Additionally, communications with other federal departments were very limited (observation based on key informant interviews), and little communications was found with designated groups (data from focus groups and key informant interviews). Most strikingly, the last publicly available report on FCP was published in 1994, with no other comprehensive public reporting on the program in the 7 years since then. This pattern was very unlike that noted for the U.S. program which involved extensive communications, and also community level efforts (See literature review). 3.11 Positive Incentives: Awards ProgramsMerit Awards: The value of the Merit Awards Programs was assessed to consider the potential for positive incentives (recognition of exemplary employers, etc.). From 1990 to 1994 almost every FCP employer who applied was given an award but since 1994 awards have not been automatic. Even though the majority of FCP employers are small, the majority of award winners are large. In part this may be because the application process for awards is costly and winning can also be costly (e.g. making video, going to award ceremony). Findings: The evaluation indicated that the Merit Awards Program has value for "rewarding" good employers and is a good illustration of best practices, but that the program has reached few employers and is little known or valued outside of those who apply. Only 5 percent of employers rated the awards process as helpful for their employment equity efforts, but 31 percent favoured better recognition for awards winners. The Merit Awards Program appears to be useful to those who participate, but a number of stakeholders suggested the program needs to reach more, and smaller, employers. New approaches could include: providing transportation and accommodation for awards winners as an encouragement to participate in awards "meetings"; the sharing of best-practices by FCP and LEEP employers; and providing positive feedback to FCP employers by reporting good performers in a widely distributed annual FCP report. 3.12 Costs to Employers and GovernmentThe Issue of Costs: The issue of whether implementing employment equity resulted in employers having a perception of, or of actually incurring, undue additional costs was addressed by the evaluation. Additionally, a number of key stakeholders expressed concern that the implementation of any new program features in the future should not impose undue costs on the participating federal departments who identify contractors as having requirements under the FCP. Findings: Economic impacts on employers from the implementation of employment equity in their workplaces was not noted as a significant concern in data collected for the evaluation. Indeed, reported actual costs were modest for employers who were engaged in active employment equity implementation,15 averaging $33 per employee. Thus, for example, on average an employer with 100 employees would face an annual cost of $3,300 to implement FCP. Further, costs appear to be offset to some degree by positive economic business impacts (see Section 4.5). Costs for Federal Departments were also not significant, according to Departments representatives who were interviewed. 3.13 Organization within HRDCOrganizational Issues: The evaluation examined administrative obstacles to FCP success, particularly in the organization of the program within HRDC, and in interdepartmental roles. FCP is located within the Labour Standards and Workplace Equity Branch and it was found that within this unit, equity is, in the eyes of many stakeholders, overshadowed by broader concerns with labour standards and occupational safety and health. This was reported to be particularly true in regional offices where Workplace Equity Officers (WEOs) are the only ones working on equity issues and often the regional manager has little or no knowledge of such issues (see Technical Report #6 — Survey of FCP Staff/WEOs). Findings from the key stakeholder interviews suggest that the location of the program within HRDC Labour program is logical because of the linkages with employment equity workplace issues. However, the actual delivery and effectiveness of the program is perceived by some as significantly hindered by a lack of priority for the program and a lack of attention by senior management.16 Historical Issues: Until 1995, the FCP was located within a separate Employment Equity Branch in HRDC and as such had a much higher profile with its own Director General and so on. That Branch also retained its own policy personnel which is an important element to a complex program such as FCP which must deal with a wide range of stakeholders and complex policy questions such as pursuing the directions of Parliament regarding equivalency. In 1995 the Employment Equity Branch was combined with Labour Standards in a new Labour Standards and Workplace Equity unit. Additionally, and a factor given great importance by key HRDC stakeholders, policy staff were removed from the employment equity program when it was combined with Labour Standards. HRDC Stakeholders emphasized that combining Employment Equity with Labour Standards, and removing its policy staff complement greatly reduced both the standing and capacity of the program. Most importantly, direct access to such policy staff was limited in the new organizational structure, reducing the extent to which policy staff could be applied to FCP issues. Current Issues: It was also noted that all the staff working on employment equity within HRDC are not in the same unit, which decreases their effectiveness. In Ottawa, the FCP unit is separate from LEEP and employment equity policy. In the regions the WEOs are responsible for both employment equity programs (LEEP and FCP) along with pay equity, which is quite different. Further, there is no legal counsel closely involved with FCP, even though there are many legal issues that need to be addressed. Finally, stakeholders noted that there is no well-established link between FCP and other employment programs run by HRDC. 3.14 Roles of Participants in FCP and StakeholdersIs there a Need to Clarify Certain Roles? Whether the roles of FCP participants are clear was examined by the evaluation with data from case studies, discussion groups, and surveys indicating that the sporadic contacts between FCP program staff and FCP employers leads to confusion about the program and its requirements. Findings: The evaluation highlighted the extent to which partners, such as representatives of designated groups, unions, and industry associations, are not aware or involved with FCP. Employers and Unions: Stakeholders and related data indicate that the roles of participants are generally unclear for workplace parties (employers, unions, etc.) as unions are not required to be involved in FCP (as they are in LEEP). This was noted as a concern since local unions also need to be educated about employment equity. Case study participants suggested that in some cases unions may be supportive of employment equity, but there are also instances where seniority/union contracts, etc., work against employment equity. Designated Groups: With regard to designated groups, it was apparent that knowledge and awareness of the program and its workings is poor among these groups and that designated groups have no formal role in FCP. Some designated groups, particularly Aboriginal peoples' groups, expressed a desire to have a role in overseeing FCP, for example, by serving on an advisory committee for the program. Thus partnerships with designated group organizations may be an avenue for building capacity for FCP.17 Other Departments: As regards other government departments, it was noted that generally, outside of PWGSC, departments reported that their role was simple and clearly understood. However, it was apparent that other departments had little understanding of FCP and its goals, which may point to a need for informational efforts on the part of the program.
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