When Parliament enacted Canada's first Employment Equity Act in 1986, it required federally regulated private-sector employers and Crown corporations to develop plans to achieve fair representation of designated groups in their workforces. Women, Aboriginal people, people with disabilities, and members of visible minority groups were to be represented according to their availability in the labour market. The law, however, had no enforcement mechanism.

Stronger legislation in the form of a new Employment Equity Act came into force on October 24, 1996. It set forth the same core obligations for developing employment equity programs, but it bolstered these obligations with a compliance monitoring process. Employers were required by twelve statutory provisions to analyse their workforces, review their employment systems, identify barriers, and implement corrective action plans to ensure that they made reasonable progress in dealing with under-representation. Furthermore, the new Act established the Canadian Human Rights Commission as the monitoring agency that would carry out compliance audits for federally regulated public- and private-sector employers. Employers were given a year to prepare for the upcoming audits, and the Commission's compliance work began in October 1997.

The overall objective of the Act is a federally regulated workforce that is fully representative of the four designated groups. Employers that have surveyed their workforces and have completed analyses that demonstrate full representation will be found in compliance if they maintain their employment equity programs. Secondly, employers whose workforces are not representative can nonetheless be found in compliance if they have completed work under each of the twelve statutory requirements and if the Commission is confident that their employment equity plans will result in reasonable progress towards equitable representation.

Canadian Human Rights Commission

What Happens in an Initial Audit

• The employer receives an audit notification letter and is then contacted by a compliance review officer. The officer negotiates an audit plan and sends a questionnaire to the employer.
• Using the questionnaire's results, the officer completes a "desk audit" that assesses compliance against the Act's twelve requirements. The officer then visits the workplace to verify the findings and review the preliminary results with the employer.
• If the employer is in compliance, a final audit report is completed. If not, the officer drafts an interim report, indicating the undertakings required for compliance and time limits of up to twelve months for their completion.
• The officer and the employer then negotiate the undertakings and time limits in the report. Once an agreement has been reached, the employer signs the report.

What Happens in a Follow-up Audit

• The employer submits a progress report and a follow-up audit is conducted to assess whether the undertakings have been fulfilled.
• If the employer is then in compliance, a final report is issued. Thereafter, the Commission will monitor the employer's annual reports, and may begin a new audit if no reasonable progress is shown.

Why a Direction Is Issued

• When an employer refuses to agree to undertakings, or has not completed the work required by undertakings, the Commission may issue a "direction" to the employer. A direction is an official instruction that stipulates the work required and the time limit for its completion. The employer can review the recommendation for a direction and may submit comments to the Commissioners before they decide whether to issue it. A follow-up audit after the time limit elapses will assess whether the employer has fulfilled the direction.

Employment Equity Review Tribunal

• Once the Commission has issued a direction, the employer may request a tribunal to reconsider it. The Commission may also ask a tribunal to issue an order when a direction has not been fulfilled.

Federal Court of Canada

• The Court may carry out a judicial review of a decision of the Commission or a tribunal.
• A tribunal order may be registered with the Federal Court, thus giving it the force of a court order.

When the Commission reported last year on its work during 1998 - the first full year of employment equity audits - two employers were found to be fully in compliance: Status of Women Canada and A.J. Bus Lines. Most employers audited had been cooperative; however, they had only limited knowledge of the Act and its provisions.

The results raised several issues: whether the rate of initial non-compliance would persist; whether employers would continue to cooperate with the audits; whether they would fulfil their undertakings; and finally, whether the Commission would need to resort to enforcement action.

Two years of experience have provided some answers. From a total of 111 initial audits completed, four employers were found to be in compliance. One hundred and three employers signed undertakings requiring follow-up audits. The remaining four audits were postponed or cancelled. As a result of follow-up audits in 1999, a further eight employers were found to be in compliance. A detailed look at the 1999 audit results follows.

Audits Under Way

Setting Goals

The Commission's goal for 1999 was to begin at least 100 audits, of which 75 were to be follow-up audits of employers' undertakings.

The Commission believed it could complete or close at least 90 audits during this time. Audits are considered "completed" when they are concluded with signed undertakings, or when an officer has recommended a direction. Audits are considered "closed" when the employer is found to be in compliance with the Act. This means that designated groups are already equitably represented in the employer's workforce, or that the Commission is confident that the employer's employment equity plans will achieve reasonable progress towards equitable representation.

Table 1
Measuring Progress against Goals

1998
Audits begun

Planned:
Actual:

Initial audits

Planned: 82
Actual: 110

Follow-up audits

Planned: -
Actual: -

Total audits begun

Planned: 82
Actual: 110

Audits completed or closed

Planned:
Actual:

Initial Audits

Planned:
Actual: 49

Follow-up Audits

Planned:
Actual: -

Total audits completed or closed

Planned:
Actual: 49

1999
Audits begun

Planned:
Actual:

Initial audits

Planned: 25
Actual: 36

Follow-up audits

Planned: 75
Actual: 68

Total audits begun

Planned: 100
Actual: 104

Audits completed or closed

Planned: 90
Actual:

Initial Audits

Planned:
Actual: 67

Follow-up Audits

Planned:
Actual: 20

Total audits completed or closed

Planned: 90
Actual: 87

Achieving Goals

Table 1 shows that the Commission completed or closed 87 audits during the same year. All but two employers required signed undertakings to bring themselves into compliance. In approximately two-thirds of the follow-up audits, employers were still not in compliance. However, because they had made significant progress towards compliance, they were granted extensions of up to 90 days to complete the remaining work. This, of course, lengthened the process, which meant that some follow-up audits were carried over to the year 2000. In four cases, the level of work accomplished was not sufficient to warrant an extension, and the Commission issued a direction to the employer to complete the undertakings.

Results and Findings

Initial Audits

As Table 2 indicates, only two of the 49 employers whose audits were completed or closed in 1998 were found to be in compliance. Initial audits in 1999 showed similar results: of 51 completed or closed audits, only two employers, Nortel Networks and the National Parole Board, were found to be in compliance.

These initial compliance rates are still low. However, there are indications that a growing number of employers are taking the steps necessary to achieve compliance with the Act before their initial audit begins. For example, recent audits have found improved self-identification surveys and better workforce analyses. In particular, many employers have established employment equity advisory groups, consulted with union representatives, and trained employees on how they can help achieve compliance.

