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Sector-wide report
Summary
The Canadian Human Rights Commission is responsible for conducting compliance audits under the Employment Equity Act (EEA). The compliance audits examine the employment equity (EE) programs of federally regulated employers and assess their degree of compliance with the EEA. Since the Commission began its compliance audits in 1996, there has been noticeable progress in improving the representation of designated groups in the public service. However, some federal departments and agencies continue to face challenges in achieving equitable representation of designated groups, as well as systemic barriers to employment.
In 2020, the Commission launched a horizontal audit on the employment of racialized people in management and executive positions in the federal public service in light of discussions surrounding systemic employment barriers faced by racialized people in the public service. In January 2021, the Clerk of the Privy Council and Secretary to the Cabinet released the Call to Action on Anti-Racism, Equity and Inclusion in the Federal Public urging leaders in the public service to implement tangible measures that will lead to systemic change. The significance of the horizontal audit launched in the public service was reinforced by the Call to Action, as the audit offered valuable insights into the EE policies and practices currently in place within the public service.
The Commission recognizes that our ability to advance and enforce EE is limited to the current legislative obligations outlined in the EEA. In its submission to the EEA Review Task Force in April 2022, the Commission strongly encouraged the Task Force to be bold and embed progressive changes with concrete recommendations to modernize the EEA such as: adopting more robust compliance and enforcement functions relating to monitoring and accountability, redefining and disaggregating designated groups to respond to particular circumstances and needs of impacted groups, and enhancing data collection methods and tools to gather better qualitative and quantitative data on designated group members. The Commission continues to advocate for legislative reform and has actively participated in consultations led by the Labour Program under Employment and Social Development Canada (ESDC).
The Commission's audit powers derive from legislation and are therefore limited to the groups presently designated in the EEA. This report therefore details the general findings of the horizontal audit on the employment of racialized people in management and executive positions in the public service. Overall, the horizontal audit found that the representation of racialized people in executive positions in the federal public service is broadly in line with their workforce availability. However, this does not include the representation of racialized people in management positions and does not disaggregate racialized people. This audit's findings point to the fact that there are still important areas within a lot of departments and agencies where more work needs to be done to remove employment barriers for racialized people.
Key findings:
- 46 departments and agencies were asked to complete a self-assessment survey as part of the horizontal audit. From this pool of 46, 18 departments and agencies were selected for audits of their EE program. Only two of the 18 departments and agencies met the requirements of the horizontal audit. This confirms that there is still important work to conduct in the public service to ensure EE compliance.
- While the representation of racialized people in executive positions is broadly in line with workforce availability across the federal public service, the representation rates among different departments and agencies vary greatly, from exceeding the workforce availability, to only meeting 50% of it.
- The representation for racialized people in management positions could not be fully assessed since the human resources systems in the federal public service do not allow for the differentiation between managers and supervisors. However, some departments and agencies have put EE measures in place in their organization to monitor the representation of racialized people in positions which would be considered to be managerial.
- The audit revealed significant issues regarding employers' EE programs during both phases of the audit process:
- The surveys collected in Phase I showed that 63.6% of the departments and agencies that conducted an employment systems review (ESR) identified barriers to hiring or promoting racialized people to management or executive positions.
- The survey findings also showed that only a limited number of departments and agencies had done the necessary work to establish a valid EE plan. While 93.5% of surveyed departments and agencies indicated that they have an EE plan, only 11.1% of those audited had an EE plan that met the requirements of the legislation and 28.3% stated that they never conducted an ESR, which is a necessary precursor to having a valid EE plan.
- Throughout the course of the individual audits (Phase II), several more employment barriers were identified. The most frequently identified barriers were in recruitment strategies, selection processes, hiring decisions, career development, and workplace culture.
- The individual audits also revealed a lack of engagement from organizations to fully understand the employment barriers faced by racialized people, EE plans that lacked concrete measures to address employment barriers or to prevent them from occurring, and unclear accountability and monitoring frameworks to address EE related matters to ensure progress.
