Information identified as archived on the Web is for reference, research or recordkeeping purposes. It has not been altered or updated after the date of archiving. Web pages that are archived on the Web are not subject to the Government of Canada Web Standards. As per the Communications Policy of the Government of Canada, please contact us to request an alternate format.
The creation of your organization’s employment equity plan brings together all elements completed in earlier steps. Your organization will use the information gathered and the recommendations (if applicable) developed in earlier stages of the employment equity process to develop a sustainable employment equity plan.
An employment equity plan gives your organization a systematic and structured approach to removing barriers and implementing positive policies, practices and special measures that will remove gaps in the representation of the four designated groups.
This plan is intended to be a “living document,” meaning that it needs to be monitored and updated. For example, if after a year your organization reaches its numerical goals for hiring and promoting visible minorities but is far behind its goals for another group, it may adjust its plan to focus more on the groups that continue to be under-represented.
Your organization’s employment equity plan must include:
This introductory section provides background and summary information on creating an employment equity plan, including:
As an organization implementing employment equity in your workplace, you are required to create an employment equity plan under the Employment Equity Act, the Employment Equity Regulations and the Federal Contractors Program Requirements.
The creation and implementation of an employment equity plan is referenced in sections 10, 11, 12, 13 and 15 of the Act.
Section 10 of the Act requires organizations to:
Section 11 of the Act requires organizations to:
Section 12 of the Act requires organizations to:
Section 13 of the Act requires organizations to:
Section 15 of the Act requires organizations to:
Section 11 of the Regulations requires your organization to establish and maintain records related to its employment equity plan and the steps it has taken to monitor the implementation of its plan.
As an organization covered under the Federal Contractors Program, you are required to adhere to requirements 7 through 10 in developing your employment equity plan:
A continued focus on communication, consultation and record keeping is crucial to creating an employment equity plan. Routinely consulting with employees, management, employee representatives and bargaining agents will ensure a transparent process and further demonstrate your organization’s commitment and accountability. Documenting your organization’s efforts to create a solid and sustainable employment equity plan will also contribute to transparency and accountability.
Your organization is required to maintain constant communication with employees, management, employee representatives and bargaining agents in developing and implementing its employment equity plan. These individuals can play a significant role in setting goals and creating positive policies, practices and measures.
Input from these individuals could help your organization establish innovative and creative:
As in previous tasks completed in the employment equity process, your organization must consult with employees, managers, employee representatives and bargaining agents throughout the creation of your formalized employment equity plan. Input from these individuals is vital to ensuring that all goals and measures set out in the plan are achievable and sustainable.
Record keeping plays a significant role in the creation of your organization’s employment equity plan. Throughout this process, you will be asked to consult past records (for example, the results of your organization’s workforce analysis and employment systems review) and to create new records of your intentions related to goals, measures and monitoring procedures.
Your completed plan is perhaps the most important record your organization is asked to create and modify over time. It contains a thorough overview of your organization’s current and future plans to create and maintain an equitable workforce where no individual is denied opportunities for reasons unrelated to ability.
This guide provides your organization with a number of tools and templates that will help you complete your employment equity plan.
Tools
Templates
Creating an employment equity plan requires significant links between the results of your organization’s workforce analysis and employment systems review. Your organization will use the results of both forms of analysis to develop a plan for addressing the under-representation of designated groups in your workforce.
The results of your workforce analysis will be used to establish short-term hiring and promotion goals that, if achieved, will result in reasonable progress toward closing gaps in the representation of the four designated groups. Your organization can achieve these numerical goals by removing all barriers uncovered by the employment systems review and by instituting positive policies, practices and special measures.
The results of your employment systems review will be used to establish an action plan that includes measures for eliminating all barriers identified in the review. Creating positive policies will enhance the workplace for all employees, with particular positive impacts for the designated groups, and special measures will ensure that gaps are reduced in a timely manner.
Timelines are required for achieving all measures. Record each measure and timeline in your employment equity plan.
The result will be a written plan that must be reviewed at least once during the three-year life of the plan and adjusted as required. The plan is just one more step in an employment equity process that is consistent with the basic tenets of any good problem-identification or problem-resolution strategy.
Note: The key standard established by the Employment Equity Act is that your employment equity plan, if implemented with reasonable efforts, will lead to reasonable progress toward removing gaps in the representation of the four designated groups
Upon completion of Step 3: Creating an Employment Equity Plan, you will have:
Task A: Review results of the workforce analysis and employment systems review
Review the results of your organization’s workforce analysis and employment systems review. The purpose of this task is to recall areas of under-representation that must be addressed and barriers that must be removed, to ensure they are covered in the plan.