Follow-up Audits

The Commission began 68 follow-up audits in 1999 (Table 3) and completed assessments of progress for 39 of them during the year. It found eight employers in compliance: Alcan, Bearskin Lake Air Services Ltd., Cameco Corporation, Canada Maritime Agencies Ltd., the Canadian Radio-television and Telecommunications Commission, Northern Telephone Ltd., N. Yanke Transfer Ltd., and Seaspan International Ltd.

The Commission granted 25 of the 39 employers short extensions to complete their undertakings, and began to assess the progress they had made at year's end. Although final reports had not yet been completed, most of the employers appear to have achieved compliance.

Table 2
Status of Initial Audits, 1998-1999

Initial audits begun

1998: 110
1999: 36
Total: 146

Audits completed with undertakings

1998: 47
1999: 49
Total: 96

Audits closed, in compliance

1998: 2
1999: 2
Total: 4

Audits postponed or cancelled*

1998: -
1999: 4
Total: 4

* Refers to employers that are undergoing significant reorganizations, or are no longer subject to audits because their workforce has been reduced to fewer than 100 employees, or have gone out of business.

Table 3 Status of Follow-Up Audits Begun in 1999

Analysis under way: 29
Analysis completed: 39

90-day extension granted: 25
Closed, in compliance: 8
Directions issued: 4
Closed because the employer was no longer subject to the Act: 2

Total of follow-up audits: 68

Issuance of Directions

By the end of 1999, four employers had not fulfilled their undertakings and had been issued directions: the Banca Commerciale Italiana of Canada, Conair Aviation Ltd., Fundy Communications (whose direction was rescinded when it was acquired by Shaw Communications), and Environment Canada, which is appealing the direction to the Employment Equity Review Tribunal.

One of the key elements the Commission considers before issuing a direction is whether an employer has completed a satisfactory employment systems review. The review is essential in identifying barriers to the employment of designated groups. If it is not conducted efficiently, the rest of the program is flawed. As a result, the employer cannot pursue activities that eliminate barriers, implement sufficient special measures to close the gaps, or set hiring and promotion goals at appropriate levels to achieve reasonable progress.

By the end of 1999, no employer had yet been referred to an employment equity tribunal for refusing to comply with a direction, since in no case had the time limit for completing work under the terms of a direction been exceeded.

Problem Areas

Identifying Barriers

Achieving employment equity requires employers to identify and eliminate barriers and establish special measures to overcome their effects. Ascertaining whether designated groups are under-represented within an organization, according to their availability within the appropriate labour market, is a first step. In 1999, an increased number of employers carried out this analysis successfully. On the other hand, identifying the barriers that contribute to under-representation continues to pose problems for most employers.

As noted above, the employment systems review is one of the most critical aspects of employment equity. It requires a clear identification of both the formal and informal policies and practices that contribute to continued under-representation, including an examination of attitudes and behaviour. The Commission has issued a guide for employers to help them understand its requirements for employment systems reviews more clearly. It explains how employers' reviews will be assessed during compliance audits.

Human resource management is complex and changing rapidly. As a result, effective employment systems reviews require expertise, the commitment of appropriate resources, and a willingness to acknowledge the factors that contributed to the gaps identified in the workforce analysis.

Setting Realistic Hiring and Promotion Goals

As outlined above, most follow-up audits demonstrate that employers are close to achieving compliance as a result of fulfilling their undertakings. Not surprisingly, those who do not establish appropriate goals are less successful. In most cases, employers that had not quite achieved compliance fell short because they did not set adequate hiring and promotion goals. Even employers that have successfully identified and removed barriers are often reluctant to set goals that will lead to increased representation within a reasonable period of time.

If an employer carries out a proper workforce analysis, the results will provide a reasonable estimate of the hirings and promotions of designated groups that could be expected if there were no discriminatory barriers. An employer that sets hiring and promotion goals for designated groups at rates lower than labour market availability cannot expect to achieve progress towards equitable representation.

The Act is also explicit about other factors that must be taken into account once these benchmarks have been established. An employer must consider the size of each gap, the level of expected turnover, and the projected growth or contraction of employment in an occupational group or category. If the gap in representation is significant, or turnover and growth levels are low, hiring at availability levels will result in very slow movement towards equality.

For example, based on a forecasting model developed by the Public Service Commission, if goals are set at availability levels it would take many departments about 28 years before full representation of some designated groups is reached. In these situations, goals of one-and-a-half or double availability may be needed.

Conversely, if an employer's gaps are relatively small, or if substantial opportunities to hire and promote are expected over the three-year period covered by the plan, significant progress can be achieved through goals that more closely reflect availability. For example, some audited employers report turnover rates in excess of 50 per cent over a given period. This provides ample opportunity to make rapid progress in closing gaps.

The Commission recognizes that goals should not unduly exclude non-designated groups from job opportunities, and reminds employers to consider this when formulating their goals and special measures.

The Reasonable Progress Clause

Many employers believe that if they implement the Act's twelve statutory requirements, they are no longer subject to audits. This is not the case. The Act requires "every employer to ensure that its employment equity plan would, if implemented, constitute reasonable progress toward implementing employment equity" and that "every employer shall make all reasonable efforts to implement its employment equity plan."

This means two things. First, before closing an audit, the auditor must be confident that the employer's plan will lead to reasonable progress. Second, once an audit has been successfully closed, the Commission will monitor performance by reviewing employers' annual reports. Private-sector companies submit these to Human Resources Development Canada, and public-sector employers submit them to the Treasury Board.

Innovative Ideas

Some employers' creative investments in their employees have resulted in steady employment equity progress. One Ontario employer, Northern Telephone Ltd., working closely with its employees' union, included a provision in its collective agreement to permit the staffing each year of two positions outside the confines established by the agreement. Over the last year, this resulted in the placement of two Aboriginal employees in jobs where under-representation had been identified. The Cameco Corporation, in Saskatchewan, committed a million dollars to the College of Engineering at the University of Saskatchewan to improve the access of Aboriginal students to engineering and science programs.

One public-sector employer, the Atlantic Canada Opportunities Agency, found that when it valued key competencies over academic credentials, five women received executive intern positions. Over time, this approach is expected to substantially improve female representation in the Agency's senior management.

Similarly, N. Yanke Transfer Ltd., an employer in the transportation sector, achieved progress in new hirings of women in non-traditional positions by replacing extensive experience requirements with more generic competencies. The employer subsequently found the performance of these new employees to be strong.

