5120571_1.DOCX REPORT OF THE EXTERNAL REVIEWER FOR THE ROYAL CANADIAN MINT Climate Review of the Protective Security Services Arleen Huggins, LSM, Partner with the assistance of Mireille Giroux, Associate Koskie Minsky LLP 20 Queen Street West, Suite 900 Toronto, ON M5H 3R3 August 11, 2021 5120571_1.DOCX TABLE OF CONTENTS MANDATE AND METHODOLOGY.............................................................................3 Mandate......................................................................................................................................3 Methodology ...............................................................................................................................4 THE MINT POLICIES AND APPLICABLE FEDERAL LEGISLATION........................7 The Mint Policies.........................................................................................................................7 Applicable Federal Legislation ....................................................................................................9 EXECUTIVE SUMMARY ........................................................................................11 REVIEW CONCLUSIONS......................................................................................13 REVIEW RECOMMENDATIONS ............................................................................14 5120571_1.DOCX MANDATE AND METHODOLOGY Mandate The Royal Canadian Mint (the "Mint") is a crown corporation operating under the Royal Canadian Mint Act, R.S.C., 1985, c. R-9 (the "Act"). The shares of the Mint are held in trust for the Crown in right of Canada. The Mint produces all of Canada's circulation coins, and also manufactures circulation coins on behalf of other nations. It also designs and manufactures precious and base metal collector coins, gold, silver, palladium and platinum bullion coins, medals, medallions and tokens. In addition, it offers gold and silver refinery and assay services. The Mint serves the public's interest, but is also mandated to operate in anticipation of profit; requiring it to operate in a commercial manner without taxpayer support. The Mint has a Board of Directors consisting of a Chair, the President and CEO and other directors. The current President and CEO is Marie Lemay ("Lemay"), who was appointed to her role in 2019. On or about September 21, 2020, I was formally retained to undertake a workplace climate review of the Protective Security Officers groups of the Mint in Ottawa and Winnipeg (the "Climate Review" or the "Review") in respect of inclusivity and discrimination/systemic discrimination relating to the four (4) equity groups enumerated in the federal Employment Equity Act, S.C. 1995, c. 44 (the "Employment Equity Act"), the representation of which federally legislated employers are required to take proactive steps to increase. They are visible minorities, Aboriginal peoples, women and people with disabilities. The purpose of the Climate Review was to assess the current (since the fall of 2019) workplace culture and climate within the Protective Services (“PSO”) groups in both Ottawa and Winnipeg locations, as well as to assess management in both groups, for the purpose of evaluating the degree to which they were effectively addressing any issues which might exist. In recent years, a number of initiatives were put in place to improve the work environment for all members of the PSO group. Some of these initiatives were put in place as part of ongoing efforts by management for greater inclusivity for designated groups but also in response to employee feedback for more cultural awareness and sensitivity. The Climate Review was to be an opportunity to assess the effectiveness of the various initiatives and surface what further improvements would be required to meet or enhance diversity and inclusion objectives. Page 4 5120571_1.DOCX The Review was to be focused in particular on the experiences of those who self-identify as BIPOC (Black, Indigenous, Persons of Colour) and women, however was to be open to all Protective Services employees, including management, in order to assess the experiences and perceptions of all members of Protective Services in respect of the equity groups described above. The Mint also wanted to review any issues related to those who self-identified as LGBTQ2+. The Climate Review was undertaken under the direction of Patrick Robinson ("Robinson"), Senior Manager, Labour and Employee Relations. Methodology Robinson expressed that the Mint wished to take an "eyes wide open" approach to the Climate Review to assess the current culture since the fall of 2019 and provide a safe environment for the Protective Services groups in Ottawa and Winnipeg. In order to do so, the PSOs were to share their experiences with me, as an external reviewer. As such, I determined that the Climate Review would be undertaken on a voluntary, confidential and non-attributable basis, in order to encourage high