As the largest employer in the country, with a workforce of over 300,000 employees, the federal public service has a great opportunity to lead the way in ensuring that its departments and agencies meet their EE obligations and responsibilities under the EEA. We all play crucial roles in making this happen. Therefore, it is important to go beyond the requirements of the EEA and avoid resorting to quick fixes and, instead, put in place effective long-term commitments towards EE.
The Commission will continue to monitor EE progress in the public service by conducting follow-up audits.
1. Introduction
The Canadian Human Rights Commission is responsible for conducting EE compliance audits under the EEA. Following the 1995 amendment of the EEA, the Commission began conducting conventional audits and has since introduced horizontal audits and blitz audits.
In 2020, the Commission launched the horizontal audit on the employment of racialized people in management and executive positions in the public service. The pool of employers for this audit consisted of departments and agencies in the federal public service with over 500 employees. The horizontal audit focused on systemic issues faced by racialized people in management and executive positions in the public service and assessed the employers' compliance with the nine requirements of the EEA. In this horizontal audit, these nine requirements were grouped into themes called lines of inquiry. This audit report summarizes and provides an analysis of the collective findings of this horizontal audit.
1.1 The Employment Equity Act
The purpose of the EEA is to achieve equality in the workplace so that no one shall be denied employment opportunities or benefits for reasons unrelated to their ability; to correct areas of disadvantage in employment experienced by women, Aboriginal peoples (Indigenous people), people with disabilities, and members of visible minorities (racialized people) by taking concrete actions to ensure their full representation in the workforce. The EEA endeavours to do more than simply treating everyone in the same way and instead mandates employers to identify and address employment areas that require special measures and/or accommodation of differences.
The EEA applies to federally regulated employers, with 100 employees and more, in the private and public sectors, including crowns corporations. The EEA requires employers to eliminate barriers of employment that prevent members of designated groups from having equitable access to the labour market.
Under the EEA, federally regulated employers are required to comply with the following legislative requirements:
- Collect information about the representation of the four designated groups within the organization.
- Conduct a workforce analysis by comparing the representation of the four designated groups within the organization to labour market availability, or workforce availability in the public service.
- Review the organization's employment systems, policies and practices to identify barriers to employment opportunity for the four designated groups.
- Create an EE plan that specifies the policies, practices and measures that the organization will apply in the short term to remove the employment barriers.
- Implement the EE plan and measure results to ensure reasonable progress toward achieving EE within the organization.
- Review and revise the EE planperiodically.
- Share information with employees about EE.
- Consult and collaborate with employees' representative and/or bargaining agents (where applicable) on EE related matters.
- Maintain records about the organization's EE program.
1.2 The EEA Stakeholders in the Public Service
In order to better understand the role of the Commission in enforcing the obligations imposed on employers, it is important to recognize the role of key stakeholders to the EEA in the public service.
The role of Employment and Social Development Canada
ESDC serves as the administrator of the EEA and provides compliance guidance to employers under sections 18 to 20 of the EEA. Through its Labour Program, ESDC ensures that employers covered under the Legislated Employment Equity Program and the Federal Contractors Program understand the EEA and its EE Regulations so they can meet their legislative obligations.
The role of the Treasury Board of Canada Secretariat
The Office of the Chief Human Resources Officer of the Treasury Board of Canada Secretariat maintains a central data bank of EE self-identification data for employees of public service organizations. This office also calculates the representation and availability rates for employers, establishes classifications of positions, and provides directives to help implement EE in the public service under section 4 of the EEA. The president of the Treasury Board issues yearly reports to Parliament on EE in the public service.
The role of the Public Service Commission of Canada
Also, under section 4 of the EEA, through the Public Service Employment Act, the Public Service Commission of Canada develops federal public service policies for staffing and recruitment. It also has the authority to include membership in a designated EE group as a criterion for job opportunities. This approach can effectively address representation gaps in the public service and ensure that it reflects the diversity of the population it serves.