Audit Standards

Achievement of Current Standards

In administering the audit program, the Commission makes every attempt to achieve results by emphasizing persuasion and cooperation. The audit process, therefore, may take time to reach mutual agreement on required action. However, in the end, this is less time-consuming than resorting to enforcement measures.

That said, a distinction must be made between reasonable and unreasonable delays, and the Commission has developed performance standards for both initial and follow-up audits.

In most cases, these standards are being respected, leading to the profile of open and closed audits outlined in Table 4. Since the start of the program, the general acceptance of the audit process by employers has contributed significantly to these results.

Table 4
Audits Begun and Completed: 1998 and 1999

Initial audits

Started: 146
Finished: 111

Follow-up audits

Started: 68
Finished: 14

Total audits

Started: 214
Finished: 125

Meeting Standards for Initial Audits

Performance standards for initial audits, reported in last year's annual report, are presented below. An audit requires, on average, between nine and eleven months to complete (Table 5). A review of current workloads, and the fact that the Commission's Employment Equity program is achieving its targets, indicates that in most cases these standards are being met. An improved information management system under development should permit a more precise measurement of results in future years.

Table 5
Standards for Initial Audits

Auditors will begin an audit within 90 days of notifying the employer.

Activity: Complete and return survey questionnaire

Auditor:
Employer: 30 days

Activity: Review survey questionnaire, complete initial assessment and validate findings through on-site visit

Auditor: 90 days
Employer:

Activity: Finalize analysis; write, submit and translate draft report

Auditor: 70 days
Employer:

Activity: Approve report and submit undertakings

Auditor:
Employer: 30-60 days

Activity: Negotiate undertakings

Auditor and Employer: 30 days

Activity: Finalize report and return to organization

Auditor: 7 days
Employer:

Activity: Obtain CEO's or DM's signature

Auditor:
Employer: 15-30 days

Activity: From start to completion

Auditor and Employer: 9 to 11 months

Setting Standards for Follow-up Audits

During 1999, the Commission developed and began to test new standards for follow-up audits. Based on the experience of the past few months, and the 68 follow-up audits begun, it appears the time required to conduct follow-up audits will closely mirror the standards developed for initial audits.

A follow-up audit will generally be completed within seven to twelve months (Table 6). The wide time range can be attributed to the extensions the Commission affords to employers that are close to compliance. As in the case of initial audits, the work may require an additional 28 to 62 working days for auditors.

Given the Commission's decision to issue short extensions to employers that are near compliance, the performance standard that requires auditors to provide prompt feedback to employers is especially critical. Auditors are required to adhere to a deadline of 45 calendar days in this respect.

Table 6
Standards for Follow-Up Audits

Compliance officers start a follow-up audit 30 days before the scheduled date by requesting a progress report from the employer.

Activity: Complete and return the progress report

Auditor:
Employer: 30 days

Activity: Complete preliminary analysis on compliance status

Auditor: 45 days
Employer:

Activity: Provide feedback on status to employer (includes possible on-site visit)

Auditor: 45 days
Employer:

Activity: Grant extension if modifications required

Auditor: 30 days
Employer: Up to 90 days

Activity: Finalize analysis; write, submit and translate compliance report*

Auditor: 70 days
Employer:

Activity: Obtain signature if report includes recommendations

Auditor:
Employer: 15-30 days

Activity: From start to completion

Auditor and Employer: 7 to 12 months

Activity: Disclose a recommendation for a direction if employer not in compliance

Auditor: 30 days
Employer:

Activity: Employer response

Auditor:
Employer: 30 days

* If employer is in compliance at this stage, the audit is closed.

Audit Plan for the Year 2000

Estimated Workload

Table 7 outlines the Commission's audit performance goals for the year 2000. As reported last year, the Commission's Employment Equity program is currently resourced to the level of ten auditors, each of whom is expected to manage ten audits per year.

Based on the initial audits conducted to date, and with its current resources, the Commission expects to begin 92 audits in the year 2000, of which 67 will be follow-up audits. In addition, 29 initial and 48 follow-up audits will be carried over from 1999, for a total workload of 169 ongoing audits in 2000. It is also projected that a total of 104 audits - 39 initial and 65 follow-up - will be completed or closed.

A Word of Caution

The experience of the past year indicates that it will be increasingly difficult for auditors to conduct ten audit equivalents per year, or for the Commission to accurately predict the number of audits launched and completed in a given year. An increasing number of variables may affect these calculations. These include the mix of initial and follow-up audits; the number of 90-day extensions granted; the requirement for a fuller audit of certain employers after a direction has expired; the need to begin monitoring the performance of employers that have been audited; and the need to conduct new audits of employers found not to be making reasonable progress.

Finally, during the year 2000, the Commission intends to give increased emphasis to auditing larger employers. This could lead to a decline in the number of initial audits possible during the year, as outlined in greater detail in the next section.

Table 7
Results from 1998 and 1999, and Year 2000 Projections
Based on a Resource Equivalent of Ten Auditors

1998 - Actuals
Initial audits begun

Started: 110
Finished: 49

Follow-up audits begun

Started: -
Finished: -

Total audits begun

Started: 110
Finished: 49

Initial audits carried over from previous year

Started: -
Finished: -

Follow-up audits carried over from previous year

Started: -
Finished: -

Total audits completed or closed: 49

Audit workload: 110

Audits per auditor: 11

1999 - Actuals
Initial audits begun

Started: 36
Finished: 7

Follow-up audits begun

Started: 68
Finished: 14

Total audits begun

Started: 104
Finished: 21

Initial audits carried over from previous year

Started: 61
Finished: 53

Follow-up audits carried over from previous year

Started: -
Finished: -

Total audits completed or closed: 74

Audit workload: 165

Audits per auditor: 17

2000 - Planned
Initial audits begun

To start: 25
To finish: 10

Follow-up audits begun

To start: 67
To finish: 25

Total audits begun

To start: 92
To finish: 35

Initial audits carried over from previous year

To start: 29
To finish: 29

Follow-up audits carried over from previous year

To start: 48
To finish: 40

Total audits completed or closed: 104

Audit workload: 169

Audits per auditor: 17

The Five-Year Cycle

The Commission had planned to audit all employers under the jurisdiction of the Act during the first five years of its mandate. By December 1999, it was evident that meeting this objective might not be possible. Experience to date has shown that more than 95 per cent of employers require follow-up audits, most frequently because they are insufficiently aware of the requirements of the Employment Equity Act.