participation, candour and honesty. In that regard, a Climate Review communication for the PSO groups in Ottawa and Winnipeg, including management, was prepared by the Mint with my assistance and circulated to all PSO employees on or about September 30, 2020 (the "Climate Review Notice"). The Climate Review Notice is attached hereto as Appendix "A". Midway during the Climate Review, by virtue of the relatively low response, on or about November 20, 2020, a second Mint communication was verbally issued to all Protective Security employees, including management. The Climate Review Notice stated, inter alia, that (i) a Climate Review would be undertaken by an external, independent third-party reviewer who specializes in employment and human rights law, as well as workplace climate reviews and workplace investigations; (ii) that the Climate Review had as its focus diversity and inclusion and any systemic and/or structural barriers; (iii) that the Review would be undertaken in confidence and on a non-attribution basis; and Page 5 5120571_1.DOCX (iv) that the employees could contact my office to arrange their interviews. All participants were invited to attend with a support person, including a union representative, if they wished to do so. The Ottawa PSOs are represented by the Amalgamated Transit Union in accordance with the terms and conditions set out in the 2018-2021 RCM-ATU Collective Agreement. The Winnipeg PSOs are represented by the Public Service Alliance of Canada in accordance with the terms and conditions set out in the 2018-2021 RCM-PSAC Collective Agreement The Climate Review interviews commenced on October 13, 2020. Interviewees were advised of the availability to conduct their interviews in French by my Associate, Mireille Giroux ("Giroux") and seven (7) of the total of forty (40) interviews were so conducted. Of the total interviewed from Protective Services, 23 were from Ottawa and 10 were from Winnipeg. In addition, I interviewed the Chief Security Officer and five (5) members of Human Resources who had involvement with Protective Services in Ottawa and Winnipeg. I also spoke with the Mint's President and CEO, Vice President, General Counsel and Corporate Secretary, Corporate and Legal Affairs, and Robinson. Included in the Protective Services interviews conducted were PSOs, analysts, clerks, team leads, supervisors, managers, senior managers and the Chief Security Officer. All of the interviews were conducted by myself and my associate. I conducted the interviews of the human resources employees, management and senior management, and I also held the discussions with the President and CEO, the Chief Security Officer, Robinson and the Vice￾President, General Counsel and Corporate Secretary, Corporate and Legal Affairs. The Protective Services groups in Ottawa and Winnipeg total approximately ninety (90) employees, including the Chief Security Officer, who has oversight over both the Ottawa and the Winnipeg groups. The employees within each group perform the same job duties and responsibilities although within different environments. Further, the demographic background of each group, based upon the limited demographic data available, would suggest that the Winnipeg group is materially more diverse in respect to visible minorities and Indigenous peoples than the Ottawa group. The Mint does not collect disaggregated demographic data so the breakdown of "visible minorities" was unknown, except to the extent that the participants answered the Review questions as to their racial/cultural background. Page 6 5120571_1.DOCX Based upon the voluntary self-identification information of PSO employees in Ottawa and Winnipeg, up to and including the level of team leads, provided to me by the Mint as at August 2020, and recognizing there may be intersectionality among the individuals so as to skew the numbers reported, the breakdown as at August 2020 was as follows: Ottawa 37 males females visible minorities Aboriginal/Indigenous 50 Winnipeg 28 males females visible minorities Aboriginal/Indigenous 48 Once the Review commenced, it was reported by a number of individuals that there had been PSO turnover even since August 2020, such that the more accurate total number in or about October 2020 was ninety (90). Given the relatively small number of employees within Protective Services, and to protect the anonymity of the employees, the demographic information above has not been further broken down in this Report by casuals vs full-time or by unit (i.e. analysts/coordinators/ administrative staff (the "Investigative unit") versus those "on the floor" ("operations")). However, the interviews conducted clearly illustrate that while the President and CEO of the Mint is female, as at the fall of 2020/winter of 2021, there have been almost no women at or above the level of team lead within PSOs in Ottawa in the past there have been no BIPOC (Black, Indigenous, People of Colour) at or above the level of team lead