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Archived - Step 4 – Implementing and Sustaining an Employment Equity Program

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Introduction

Step 4 provides guidance on how to sustain your employment equity plan once it has been developed and put in place.

Your organization must make all reasonable efforts to implement its employment equity plan to ensure that reasonable progress is achieved toward a favourable workplace environment and a representative workforce.

You must put into action the mechanisms from Steps 1, 2 and 3 to:

1. recognize positive and negative results of employment equity implementation and correct areas where it has not produced the desired results;
2. communicate with employees, employee representatives and bargaining agents;
3. ensure consultation and collaboration between managers, employee representatives and bargaining agents;
4. keep appropriate employment equity records;
5. monitor implementation of employment equity, particularly the measures outlined in your employment equity plan;
6. keep your workforce analysis and employment systems review results current; and
7. review and revise your employment equity plan goals and measures, as appropriate.

An employment equity plan is a systematic and structured approach to removing barriers and implementing positive and special measures that will decrease and eventually eliminate all gaps in representation of the four designated groups.

Your plan is an important document. It keeps the goals of employment equity and the path to reach those goals clear. Having completed Steps 1 through 3, you have developed an appropriate employment equity plan and will now move forward to implement it.

Step 4 is for organizations that have completed Steps 1 to 3 and have an employment equity plan. If you have completed Steps 1 to 3 and are not required to have a formal employment equity plan, and you have chosen not to develop an informal plan, see Appendix 4B for details on how to implement an effective employment equity program when a formal plan is not required.

Through compliance reviews, your organization’s employment equity plan and program are subject to scrutiny and evaluated for compliance with the Act, Regulations and Federal Contractors Program Requirements. More details on initial and follow-up compliance reviews are available in the introductions to the four steps.

This introduction provides background and summary information on sustaining an employment equity program, including:

• a summary of the legislative requirements under the Act, the Regulations and the Federal Contractors Program;
• the key points to remember;
• the tools and templates associated with Step 4; and
• a summary of the basic methodology involved in sustaining an employment equity program.

Following this introduction is an outline of the tasks involved in sustaining employment equity in your workplace and details on how to complete each task.

Legislative Framework

The implementation and maintenance of your employment equity program is required by the Act, the Regulations and the Federal Contractors Program Requirements.

The Employment Equity Act

Sections 11, 12 and 13 of the Act require that you make all reasonable efforts to implement your employment equity plan, to monitor this implementation, and to review and revise your plan at least once every three years to ensure that reasonable progress is achieved. Reviewing and revising your employment equity plan includes updating your goals and making any other changes necessary as a result of changing circumstances.

Sections 5, 14 and 15 of the Act continue to apply in Step 4, because they are required ongoing activities whose purposes are to sustain work already completed and to ensure that positive results are achieved. This includes identifying and eliminating employment barriers; instituting positive policies and practices; making reasonable accommodations; communicating with employees and bargaining agents; consulting with employee representatives and bargaining agents to get their help with communications; and preparing, implementing and revising your employment equity plan.

Employment Equity Regulations

Sections 5, 9(2), 11 and 12 of the Regulations refer to the ongoing requirements necessary to maintain an employment equity program. Essentially, you are required to keep all employment equity information up to date and maintain a record of activities undertaken for a minimum of two years after the activity or document to which they relate is complete.

Federal Contractors Program Requirements

As part of the Federal Contractors Program, you must comply with the requirements. Your organization must implement and sustain its employment equity program in order to meet the requirements by:

• making reasonable efforts to implement your employment equity program;
• achieving reasonable progress toward a representative workforce;
• reviewing and revising your employment equity plan and program at least once every three years; and
• continuing to satisfy the obligations outlined by each requirement.

Key Points to Remember

Communication, consultation and record keeping are crucial to the maintenance of employment equity. These three ongoing requirements cannot be stressed enough; they are often the key factors that determine the success of employment equity implementation in your workplace.

Communication

Communicating information from senior positions in the organization to employees plays a significant role in the success of your employment equity program. This ongoing communication regarding the program must be with employees, employee representatives and bargaining agents.