Task B: Establish recruitment and promotion goals in the short term
Establish short-term goals of one to three years to close gaps in the representation of designated groups identified in your workforce analysis. These short-term numerical goals must be sufficient to ensure that reasonable progress will be made in closing the gaps over three years.
Task C: Create an action plan for removing barriers in the short term and implementing positive policies and practices, special measures, and accommodation
Develop measures and an action plan for removing barriers and achieving short-term hiring and promotion goals. This includes measures for eliminating employment barriers identified in your employment systems review, creating and implementing positive policies and practices, creating special measures to accelerate the closure of gaps in representation, and creating and implementing reasonable accommodation measures.
Task D: Establish representation goals for the long term
Long-term goals are goals that will be achieved after the three years of the plan. Long-term goals indicate your organization’s objectives with respect to achieving full representation of under-represented designated groups in your workforce over time. Long-term goals may be numerical, non-numerical or both.
Task E: Establish monitoring and revision procedures
Like all corporate plans, your organization’s employment equity plan is a living document that must be continuously monitored, evaluated and revised. The plan must be reviewed and revised at least once every three years.
Task F: Write your organization’s official employment equity plan
An employment equity plan must include an introduction outlining the steps your organization has taken to communicate with employees, a section identifying those accountable for employment equity within your organization, and your workforce profile.
The plan must have a results table detailing how your employment equity plan will address problem areas identified in both your workforce analysis and your employment systems review.
Lastly, your plan must include a detailed description of the monitoring system your organization will put in place to monitor progress as well as review and revise the plan.
To ensure that your organization’s employment equity plan will close gaps in the representation of designated groups and eliminate barriers, you must first review the results of both your workforce analysis and your employment systems review.
Upon completion of Task A, you will have:
To review the results of your organization’s workforce analysis, consult the results table in your workforce analysis summary report. This table provides the scope your action plan is required to cover, as it identifies all the gaps to be addressed.
The same is required for the review of the results of your employment systems review. You must take note of the recommendations made in the employment systems review. If your organization chooses not to incorporate certain recommendations into your employment equity plan, a justification is required. While developing the plan, it may well be possible to identify more effective measures for dealing with barriers or implementing special measures.
Note: Your plan must respond to all identified gaps and barriers.
To correct issues of under-representation identified in your workforce analysis, your organization must establish short-term hiring and promotion goals. These goals should cover a period of one to three years.
Upon completion of Task B, you will have:
When establishing numerical hiring and promotion goals, it is important to keep in mind that you are not being asked to implement quotas. Quotas are explicitly prohibited from being made mandatory under Subsection 33(2) of the Employment Equity Act. These goals are related to your organization’s own gaps in representation and are calculated in a way that is appropriate and attainable for your workforce. These goals are similar to all other performance goals in your organization and serve as key measures of the success of your employment equity plan. As such, they provide the same quality of performance indicators most organizations establish for their lines of business.
Employment equity is also not about hiring or promoting unqualified candidates or having your organization suffer undue hardship. Rather, it is about taking the necessary steps to ensure that designated group members are hired, promoted and retained equitably.
You may choose to use either absolute numbers or percentages in creating your goals. Typically, absolute numbers are used in instances where there are small gaps in representation, and percentage goals are used where there are large gaps. Percentage goals are better at automatically reflecting changes in your level of staffing actions in any given year.
Organizations must aim to achieve rates of hiring and promotion of designated group members that are at a minimum on par with availability, as identified in the workforce analysis. As such, hiring goals must not be lower than the relevant external availability figure. However, it is often necessary to set goals above availability in order to make reasonable progress toward closing the gaps. How much greater than availability will depend on a number of factors as set out in Section 10(2) of the Employment Equity Act, which states that employers shall consider the following in establishing numerical goals:
As we will see, you have to establish positive policies and special measures that provide a reasonable expectation that these goals will be achieved.
Designating responsibility for the achievement of goals is a significant measure for increasing the likelihood that gaps in representation are closed. The responsible individuals could include managers or human resources officials. Goals established and the time frame in which these goals are to be achieved must be communicated to each individual selected to oversee the hiring and promotion of designated groups that are under-represented in their areas of concern. Again, this is consistent with the standard practices of good management.
The Basic Goals Tool in Appendix 3A, allows your organization to anticipate the representation of designated group members in your workforce by projecting annual hires and terminations over a three year period. This tool is an Excel table that automatically calculates hiring goals as percentages. You will also find instructions on how use this tool in Appendix 3A.