within the PSOs in Ottawa, past or current, and no BIPOC employees above the level of team lead within the Winnipeg PSO group. While we did not have any data as to the number of persons with disabilities (mental or physical) or those who self-identify as LGBTQ2+, some of the participants self-identified as such. The Findings of the Climate Review as described herein are based solely upon the opinions, perceptions and experiences of the participants, as reported to the Reviewers. The Page 7 5120571_1.DOCX Recommendations to the Climate Review are those of the Reviewers and do not account for any Collective Agreement, governance or Mint policy factors which may affect or impact upon the feasibility of the implementation thereof. THE MINT POLICIES AND APPLICABLE FEDERAL LEGISLATION The Mint Policies The Mint has workplace policies governing the conduct of its employees. The Mint has a Violence in the Workplace, Harassment and Discrimination policy, revised on October 1, 2009, with an effective date of June 9, 2010. In the midst of the Review, and in response to amendments to certain amendments to federal legislation, as hereinafter described, the Discrimination Policy was amended effective January 1, 2021 (the "Discrimination Policy"). The Discrimination Policy provides in section 3.2 that the Mint is "committed to providing a safe and respectful work environment for all. No one, whether a manager, an employee, a contractor, a customer, a supplier or a member of the public, needs to tolerate violence, harassment and discrimination in our workplace, for any reason, at any time". Section 1.1 of the Discrimination Policy provides that every employee is to be treated fairly in the workplace "in an environment free of harassment, violence and discrimination. Any behaviour which denies the dignity and respect of an individual is unacceptable and will not be tolerated. Harassing, committing violence and discriminating in the workplace all constitute disciplinary infractions subject to penalties up to and including dismissal…". Section 1.1 of the Discrimination Policy also states that the Mint is committed: "(a) to providing a safe, healthy and violence-free workplace; (b) to dedicating sufficient attention, resources and time to address factors that contribute to workplace violence, including, but not limited to, bullying, teasing and abusive and other aggressive behavior and to prevent and protect against it; (c) to communicating to its employees information in its possession about factors contributing to workplace violence and harassment; (d) to offering workplace harassment and violence prevention training specific to the workplace’s culture, conditions, and activities; Page 8 5120571_1.DOCX (e) to assisting employees who have been exposed to workplace violence or harassment by supporting them with appropriate resolution of an occurrence of violence or harassment; and (f) to offering support to its employees by making available to them information regarding medical, psychological or other support services available in their geographical area". The Discrimination Policy defines "Harassment" as "any behavior that demeans, humiliates or embarrasses a person, and that a reasonable person should have known would be unwelcome". It further states that Harassment may be "a single incident or continue over time". "Sexual Harassment" is defined as including "offensive or humiliating behaviour that is related to a person's sex, as well as behaviour of a sexual nature that creates an intimidating, hostile, or "poisoned" work environment, or that could reasonably be thought to put sexual conditions on a person's job or employment opportunities". "If the person who is accused of harassment should have known that the behaviour was unwelcome, he or she will be considered responsible, even for unintentional harassment". The Discrimination Policy defines "Discrimination" as occurring when "a distinction, exclusion or preference is made and acted upon based on prohibited grounds such as race, national or ethnic origin, colour, religion, age, sex, marital status, family status, disability, pardoned conviction, sexual orientation, generic characteristics or gender identity or expression". The Discrimination Policy also states that "appropriate performance reviews, counselling, withholding opportunities for promotion or career development based on performance and discipline are not considered harassment or discrimination". The Mint Code of Conduct and Ethics, effective September 16, 2019 (the "Code of Conduct"), states that the Mint is "committed to a corporate environment that both fosters and demonstrates ethical behaviour at all levels of the organization, without exception". It notes that its reputation is "dependent on the quality of the actions and the integrity of the behaviour of its employees," and provides a guide to what is ethical behaviour. It establishes three core values ("honesty, respect and passion & pride") that