Consultation

Consultation requires that information be given and received by all individuals involved. Through ongoing consultations, you will involve employees, management, bargaining agents and employee representatives in your employment equity program, which will increase the program’s sustainability and success.

Record Keeping

Record keeping plays a significant role in tracking your progress and efforts to implement your employment equity program. Record keeping becomes particularly critical when your organization is chosen for a compliance review under the Federal Contractors Program.

Resources for Sustaining Employment Equity

Step 4 provides a tool to calculate numerical progress, a tool that outlines the ongoing requirements, and a tool that details how to implement employment equity effectively when a formal employment equity plan is not required. It also provides two template examples of how you may undertake ongoing communications with employees through bulletins. Part of sustaining your employment equity program is updating and analyzing workforce data regularly and monitoring and reviewing your employment systems and your employment equity plan continuously. You will need to continue to use the tools and templates provided in the previous three steps, or your own equivalents, as appropriate.

Summary of Methodology

Step 4 clarifies how to satisfy the ongoing requirements to implement, track, monitor, review, revise and sustain, as appropriate, all work completed in the previous steps and to ensure that reasonable efforts and reasonable progress are made toward achieving a favourable workplace and a representative workforce. Appendix 4A provides a complete list of the ongoing employment equity requirements your organization must fulfill. You sustain your employment equity program by:

• having a clearly identified person or team led by a senior official responsible for your employment equity program, who will be held accountable for the success of implementing the program in your workplace;
• communicating with employees, employee representatives and bargaining agents the purpose of employment equity, the actions taken or planned to implement employment equity, and the progress made;
• consulting and collaborating regularly with employee representatives and bargaining agents by inviting them to provide input on the assistance they could give in implementing employment equity and communicating to the workforce as well as the preparation, implementation and revision of the employment equity plan;
• maintaining records of all employment equity activities that are sufficient to demonstrate satisfaction of the Federal Contractors Program Requirements at all times;
• making reasonable efforts to implement, monitor and update your employment equity plan and program to ensure reasonable progress toward the implementation of employment equity;
• updating, monitoring and analyzing your workforce and workplace information (Step 2: Workforce Analysis and Employment Systems Review) to identify and eliminate under-representation and employment barriers;
• reviewing your new employment systems to ensure that they do not constitute a barrier to the employment of designated group members and reviewing all systems related to any new gaps in representation; and
• reviewing and revising your employment equity plan at least once every three years and implementing the newly revised plan to ensure continued reasonable progress and to respond to areas where reasonable progress has not been achieved.

Implementing and Sustaining an Employment Equity Program: A–E Task Outline

Task A: Sustaining accountability, communication, consultation, collaboration and record keeping

For your employment equity program and plan to maintain direction and produce results, a senior official and other managers must be responsible for ensuring their success. This includes instituting an accountability mechanism to support the achievement of employment equity goals and measures.

To further support your implementation of employment equity, management, employees, employee representatives and bargaining agents must communicate, consult and collaborate on employment equity matters on a continuous basis. Finally, you must also maintain appropriate records of all employment equity activities.

Task B: Make all reasonable efforts to implement your employment equity plan

Now that an appropriate employment equity plan is developed, make all reasonable efforts to implement its components in a manner that would be expected to achieve the desired results and within the time frames established.

Task C: Monitor for reasonable progress

Keep your employment equity information current; this includes keeping self-identification information up to date and updating your workforce analysis regularly.

Using the Achievement Table, or an equivalent tool, assess if your organization is achieving reasonable progress toward eliminating gaps in representation.

Task D: Monitor and assess new human resources systems, policies and practices

Review all new employment systems to determine whether or not they have an adverse impact and, if so, whether or not they are valid. If new gaps appear, the employment systems that may have had an impact must be considered. Further, you must monitor previously reviewed systems to ensure that they remain barrier free.