A shorter and simplified approach was introduced for audits of employers found to have completed only limited work, but it is too early to determine the long-term impact of this measure. Similarly, during 1998, the Commission encouraged the Treasury Board Secretariat, the Public Service Commission, and Human Resources Development Canada to provide additional technical advice through consulting services to public- and private-sector employers. If employers are to achieve compliance with the law at an earlier stage in the process, additional efforts will be required on their part - and from the agencies with a mandate to assist them.

Year Three Audit Selections

During 1998 and 1999, the first two full years in which the Commission undertook audits, employers were grouped by industrial sector, size and location, and then randomly selected for audit. By the end of 1999, the 146 employers whose initial audits had begun represented 23 per cent of all employees working for federally regulated employers. Tables on the size and scope of employers covered by the Act are contained at the end of this chapter.

In its 1998 Annual Report, the Commission undertook to determine whether some adjustments might increase the initial impact of the audit program. During the year 2000, the Commission will focus on conducting initial audits of employers whose workforces exceed 1,000 employees. In this way, it is intended that by the end of the year 2000, over 60 per cent of federally regulated private-sector employees and 80 per cent of the public service's workforce will have been covered by audits.

An Assessment of Progress for the Four Designated Groups

Employers in the federally regulated private sector have been filing annual employment equity reports with Human Resources Development Canada for twelve years. The reports contain detailed data on the representation, hiring, promotion and termination of designated group employees.

In 1999, some 333 employers in banking, communications, transportation and "other" sectors filed data on their combined workforce of about 586,000 employees for the year ending December 1998. The "other" sector includes a variety of employers such as grain companies, uranium mines, nuclear power operations, credit corporations and museums.

For the public sector, the Treasury Board reported on employment equity in 65 federal departments and agencies, with a combined workforce of about 178,000 employees. The latest data for the federal public service are from March 31, 1999.

The increase of 2.8 per cent in the private-sector workforce can be attributed to the fact that several employers that did not report in 1998 submitted reports in 1999. In the private sector, over 80,000 positions were filled - about 14,500 more than the previous year. This suggests that there were ample opportunities to hire members of the four designated groups. Once again, however, few employers took advantage of these opportunities. As in the past, some designated groups fared better than others, and progress varied by industrial sector.

Overall, the federal public service decreased slightly in size during the year, but approximately 17,000 job openings were filled, of which 2,500 were for permanent positions. Some of these opportunities were used to hire designated group members, particularly women and Aboriginal people. However, as discussed below, people with disabilities and members of visible minority groups were hired at rates substantially below their availability in the Canadian workforce.

In evaluating the latest data, the following points should be kept in mind.

• The following sections compare workforce data in both the private and public sectors with the 1996 Census availability for women, visible minorities and Aboriginal people. The graphs included compare the progress of the four designated groups from 1987 to 1998.
• The availability estimates for people with disabilities date from the 1991 Health and Activity Limitation Survey, or HALS, since the survey did not form part of the 1996 Census.
• Because a new system of grouping occupations in the private sector was adopted in 1996, it is not always possible to make comparisons using these groupings with data from before that year.
• The availability estimates for members of visible minority groups prepared by the Treasury Board Secretariat use 1996 Census data and include only Canadian citizens. Previous estimates were based on the 1991 Census. The Treasury Board's estimate of 9.0 per cent availability for the public sector was similar to the 9.1 per cent availability estimate for the private sector, and both included permanent residents as well as Canadian citizens. Although the 1996 Census indicates that the overall availability of visible minorities has risen to 10.3 per cent, the Treasury Board's estimate has decreased to 8.7 per cent because it excludes permanent residents. The rationale for excluding them is that the Public Service Employment Act gives preference to Canadian citizens in hirings into the federal public service. However, this preference is currently the subject of a court challenge, and the Commission will therefore assess public service hiring goals for visible minorities against the 10.3 per cent benchmark.
• The shares of hirings or terminations in the following summaries refer to the percentage of people who are members of a designated group. Normally, if there were no employment barriers, a designated group could be expected to receive the same share of hirings as its availability in the Canadian workforce. For terminations, however, the group's share should correspond to its existing representation within the organization.

Women

In the private sector: The representation of women increased from approximately 40.1 per cent in 1987 to 44.3 per cent in 1998, and remains close to their 46.4 per cent availability. Women's share of hirings increased somewhat from 39.2 per cent in 1997 to 41.4 per cent in 1998.

Women's representation ranged from 72.5 per cent in the banking sector to 23.5 per cent in transportation and 25 per cent in the "other" sector. Their representation increased in most occupational groups in the private-sector workforce and in senior management positions in all sectors.

In the banking sector, women registered increases in management and professional occupations and now occupy close to half of all these positions. In senior management, their representation increased to 19.5 per cent in 1998, but was still somewhat lower than the 1996 Census benchmark of 20.8 per cent for these occupations. Overall, their share of hirings in banking has fallen dramatically from 76.3 per cent in 1987 to 59.1 per cent in 1998. This is largely due to a decrease in the number of clerical occupations in the banking workforce.

Women over the Past Decade -
Private Employers and Crown Corporations

1987
Availability: 43 %
Representation: 40.1 %
Hiring: 42 %

1998
Availability: 46.4 %
Representation: 44.3 %
Hiring: 41.4 %

In transportation, women's share of hirings has increased from 21.9 per cent in 1987 to 29.8 per cent in 1998, leading to a steady increase in their representation from 16.0 per cent to 23.5 per cent. Compared to 1997, women's share of hirings in some non-traditional occupational groups increased slightly, while remaining well below availability.

In 1998, about 22 per cent of women in the private sector worked part time, compared to approximately eight per cent of men. The pattern is similar for women who are members of a minority group: close to 27 per cent of Aboriginal women, and over 20 per cent of women with disabilities, worked in part-time jobs.

In the public sector: Women's representation in the federal public service was 51.5 per cent as of March 31, 1999, an increase of about one percentage point from 1997. This represents substantial progress since 1987, when their representation was about 42 per cent. The figure is also in line with women's 46.4 per cent availability in the Canadian workforce. Their share of hirings was about two percentage points higher than in 1997, and stood at 62.1 per cent as of March 31, 1999. However, only 11 per cent of all women hired obtained permanent positions, compared to 22 per cent of men. As in the past, a substantially higher proportion of women were hired into temporary positions, which are of course less secure.