employees are expected to demonstrate in the performance of all activities pursuant to the Mint's mandate and in the "creation of a healthy and productive workplace". Section 5.2 therein repeats the principles of the Discrimination Policy and provides that "any behaviour which denies the dignity and respect of an individual is unacceptable and will not be tolerated. Harassing, committing violence and discriminating in the workplace all constitute Page 9 5120571_1.DOCX disciplinary infractions subject to penalties up [to] and including dismissal". It further states that employees should report violations of the Code of Conduct, or violations of any other Mint misconduct, policies or procedures of which they become aware, to their immediate supervisors, a Human Resources professional, or through the use of "Clearview Connects", a confidential and anonymous third-party process, and that no person so reporting in good faith shall be subject to reprisals. The Mint's Protective Services group also has two Statements of Responsibilities, one for regular employees and the other for supervisors and managers which was created and circulated on or about June 2019 for the establishment of a respectful workplace. The Statement of Responsibilities for employees was said by senior management to impose personal responsibility for one's conduct and to require employees be proactive in denouncing inappropriate behaviour by others. It specifies that employees will, inter alia: "… • facilitate open communication and establish a relationship of trust between employees at all levels, thus fostering collaboration and mutual assistance; • ensure a healthy, positive and respectful work environment, by fostering team work and knowledge transfer; • take responsibility for decisions, to act autonomously and exercise leadership; • express their expectations and listen to those of other employees and to quickly resolve problems with others; and • acknowledge a job well done and outstanding performance." The Statement of Responsibilities for supervisor and managers was stated by senior management to not only impose personal responsibility for conduct but also to hold supervisors and management accountable for addressing unsatisfactory behaviour on the part of employees. Applicable Federal Legislation Section 3(1) of the Canadian Human Rights Act, R.S.C., 1985, c. H-6 (the "Human Rights Act") sets out the prohibited grounds of discrimination as being "race, national or ethnic origin, colour, religion, age, sex, sexual orientation, gender identity or expression, marital status, family status, Page 10 5120571_1.DOCX genetic characteristics, disability and conviction for an offence for which a pardon has been granted or in respect of which a record suspension has been ordered". Section 3(2) provides that "where the ground of discrimination is pregnancy or childbirth, the discrimination shall be deemed be on the ground of sex". Section 7 of the Human Rights Act provides that "it is a discriminatory practice, directly or indirectly, (a) to refuse to employ or continue to employ any individual; or (b) in the course of employment, to differentiate adversely in relation to an employee, on a prohibited ground of discrimination." The Canadian Human Rights Commission's definition of "discrimination" is "an action or a decision that treats a person or a group badly for reasons such as their race, age or disability". Section 14(1) of the Human Rights Act provides that it is a discriminatory practice "in matters related to employment, to harass an individual on a prohibited ground of discrimination". Section 14(2) deems sexual harassment to be harassment on a prohibited ground of discrimination for the purposes of section 14(1). Section 65(1) and (2) of the Human Rights Act provides for vicarious liability upon a person, association or organization for acts or omissions of an officer, director, employee or an agent of any person, association or organization in the course of employment, unless they can show they did not consent to the act or omissions and exercised all due diligence to prevent the act or omission from being committed, and subsequently, to mitigate or avoid the effects thereof. Section 9 of the Workplace Harassment and Violence Prevention Regulations (SOR/2020-130), which came into force on January 1, 2021 pursuant to Bill C-65, An act to amend Part III of the Canada Labour Code, R.S.C. 1985, c.L-2, (Occupational Health and Safety), (the "Code"), outlines the essential elements of a workplace harassment and violence prevention policy and procedures to respond to incidents of workplace harassment and violence. The Regulations require a federally regulated employer to, inter alia, develop preventative measures to mitigate the risk of harassment and violence in the workplace; develop an implementation plan for the preventative measures and implement the measures in accordance with the plan. As well, the Regulations require a federally