Task E: Review and revise your employment equity plan

Review and revise your employment equity plan to ensure that you make reasonable efforts and progress toward a fully representative workforce and a favourable workplace environment. A full review and revision of the employment equity plan has to be completed at least once every three years.

Task A: Sustaining Accountability, Communication, Consultation, Collaboration and Record Keeping

The first task for sustaining employment equity in your workplace is to sustain the mechanisms for accountability, communication, consultation, collaboration and record keeping that you first developed and implemented in Step 1. These mechanisms are continuous strategies that form the foundation for a sustainable employment equity program and for the success of your employment equity plan.

Accountability

The responsibilities of the senior official accountable for employment equity do not end once the employment equity plan is developed and the employment equity program is being implemented. The implementation of employment equity is continuous. The responsible senior official and his or her team must be accountable for the successes and failures of all ongoing employment equity activities. They are also responsible for evaluating progress and undertaking actions to correct issues that may be having a negative impact on the employment equity process and on achieving quantitative goals.

As detailed in Step 1, the accountability mechanism you use is appropriate for your organization and applied to each person involved in achieving an employment equity goal or measure. This accountability mechanism can take many forms, and you are encouraged to be creative in order to establish a mechanism that works in your workplace. Examples of potential accountability mechanisms that complement the assignment of a senior official responsible for employment equity include:

• linking employment equity goals and measures to year-end bonuses;
• making the achievement of employment equity goals and measures part of the responsible employee’s performance agreement; and
• requiring managers of areas with gaps in representation of the designated groups to report on efforts and progress made to remove barriers and eliminate the gaps.

Support and sustain the implementation of employment equity in your workplace by doing the key activities highlighted in each step regularly: communication, consultation, collaboration and record keeping.

Communication

Communication is required to ensure that all staff are provided with the information they need to understand and support employment equity in your workplace. Communication enables management to:

• convey to employees the importance of employment equity, the benefits to be gained through an equitable workplace environment, and the message that management will not tolerate discrimination based on gender, race, culture, disability or ethnicity
• remind employees regularly that they may update their self-identification information, that the information they provide for employment equity purposes (i.e., answers on the self-identification questionnaire) is kept confidential and separate from personnel files and that identification as a designated group member is voluntary;
• inform employees of the employment equity efforts undertaken by your organization; and
• update employees on progress made to implement employment equity and to achieve a favourable workplace environment and a representative workforce.

Often, communications with employees take the form of a progress report or a reminder bulletin. For examples of what you might include in regular communications to employees, please consult Appendices 4C and 4D.

As indicated in Step 1, you must communicate information related to employment equity to all staff at least once a year. More frequent updates (for example, weekly, bi-weekly or monthly) are strongly encouraged but will depend on what works best in your organization.

Consultation

Consultations enable employee representatives and bargaining agents to respond to how initiatives are progressing and to contribute to any new actions or emerging issues. This will often give employees a sense of ownership and personal interest in the success of the employment equity program in the organization. Consultations are required to ensure that:

• employees and bargaining agents understand the purpose of employment equity in general and in your workplace;
• the perspectives of employees and bargaining agents are taken into consideration when your organization undertakes activities related to employment equity; and
• you have a high degree of certainty that the employment equity activities you implement will achieve their purpose.

As with communication, and as related in Step 1, you must consult with employee representatives and bargaining agents at least once every year, although more frequent consultations are strongly encouraged. Organizations often maintain an ongoing employment equity committee to ensure regular and informed consultations.

Collaboration

Collaboration encourages employees and bargaining agents to participate in implementing employment equity activities, and it plays a key role in ensuring that employees develop a personal interest in the success of your employment equity program.

As detailed in Step 1, you must collaborate with employee representatives and bargaining agents regarding the preparation, implementation and revision of your employment equity plan and program.

Record Keeping

As with all good corporate initiatives or programs, record keeping is integral to demonstrating work done and results achieved, as well as for determining how best to move forward with implementing employment equity. There is no ideal procedure for ensuring that your organization has good record keeping mechanisms in place. Use your own corporate experiences to determine the most effective processes to keep clear and accessible employment equity records while satisfying the Federal Contractors Program Requirements.