The role of the federal departments and agencies
Federally regulated departments and agencies are responsible for implementing an EE program in their workplace, and to comply with their legislative obligations under sections 5 to 18 of the EEA. To address any under-representation of designated groups, departments and agencies must analyze their workforce and review their employment systems in order to create an EE plan. These plans must be regularly reviewed, in consultation with employees' representatives, to ensure reasonable progress is achieved.
The role of the Canadian Human Rights Commission
The Canadian Human Rights Commission is responsible for the enforcement of the requirements imposed on federally regulated employers under sections 22 to 27 of the EEA. The Commission's EE Compliance Division conducts audits to assess federally regulated employers' compliance with the EEA. During its audits, the Commission considers the challenges faced by employers, recognizes their progress, and supports employers by issuing reports on their degree of compliance with the EEA requirements.
1.3 The Horizontal Audit
The purpose of the horizontal audit
The horizontal, or issue-based, audit examines systemic issues faced by members of one designated group in a specific sector. This approach allows the Commission to focus resources on persistent representation gaps in one designated group. It also seeks to better understand the situation and experiences of that designated group, while also using a diversity and leadership lens in order to promote higher representation in the organization.
The goals of the horizontal audit
- to better understand where in the employment process a designated group faces barriers to equitable representation within a particular sector
- to identify barriers to equitable representation in the workplace, as well as systemic issues
- to identify employment practices that attract and retain employees from a designated group
- to publish a report on the key findings of the horizontal audit to the public and share these positive practices beyond the federally regulated private and public sectors
For details on positive practices identified during the horizontal audit, consult sections 3.5 and 4.3 of this report, and for details on common barriers, consult sections 3.2 and 4.2 of this report.
The approach used during the horizontal audit
The Commission works collaboratively with employers to obtain information and supporting documentation on their EE programs and assess their compliance with the EEA. Throughout the horizontal audit process, the Commission uses an approach that is transparent, fair and understanding of employers' individual circumstances. However, the Commission can apply enforcement measures if it believes that an employer is not cooperating with the EE audit or is refusing to comply with the requirements of the EEA.
The horizontal audit process
- Step 1 – Notification (Phase I):
- The Commission notifies employers in the target sector of the horizontal audit and issues a survey to complete about their EE program.
- Step 2 – Selection of employers:
- The Commission selects a random sample of employers to undergo the horizontal audit process.
- Step 3 –Notification (Phase II):
- The Commission notifies the employers selected for audits and sends a submission index for them to complete and submit along with their supporting documentation.
- Step 4 –Assessment:
- The Commission's program auditors are assigned to the selected employers and assess each employer's submissions against the legislative requirements of the EEA (which are grouped into lines of inquiry for the horizontal audit). This step also involves presenting the horizontal audit process to the employer, conducting confidential interviews with a sample of the employer's staff and a possible on-site visit to the premises to validate the preliminary findings.
- Step 5 – Reporting:
- The program auditor prepares a confidential report detailing the audit findings, which is issued to the employer. Where there are areas of non-compliance with the lines of inquiry, the audit report includes a Management Action Plan (MAP) with remedial actions and associated deadlines.
- Step 6 – Monitoring of the MAP:
- For employers that had areas of non-compliance in their EE program and received a MAP, theprogram auditor assesses and validates the evidence submitted by the employer for the remedial actions outlined in the MAP and drafts an analysis of the evidence.
- Step 7 – Closure of the horizontal EE audit:
- Once the employer's MAP is completed, the Commission reviews the MAP, and if it is satisfied that the employer met all the outstanding lines of inquiry, the Commission informs the employer of the closure of the horizontal audit in writing.
- Step 8 – Sector-wide horizontal audit report:
- At the end of the horizontal audit process, the Commission publishes a report detailing the overall findings of the horizontal audit for the sector.
1.4 The Context for this horizontal audit
The Commission's 2018-2019 Departmental Plan adopted a modernized approach to EE audits through a horizontal audit model. This model aimed to identify systemic employment barriers, as well as highlight promising practices that support the increased representation and better retention of designated group members within a particular sector. Horizontal audits rotate between the various designated groups and the federally regulated sectors (i.e., banking, communications, public service, ground transportation, air transportation, water transportation, the service industry, and the production industry) to address employment barriers and representation gaps.