Women's representation in the Executive group has increased by close to two percentage points since 1997, and now stands at 26.9 per cent. Their representation also increased in all other occupational categories.

Women over the Past Decade -
Federal Public Service

1987 Availability: 43 % Representation: 42 % Hiring: 47.5 %

1998 Availability: 46.4 % Representation: 51.5 % Hiring: 62.1 %

For organizations with 200 or more employees, women's representation was highest in the civilian component of the Royal Canadian Mounted Police, at 81 per cent. This is because 74 per cent of the jobs in this component are clerical positions, in which women are highly concentrated. Women's representation was lowest in the Department of Fisheries and Oceans, at 26.5 per cent. This is largely attributable to this department's high proportion of scientific, technical and operational jobs, in which women have traditionally been under-represented.

Members of Visible Minority Groups

In the private sector: The representation of members of visible minority groups has more than doubled in the past twelve years, increasing from 4.9 per cent in 1987 to 9.9 per cent in 1998. However, it remains below the 10.3 per cent availability rate established by the 1996 Census.

Overall, the share of hirings received by members of visible minorities decreased from 12.1 per cent in 1997 to 11.3 per cent in 1998. However, this remains substantially higher than the 5.2 per cent share recorded in 1987.

As in the past, the representation of this group varies considerably by sector. In banking, their representation is 15.3 per cent, slightly higher than the year before, but considerably higher than the 9.5 per cent registered in 1987. In communications, they make up 9.0 per cent of the workforce, up slightly from the previous year. This is below availability, but more than double their 4.0 per cent representation in 1987. Progress in both these sectors can be attributed to the fact that visible minority hirings took place at a rate higher than the group's general availability.

Visible Minorities over the Past Decade -
Private Employers and Crown Corporations

1987
Availability: 6.3 %
Representation: 4.9 %
Hiring: 5.2 %

1998
Availability: 10.3 %
Representation: 9.9 %
Hiring: 11.3 %

In the "other" sector, visible minorities made up 7.9 per cent of the workforce in 1998, a substantial increase from 2.5 per cent in 1987. Their representation, however, was lower than the 8.1 per cent reported in 1997, because their share of hirings fell from 15.5 per cent in 1997 to 6.4 per cent in 1998.

Progress was slowest in the transportation sector, where the representation of visible minority groups was 5.7 per cent in 1998, up from 5.3 per cent the year before and from 2.5 per cent in 1987. Although the group's share of hirings has been consistently below availability, their share of terminations has been in line with representation, enabling them to make small gains in a workforce that has shrunk more than 27 per cent since 1987.

Even though steady progress is being made for this group, much remains to be done. Members of visible minorities remain concentrated in some occupational groups and under-represented in others, including senior management.

In the public sector: As of March 31, 1999, the representation of members of visible minority groups in the federal public service stood at 5.9 per cent, slightly higher than the 5.1 per cent of 1997. The data indicate that there were 1,297 more members of visible minorities in the federal public service than in 1997. However, since only 730 new hirings took place, close to half of this increase can be attributed to a higher rate of self-identification. It is disappointing to note that, once again, departments did not take advantage of the ample hiring opportunities that existed to recruit members of this designated group, whose share of hirings was only 4.4 per cent, slightly higher than in 1997, but still far short of their 10.3 per cent availability in the Canadian workforce. In fact, if visible minorities had been hired at a level commensurate with their availability, they would have obtained 1,730 positions. Not only were they overlooked when it came to indeterminate positions, where their share was only 6.9 per cent, but also in term positions, where they received only four per cent of all hirings.

Visible Minorities over the Past Decade -
Federal Public Service

1987
Availability: 5.7 %
Representation: 2.8 %
Hiring: 3.3 %

1998
Availability: 10.3 %
Representation: 5.9 %
Hiring: 4.4 %

Although the share of hirings was low in each occupational category, it is encouraging to note that four of the 38 appointments to the Executive group, the most senior level of management in the federal public service, were visible minorities.

Among departments and agencies with more than 200 employees, the representation of visible minorities was highest in the Immigration and Refugee Board, at 18.3 per cent. It was close to ten per cent in Health Canada and Citizenship and Immigration Canada. However, 23 organizations had representation of less than half the 10.3 per cent Canadian workforce availability.

Aboriginal People

In the private sector: Aboriginal people did not benefit from the substantial number of hiring opportunities in 1998. Although their representation in 1998, at 1.3 per cent, was higher than the 0.6 per cent reported in 1987, it was unchanged from the previous year. For the fourth year in a row, the Aboriginal share of hirings continued to decline, and, at 1.4 per cent in 1998, was considerably lower than the 2.1 per cent availability. The difficulties faced by this group were compounded by their disproportionately high share of terminations.

Aboriginal People over the Past Decade -
Private Employers and Crown Corporations

1987
Availability: 2.1 %
Representation: 0.6 %
Hiring: 0.5 %

1998
Availability: 2.1 %
Representation: 1.3 %
Hiring: 1.4 %

The only increase in Aboriginal people's representation came in the transportation sector. Although their share of hirings fell from 2.0 per cent in 1997 to 1.9 per cent in 1998, there were fewer terminations of employment than hirings. As a result, representation increased marginally from 1.2 per cent to 1.3 per cent.

There was no change in Aboriginal people's representation in banking, at 1.3 per cent, or in communications, at 1.1 per cent. In these sectors, their share of hirings, although marginally higher than in 1997, was only about half their 1996 Census availability.

In the "other" sector, the steady progress of recent years came to a halt, as the Aboriginal share of hirings fell from 3.3 per cent in 1997 to 1.8 per cent in 1998, resulting in a decrease in representation from 2.1 per cent to 2.0 per cent.

In the public sector: In contrast with the private sector, the representation of Aboriginal people in the public sector continued its increase of recent years, reaching 2.9 per cent as of March 31, 1999. This is higher than the 1996 Census benchmark of 2.1 per cent. However, as noted in previous years, there are dramatic differences in the distribution of Aboriginal people among federal departments and agencies. The Department of Indian and Northern Affairs, where over 27 per cent of employees are Aboriginal, employs close to 17 per cent of all Aboriginal employees in the federal public service. On the other hand, 23 of the 42 organizations employing more than 200 employees do not meet the Census benchmark.