According to Section 11 of the Regulations, you must maintain the following records as evidence of successfully implementing employment equity:

• a record of each employee’s:
  • designated group membership;
  • occupational group classification;
  • salary;
  • salary increases;
  • promotions;
• a copy of the self-identification questionnaire and any other related information provided to employees;
• a copy of all information used to conduct workforce analyses;
• a summary of the workforce analyses results;
• a description of the employment systems review activities and results;
• a copy of the current employment equity plan and any previous version, as well as a description of review and revision activities undertaken;
• a record of monitoring activities undertaken in relation to employment equity implementation; and
• a record of activities undertaken and information provided to employees, employee representatives and bargaining agents over the course of communications, consultations and collaborations.

The Regulations also specify that these records must be kept for at least two years after the end of an employment equity plan to which the record relates. For terminated employees, keep a record of the terminated employee’s employment equity data for a minimum of two years after the termination date. Please note, however, that the Federal Contractors Program requires at least three years of workforce employment equity data to conduct a thorough review of evidence and determine if your organization has implemented employment equity in compliance with the Requirements. In light of this, a five-year life cycle is recommended for employment equity records.

Task B: Make All Reasonable Efforts to Implement Your Employment Equity Plan

You must make reasonable efforts to implement employment equity in terms of executing the actions outlined in your plan effectively. Further, you are required to monitor the implementation and take corrective action if reasonable efforts are not being made.

To assess whether or not you made reasonable efforts to implement your employment equity plan, ask yourself three questions for each measure outlined by the plan:

1. Was the measure carried out?
2. Was the quality of the measure carried out sufficient to create a reasonable expectation of success?
3. Was the measure carried out according to the plan’s deadlines?

Other indicators that reasonable efforts were made to implement the measures contained in your employment equity plan include:

• there is evidence of ongoing senior-level support for employment equity and its implementation;
• accountability mechanisms are in use for the implementation of employment equity;
• adequate resources (financial and human) are devoted to the implementation of each measure contained in your employment equity plan;
• a measure is replaced with a more appropriate measure where the measure was not implemented or was found to have no or little effect; and
• new or additional measures, not originally included in the plan, were undertaken. This might include using internal expertise (employees, including members of designated groups) and external sources (such as the community and advocacy organizations, employer associations, regional and national labour federations, government departments and agencies) to maximize your success in implementing employment equity.

Example:

If your plan includes outreach to organizations capable of providing candidates of a particular designated group for Semi-Skilled Manual Workers, you would ask some of the following questions:

• Did outreach occur? If so, what was its frequency? Does it take place each time there is recruitment?
• What efforts were made to identify appropriate organizations?
• Were records kept of efforts and results?
• Were alternative actions taken if results were not satisfactory?
• What is the impact on the numerical goal?

Example:

If your employment equity plan includes introducing a more structured and objective process for selection, you would ask:

• Has this been done and, if so, was it done within the deadline of the plan?
• What were the steps taken to ensure objectivity?
• Is the new process now being implemented consistently when staffing?
• Is the selection process properly documented?
• What is the impact on the numerical goal?

Implementing employment equity does not require your organization to take measures that would cause undue hardship, to hire or promote unqualified people, or to create new positions within your organization (Section 6 of the Act). It does require a concerted effort and an ongoing commitment to achieve a representative workforce and a favourable workplace environment.

Task C: Monitor for Reasonable Progress

The Employment Equity Act requires that the hiring and promotion goals in your employment equity plan be sufficient to ensure that reasonable progress is made toward achieving full representation within the time frame of the plan. To measure progress made toward achieving the goals you have set effectively, first update your workforce information, workforce analysis, flow data analysis and clustering analysis.

Maintain Workforce Information and Update Analyses

In Step 1, you collected all required workforce information. Now, it is necessary to keep the information accurate and current. To do so, provide a self-identification questionnaire to all new employees and to employees who request to change or update information, and keep track of hires, promotions and terminations within your workforce.

