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Thank you for the opportunity to come and speak to you today on behalf of HRSDC and the labour program.
The labour program administers the Canada Labour Code, which covers labour relations, which is part I, occupational health and safety, which is part II, and labour standards, which is part III, for federally regulated, private sector employers. For part II, it's important to note that we have extended jurisdiction and we also cover the federal public sector, while for parts I and III we do not.
Today I want to focus my opening remarks on how occupational health and safety regulations and labour standards obligations address sexual harassment concerns in the workplace. Both occupational health and safety and labour standard obligations are a shared responsibility between the labour program and employers. That's an important point.
The labour program sets the legislative and regulatory framework for employer policies. We educate workplace parties, and we enforce the Canada Labour Code requirements via inspections and handling of complaints. Employers are responsible for complying with the requirements of the code and for administering workplace policy. In this case it's the policies that address violence in the workplace and sexual harassment. This includes investigating and responding to incidents of violence in the workplace, as well as allegations of sexual harassment.
With regard to occupational health and safety, the Canada occupational health and safety regulations, which were introduced in 2008, establish a regulatory framework for violence prevention in the workplace. They apply to federally regulated workplaces, including the federal public sector. In the case of the federal public service, the Treasury Board policy on harassment prevention and resolution incorporates these regulations by reference. I understand that Treasury Board witnesses were in front of the committee last week, so I know you've heard from them about their policy.
Workplace violence is defined as “any action, conduct, threat or gesture of a person towards an employee in their workplace that can reasonably be expected to cause harm, injury or illness to that employee”. While this policy requirement has a broader application to address bullying and other types of aggressive behaviour in the workplace, it can also be applied to sexual harassment toward an employee.
In establishing a violence prevention program, an employer must consult with it's workplace health and safety committee, which comprises employee representatives, and assess the workplace to determine the potential workplace violence issues. The workplace violence program does not need to address sexual harassment specifically and focuses more broadly on all forms of workplace violence.
In addition, each employer must develop and post a workplace violence prevention policy. This should include a commitment to providing a violence-free workplace and a statement that bullying, teasing, and abuse and other aggressive behaviour will not be tolerated; an indication that the employer will share any information concerning the factors that contribute to workplace violence; assistance for employees who've been exposed to workplace violence; and finally, procedures to follow should an employee be subject to workplace violence.
Employees also have a responsibility in creating and sustaining a violence-free workplace. They're to report cases of violence to the employer, who's responsible for recording and investigating the act of violence. It goes without saying that they must abstain from violence or be subject to disciplinary actions.
It's important to know that part II of the code does not require employers to inform the labour program of any employee complaints of violence in the workplace, including sexual harassment. They're responsible for dealing with any such complaint, and should employees not be satisfied with the results of the employer's investigation, then they can file a complaint with the Canadian Human Rights Commission, which I understand also presented in front of the committee last week.
I'll now turn to part III of the code, which establishes an employee's right to employment free of sexual harassment and requires employers to prevent sexual harassment in the workplace. This applies to federally regulated workplaces, but does not cover the public sector.
In comparison with the federal public service, federally regulated workplaces are required to have a policy that addresses sexual harassment specifically, while the Treasury Board policy on harassment prevention and resolution addresses all types of harassment.
The code defines “sexual harassment” as:
any conduct, comment, gesture or contact of a sexual nature
(a) that is likely to cause offence or humiliation to any employee; or
(b) that might, on reasonable grounds, be perceived by that employee as placing a condition of a sexual nature on employment or on any opportunity for training or promotion.
Every employer, after consulting with employees and their representatives, must issue and post a policy on sexual harassment. The policy must contain the definition of “sexual harassment”, a statement entitling employees to employment free of sexual harassment, a statement specifying the employee will make every reasonable effort to prevent sexual harassment, a statement confirming that the employee will take appropriate disciplinary measures against any person who subjects any employee to sexual harassment, a statement explaining how complaints of sexual harassment may be brought to the employer's attention, a confidentiality statement, and a statement informing employees of their rights to seek redress under the discriminatory practices provisions of the Canadian Human Rights Act.
The compliance activities under the code with respect to both sexual harassment and violence prevention in the workplace range from proactive counselling and inspections to reactive investigations of employees' complaints, and finally, as a last recourse, to prosecutions.