regulated employer to develop and provide workplace harassment and violence training to all employees, which is "specific to the culture, conditions and activities Page 11 5120571_1.DOCX of the workplace", and provide same within three (3) months after the day upon which the employees' employment begins, or if the employee was hired prior to the Regulations coming info force, within one year after the Regulations came into force, and at least every three years thereafter, and following any update to the training or to an employee's assignment to a new activity for which there is an increased or specific risk of workplace harassment and violence. "Harassment" is defined in Bill C-65 as "any action, conduct or comment, including of a sexual nature, that can reasonably be expected to cause offence, humiliation or other physical or psychological injury or illness to an employee, including any prescribed action, conduct or comment". In law, employers who fail to take reasonable steps to address reports of discrimination and harassment on the part of coworkers and/or supervisors and management can be held legally liable for damage awards before human rights tribunals for, inter alia, monetary compensation for loss of earnings, wage differentials between the previous and a current job, future loss of earnings, pension loss, expenses, disbursements as well as injury to dignity, feelings and self-respect (Reeves v. Deputy Head (Department of National Defence), 2019 FPSLREB61 (Federal Public Sector Labour Relations and Employment Board); TM and Manitoba (Justice), Re, 2019 CarswellMan 989; Francis v. BC Ministry of Justice (No. 3), 2019 BCHRT 136; and Francis v. BC Ministry of Justice (No. 5), 2021 BCHRT16). While there is no general common law tort of "harassment" or "discrimination" which has been recognized in Canada (unless it is through internet communications: Caplan v. AOS, 2021 ONSC 670), there is no specific prohibition in the Human Rights Act for an individual to bring a human rights claim with other civil causes of action such as, international infliction of mental suffering, defamation, assault, battery, intrusion upon seclusion/invasion of privacy, in a civil proceeding. EXECUTIVE SUMMARY There was a marked difference between Ottawa and Winnipeg in respect to the experiences of the Protective Services employees. Overall, the Winnipeg employees reported far less sexist/racist incidents, both in number and severity, and many felt their environment was healthy. However, there were complaints about preferential treatment based upon favouritism and continuing irregular racist comments. Page 12 There were also significant differences between the experiences of employees in Ottawa who worked in operations and those who worked in the investigative unit (personnel screening analysts, security analysts, administrative clerks). ‘The Ottawa investigative unit reported that they currently have strong supportive management who does not allow or condone sexist, sexualized or racist conduct and that the environment is. very professional. The experiences of Ottawa operations PSOs was markedly different, vith both female and racialized operations employees describing somewhat irregular but stil blatantly offensive, ‘sexualized, sexist and racist jokes, slurs, comments and conduct, and for some of them, an I making irregular but offensive gender based, racist and homophobic ‘comments/jokes/slurs, albeit often outside of the purview of supervisors and senior management. ‘Though the clear perception was that the current environment in Ottawa was not as toxic as in the past (which participants described as "hell, highly toxic", "unbearable" and traumatizing"), female and racialized PSOs, together with participants from the investigative unit, collectively reported the continuation of very problematic behavior occurring, albeit irregularly and often outside of the purview of management and senior management. The problematic conduct reported by some BIPOC employees included perceived inequitable advancement opportunities for visible minorities. There were also participants who reported a lack of trust in some management who are stil perceived by some as not effectively addressing issues that are brought to their attention. s120671_100Cx Page 13 5120571_1.DOCX REVIEW CONCLUSIONS Based on the interviews, it is evident that although significant progress has been made, a toxic environment remains within operations in Ottawa, albeit nowhere near as prevalent as pre-fall of 2019. Reports of sexualized comments, jokes and overtures continue, as well as, to some extent, racial comments and jokes, all of which are clearly in violation of the Mint's Code of Conduct and Ethics, Discrimination Policy and Statement of Responsibilities as hereinbefore described, as well as contrary to the Canadian Human Rights Act and the Code. Many of the individuals interviewed knew that the perpetuation of sexualized jokes and overtures as well as