In 2020, the Commission launched the horizontal audit on the employment of racialized people in management and executive positions in the federal public service in light of discussions surrounding systemic employment barriers for racialized people in the public service. This horizontal audit sought to assess EE programs across the federal public service and to ensure that the federal public service takes concrete measures to improve the representation of racialized people in management and executive positions.
The Clerk of the Privy Council's Call to Action on Anti-Racism, Equity, and Inclusion, released in 2021, called on leaders to take practical actions to facilitate systemic change in federal institutions by appointing, sponsoring, supporting, and recruiting qualified Black, Indigenous, and other racialized employees into leadership roles. The importance of the horizontal audit launched in the public service was emphasized by the Call to Action. The audit would provide valuable information on the EE policies and practices in the public service and investigate the employment barriers faced by racialized people in management and executive positions.
2. Methodology
2.1 Phase one of the horizontal audit: A survey of the public service
During the first phase of the audit, the Commission distributed for completion an EE survey to 46 public service departments and agencies with over 500 employees. The survey aimed to gather information on the measures taken by each organization to identify employment barriers that impede the fair representation of racialized people in management and executive positions and ensure their representation in the public service. The responses to this survey were self-reported by each organization.
The survey included questions on six themes:
- Theme one: Knowing Your Workforce
- Theme two: Understanding Barriers Faced by Racialized People
- Theme three: Addressing Employment Barriers
- Theme four: Diversity Among Managers and Executives
- Theme five: Positive Practices
- Theme six: Accountability and Monitoring
2.2 Phase two of the horizontal audit: An audit of 18 departments and agencies from the public service
After compiling the survey results, the Commission selected 18 departments and agencies for an audit of their EE program. The number of employees in the 18 departments and agencies (referred to henceforth as "employers") totalled over 140,000. Compliance with the requirements of the EEA was considered using four lines of inquiry:
- Enabling your EE program
- Understanding employment barriers for racialized people
- Improving the representation of racialized people
- Designing an accountability framework
The Commission invited the 46 departments and agencies to an information session about the horizontal audit process. The selected employers were asked to submit information about their EE programs and to provide records as supporting evidence. The Commission's program auditors also conducted interviews with employees of the organization to validate initial findings based on the submitted information.
Where possible, program auditors interviewed a wide range of managers and employees, including racialized employees, senior and hiring managers, human resources personnel, members of EE committees or resource groups for racialized people, and local executive unions.
The interviews covered themes linked to employers' EE programs as they related to racialized people, including:
- the role of EE within the corporate culture
- barriers to recruitment, retention and career advancement of racialized people
- initiatives planned to inform and promote EE in the workplace
- how accountability and EE progress is measured
Program auditors assessed the information and prepared a confidential audit report for each employer. Two of the 18 employers selected for the horizontal audit met the requirements of the lines of inquiry. The audits for these two organizations were subsequently closed. For the other 16 employers, the audit report included a MAP with remedial actions required to comply with the requirements of the audit. The MAPs included deadlines for each remedial action. During the monitoring phase of the MAP, program auditors maintained communication with employers to address any questions, validate the evidence received and clarify expectations. Before closing the audit file, the Commission reviewed and evaluated the evidence submitted by the employer to ensure the MAP requirements were met.
3. Sector-wide Survey Results
The survey results for the entire public sector are categorized into six themes. Please note that the data in this section of the report is based on information provided directly by the 46 surveyed employers. The accuracy of this information has not been independently verified.
3.1 Theme one: Knowing your workforce
Conducting a self-identification survey
The EEA mandates that employers must identify representation of the four designated groups based on occupational groups, both in terms of the number of employees and as a percentage of the total workforce. The EEA also requires employers to conduct surveys among their employees to determine the levels of representation of designated groups. Employers can only count individuals who voluntarily self-identify as members of designated groups (consult EE Regulations, s. 3(6)a)). Employers cannot attribute or assign membership in a designated group to its employees. Instead, employers should proactively promote self-identification.