The labour program utilizes inspections as one of the program activities to ensure employers' compliance. In cases where violations are noted by the inspector, employees are encouraged to voluntarily comply through education and counselling.
Under part II of the code, a labour program officer may direct an employer to comply with the regulatory requirements for a violence prevention program. In accordance with provisions of part II of the code, an employee may submit a complaint to their employer using the internal complaint resolution process, which promotes the internal resolution of complaints by the workplace parties. Only unresolved issues with respect to the implementation of the violence prevention program would be reported to the labour program for investigation.
Under part III of the code, an employee may file a complaint with the labour program alleging that the employer has not developed or posted a sexual harassment policy in the workplace. The complaint would be investigated and all attempts would be made to educate and counsel the employer with the goal of obtaining voluntary compliance.
Under both parts II and III of the code, individual complaints of sexual harassment are referred to the Canadian Human Rights Commission to be addressed under the discriminatory practices provisions of the Canadian Human Rights Act, as they are the primary authority to address discrimination in the workplace.
The labour program has received some complaints where employers were not compliant with the violence prevention regulations and sexual harassment provisions of the code. These mostly related to the lack of policies, and in all cases, employers were able to correct the situation and comply with the code.
Over the last five years, from 2007 to 2012, the labour program received only two complaints with respect to sexual harassment provisions under part III of the code, and both complaints were unfounded.
In conclusion, the labour program strives to create Canadian workplaces where trust and respect for everyone are the norm. We're committed to protecting the fundamental right of workers and employers to work in an environment that is safe and free of violence and sexual harassment.
I'd first like to thank the committee for allowing me to appear by video conference. It's much appreciated.
I am the chair of the Canada Industrial Relations Board, which is responsible for the administration, interpretation, and enforcement of part I of the Canada Labour Code. Part I governs the relationship between unions and employers in the federally regulated private sector.
Ms. Cyr has already given you an indication of what that federally regulated private sector encompasses.
Under part I, the board hears applications related to the acquisition and termination of bargaining rights, unfair labour practice complaints, and the maintenance of activities that are essential to public health and safety in the event of a work stoppage.
We very rarely hear any cases directly related to harassment of any kind, let alone sexual harassment. The only way in which those cases tend to come before the board is in respect to an obligation that unions have under the code to fairly represent all of the employees in a bargaining unit. The union is obliged to act in a manner that is not discriminatory, in bad faith, or arbitrary.
I had a survey done of the cases since the amendments to the Canada Labour Code—
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Thank you, Madame Morin.
Again, thank you to the committee for allowing me to appear by video conference, but I regret the difficulties that have occasioned for the committee.
To reiterate, I'm the chair of the Canada Industrial Relations Board, which is the body responsible for the interpretation and enforcement of part I of the Canada Labour Code. Part I deals with such matters as the acquisition and termination of bargaining rights, unfair labour practices, and the maintenance of activities that are essential for public health and safety in the event of a work stoppage.
Our duties mainly revolve around the relationships between unions and employers. It's very rare that we would have a case involving harassment or sexual harassment coming in front of the board. Those kinds of complaints may, and very rarely do, come to us peripherally, as part of a complaint against a union that would be filed under the duty of fair representation provision of the code. That section of the code requires unions to act in a manner that is not arbitrary, discriminatory, or in bad faith with respect to their representation of the employees vis-à-vis their rights under a collective agreement.
I caused a study to be done of the jurisprudence of the board over the last dozen years or so. We were only able to find about 30 cases where an individual had complained about the way their union behaved with respect to allegations of sexual harassment. Interestingly enough, the majority of those complaints were from the harasser, who was complaining that the union didn't do enough to defend him or her against the allegations of harassment.
There are some cases where an individual who was harassed complained that the union wasn't doing enough to represent them, and of course those are the kinds of cases that the board would hear and determine.
As I said, though, it's very rare that we have any involvement whatsoever in the subject matter of your inquiry.
I'm quite prepared to take any questions you may have.
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The employer has the responsibility to educate their employees on acceptable behaviour in the workplace. The responsibilities are a little bit different under part II than under part III, so I'll present them separately.
Under part II, the occupational health and safety component, in accordance with the violence prevention regulations, all employees in a workplace unit must receive training from their employer in any skills that would allow them to identify, prevent, or avoid any workplace violence. That can include sexual harassment, as I mentioned earlier.
The employer must provide employees with the information, the guidelines, and the training at least every three years, as a minimum. That's in the legislation.