racist jokes, slurs and comments and gender and racial stereotypes, even those viewed to be "advantageous " by some non racialized PSOs, constituted sexual and racial harassment and discrimination. However, others appeared to be subjectively unaware, though objectively they ought to have known, that the stereotypes were offensive and unwelcome and lacked an appreciation of the significant psychological trauma which the comments had upon women and racialized employees. The lack of targeted diversity recruitment strategies, the lack of effective and consistent EDI training across all Protective Services employees in Ottawa, and the scarcity of women and racialized employees as team leads and in operations management, have resulted in extremely low levels of representation of women and BIPOC individuals in Ottawa and left a vacuum for the hiring and promotion of certain individuals with sexist and racist views which, while more hidden than in the past, still permeate the culture "behind the scenes". This has resulted, for some, in a continued toxic environment and a continued culture of fear and resignation. While the relatively recent hiring and promotion of LGBTQ2+ and women are lessening some of the problems to some degree, it has not proven to be a solution to the continued poor culture for straight women or racialized PSOs which continue to exit. Ottawa in particular still has very concerning issues to address to remediate the still toxic workplace for some female and racialized Protective Services employees. To a much lesser degree, and far less frequently, Winnipeg still suffers from a culture wherein racist remarks and jokes are engaged in. Management's strategy of discussion with the offender, with the odd email to the group, does not appear to be entirely effective. Not only is the behaviour continuing, but the perception is, rightly or wrongly, that management is aware of the issues but is not taking these matters seriously enough. Page 14 5120571_1.DOCX Also, both Ottawa and Winnipeg participants expressed real fear of reprisals for participating in the Review and stated that a "lot of people" on the floor expressed that to participate in this Review was "career suicide" and that it "would not do anything anyway". This culture of fear, as I have mentioned above, is very disconcerting and in and of itself suggests an environment where employees are afraid to address issues not only internally, but to an external third party on an anonymous basis, for fear that their anonymity be pierced and their identities detected. This suggests a lack of trust, at least to some degree, in certain management individuals. REVIEW RECOMMENDATIONS These Recommendations are not meant to be exhaustive. Also, all of the recommendations below are important and can be implemented concurrently, depending upon organizational issues, including resources, timing of collective bargaining and other factors. The intent of the Recommendations is not to "blame and shame" but to encourage best practices and accountability measures to assist the Protective Services group, as a whole, to transform what still appears to be, albeit in varying degrees, a climate of sexism, racial/cultural intolerance and insensitivity, and a material degree of unprofessionalism, which remain more hidden than in the past, but still intact. This is notwithstanding the demonstrable efforts of certain supervisory and management personnel to stamp it out. Those demonstrable efforts alone are insufficient, especially in Ottawa, to eradicate some long standing and deep-seated inappropriate ideas of what is and is not acceptable, not only within a workplace, but generally. Ottawa especially must utilize more proactive recruitment strategies to address not only the significant underrepresentation of, in particular, racialized employees, within its group but also the character of those being hired. It also needs to look closely at providing opportunities to members of the four equity groups, as well as those from the LGBTQ2+ community, to address the past inequities and to create future BIPOC and female leaders in the same way as it has done with lesbian employees. Both Ottawa and Winnipeg must also use performance and disciplinary strategies, as well as education and training, to change the behaviour of the "few bad apples" who are impacting the emotional well being of others, or remove them. Finally, both groups need to better demonstrate, from the very top, a commitment to diversity and inclusion by holding all levels of PSOs accountable for changing the workplace culture, especially Page 15 5120571_1.DOCX team leads, who have the most day to day contact with, and influence over, the climate in operations. Workplace Culture 1. The Mint's Code of Conduct e-module training should be amended to emphasize the importance of “dignity” when discussing the value of "respect" and the Mint's commitment to diversity and inclusion should be emphasized. At the next opportunity. the Code of Conduct's organizational Values should be revised to add "& dignity" to the "respect" core value, to mirror the language of human rights legislation. Further, as soon as practical to do so, the Mint should add a fourth value, being "diversity and inclusion". There appears to be a tendency, in particular in Ottawa, to equate "respect" with "inclusion", however educating PSOs about respect is insufficient to promote gender and racial equity and inclusion. 