Ensuring Reasonable Progress and the Importance of Performance Measurement Reasonable Progress
The Employment Equity Act (the Act) requires organizations to ensure that their employment equity plan would constitute reasonable progress towards implementing employment equity. The Act also requires organizations to make reasonable efforts to implement their employment equity plan and monitor implementation on a regular basis to assess whether they are making reasonable progress. The minimum standards of reasonable progress are:
- The achievement of appropriate representation of designated group members or the movement towards this goal at an appropriate rate of progress;
- In cases where the improvement in overall representation is evolving slowly, the hiring rate should not be lower than the labour market availability rate and the rate of promotion should not be lower than the designated group's representation in a specific occupational group;
- The short-term numerical goals will result in a reduction in the representation gaps, which may entail hiring above the rate of labour market availability; and
- The employment equity plan contains measures that are likely to ensure progress in overall representation.
On the issue of reasonable effort, minimum standards include:
- The degree to which various components of the plan have been implemented according to schedule;
- An indication of on-going senior-level support for employment equity programming;
- An indication that the organization has sought input from the union in making a collaborative effort to implement the employment equity plan;
- The establishment of clear lines of responsibility and an accountability mechanism for implementation;
- The dedication of adequate financial and human resources to facilitate implementation of each element of the plan; and
- The establishment of regular review mechanisms to ensure that time frames are adhered to and goals are met. These mechanisms should ensure the participation of employee representatives.
Appropriate Data Collection and Possible Measures and Data Sources
Appropriate data collection plays an important role in creating strong employment equity practices and inclusive workplaces. Data collection can help to monitor discrimination, to identify and remove systemic barriers, to prevent disadvantages, and to promote equality. Federally regulated organizations should, at minimum, collect two basic types of measurable information on human rights: data relating to grievances/complaints of discrimination and/or harassment; and data relating to employment equity. The following are possible measures and data sources:
- Percentage of managers trained on the Canadian Human Rights Act (CHRA) and the Employment Equity Act;
- All dedicated resource persons provided with x number of specialized employment equity training sessions on unconscious bias, hiring strategies for Indigenous people or persons with disabilities, managing a diverse workforce, understanding and accommodating cultural differences, mentoring women (or other designated groups) for management positions;
- Survey on the level of EE awareness of staff (awareness of EE purpose and of the organization’s EE objectives);
- Data systems related to discrimination, harassment, failure to accommodate, and accessibility grievances or complaints;
- Data system to capture employment equity data;
- In-depth interviews, qualitative surveys and/or focus group reports containing information on perceptions of fairness, discrimination, harassment, accommodation, accessibility, access to training and opportunities for promotion
- Documentation related to implementation of employment equity requirements;
- Documentation related to implementation of the EE plan and individual action steps in the EE plan;
- Evaluations of the effectiveness of implementation of action plans, policies and processes;
- Workforce surveys measuring employee satisfaction, engagement, and morale;
- Communication items demonstrating the visibility of employment equity advocates and designated group members in senior leadership positions;
- Promotion/championship of employment equity by the senior leadership;
- Performance agreements showing inclusion of employment equity responsibilities in work objectives of managers and supervisors; and
- Performance assessments showing achievement of EE objectives as an element in the rating of individual managers.
- Performance bonus being tied to the implementation of specific measures from the EE plan and results achieved in terms of increasing representation where needed.
Evaluation for Performance Measurement and Continuous Improvement
Several types of systems can be used to monitor employment equity. An organization’s approach will be determined by the size of the organization and its employment equity program, as well as its existing methods of performance measurement and goals. Examples of systems include:
- Developing a performance measurement framework: Some organizations may choose to design an employment equity performance measurement framework. Based on the trends, the organization sets specific employment equity goals. In order to assess these goals, it establishes a structure to collect objective information. In this context, a performance measurement framework should include strategic outcomes, expected results, performance indicators and associated targets, data sources and data collection frequency, as well as the actual data collected for each indicator related to employment equity. Other organizations may choose to add employment equity outcomes to their overall performance measurement framework.
- Existing scorecard or dashboard: Other organizations may prefer to develop a dashboard or use an existing scorecard to monitor progress. Scorecards or dashboards are now widely used in organizations. Dashboards monitor and measure processes. The common understanding of a dashboard is that it gives a real-time update as employment equity progress happens. A scorecard, on the other hand, charts progress toward objectives. It displays periodic snapshots of performance associated with an organization's objectives and plans. It measures business activity at a summary level against predefined targets to see if performance is within acceptable ranges. No matter which approach your organization is using to capture its business performance, employment equity data, indicators or targets can easily be anchored to it.
- Senior leadership driving the monitoring system: In order to be successful, the monitoring system should be seen as a strategic process coming from senior leaders of the organization. It helps secure the resources (human and financial) to implement the monitoring system and gives credibility to the trends and best practices highlighted in the process.
Over the course of many years, the Commission has audited many employers and identified activities that although not required can be very effective at promoting equality in the workplace, including adequate representation of the members of the designated groups. Here are some examples:
- Adding overall employment equity results to scorecard: One organization, who had been using a scorecard approach for monitoring its business performance, added one specific measure on its employment equity program. It added the overall employment equity results of all four designated groups from its workforce analysis to be able to compare them with availability. With this approach, each year, that organization can determine whether or not the organization made progress with respect to the representation of the designated group members in its workforce.
- Adding action items from the employment equity Work Plan to the Integrated Human Resources Plan: An organization is incorporating action items it has identified on its employment equity work plan into its integrated human resources plan. The integrated plan is discussed with senior leadership and shared with all employees.
- Creating competency profiles: Several organizations have introduced competency profiles as a means to focus their learning approach on a strategic, operational and motivational level. The competency profiles define the knowledge, skills, abilities, and behaviors that employees use in performing their work and their role in the employment equity continuous improvement process.
- Using a self-analysis matrix: Some organizations are using a self-analysis matrix to compare their results in terms of employee engagement, customer satisfaction, and society impact against pre-established key performance results.
- Include learning objectives as part of your performance appraisal process: Consider adding anti-discrimination and employment equity training to individual learning plans.
- Create inclusive job posters: Many federally regulated organizations have created jobs with employment equity responsibilities included. These posters often include a diversity statement, as well as a statement about the organization’s willingness to accommodate. This helps to put applicants at ease and lends credibility to an organization’s diversity initiatives.
- Seeking informed consent: When collecting data, an organization informs employees, stakeholders and the broader public about why the data is being collected, and how it may potentially be used.
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