Establishing a three year employment equity action plan is required to support the numerical goals set in the previous task. Your organization’s short-term action plan must include:
Upon completion of Task C, you will have:
Your organization’s employment equity plan must include measures for removing the barriers identified in your employment systems review. In many cases, the recommendations (if any were made) in your employment systems review will be the most appropriate to adopt. Barriers are generally defined as policies and practices that have an adverse impact on one or more designated groups and are not required for the safe and efficient operation of the business. They must be removed as quickly as possible. For example, barriers such as invalid tests and standards must—and can—be removed immediately.
However, some measures for eliminating barriers, such as the development and implementation of more structured human resources practices, may take time to implement. Still others may be a function of the organization’s current status and may be retained with the addition of supplemental initiatives to overcome their negative impacts. For example, word-of-mouth recruitment is often a very effective approach for employers, and its negative impact is the result of current levels of under-representation.
In the final analysis, however, your organization must ensure that its practices over the three years of the plan are capable of permitting it to meet the short term hiring and promotion goals.
Measures that will be taken to remove barriers are to be recorded in a table found in Appendix 3B. Each measure is to be paired with an individual responsible for implementing the measure, and the time frame for the removal of the barrier.
Positive policies and practices are measures that, although not explicitly targeted at designated group members, create an environment that supports a diverse workforce and the removal of barriers.
There are many types of positive policies and practices that your organization may implement, for example:
These are just some of the policies and practices you might implement. Be creative and innovative in adopting positive policies and practices to promote and encourage a more representative workforce.
Developing Positive Policies
When developing positive policies, it is important to be clear and concise.
All positive policies should include:
The Labour Program has developed examples of an employment equity policy (Appendix 3C), an anti-harassment policy (Appendix 3D), and an accommodation policy (Appendix 3E). In order to be found in compliance, an organization must have at least a minimum these three policies, although it may choose to draft its own versions.
If your organization has areas of significant under-representation, special measures are required to speed up the closure of gaps and to specifically target and encourage the recruitment, promotion and retention of designated group members. Special measures may also be required where it will take time to remove an identified barrier. These initiatives are aimed explicitly at attracting, promoting and retaining members of the designated groups to address the ongoing effects of under-representation.
Section 2 of the Employment Equity Act states that employment equity means more than treating people in the same way—it also requires special measures and the accommodation of differences. Section 15 of the Canadian Charter of Rights and Freedoms permits special programs, as do all federal, provincial and territorial human rights Acts.
Examples of special measures include targeted:
Note: The fact that these measures are explicitly targeted at one or more designated groups makes them “special measures.” Normally, such measures are used until the gap has been closed.
Other special measures could include:
Your organization is encouraged to be creative and innovative in creating special measures to ensure that goals are achieved and gaps are reduced. It is crucial that special measures are targeted at areas of under-representation and are clearly designed to support the goals your organization has established.
Reasonable accommodation involves adopting new initiatives or adjusting current policies to eliminate barriers to the full participation of all designated group employees and prospective employees. Accommodations are not reserved for persons with disabilities; they may also be made to accommodate employees’ family status or religious adherence. It is important to note that these policies are not intended to cause your organization undue hardship.
Undue hardship implies that some hardship in providing accommodation must be expected. To determine when it becomes “undue,” the employer considers cost and health and safety.
Examples of accommodation include:
An accommodation policy must have clearly outlined procedures that provide guidelines for managers and supervisors who provide accommodation and for employees requesting it. It should also respond to all the prohibited grounds of discrimination covered in the human rights act that applies to your province or territory of operation. You will find an example of an accommodation policy and procedures in Appendix 3E.
Note: Accommodation should only be applied when a barrier is deemed to be valid. If the barrier is not valid, it must be removed, as mentioned in the Employment Systems Review Policies and Practices Diagnostic Tool.
Just as you recorded your short-term numerical goals in a table, you must do the same for the Special Measures, Positive Policies and Practices and Reasonable Accommodation Measures to be implemented.
In order to complete the suggested table, identify the Employment Equity Occupational Group that the policy or practice is affecting negatively, record the barrier that was identified in your employment systems review, and then record the measures that you have established, the time frame in which you expect to reach that goal, and the manager responsible.
To complete the Employment Equity Action Plan: Special Measures, Positive Policies and Practices and Reasonable Accommodation Measures, list the objective to be achieved; the actions to be taken; the individual to be responsible for taking action; and the time frame for completion.
You will find a blank table for your use in Appendix 3F.