2. There was no evidence that Protective Services in either Ottawa or Winnipeg had a practice of educating PSOs about, or celebrating, cultural or other differences. There was a suggestion that the DEIC promoted equity events, however, there is a need to bring those events "in house" to Protective Services. Special events surrounding, for instance, Black History Month and Pride, could be promoted by management and team leads. 3. Promote the Women's group to Winnipeg through widespread communication mechanisms. 4. The "Diversity Champion" framework, together with plans to put structure to the Mint wide DEIC, described by the President and CEO, is clearly needed to illustrate the Mint's commitment to diversity and inclusion. Complaint Reporting 5. Establish an effective reporting system for employees to report incidents of discrimination and harassment to human resources. All incidents reported should be fully documented and formal records should be properly kept and maintained by human resources of all reports of concerns, whether or not a formal complaint is made. 6. It is essential to keep disaggregated demographic data as to the incidents/occurrences of racial or sexual harassment/discrimination, irrespective of whether these occurrences are Page 16 5120571_1.DOCX handled formally or informally. Reporting to management only is resulting in incidents not being properly tracked or documented, resulting in the underreporting of incidents and the failure to recognize systemic issues when they occur. 7. Human resources should continue to initiate investigations, even without receiving a specific complaint, consistently, where it appears that the number or type of concerns made indicate a systemic or unresolved matters, or a pattern in respect to particular perpetrators, in order to proactively address issues early. 8. Human Resources should widely and regularly promote the Mint's third-party vendor anonymous reporting mechanism, Clearview, to encourage reporting of incidents. 9. Add LGBTQ2S+ to voluntary self-identification questions for applicants, existing and departing employees. . 10. Maintain voluntary disaggregated self-identification data of all departing employees in order to track patterns of resignations based upon the four equity groups. 11. Ensure "complainants" raising concerns or filing complaints receive timely updates as to the steps being taken in respect of their concerns/complaints, including what steps are being taken in respect of the perpetrator. Training 12. Ensure team leads, supervisors and managers at all levels undertake management leadership training which includes diversity, inclusion and workplace accommodation training and how to proactively promote a healthy, equitable, inclusive and non￾discriminatory workplace culture; 13. Ensure a systematic and frequent training schedule for all employees at every level. Ensure Unconscious Bias/Diversity and Inclusion and Harassment Prevention training is undertaken in person or if not possible, virtually live method rather than through e-learning modules by effective facilitators with specialized expertise to encourage participation, and dialogue; both of which are critical for the understanding and adoption of equity, inclusion and diversity principles. Page 17 5120571_1.DOCX 14. Introduce more robust and specialized training, such as anti-racism and anti-Black racism training for all employees on an in person or, if not possible, virtually live method, facilitated by an effective trainer with specialized expertise. Recruitment 15. Engage in collective bargaining with the unions to dispense with or at least minimize the use of the category of "casuals", which is an inherent barrier to the attraction and recruitment of women and racialized employees, and is resulting in a high turnover of employees and wasted training costs. 