Training and education are essential when we strive to have a workplace that is free from violence and sexual harassment.
Under part III, the employer is responsible for providing a workplace that's free from sexual harassment. I defined that earlier in my presentation. The employer has to make every reasonable effort to maintain a workplace that is free of sexual harassment, and that often involves ensuring through their policy that they can provide the right information and the right training to their employees.
With respect to what the labour program's responsibilities are, we provide education and counselling to the federally regulated employers, either upon an employee's request to do so or as part of our duty to inspect the workplaces. During our inspections, the officers will explain the requirements of the regulations, and will share the available tools, such as pamphlets, which can provide an overview of the provisions in question. In some instances, we have what we call IPGs, interpretation, policies and guidelines documents. If we have them, these are brought to the attention of the employer to comply with.
As an example, under violence prevention, the labour program has created a guide, which is on our website and which I'll be happy to provide a link to, that is meant to assist employers, members of a policy or workplace committee, and health and safety representatives in preventing violence in the workplace. The guide outlines very practical procedures, almost like a step-by-step of how to comply with the requirements of the code, so that they can follow those instructions in implementing the prescribed steps for the prevention of violence. It includes the step of providing employee training and education.
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That's part of the follow-up we do, as I mentioned earlier. We will do a proactive follow-up. It's what we call the inspections. We go into the workplace and ensure that the employers are compliant with the requirements of the code.
We can go into the workplace and look at a variety of things. It doesn't necessarily mean that our visits are targeted only to violence prevention. We might be going there for something else and would look at the violence prevention at the same time.
We have those follow-ups, and we ensure that, indeed, the policy statements and the definitions, all of these things, are aligned with the provisions of the code, either part III for sexual harassment, or violence prevention in part II. If they're not, this is where we play our education and counselling role. We work with employers.
Generally speaking, we are successful through what we call an assurance of voluntary compliance, AVCs, where they voluntarily agree to comply with that. After that agreement, we will do a follow-up, or they will be asked to send us whatever is lacking or whatever needs to be redressed.
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Yes, because I would find it difficult, when you talk about violence in the workplace and then you try to tie that in to sexual harassment, to see how people would view that.
It seems to me that your mandate really needs a very serious update to better reflect some of the challenges we're facing out there today, specifically for women, and the whole bullying and intimidation issues that aren't violence, as you would call violence in the workplace, but are intimidation and so on. A recommendation that I think the committee might want to make is that you update that. Certainly, it doesn't gel with the numbers we heard from Treasury Board as to what's really happening in various departments and agencies.
One of the smaller agencies we heard about had a 51% complaint ratio, yet none of them got to you. I guess that's not your role, unless the employers are going to come to you, and you've only had two complaints. I find it alarming. I mean, I don't want you to have a whole lot of complaints. I like to think of the federal service as being terrific, which it is, but any huge employer will have lots of challenges, and there are those that are unwarranted complaints. We all know about them, but there are lots of other complaints out there that are clearly warranted. I think if 5% come forward with complaints, it's probable there are 8% or 9% more that could. However, people do not jump into filing complaints against their employer easily. I think there has to be a very serious issue because, right off the bat, you know there is going to be an issue to do with your job future, no matter how much protection we might put down.
Everything sounds wonderful and reassuring in your policies. All the right words are there. We heard all the right words from Treasury Board last week, and yet there is still an alarming number of people coming forward. If 29% come forward, then there's another significant amount that aren't coming forward. It's a bit concerning as we move forward on this in trying to create that culture where people feel comfortable in an environment, because they would be more successful in their jobs if they felt more comfortable. You really don't cover that off when you talk about violence in the workplace.
By way of introduction, my name is Christopher Rootham. I've been practising labour and employment law in the private sector for approximately 10 years. I'm also a lecturer and professor of labour law at Queen's and the University of Ottawa. I've written extensively about human rights, labour and employment law, particularly with an emphasis on the federal public service. I would like to confine my introductory remarks to dealing with the question of recourse available to the victims of sexual harassment within the public service.
In my view, there are five essential characteristics of an effective system of recourse. It must be expeditious, because justice delayed is justice denied. It must be procedurally fair, including the opportunity to be heard by an impartial decision-maker. There must be expertise by the decision-maker. There should be broad acceptance of that decision-maker within the community. There should be effective redress at the end of that recourse mechanism—can the system right the wrong?
