Reports

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EVALUATION OF THE EMPLOYMENT EQUITY COMPLIANCE PROGRAM by Consulting and Audit Canada (CAC) CAC CONCLUSIONS CHRC MANAGEMENT RESPONSE AND ACTION PLAN October 9, 2003   ISSUE 11: How useful is the Employment Equity Annual Report? CAC Conclusions The Employment Equity Annual Report is required by the EE Act but is also useful to employers. Employers value the report mostly for information on others in their industry and for best practices. Partners are of the opinion that the report could be more positive, more analytical and provide more examples of best practices. The report is becoming more analytical in highlighting problem areas and best practices. CAC Recommendation 11.1: The CHRC should continue to make the EE Annual Report more analytical: highlight common problems in achieving compliance; identify prevalent employment barriers and successful solutions; identify government-wide and industry-wide issues; continue to provide examples of best practices. CHRC Management Response: Agree This reflects current practice, and is undoubtedly one of the principal reasons why 91% of employers stated being familiar with the CHRC’s Annual Report during the employer survey, and 78% having found it useful. This recommendation is also in keeping with the report tabled by the Parliamentary Committee reviewing the Act , to the effect that the CHRC be provided with sufficient resources to facilitate employers fulfilling their obligations, and also relates to recommendation 8.3 under Issue 8. ACTION PLAN: The Commission is looking at ways by which it can enhance its capacity in this respect.   ISSUE 12: Is the audit selection process effective? CAC Conclusions A large majority of employers achieve compliance only after being audited. Most stakeholders are supportive of the focus on large employers. There are mostly only small employers left for the first round of audits. If 100% auditing continues, the audit cycle may be around 12 years in total. There is some support for focussing audits on employers with the greatest potential to impact representation levels(large employers who are in expanding industries). All CHRC managers and auditors believe that 100% auditing should continue. CAC Recommendation 12.1: The CHRC should consider whether 100% auditing is optimal in light of the expected audit cycle and whether all remaining small employers should be audited in the first round (recognizing that employers who are not audited are unlikely to achieve compliance in the absence of an audit). CHRC Management Response: Disagree This recommendation contradicts recommendation 7.1 of the Report which states that “the CHRC should continue auditing of employers up to the development of EE plans.” As the Report acknowledges, if the CHRC were not to audit these smaller employers, it is unlikely they would comply with the Act. This would create two classes of employees: those who are afforded the protection of the Act because they work for larger employers, and those who are not, because their employer is smaller. The CHRC believes that this is incompatible with the spirit of the Act. However, as proposed in recommendation 5.3, the CHRC is implementing a streamlined audit approach for smaller employers. ACTION PLAN: No action required CAC Recommendation 12.2: In the next round of auditing, the CHRC should consider whether a focus on employers or sectors with the biggest potential for impact on EE should be the focus. CHRC Management Response: Agree The Employment Equity Branch focussed on employers with the biggest potential for impact in the first round of audits, and will continue to do so when auditing for reasonable progress. Audits of employers now cover 79% of the employee population, as well as the entire public service. Although the evaluation did not identify criteria which could apply, the Commission has identified lack of progress in representation, degree of remaining under-representation, and growth in some industrial sectors, as important indicators. ACTION PLAN: Reflects existing practice.   ISSUE 13: To what extent can the audits be streamlined? CAC Conclusions The proposed audit cycle and the audit service standards are not being met. Almost half of employers believe the audit process can be streamlined. Employers believe the audit process would be much streamlined if more detail was provided to them on what exactly is required of them. The most frequently mentioned recommendation to streamline audits is to provide more tools, templates and examples to employers. Stakeholders and CHRC staff also believed that the audit reports could be significantly shortened to provide only the information necessary to employers and that the process should be simplified for small employers. CAC Recommendation 13.1: The CHRC should work in cooperation with HRDC and TBS to ensure employers have the tools and templates they need, and examples of how employers can comply with the requirements. CHRC Management Response: Agree The Commission has, over the last five years, shared with HRDC and TBS the tools and templates it uses for auditing purposes. These include the guide and analytical template on Employment Systems Review, the statistical template for Workforce Analysis, and the Audit Process Manual. HRDC has put many of these tools on its web site for employers. The Commission’s streamlined audit approach for smaller employers utilizes new tools and templates which have also been shared with both agencies. ACTION PLAN: Reflects existing practice. CAC Recommendation 13.2: The CHRC should follow through on its internal review of documents and templates and its investigation of ways of streamlining the audit process for small employers. CHRC Management Response: Agree The Employment Equity Branch established a task force in 2001 to review 46 existing documents and templates. Recommendations resulting from this task force have been implemented. Other than asking the Commission to continue with its work, the evaluation report does not identify any suggestions as to how the audits can be streamlined as requested under this issue. The audit process for small employers has already been developed. ACTION PLAN: Reflects existing practice. CAC Recommendation 13.3: The CHRC should examine the feasibility of the other recommendations for streamlining made by stakeholders and CHRC staff that are identified in this report. CHRC Management Response: Agree The evaluation includes direct quotes from persons interviewed but no analysis of their feasibility. ACTION PLAN: The Commission reviewed these suggestions in developing a streamlined approach for smaller employers.   Back to top   Previous Page Table of Contents Next Page