Record all changes in your workforce employment equity information system (for example the Workplace Equity Information Management System) and use this information to keep the workforce analysis you completed in Step 2 updated. You are required to update your analysis (like the one you completed as a part of Step 2) once every three years. However, in order to ensure that you respond effectively to developments in your organization and achieve your employment equity goals and measures, it is recommended that you complete workforce analyses quarterly or, at minimum, once every year.

Now that the implementation of employment equity is in progress in your organization, you will complete a flow data analysis and a clustering analysis to determine more accurately the representation of the four designated groups and any areas where they may face employment barriers in your workplace.

Flow Data Analysis and Clustering Analysis

If you have not already completed a clustering analysis, you may choose to complete one according to the instructions provided in Step 2. The information may be very useful to you. A clustering analysis provides information about whether or not, over time, designated group members receive disproportionately lower salaries, and if they tend to work more frequently than their counterpart employees who are not members of designated groups in lower salary occupational groups in your workforce.

Step 2 informed you that you must keep records of hires, promotions, salaries and terminations for three consecutive years. Using this information, and the instructions provided in Step 2, you will be able to complete a flow data analysis. A flow data analysis reveals whether or not employees who are members of designated groups in your workforce are hired at rates less than expected, receive fewer promotions than expected or are terminated more frequently than are their counterpart employees who are not members of designated groups. The information gathered through a flow data analysis can assist you in identifying issues with the hiring, promotion and termination of specific designated group members in certain occupational groups.

For example:

Hiring: Aboriginal peoples constitute 1.5 percent of all hires into Semi-Skilled Manual Workers positions, while there is a labour market availability of 2.7 percent.

Promotion: Women constitute 12 percent of all those promoted into Middle and Other Managers, even though their representation in the Professionals occupational group (the primary source for Middle and Other Managers) is 28 percent.

Termination: Persons with disabilities constitute 6 percent of all terminations in Clerical Personnel, although they are only 2.3 percent of representation.

The information used to conduct a flow data analysis is also used to verify if reasonable progress is being made toward closing gaps in representation in your workforce, and maintaining full representation where it exists.

Assess Reasonable Progress

Reasonable progress is determined by verifying to what extent you have achieved your hiring and promotion goals as established in Step 3 and included in your employment equity plan.

To simplify the calculation of progress, the Federal Contractors Program uses an Achievement Table (see the following sample table—the full tool and explanation are located in Appendix 4E).

Achievement Table for Women

Representation Data								Hiring and Promotion Goals
Employment Equity Occupational Group (EEOG)	Year	Total Number of Employees	Women		2006 Census Availability		Gap	Total Number of New Entrants	Number of New Entrants: Women		Goal	Percent of Goal Met	Comments
		#	%	#	%	#			%	#	%
Senior Managers	2003		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
	2004		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
	2005		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
	2006		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
Sub-Total		0.0	#DIV/0!	0.0	0.0	0.0	0.0	0.0	#DIV/0!	0.0	0.0	#DIV/0!
Middle & Other Managers	2003		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
	2004		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
	2005		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
	2006		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
Sub-Total		0.0	#DIV/0!	0.0	0.0	0.0	0.0	0.0	#DIV/0!	0.0	0.0	#DIV/0!
Professionals	2003		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
	2004		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
	2005		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
	2006		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
Sub-Total		0.0	#DIV/0!	0.0	0.0	0.0	0.0	0.0	#DIV/0!	0.0	0.0	#DIV/0!
Semi-Professionals & Technicians	2003		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
	2004		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
	2005		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
	2006		#DIV/0!		0.0	0.0	0.0		#DIV/0!			#DIV/0!
Sub-Total		0.0	#DIV/0!	0.0	0.0	0.0	0.0	0.0	#DIV/0!	0.0	0.0	#DIV/0!

Note: You may choose to use a different tool, but it must be capable of providing the required information.