In the federal public service there are at least five different systems of recourse that could be used by a victim of sexual harassment, depending on the circumstances of that harassment. A victim could file a sexual harassment complaint by policy, either Treasury Board's policy or a policy in place at a separate agency or separate employer. The victim could file a grievance under the Public Service Labour Relations Act. The victim could file a complaint with the Public Service Staffing Tribunal or the Public Service Commission, if the complaint refers to sexual harassment in an appointment process in the core public administration. A victim could file a complaint with the Public Sector Integrity Commissioner or with the Canadian Human Rights Commission.
The first difficulty with this system is the sheer number of different recourse mechanisms available. This leads to confusion, overlap of functions, and inefficiencies because of duplication, or alternatively, passing the buck, as victims are passed from jurisdiction to jurisdiction in an effort to find someone who will take control or take jurisdiction over their matter.
There are also difficulties within or about each of the particular systems. With respect to a sexual harassment complaint, there are three difficulties I'd like to bring to your attention. First, a sexual harassment complaint is not available to the victims of harassment if they have already grieved or attempted to use some other method of recourse. Second, there's no requirement under the policy to provide redress to the victim. The policy talks about corrective measures to address what to do with the perpetrators of the harassment, but not to talk about what to do for the victims. Third and finally, there's no requirement that the deputy head or the deputy minister agree with or implement the recommendations of the investigator.
With respect to the grievance system, there are two categories of grievances in the federal public service: grievances that can be referred to adjudication, which is independent third party resolution; and grievances that cannot be referred to adjudication, which are finally decided by the deputy head or his or her delegate.
Grievances can be referred to adjudication if they are about discipline or if they are about collective agreement violations. For those employees who are represented by a bargaining agent who has successfully negotiated a sexual harassment clause into their collective agreement, the grievance may be referred to adjudication. The grievances of unrepresented employees or employees whose bargaining agents have not negotiated sexual harassment clauses are finally decided by the deputy minister alone.
If the matter is not referred to adjudication, this is not a truly impartial hearing for unrepresented employees or for certain represented employees, particularly with respect to the remedy. Is a deputy head expected to award damages to the victims of sexual harassment or career assistance that costs money, or other remedies with a financial consequence when this money is going to be taken out of their budget for other priorities? Further, deputy heads have no expertise in assessing damages. They have no expertise in adjudicating. Their expertise is in management, in program administration; it's not in remedying the effects of sexual harassment.
Another category of recourse is to the Public Service Staffing Tribunal or the Public Service Commission. This deals with only a limited number of cases, if the harassment occurred in the context of an appointment process to the core public administration, to Treasury Board. There are limited remedies in that case, because the complaint is only about that staffing action.
A victim could file a complaint with the Public Sector Integrity Commissioner. However, the Public Servants Disclosure Protection Act permits the commissioner to refuse to investigate a complaint of sexual harassment on the grounds that there is another method of recourse available. Frankly, we're in early days with the Public Sector Integrity Commissioner in terms of learning how they're going to deal with complaints of sexual harassment. We simply don't know if that is going to be an effective recourse.
Finally, a federal public servant could file a complaint with the Canadian Human Rights Commission. The Canadian Human Rights Commission, as you're aware, is a gateway to get to a tribunal. The commission does not make decisions. The commission screens complaints. Only approximately 9% of cases or complaints filed with the commission make their way to a tribunal.
The commission can refuse to refer a complaint of sexual harassment to the tribunal for a number of reasons. One of them is that paragraph 41(1)(a) of the Canadian Human Rights Act permits the commission to refuse to investigate a complaint on the grounds that it should be dealt with in another method of recourse. Both legally and experientially, I can tell you that the commission routinely refuses to investigate complaints of sexual harassment in the federal public service because those victims should be going to grievance or through Treasury Board's harassment policy.
Also, the commission can refuse to refer a complaint to the tribunal if, in its opinion, an offer to settle has been made to the victim and the victim should have accepted it. This is a valid complaint where the commission concludes there is merit to the complaint, and yet the commission refuses to allow it to proceed to the tribunal. This instead forces the complainant to accept a settlement.