Employers can encourage higher return rates and rates of self-identification in several ways, including:
- making the return of surveys mandatory (consult EE Regulations, s. 3(7))
- communicating the importance of self-identification to employees (e.g., using an organization-wide email campaign to explain the purpose of EE and how the employer uses the collected data)
- implementing a follow-up strategy to reach employees who did not return the survey
Results from the sector-wide survey indicate that most employers have the proper self-identification systems and strategies in place. Among the employers surveyed, 95.7% (44 employers) have human resources management systems which enable employees to self-identify. 95.7% (44 employers) also have an ongoing approach to promote self-identification among racialized employees.
Chart 1 - Text version
A donut chart showing that 44 employers (95.7%) responded that their human resources management system enabled employees to identify their race, and two employers (4.3%) did not.
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Chart 2 - Text version
A donut chart showing that 44 employers (95.7%) responded that their organization has an ongoing approach to promote self-identification among racialized employees, and two employers (4.3%) did not.
To learn more about self-identification surveys and requirements of the EEA, consult the page: Collecting your workforce EE information.
Sharing the workforce analysis results
A workforce analysis shows the representation of each designated group by occupational group in an organization's workforce. It compares the levels of representation to workforce availability rates in order to determine the degree of under-representation.
An employer can encourage participation in its EE program by sharing the results of its workforce analysis with employees and managers (while suppressing data that might reveal the identity of specific employees). Making an organization's employees and managers (hiring managers, in particular) aware of gaps in the representation of racialized people at the management and executive levels can help them better understand the need to remove barriers, take corrective staffing action, and/or adopt special measures to correct areas of under-representation.
All employers surveyed communicate the results of the workforce analysis to executives and managers, while only 69.6% (32 employers) communicate the results to all employees.
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Chart 3 - Text version
A donut chart showing that 46 employers (100%) responded that their organization communicated the results of its workforce analysis to executives and managers.
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Chart 4 - Text version
A donut chart showing that 32 employers (69.6%) responded that their organization communicated the results of its workforce analysis to employees, and 14 employers (30.4%) did not.
For more information about conducting a Workforce Analysis, consult the page: Conducting a workforce analysis.
EE committee
The EEA requires employers to consult with employees' representatives regarding:
- the help that these representatives could provide to employers to implement EE in the workplace, including help with communicating to employees on matters relating to EE
- the preparation, implementation, and revision of the employer's EE plan (EEA, s. 15 and Communicating and consulting on EE)
An EE committee is an effective way for employers to understand their workforce better, and to meet the EEA's requirement to consult and collaborate with employees' representatives. These committees can also be a valuable resource to communicate EE information to the workforce, help identify employment barriers, suggest referral sources, and design special measures for under-represented designated groups. Having a representative from every designated group ensures that each group has a voice on the committee. Among the employers surveyed, 97.8% (45 employers) have an EE committee and 95.6% (43 employers) have racialized people on their committee.
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Chart 5 - Text version
A donut chart showing that 45 employers (97.8%) responded that they have a committee that is responsible for EE, and one employer (2.2%) did not.
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Chart 6 - Text version
A donut chart showing that 43 employers (95.6%) responded that there are racialized people on their EE committee, and two employers (4.4%) did not.
Overall, data collected in Theme one of the survey showed that most employers surveyed are taking the right steps by having self-identification strategies and EE committees in place. However, there is room for improvement when it comes to sharing workforce analysis results with all employees.
3.2 Theme two: Understanding employment barriers for racialized people
Employment systems review
The purpose of EE is to remove employment barriers for the four designated groups and to close any representation gaps. Barriers vary by designated group, by occupational group, and by workplace. The ESR is a tool for employers to understand the challenges faced by designated group members in their workplaces.
The ESR is an in-depth analysis of an organization's formal and informal employment systems, policies, and practices. The ESR considers attitudes, behaviours, and corporate culture. It must include direct consultation with members of under-represented designated groups. The ESR should focus on each significant representation gap identified in the workforce analysis. A thorough ESR is key to building an effective EE plan that complies with the EEA.