Aboriginal People over the Past Decade -
Federal Public Service

1987
Availability: 1.8 %
Representation: 1.8 %
Hiring: 3.1 %

1998
Availability: 2.1 %
Representation: 2.9 %
Hiring: 3.0 %

In the federal public service as a whole, the data suggest that Aboriginal people received a fair share of hirings in all occupational categories, and to indeterminate and term positions. However, given the disproportionate impact of staffing actions at the Department of Indian and Northern Affairs, the Commission will pay close attention to the hiring goals of other departments and agencies to ensure they are sufficiently high to lead to a significant increase in the representation of Aboriginal people throughout the federal public service.

People with Disabilities

In the private sector: As noted above, 1998 saw a large increase in hiring opportunities, but people with disabilities did not reap any of the benefits. While their overall representation in the private sector remained unchanged at 2.3 per cent, their share of hirings fell for the fifth year in a row, and reached the lowest level since 1988. In the past twelve years, the share of hirings for people with disabilities has not come close to matching their availability in the workforce.

People with Disabilities over the Past Decade -
Private Employers and Crown Corporations

1987
Availability: 5.5 %
Representation: 1.6 %
Hiring: 0.6 %

1998
Availability: 6.5 %
Representation: 2.3 %
Hiring: 0.9 %

People with disabilities were under-represented in each industrial sector, ranging from a low of 1.8 per cent in transportation, to 2.3 per cent in banking, 2.4 per cent in communications and 2.9 per cent in the "other" sector. As in the past, the cause of this under-representation is directly attributable to the unfortunate fact that the group did not receive a fair share of job opportunities. In 1998, people with disabilities obtained only 0.9 per cent of all hirings, down from 1997 and less than one-seventh of the 6.5 per cent benchmark established by the Health and Activity Limitation Survey, or HALS. This dismal performance was apparent across all sectors, in none of which their share of hirings exceeded 1.1 per cent.

In the public sector: In contrast, the representation of people with disabilities increased in the public sector, from 3.9 per cent in 1997 to 4.6 per cent in 1998. Although this is close to the 4.8 per cent benchmark used by the Treasury Board, it is still short of the group's 6.5 per cent representation in the Canadian workforce (based on the 1991 HALS). Moreover, the data suggest that the increase was largely attributable to increased self-identification.

People with Disabilities over the Past Decade -
Federal Public Service

1987
Availability: 4.6 %
Representation: 2.6 %
Hiring: 2.1 %

1998
Availability: 6.5 %
Representation: 4.6 %
Hiring: 2.0 %

Although the overall number of people with disabilities in the federal public service increased by 1,194 during the year, their share of hirings - 380 in total - remained disappointingly low. They obtained only 51 (two per cent) of the 2,533 permanent positions filled, and only 329 (2.4 per cent) of the 14,000 term positions of three months or more. Not a single person from this designated group was hired into the Executive group. Of the close to 4,000 hired into administrative and foreign service jobs, only 59 were people with disabilities. They received only 34 of the 3,000 hirings into scientific, professional and technical jobs.

The continuing poor record of the federal public service with regard to hiring people with disabilities is reflected in the fact that 38 of the 42 public-sector organizations employing more than 200 employees fell short of the 6.5 per cent HALS benchmark. In fact, seventeen organizations had fewer than half of the people with disabilities that would be expected, and only four met or exceeded the 6.5 per cent HALS benchmark: the Canadian Transportation Agency, Human Resources Development Canada, the Public Service Commission and the civilian division of the RCMP.

Summary

Despite progress for some designated groups, the results of the past year make it clear that movement towards an equitable federal workforce continues at a snail's pace. In particular, Aboriginal people and people with disabilities in the private sector, and visible minorities and people with disabilities in the public sector, are simply not making acceptable gains.

Partnerships for Change The Public Sector For a number of years, the Commission has registered its growing concern over the serious inequities that persist in the federal public service, particularly for people with disabilities and members of visible minority groups. Concerns on the part of visible minorities undoubtedly contributed to the establishment of the National Council of Visible Minorities in the Public Service, whose members included more than 200 employees from eighteen federal departments and agencies. The Council organized its inaugural conference in October 1999; its participants included the Deputy Prime Minister, deputy ministers and senior public servants, and a representative from the Commission. The conference, whose title was "Building a Representative Federal Public Service Now and in the New Millennium," sought to promote a more cooperative approach among departments and agencies and to raise awareness of the employment equity issues facing visible minorities. The conference focused on the slow pace of change in the federal public service, and heard encouraging words from the Deputy Prime Minister, who emphasized that:

Employment equity is a key element of the renewal of the federal public service, which will continue to provide excellent service to all Canadians. The measures aimed at increasing the representation of visible minorities at all levels are an important part of this overall strategy - culture change, commitment by senior management, communication, education and the forging of partnerships that cut across departments and regions of our federal public service - are all key to our success in this area.

Another important initiative during 1999 saw the establishment of the Task Force on the Participation of Visible Minorities in the Federal Public Service, chaired by Lewis Perinbam. The task force, which includes representatives from advocacy groups and individuals with public- and private-sector experience, is undertaking a comprehensive review of barriers affecting members of visible minority groups. The Chief Commissioner took the opportunity to meet the task force. The Commission hopes that when the task force issues its report, the recommendations will receive prompt and serious attention.

During 1999, Commission staff continued to work closely with their counterparts at Human Resources Development Canada to ensure the smooth implementation of the Employment Equity Act. However, the Commission remains concerned over the capacity of the Department's consultative services to provide the necessary level of assistance to ensure that private-sector employers and Crown corporations develop and implement appropriate employment equity plans. Despite the considerable efforts of those assigned to provide assistance, the low level of initial compliance with the Act suggests that an increase in the level of resources devoted to this task would pay ample dividends.

The RCMP, the Canadian Forces, and the Canadian Security Intelligence Service

When the Employment Equity Act received Royal assent, provision was made to extend its coverage to the Canadian Forces, the Canadian Security Intelligence Service and the RCMP. It is regrettable that these agencies continue to remain outside the Act's purview. The Commission is unaware of any valid reason for the continued delays in issuing the necessary order in council to extend the Act's coverage.

The RCMP cooperated fully with the Commission on a voluntary employment equity review several years ago. It has since demonstrated excellent progress towards achieving equity in employment. There is no reason to suppose that the Canadian Forces or CSIS would be less successful, and their continued absence from the statutory scheme sends an unfortunate message.