The Canadian Human Rights Commission can be slow in many cases. It takes an average of nine months for the commission to investigate its complaints. That does not include the complaints that are dismissed expeditiously because they're in the wrong forum or wrong jurisdiction, or they should go to another forum. The complaints that are valid often take longer than nine months to investigate. That does not take into account the fact that if the result of the investigation by the Canadian Human Rights Commission is that the matter is referred to a tribunal, you're looking at another nine to ten months in order to complete a hearing in front of the tribunal.
Finally, the human rights system has the authority to grant substantial remedies for the victims of harassment, but there is one hole in that legislation; namely, that the Canadian Human Rights Tribunal has no jurisdiction to award legal costs to a victim of harassment. That was set out in the Supreme Court of Canada decision in Mowat, which involved an employee who was sexually harassed in the workplace. The tribunal awarded her $4,000 in damages, but that did not go anywhere near to meeting the legal expenses she incurred, because she retained private counsel.
The concern is that victims are not accessing these particular forms of recourse because of the flaws in them, because there's no true remedy at the end of the day, and because the expenses of pursuing the matter would outweigh any possible recovery.
In conclusion, I suggest that one way to protect the victims of sexual harassment would be to carefully examine the systems of recourse to ensure that there is expeditious, effective, and fair recourse available to the victims of sexual harassment.
In the time allotted what I would like to do is confine my remarks to three general areas. First, I'd like to speak about where I fit into this process of sexual harassment prevention and resolution. Second, I'd like to speak very briefly about the Treasury Board of Canada’s new harassment policy and highlight some differences I see in comparison with the old policy. Third, I have some practical experience and some issues I'd like to bring to your attention and perhaps provide some advice for the future by way of concluding remarks.
First of all, I will start with a brief description of who I am and how I fit in. I am a lawyer by training and experience. I was called to the Bar of Ontario in 1989. I had a traditional law practice in the past, but I no longer have a traditional law practice. It now consists almost exclusively of alternative dispute resolution, or what we call ADR. This consists of mediation, arbitration, workplace facilitation, and investigation work.
I am regularly called upon to investigate harassment complaints within federal government departments, agencies, boards, and tribunals. I have investigated wrongdoing, including sexual harassment, by lower level employees,all the way up to some of the highest levels in the public service and its related organizations. In other words, I fit in near the end of the process. Once the complaint has been submitted and vetted by human resources officials, once the parties have been notified, once there is a level of dysfunction already in the workplace, and once informal resolution has failed, that’s when I come in. My perspective is somewhat narrow. It is not that of a theorist or academic; it's that of a practitioner.
My investigation work is typically carried out pursuant to organizational harassment policies, most often the Treasury Board policy. As the committee now knows from hearing from Treasury Board officials, the Treasury Board just released its new harassment policy, “Policy on Harassment Prevention and Resolution”, which was made effective October 1, 2012. This replaces the old policy, which had not been revised since 2001. They are similar, but there are some notable differences. As you will see, the name change reflects one of the key features of this new policy.
The formation of this new policy was no doubt a major undertaking and a positive development, in my view, to deal with harassment in the workplace. There are a number of documents and guides which I understand are still under development. I think we all need to see how the policy is applied in practice before we pass judgment on its effectiveness.
Let's start with the new policy versus the old policy. Like most of you, I have not had a chance to do an extensive review, but I have looked at it as carefully as I could have within the last few days. A number of related documents, as I said earlier, still have yet to be released. I will highlight a couple of key features.
One item is scope. The new policy specifically includes harassment outside the workplace, including travel locations, conferences, training, and informational sessions. As long as these outside locations are related to the workplace, a harassment complaint can be made.
Another is the harassment definition. The difference between the old and new definition is the idea that harassment can take place outside the traditional workplace. Finally and importantly, with respect to the new harassment definition, there used to be guides contained right in the definition itself with respect to what may or may not constitute harassment. Those are no longer there. Those may come out with some of these guides and other documents, as I indicated that Treasury Board is currently working on, but I don't see them in the current harassment definition. I don't think that's a critical problem. However, it was certainly useful to enable investigators and the parties to a harassment complaint to get a better understanding of what is inside and outside the lines of harassment.
Manager's obligations is the third key feature that I see as a difference between the old and new policy. Again, this may show up in some of the further documents that Treasury Board is developing.
The old policy had a section entitled “Expectations”. It discussed the expectations placed upon employees, parties to the harassment complaint, and managers. This, as I said, apparently no longer exists. One of the main features of this, which I had relied on a number of times in doing my work, was an obligation on the part of the manager to independently authorize an investigation where the manager becomes aware of alleged harassment in the absence of a formal complaint.