As workplaces change over time, the Commission recommends that employers conduct an ESR every three to five years. Among the employers surveyed, 50.0% (23 employers) conducted an ESR five or more years ago, while 28.3% (13 employers) had never conducted an ESR. Without a recent ESR, employment barriers may be overlooked, resulting in higher representation gaps.
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Chart 7 - Text version
A bar chart showing the elapsed time since the organization surveyed completed an ESR.
| Time since last ESR | Number of organizations |
|---|---|
| Less than a year ago | 1 |
| Two years ago | 3 |
| Three years ago | 4 |
| Four years ago | 2 |
| Five and more years ago | 23 |
| Never done an ESR | 13 |
Barriers to promotion for racialized people
Creating an equitable workplace requires employers to understand the barriers to employment faced by racialized people. To achieve true EE, it is essential to identify and remove these barriers, which can occur at any point in the hiring process and take many forms. Examples of barriers include selection processes, workplace culture (e.g., systemic racism, unconscious bias), lack of diverse hiring boards, second official language requirements, and lack of disaggregated data on designated groups.
Of the 33 employers who conducted an ESR, 63.6% (21 employers) identified barriers to hiring or promoting racialized people to management or executive positions.
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Chart 8 - Text version
A donut chart showing that 21 employers (63.6%) responded that their ESR identified barriers preventing racialized people from being hired into or promoted to manager or executive level positions, and 12 employers (36.4%) responded that their ESR had not identified barriers.
The top four frequently identified barriers for racialized people seeking management and executive positions were: recruitment strategies, selection processes, hiring decisions, and career development.However, there is an information gap in this data due to the employers who did not conduct an ESR to identify employment barriers.
| Barrier | Number of employers who reported this barrier |
|---|---|
| Recruitment strategies | 18 |
| Selection processes | 18 |
| Hiring decisions | 14 |
| Career development | 14 |
| Access to training | 12 |
| Lack of mentoring | 12 |
Overall, data collected in theme two of the survey showed that only a small portion of employers conducted an ESR in the three years prior to the horizontal audit. Many employers had no ESR or a dated ESR, which means that some employment barriers for racialized people may be unidentified and overlooked.
For more information on the ESR, consult the pages: EE Regulations, ss. 8 - 10 and Conducting an ESR.
3.3 Theme three: Addressing employment barriers
EE plan
The EEA requires employers to create an EE plan if they have representation gaps for members of designated groups (as identified in their workforce analysis). An EE plan is an action plan to remove employment barriers identified in an ESR, and to correct the under-representation of designated group members. Each item listed in an EE plan must have a timeline, a performance indicator, and a designated lead who is responsible for implementation.
Among the employers surveyed, 93.5% (43 employers) have an EE plan, and 83.7% of those 43 employers (36 employers) met the EEA requirement to consult with racialized employees during the development of their EE plan.
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Chart 9 - Text version
A donut chart showing that 43 employers (93.5%) responded that their organization has an EE plan, and three employers (6.5%) did not.
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Chart 10 - Text version
A donut chart showing that 36 employers (83.7%) responded that their organization consulted with racialized employees during the development of the EE plan, and seven employers (16.3%) did not.
Actions and Measures
The action items in an EE plan outline the steps the organization plans to take to remove the barriers identified in the ESR, such as revising job qualifications to consider a candidate's lived experience and developing and promoting a policy on flexible work arrangements. Although most employers reported having an EE plan, only 17.4% (eight employers) took steps to address all barriers identified during the ESR, while 23.9% (11 employers) took steps to address most barriers. 58.7% (27 employers) reported only addressing some barriers, none of the barriers or having no ESR or a dated ESR. Unaddressed employment barriers could result in wider gaps in representation for racialized people in management and executive positions.