16. The underrepresentation of women and racialized employees, especially in Ottawa, must be addressed on a proactive and expedited basis through more thoughtful and strategic recruitment strategies, which we understand is currently in progress. This may involve: (i) continuing to expand diverse networks for postings; (ii) reviewing the PSO job description and re-evaluate the decision to only seek to hire individuals with a policing and security education background experience rather than expanding to a search for individuals from more demographically diverse educational programs with a commitment to serving the public with respect and dignity, and who hold progressive, tolerant and open-minded ideology; (iii) expanding the traditional networks for recruitment and continuing to look for diverse law enforcement associations/organizations from which to recruit; (iv) undertaking pre-hiring reference checks and due diligence and ensuring a review is undertaken of social media platforms for inappropriate, racist, sexual/homophobic views; (v) PSOs provide an internal central service to employees and an external service to the visiting public. Central services and service to the public must be offered in both official languages in Ottawa pursuant to the Official Languages Act. In Winnipeg, service to the public must be offered in both language, however Winnipeg is not “bilingual” for purposes of language of work and therefore central services to employees do not need to be offered in both official languages. However, human resources has advised that French language is sometimes occupationally unnecessary for the PSO role. French language is likely acting as an additional barrier to diverse recruitment of casual employees. Subject to the requirements of the Official Languages Act, consider dispensing with any French language requirement on the job posting as in Winnipeg. Instead, ensure that each crew has a bilingual PSO. Invest in language training for all English only speaking new hires; Page 18 5120571_1.DOCX (vi) dispense with the requirement for PAL and emergency preparedness as a requirement or "asset" for hiring and incorporate the PAL and emergency preparedness into the PSO training framework, as is apparently done with traditional police forces; (vii) include screening for cultural, gender and LGBTQ2+ sensitivity in the psychological screening; (viii) include in the job application voluntary disaggregated self-identification questions so as to have a better understanding of who is applying for positions. This can be easily achieved through an online application tracking system/portal instead of hard copy applications; (ix) ensure that human resources personnel is on all hiring panels for PSO hirings; (x) Engage in continual research on human resources best practices in respect to diversity recruitment, advancement and retention policies/practices/ initiatives and disaggregated demographic data collection. All of the above recommendations require resources, including a dedicated hiring manager. Expanded human resources are definitely required in Ottawa and potentially in Winnipeg. Retention 17. Mint collective bargaining proposals should include a review and update of all collective agreement provisions and employer policies relating to acting positions, advancement/promotion with an anti-racism, equity lens to remove inherent biases and barriers for, in particular, racialized individuals and women. 18. Mint collective bargaining proposals should include a policy for acting team lead; escort and other career advancing opportunities which do not rely on discretion or favouritism, or strictly seniority (as BIPOC and women will tend to be the least senior employees), but rather on objective skills/knowledge-based criteria which are transparent, widely publicized and subject to review. Be cautious about using prior acting team lead experience as a criteria as there is a history of favouritism, exclusion and discrimination within Ottawa which has resulted in a lack of past opportunities for racialized and female PSOs. Until such time as all PSOs have had equal acting team lead experience, requiring such experience will act as a barrier to advancement for all equity groups Page 19 5120571_1.DOCX 19. Eradicate favouritism in respect to job promotion, advancement or other career opportunities by using objective, skills/knowledge-based criteria which are transparent, widely publicized and subject to review. 20. Undertake regular written performance reviews in Winnipeg as in Ottawa, to provide employees with regular feedback and suggestions for the skills required to succeed and advance. 21. Undertake a third party designed and implemented Employee Engagement Survey to be taken by all PSO employees in Ottawa and Winnipeg, on an anonymous basis, annually, or at least every two years, so as to better track systemic and other issues to be addressed. It should include questions in respect of the effectiveness of team leads and management at all levels. 22. Reinstate exit interviews for all resigning employees, including casual employees, and ideally have them performed by a human resources employee who has the trust of the PSO employees in order to obtain more worthwhile and candid information. 23. Consider introducing a career development/leadership mentorship program (as compared to support only) element to the Women's Group in collaboration with other divisions of the Mint. 24. Introduce a Mint wide racialized employee career development/leadership mentorship program in collaboration with other divisions of the Mint. Arleen Huggins, External Reviewer