To determine reasonable progress, compare your goal to your results for each designated group and Employment Equity Occupational Group where a goal was set, and calculate the extent to which your goal was met (as a percentage). If you do not meet your goal, you must provide a reasonable explanation for the shortfall. If you meet or exceed your goal, you are encouraged to evaluate the measures you undertook to meet the goal and apply them to achieve your goals in other areas, where possible.

Task D: Monitor and Assess New Human Resource Systems, Policies and Practices

Human resource management is a rapidly evolving area of corporate interest. Your organization may make minor or significant changes to its employment policies and practices over the course of your employment equity plan implementation. For example, an organization may decide to implement human resource systems based on a competency model rather than a traditional skill-based assessment process. In addition, new occupational requirements, diversification or industrial sector changes may result in the implementation of new or modified job descriptions, practices, etc.

It is important that you monitor these human resource developments and assess how you intend to implement changes that may have an impact on your employment equity objectives. This means:

• reviewing proposed changes to assess their potential impact using the same assessment procedures outlined in Step 2: Employment Systems Review;
• monitoring previously validated employment systems (policies and practices) to ensure that they do not develop barriers as changes and modifications are introduced; and
• reviewing employment systems that have an impact on occupational groups where new gaps in representation are found during monitoring and revision of the workforce analysis.

The process of how to ensure that these activities take place was outlined in Step 3. During the life of the employment equity plan, you must ensure that this process is followed and the results are documented.

Example:

Formal succession planning is initiated to ensure a smooth and efficient transition as expected vacancies occur. The requirement is to ensure that the process put in place uses valid standards to select candidates for eventual promotions; that development opportunities are equitably available to potential candidates; and that source areas for pulling candidates do not unduly restrict access in a manner that creates an adverse impact.

Task E: Review and Revise Your Employment Equity Plan

To ensure the success of your organization’s employment equity program, review and revise your employment equity plan frequently. This is critical to ensure that it adapts to changing circumstances, that reasonable progress is achieved and that reasonable efforts are always evident.

At minimum, you must review your organization’s employment equity plan and produce a revised version at the end of the plan’s original time frame of three years. This newly revised employment equity plan will then also be implemented, monitored, reviewed and revised over the next three years. Thus, every three years, you must perform a detailed review of the employment equity plan and produce a newly revised version of the plan.

Review and Revise Core Mechanisms

The first part of reviewing and revising your employment equity plan is to verify that all elements of your organization’s accountability, communication, consultation, collaboration and record-keeping mechanisms outlined in your employment equity plan are in use and are contributing to a positive workplace environment. You will have reviewed these mechanisms as part of Task A.

Using the results of Task A, mechanisms that have proven successful do not need to be revised in the employment equity plan. However, if any element of a mechanism has not produced the desired result, you must change the element in the employment equity plan and monitor the results of the change.

Review and Revise Representation Goals

Once you have reviewed the core mechanisms, review and address all gaps in representation that remain and any new gaps that have developed. Compare your previous workforce analysis to the updated workforce analysis you completed in Task C. Then, revise your employment equity plan goals to reflect your organization’s current situation in three ways.

1. Where a gap in representation is closed, record the goal as fulfilled and remove it from the employment equity plan. Then consider using the same measures, policies or practices to close gaps in other areas.
2. Where previously noted gaps persist, assess if you have made reasonable progress to close the gap.

   If reasonable progress to close the gap is evident, continue to implement the measures related to this gap until it is closed.

   If reasonable progress is not evident, verify if reasonable efforts were made to implement the measures related to this gap:

   • if reasonable efforts to implement the measures related to this gap are evident, further review employment systems and develop new measures to ensure that all barriers are removed;
   • if reasonable efforts to implement the measures related to this gap are not evident, hold the responsible person(s) accountable and begin making reasonable efforts to implement the employment equity plan measures.
3. Where new gaps in representation have developed, determine if they are significant or minor, as per the workforce analysis portion of Step 2.

   If the new gaps are minor, establish new numerical goals in the organization’s employment equity plan to close the gap.