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Chart 11 - Text version
A bar chart showing how many of the barriers identified in the organization's ESR they have taken action to eliminate.
| Extent barriers from ESR were addressed | Number of organizations |
|---|---|
| All of them | 8 |
| Most of them | 11 |
| Some of them | 10 |
| None | 1 |
| No ESR / Dated ESR | 16 |
Special measures
Special measures refer to the actions that an employer can take to increase the representation of a designated group where there is a persistent area of under-representation. The special measures can be programs, policies, or practices that apply to the under-represented designated group for a specific condition and a specific period of time. Only 46.5% (20 employers) reported that their EE plan contained special measures to increase the representation of racialized people in management and/or executive positions.
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Chart 12 - Text version
A donut chart showing that 20 employers (46.5%) responded that their organization's EE plan contains special measures to increase the representation of racialized people in either or both the management and executive levels, and 23 employers (53.5%) did not.
Overall, data collected in theme three of the survey showed that most employers surveyed have an EE plan and do consult racialized employees, as required by the EEA. However, there is room for improvement when it comes to putting this plan into action and addressing the barriers uncovered during the ESR.
For more information on the EE plan, consult the page: Creating your EE plan.
3.4 Theme four: Diversity among managers and executives
Succession planning
Succession planning can be a useful way to address gaps in representation, particularly at the middle and senior management levels. For succession planning to be effective, it is important to have a clear strategy in place that includes specific and measurable goals. The strategy may include setting numerical targets in the succession plan to improve the representation and career development for racialized people in senior management roles. It may also involve considering racialized candidates during external hiring processes.
Results from the sector-wide survey indicated that 45.6% (21 employers) identified racialized employees for executive positions within their organization. Yet only 21.7% (10 employers) offered mentoring and/or job shadowing of executives to racialized employees. This result indicates that commitment is present, but more action may be needed to achieve long-term results. Only 29.0% (nine employers) of the 31 employers with a succession plan incorporated strategies to hire external racialized candidates at the management or executive level.
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Chart 13 - Text version
A donut chart showing that 10 employers (21.7%) responded that their organization offers mentoring and/or job shadowing of executives that is targeted to racialized employees and/or managers, and 36 employers (78.3%) did not.
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Chart 14 - Text version
A donut chart showing that nine employers (29.0%) responded that their organization's succession plan includes strategies to hire qualified racialized candidates at the management and/or executive level from outside of the organization, and 22 employers (71.0%) did not.
Commitment to EE
The commitment from senior management is critical to the successful implementation of EE within an organization. Survey results revealed that 80.4% (37 employers) have a champion dedicated to increasing the representation of racialized people in management or executive positions. However, 71.7% (33 employers) only discuss increasing the representation of racialized people in management and executive positions semi-annually or annually.
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Chart 15 - Text version
A donut chart showing that 37 employers (80.4%) responded that their organization has a champion to increase the representation of racialized people as managers and/or executives within their organization, and nine employers (19.6%) did not.
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Chart 16 - Text version
A bar chart showing the frequency of discussions, at the senior management level, on increasing the representation of racialized people in manager and/or executive positions.
| Frequency of discussions | Number of organizations |
|---|---|
| Monthly | 2 |
| Quarterly | 10 |
| Semi-annually | 20 |
| Annually | 13 |
| Never discussed | 1 |
Overall, the data collected in theme four of the survey shows a clear commitment to EE is present within the surveyed organizations. However, there is room for improvement in terms of succession planning and ongoing discussions.
3.5 Theme five: Positive practices
The Commission asked surveyed employers to identify initiatives and/or actions which have helped them promote EE and work towards the equitable representation of racialized people in their workplaces. The top four results from the survey revealed that clear job advertisements, training on anti-harassment, and anti-discrimination/anti-harassment policies were the main practices and initiatives used by employers to promote EE.
| Area | Positive practice | % of employers surveyed |
|---|---|---|
| Recruitment | Your organization's job advertisements clearly outline essential job requirements. | 95.7% |
| Recruitment | Your advertising methods promote your organization's vision of a diverse workforce that specifically includes racialized people and is gender inclusive. | 80.4% |
| Training | Your organization offers employees training on anti-harassment. | 97.8% |
| Training | Your organization offers managers and executives training on anti-harassment. | 95.7% |
| Training | Your organization offers employees training on unconscious bias. | 87.0% |
| Promotion | Employee selection processes for promotion are transparent. The criteria for employee selection are available and accessible to everyone. | 89.1% |
| Retention and departures | Your organization has an anti-discrimination and anti-harassment policy. | 95.7% |
| Retention and departures | Your organization has a flexible leave policy that accommodates the cultural needs of racialized people. | 80.4% |
For more information on positive practices, consult the page: Implementing and monitoring your EE plan.