Preparing for the Legislative Review

The Employment Equity Act includes provision for a review of the legislation after five years. The Act came into force on October 24, 1996, with an initial year for employers to prepare for the Commission's audits, which began late in 1997. A legislative review is therefore expected to begin near the end of 2001, or four years after the Commission received its audit mandate. Two performance measures that will undoubtedly be relevant to any such review are the increase in the number of employers with non-discriminatory employment systems in place, and the growth (or decline) in the representation of designated groups at all levels of employers' workforces.

In this regard, the Commission has established as a goal that one year after having been found in compliance, at least 80 per cent of employers initially found to have under-representation will show improvement. The number of compliance audits begun and completed of course remains an important operational goal. But in the end, the success or failure of the Act will be measured by the degree to which the federal workforce achieves equity.

Table 8
Total Number of Employers and Employees by Sector
Subject to the Employment Equity Act
And under Audit

As of December 31, 1999

Sector: Private Sector, Sub-sector: Banking

Subject to the Act: 18 employers, 174,133 employees
Under Audit: 7 employers, 9,450 employees

Sector: Private Sector, Sub-sector: Communications

Subject to the Act: 98 employers, 194,780 employees
Under Audit: 32 employers, 53,844 employees

Sector: Private Sector, Sub-sector: Transportation

Subject to the Act: 167 employers, 156,861 employees
Under Audit: 58 employers, 37,697 employees

Sector: Private Sector, Sub-sector: Other*

Subject to the Act: 50 employers, 60,814 employees
Under Audit: 16 employers, 18,330 employees

Sector: Federal Public Service

Subject to the Act: 65 employers, 178,479 employees
Under Audit: 31 employers, 83,068 employees

Sector: Separate Federal Agencies

Subject to the Act: 16 employers, 106,817 employees
Under Audit: 2 employers, 609 employees

Total:

Subject to the Act: 414 employers, 871,884 employees
Under Audit: 146 employers, 202,998 employees

* The "other" sub-sector includes such diverse industries as grain companies, uranium mines, nuclear power operations, credit corporations and museums.

Table 9
Public-Sector Organizations
Under Audit by Employer Size

10,000 plus: Public Service As of March 1999

Subject to the Act: 5 employers, 100,216 employees.
Under Audit: 3 employers, 43,651 employees.

10,000 plus: Separate Agencies As of January 2000

Subject to the Act: 2 employers, 85,739 employees.
Under Audit: 0 employer, 0 employee.

2,000-9,999: Public Service As of March 1999

Subject to the Act: 15 employers, 65,316 employees.
Under Audit: 8 employers, 31,107 employees.

2,000-9,999: Separate Agencies As of January 2000

Subject to the Act: 5 employers, 17,661 employees.
Under Audit: 0 employer, 0 employee.

1,000-1,999: Public Service As of March 1999

Subject to the Act: 2 employers, 2,450 employees.
Under Audit: 1 employer, 1,233 employees.

1,000-1,999: Separate Agencies As of January 2000

Subject to the Act: 0 employer, 0 employee.
Under Audit: 0 employer, 0 employee.

500-999: Public Service As of March 1999

Subject to the Act: 8 employers, 5,375 employees.
Under Audit: 6 employers, 4,120 employees.

500-999: Separate Agencies As of January 2000

Subject to the Act: 2 employers, 1,475 employees.
Under Audit: 0 employer, 0 employee.

100-499: Public Service As of March 1999

Subject to the Act: 18 employers, 4,515 employees.
Under Audit: 13 employers, 2,957 employees.

100-499: Separate Agencies As of January 2000

Subject to the Act: 7 employers, 1,942 employees.
Under Audit: 2 employers, 609 employees.

less than 100: Public Service As of March 1999

Subject to the Act: 17 employers, 607 employees.
Under Audit: 0 employer, 0 employee.

less than 100: Separate Agencies As of January 2000

Subject to the Act: 0 employer, 0 employee.
Under Audit: 0 employer, 0 employee.

Total: Public Service As of March 1999

Subject to the Act: 65 employers, 178,479 employees.
Under Audit: 31 employers, 83,068 employees.

Total: Separate Agencies As of January 2000

Subject to the Act: 16 employers, 106,817 employees.
Under Audit: 2 employers, 609 employees.

Table 10
Private-Sector Organizations and Employees Subject to the Employment Equity Act
By Province and Sector

As of December 31, 1999

Newfoundland
Sector: Banking; 5 employers, 1,491 employees.
Sector: Communications; 4 employers, 2,757 employees.
Sector: Transportation; 6 employers, 1,475 employees.
Sector: Other*; 0 employer, 0 employee.
Total: 15 employers, 5,723 employees.

Prince Edward Island
Sector: Banking; 4 employers, 386 employees.
Sector: Communications; 2 employers, 487 employees.
Sector: Transportation; 3 employers, 284 employees.
Sector: Other*; 0 employer, 0 employee.
Total: 9 employers, 1,157 employees.

Nova Scotia
Sector: Banking; 6 employers, 5,274 employees.
Sector: Communications; 7 employers, 5,423 employees.
Sector: Transportation; 13 employers, 3,200 employees.
Sector: Other*; 2 employers, 1,835 employees.
Total: 28 employers, 15,732 employees.

New Brunswick
Sector: Banking; 6 employers, 2,722 employees.
Sector: Communications; 8 employers, 6,437 employees.
Sector: Transportation; 10 employers, 3,310 employees.
Sector: Other*; 0 employer, 0 employee.
Total: 24 employers, 12,469 employees.

Quebec
Sector: Banking; 14 employers, 31,378 employees.
Sector: Communications; 33 employers, 42,350 employees.
Sector: Transportation; 41 employers, 27,442 employees.
Sector: Other*; 9 employers, 2,454 employees.
Total: 97 employers, 103,624 employees.

Ontario
Sector: Banking; 13 employers, 88,180 employees.
Sector: Communications; 52 employers, 79,608 employees.
Sector: Transportation; 74 employers, 49,142 employees.
Sector: Other*; 30 employers, 35,088 employees.
Total: 169 employers, 252,018 employees.

Manitoba
Sector: Banking; 6 employers, 5,106 employees.
Sector: Communications; 12 employers, 7,399 employees.
Sector: Transportation; 20 employers, 12,020 employees.
Sector: Other*; 15 employers, 5,247 employees.
Total: 53 employers, 29,772 employees.