   If the new gaps are significant, review all employment systems related to the occupational group where the gap is present to identify barriers to the employment of designated group members (as per the Employment Systems Review section of Step 2). Then, add measures into the organization’s employment equity plan to remove those barriers, as per Step 3.

Review and Revise Measures to Remove Barriers

To ensure that all gaps in representation are closed and no new gaps develop, there cannot be any barriers to the employment of designated group members in your employment systems. Compare the results of your employment systems monitoring and revision activities, including those completed as a part of Task D, to the measures outlined in your employment equity plan. Using this comparison, adjust your employment equity plan in three ways to ensure that reasonable efforts and progress are evident toward a favourable work environment and a representative workforce:

1. Where the barrier is no longer present, record the measure as having successfully removed the barrier and remove it from the employment equity plan. You may consider the measure for use in the removal of other barriers, as appropriate.
2. Where a barrier persists, revise the measure(s) in place to remove the barrier. The revision of the measure(s) must result in the removal of the barrier and requires that you either:
   1. modify the measure(s);
   2. replace the measure with a new measure; or
   3. add a new measure and/or a special measure.
3. Where a new barrier is identified, develop new measures to remove this barrier and include them in your employment equity plan.

If a measure has successfully removed a barrier, but the numerical gap in representation continues to exist, determine if additional barriers are blocking progress. New measures must then be outlined in the employment equity plan to remove each identified barrier.

Review and Revise Special Measures, Positive Policies and Practices and the Monitoring Mechanism

To support your employment equity goals and measures to remove barriers, your organization’s employment equity plan will include special measures, positive policies and practices and a monitoring mechanism. Each of these must be assessed to ensure that it is further achieving these goals and this barrier removal. Begin the assessment by determining the effect of the special measure, positive policy or practice and the monitoring mechanism.

If the effect is desired, continue to implement the action until it is no longer necessary (positive policies and practices and the monitoring mechanism will often be ongoing).

If the effect is not desired, the special measure, positive policy or practice or the monitoring mechanism must be revised by changing it, replacing it or adding to it.

For example, you could implement a special measure to undertake targeted recruitment of visible minority professionals using the NAS Institute Job and Education Fairs for new Canadians, Aboriginal peoples and visible minorities. If you discover that it did not address the under-representation in Professionals, but it did provide Skilled Crafts and Trades Workers, you would review the potential of using this special measure to address any representation gaps in the Skilled Crafts and Trades Workers occupational group and develop a new special measure, such as targeted recruitment with a different institute, for the under-representation of visible minorities in the Professionals group.

Review and Revise Your Employment Equity Plan to Ensure Reasonable Efforts and Reasonable Progress

The review of the measures in the organization’s employment equity plan that you have implemented will determine which measures where successful and which were not. A successful measure is one that supported the goal and enabled you to make reasonable progress toward eliminating the gap in representation that the measure was put in place to address.

If a measure was successful, continue to implement it until the gap is eliminated and full representation is achieved. Review the possibility of adjusting the measure for use in making reasonable progress toward achieving other goals outlined in the employment equity plan.

For each measure that was not successful, take corrective action and outline a new measure to make reasonable progress toward removing the barriers and closing the gap in representation.

Where you discover that reasonable efforts are not being made to implement the employment equity plan, you must take steps to ensure that the situation is rectified and that the appropriate people are held accountable.

Review and Revision Records

Detailed records of the review and revision of your employment equity plan are required.

For example, if one of your employment equity plan measures was to build a ramp to make your head office accessible, once the ramp was completed, you could create a record as follows:

"The ramp construction was completed within the timeline allotted by the employment equity plan. As a result, physical access to the premises is no longer a barrier to the hiring of persons with disabilities and it is no longer the cause of their overall under-representation in the workforce. This measure has been removed from the employment equity plan. The representation of this designated group will be monitored and, if gaps do not decrease within six months, a new employment systems review will be undertaken to identify any other barriers. New measures to remove the barriers and special measures to improve representation will be added into the employment equity plan."

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Date Modified:

2012-02-27