By way of example, I have investigated a matter involving sexual harassment where the manager was accused of failing to intervene even though there was no complaint filed. I determined in that case that there had been a failure by the manager to sufficiently act upon the allegations. I hope and expect there will be a way to authorize investigations independently in the absence of a harassment complaint, and that obligation or that capacity will be given to the manager or the delegated manager.
Currently, the new policy seems more focused on the responsibilities of the deputy head, as I read it, rather than those of the individual manager. Again, we do need to suspend judgment until some of these other documents are released.
I can bring some practical concerns and issues to your attention. As I said, I'm not a theorist or an academic. I do quite a bit of teaching, and I've certainly spoken on harassment a number of times. I don't bring to you statistics; I bring practical experience. The vast majority of investigations that I've performed have involved harassment in the form of misconduct or abuse of authority, but not sexual harassment. There have only been a handful of those. Why is this? Are there simply fewer cases of sexual harassment than we imagine? Are we now in an improved society where people better understand what sexual harassment is and how to better comport themselves in the workplace, or is sexual harassment under-reported? My answer is it's a bit of both.
I cannot give you statistics, as I said, but I can tell you that based on the cases that I've investigated, incidents of sexual harassment in my view are probably under-reported. I can think of two major investigations that I undertook that provided me with some insight into this problem.
One case involved the alleged failure of a senior manager to intervene—I mentioned this earlier—when the manager became aware of potential harassment in the workplace. A number of women were subjected to alleged sexual harassment by an employee who was under that manager's direction. None of the women filed complaints. What surprised me, frankly, was that based on the evidence that I gathered, it was obvious to me that each was fearful of the employee's close relationship with that senior manager. No one wanted to make waves. None of the women, in my view, wanted to be ostracized or have their careers adversely affected.
Another case involved sexually inappropriate remarks and physical touching alleged against a senior male official by a female colleague who was essentially at the same seniority level. She, too, would not file a complaint. Instead, she reported her concerns to management, which appropriately authorized an investigation. I did that investigation. She was adamantly opposed, and this surprised me. I was surprised to learn how fearful she was to come forward even though this colleague was effectively at the same level. What also astounded me was that during the course of my interviews, including interviews with some senior women who also worked in the same office, they too experienced unwanted sexual advances and touching by the same individual. There were others I found out about through hearsay evidence who also experienced this. None of these people came forward. Every one of them was reluctant to come forward.
I said at the beginning of this process that I come in near the end. What this tells me about sexual harassment, just from anecdotal experience, is that it often goes unreported and unchecked, notwithstanding the existence of good policy, and notwithstanding the existence of good managers. At the very end of the process, management has to decide what to do once there is a sexual harassment complaint that has been founded. As I alluded to earlier, there are cases where the manager has inadequately dealt with the situation. I believe that too often there is an ineffectual follow-up once the investigation is completed.
I know this committee is concerned with recent allegations of sexual harassment within the RCMP. I've looked at the RCMP policy. I undertook an investigation, which did not involve sexual harassment but involved alleged harassment against some RCMP officers. I think they have a good policy. The policy that I have with me today is from 2008. It's actually much more specific and broader than the Treasury Board policy. It creates some really compelling obligations on management, on the employees, and on the parties to an investigation. Yet apparently we still have problems. As I said earlier, you can have good policy, good managers, and still have problems.
To both Mr. Gaon and Mr. Rootham, thank you so much for your information today. It helps to give us a handle on it to hear from people from the outside who deal with this. We can hear from all kinds of departments, but we're hearing the real stuff from both of you as far as the kind of work you do and what you've actually seen.
I have to say that I have great faith in our country and in our public service at all levels, because I think we're way ahead of a lot of countries. But even though we may be ahead, we still have significant issues.
If you don't change the culture of the environment people are working in, it's impossible, no matter how many rules there are. The RCMP's 2008 policy you referred to was a great policy. They've had huge problems, and so have many others, with acts that are under-reported. It's for a lot of reasons, and I'm not sure that the policies are going to change that. It's more to do with the culture and training.
I think the federal public service is an example of putting all kinds of things in place but still having the problems. Until we change the culture of organizations, I'm not sure we're going to be able to solve some of these issues. I'd like your comments.