Saskatchewan
Sector: Banking; 5 employers, 4,207 employees.
Sector: Communications; 7 employers, 3,040 employees.
Sector: Transportation; 11 employers, 3,604 employees.
Sector: Other*; 9 employers, 5,003 employees.
Total: 32 employers, 15,854 employees.

Alberta
Sector: Banking; 8 employers, 13,970 employees.
Sector: Communications; 19 employers, 19,080 employees.
Sector: Transportation; 35 employers, 19,601 employees.
Sector: Other*; 11 employers, 5,543 employees.
Total: 73 employers, 58,194 employees.

British Columbia
Sector: Banking; 9 employers, 20,212 employees.
Sector: Communications; 21 employers, 23,504 employees.
Sector: Transportation; 37 employers, 27,368 employees.
Sector: Other*; 12 employers, 2,449 employees.
Total: 79 employers, 73,533 employees.

Northwest Territories
Sector: Banking; 2 employer, 78 employees.
Sector: Communications; 2 employers, 346 employees.
Sector: Transportation; 4 employers, 670 employees.
Sector: Other*; 0 employer, 0 employee.
Total: 8 employers, 1,094 employees.

Yukon
Sector: Banking; 2 employer, 74 employees.
Sector: Communications; 1 employer, 309 employees.
Sector: Transportation; 0 employer, 0 employee.
Sector: Other*; 0 employer, 0 employee.
Total: 3 employers, 383 employees.

Residual**
Sector: Banking; 1,055 employees.
Sector: Communications; 4,040 employees.
Sector: Transportation; 8,745 employees.
Sector: Other*; 3,195 employees.
Total: 17,035 employees.

Canada***
Sector: Banking; 18 employers, 174,133 employees.
Sector: Communications; 98 employers, 194,780 employees.
Sector: Transportation; 167 employers, 156,861 employees.
Sector: Other*; 50 employers, 60,814 employees.
Total: 333 employers, 586,588 employees.

Note:

* The "other" sub-sector includes such diverse industries as grain companies, uranium mines, nuclear power operations, credit corporations and museums.

** Employees for whom no detailed reports were filed since employers only have to report in those regions where they have at least 100 employees.

*** The number of employers reported by province and territory includes regional offices, which are not included in the "Canada" line.

Table 11
Private-Sector Organizations and Employees under Audit by Province and Sector

As of December 31, 1999

Newfoundland
Sector: Banking; 0 employer, 0 employee.
Sector: Communications; 0 employer, 0 employee.
Sector: Transportation; 2 employers, 223 employees.
Sector: Other*; 0 employer, 0 employee.
Total: 2 employers, 223 employees.

Prince Edward Island
Sector: Banking; 0 employer, 0 employee.
Sector: Communications; 0 employer, 0 employee.
Sector: Transportation; 0 employer, 0 employee.
Sector: Other*; 0 employer, 0 employee.
Total: 0 employer, 0 employee.

Nova Scotia
Sector: Banking; 0 employer, 0 employee.
Sector: Communications; 4 employers, 617 employees.
Sector: Transportation; 5 employers, 727 employees.
Sector: Other*; 3 employers, 1,968 employees.
Total: 12 employers, 3,312 employees.

New Brunswick
Sector: Banking; 0 employer, 0 employee.
Sector: Communications; 5 employers, 4,700 employees.
Sector: Transportation; 3 employers, 1,224 employees.
Sector: Other*; 0 employer, 0 employee.
Total: 8 employers, 5,924 employees.

Quebec
Sector: Banking; 5 employers, 2,944 employees.
Sector: Communications; 12 employers, 8,135 employees.
Sector: Transportation; 13 employers, 4,313 employees.
Sector: Other*; 4 employers, 969 employees.
Total: 34 employers, 16,361 employees.

Ontario
Sector: Banking; 5 employers, 2,883 employees.
Sector: Communications; 16 employers, 15,935 employees.
Sector: Transportation; 22 employers, 10,550 employees.
Sector: Other*; 9 employers, 6,879 employees.
Total: 52 employers, 36,247 employees.

Manitoba
Sector: Banking; 0 employer, 0 employee.
Sector: Communications; 4 employers, 950 employees.
Sector: Transportation; 5 employers, 1,369 employees.
Sector: Other*; 4 employers, 2,564 employees.
Total: 13 employers, 4,883 employees.

Saskatchewan
Sector: Banking; 0 employer, 0 employee.
Sector: Communications; 1 employer, 220 employees.
Sector: Transportation; 1 employer, 142 employees.
Sector: Other*; 3 employers, 3,226 employees.
Total: 5 employers, 3,588 employees.

Alberta
Sector: Banking; 1 employer, 370 employees.
Sector: Communications; 8 employers, 9,638 employees.
Sector: Transportation; 12 employers, 4,987 employees.
Sector: Other*; 3 employers, 916 employees.
Total: 24 employers, 15,911 employees.

British Columbia
Sector: Banking; 2 employers, 2,824 employees.
Sector: Communications; 7 employers, 12,400 employees.
Sector: Transportation; 11 employers, 9,200 employees.
Sector: Other*; 4 employers, 932 employees.
Total: 24 employers, 25,356 employees.

Northwest Territories
Sector: Banking; 0 employer, 0 employee.
Sector: Communications; 0 employer, 0 employee.
Sector: Transportation; 2 employers, 591 employees.
Sector: Other*; 0 employer, 0 employee.
Total: 2 employers, 591 employees.

Yukon
Sector: Banking; 0 employer, 0 employee.
Sector: Communications; 0 employer, 0 employee.
Sector: Transportation; 0 employer, 0 employee.
Sector: Other*; 0 employer, 0 employee.
Total: 0 employer, 0 employee.

Residual**
Sector: Banking; 429 employees.
Sector: Communications; 1,249 employees.
Sector: Transportation; 4,371 employees.
Sector: Other*; 876 employees.
Total: 6,925 employees.

Canada***
Sector: Banking; 7 employers, 9,450 employees.
Sector: Communications; 32 employers, 53,844 employees.
Sector: Transportation; 58 employers, 37,697 employees.
Sector: Other*; 16 employers, 18,330 employees.
Total: 113 employers, 119,321 employees.

Note:

* The "other" sub-sector includes such diverse industries as grain companies, uranium mines, nuclear power operations, credit corporations and museums.

** Employees for whom no detailed reports were filed since employers only have to report in those regions where they have at least 100 employees.

*** The number of employers reported by province and territory includes regional offices, which are not included in the "Canada" line.

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