Establishing long-term representation goals is crucial for increasing the likelihood that gaps in the representation of designated groups remain closed and that no new gaps will be identified. The purpose of long-term goal setting is to enable your organization to set aside immediate operational requirements and consider the broader picture. Long-term representation goals will help your organization to establish employment-equity-related objectives for a period of more than three years. These goals may be numerical, non-numerical or both, depending on the needs of your organization.
Upon completion of Task D, you will have:
The focus of long-term numerical goals is to address gaps that may require more than three years to close. For example, a long-term numerical goal could be to achieve full representation of all designated groups in all management positions within five years.
Long-term action plan initiatives are meant to be larger efforts to eliminate specific barriers in the workplace. For example, long-term non-numerical goals could include completing building modifications to improve access for, and accommodation of, persons with disabilities or establishing an on-site daycare facility. Another qualitative goal could be to organize, over time, training and information sessions to eliminate cultural and attitudinal barriers.
Your organization’s long-term action plan may be recorded using the Employment Equity Action Plan: Measures to Remove Barriers, and the Employment Equity Action Plan: Special Measures, Positive Policies and Practices, Reasonable Accommodation Measures in Appendices 3B and 3F.
To ensure the effectiveness and sustainability of your organization’s employment equity plan, you must create and implement monitoring and revision procedures.
Monitoring is the regular evaluation of your organization’s employment equity plan to assess whether reasonable progress toward implementing employment equity is being made. Your organization is required to update numerical goals and make any changes that are necessary upon review. An employment equity plan must be reviewed at least once in the period during which short-term numerical goals are established (i.e., once every three years).
Upon completion of Task E, you will have:
Continuous monitoring of your employment equity plan will help your organization to:
A good monitoring system measures the extent to which the key activities set out in your employment equity plan are being implemented and tracks progress in achieving the organization’s short- and long-term goals with measurement at appropriate intervals. It helps ensure that the activities are undertaken within the time frame set out in your plan and evaluates whether the time frames themselves are realistic and achievable. The information obtained in the monitoring process is used to review the effectiveness of the plan and provide direction in revising it.
Changes in the representation of designated groups provide an indication over time of how successful various activities aimed at increasing representation have been. If your organization is not meeting its short-term numerical goals, it must examine the action plan closely to determine why its measures are not effective and make necessary adjustments or replace them with more appropriate measures.
To create a successful and efficient monitoring system, your organization must describe:
It is expected that if a goal or measure is not being achieved, the plan will be revised to include additional new and/or modified measures and activities.
To facilitate monitoring, all statistics and documents related to employment equity must be retained for two years after the period covered by your employment equity plan.
Your organization’s employment equity plan must include a thorough summary of the efforts that have been undertaken to implement employment equity to the point of finalizing the plan. It must also include a thorough summary of the concrete steps you will take to implement your plan, including monitoring and revising its contents regularly to ensure that progress is sustainable.
Upon completion of Task F, you will have:
An employment equity plan must include:
You will find detailed instructions for the completion of each of these elements below.
For an employment equity plan template, see Appendix 3G.
The introduction of your organization’s employment equity plan is an overview of your organization’s workforce profile, actions taken to communicate with various individuals throughout the creation of your employment equity plan, and measures put in place to ensure accountability.
Record your workforce profile. The information required is:
Describe in detail consultations that took place and communications that were circulated in the process of creating your organization’s employment equity plan.
Your organization likely consulted with employees, management, employee representatives, bargaining agents and other individuals on a number of occasions. Describe actions that were taken to announce:
Your organization will have communicated with these actors in various scenarios throughout the implementation process. It is important to note all of these occurrences to substantiate your efforts to communicate.
Describe how accountability was maintained throughout the creation of your employment equity plan. In this section, identify the individuals responsible for various tasks undertaken in this step.
Identify:
Also identify:
In this section, you are required to describe:
Discuss how your organization’s long- and short-term numerical and non-numerical goals will address areas of under-representation identified in your workforce analysis and eliminate barriers identified in your employment systems review.
Providing a review of results will add to your organization’s efforts to document the employment equity process appropriately as well as add meaning to the planned goals and measures.
In this section of your organization’s employment equity plan, you must provide a detailed description of the measures to be put in place to monitor and revise the plan. This must include the names and contact information of those responsible for monitoring the employment equity plan, how often a review will take place, what types of consultations with employees will take place regarding the monitoring of the plan, to whom the results of the monitoring process will be reported, and how the results of the monitoring process will be reported to employees.
Again, you may wish to consult the employment equity plan template in Appendix 3G.
Once your employment equity plan is complete, you will move on to the fourth and final step of this process: retaining compliance by successfully implementing your employment equity plan, revising it as required and sustaining your employment equity program.