3.6 Theme six: Accountability and monitoring
To ensure an inclusive work environment, the EEA requires organizations to regularly monitor and assess the implementation and progress of their EE plan consult the page EEA, s. 12. Additionally, it is essential to designate a senior management representative who will be responsible for promoting EE within the organization. Results from the survey revealed that 74.4% (32 employers) have a mechanism to monitor measures in their EE plan targeted to racialized people. Additionally, 91.3% (42 employers) have a member of senior management who is held accountable for EE performance.
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Chart 17 - Text version
A donut chart showing that 32 employers (74.4%) responded that their organization has a mechanism to monitor measures in their EE plan related to racialized people, and 11 employers (25.6%) did not.
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Chart 18 - Text version
A donut chart showing that 42 employers (91.3%) responded that their organization has a member of senior management who is ultimately accountable for EE performance, and four employers (8.7%) did not.
4. Sector-wide audit results
Of the employers surveyed, the Commission selected 18 employers for full audits of their EE programs. The Commission requested that employers provide evidence of their compliance with the EEA requirements and submit relevant documentation about their EE programs. As part of the review phase of the EE horizontal audit process, auditors examined the submitted documents and conducted interviews with employees from various levels within the audited organizations to verify their compliance.
Auditors assessed each employer's compliance with the requirements of the EEA through four lines of inquiry:
- Enabling your EE program
- Understanding employment barriers for racialized people
- Improving the representation of racialized people in management and executive positions
- Designing an accountability framework
4.1 Line of inquiry one: Enabling your EE program
This line of inquiry examined the steps the employer took to ensure that its EE program would successfully support the employment and retention of racialized people. The Commission evaluated five sub-lines of inquiry to assess whether the employer:
- Defined the roles and responsibilities of senior and other managers with respect to the EE program
- Dedicated sufficient human and financial resources to facilitate the coordination of the EE program
- Established a monitoring framework that included a clear reporting mechanism for the EE program
- Communicated expectations and obligations to all managers and staff
- Produced a workforce analysis that showed gaps in representation by designated group and occupational group
Observations
Of the employers selected for full audits, 88.9% (16 employers) defined the roles and responsibilities of managers with respect to the EE program. 83.3% (15 employers) dedicated sufficient human and financial resources to facilitate and coordinate the EE program. For many of these employers, this included dedicated human resources staff for the EE program. However, several employers reported challenges with information exchange between these dedicated human resources staff and hiring managers.
Only 55.5% (10 employers) established a monitoring framework with a clear reporting mechanism for their EE program. A monitoring framework is essential for removing employment barriers and promoting greater representation of designated group members at all levels of an organization. It helps ensure the successful implementation of the EE program and allows employers to assess the program's effectiveness.
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Chart 19 - Text version
A bar chart showing the number of audited employers who met each sub-line of inquiry (1.1 to 1.5).
| Sub-lines of inquiry | Number of audited employers (Total= 18) |
|---|---|
| 1.1 Defining the roles and responsibilities of senior and other managers with respect to the EE program | 16 |
| 1.2 Dedicating sufficient human and financial resources to facilitate the coordination of the EE program | 15 |
| 1.3 Establishing a monitoring framework that includes a clear reporting mechanism for the employment equity program | 10 |
| 1.4 Communicating expectations and obligations to all managers and staff | 11 |
| 1.5 Producing a workforce analysis that shows gaps in representation by designated group and occupational group | 18 |
4.2 Line of inquiry two: Understanding employment barriers for racialized people
This line of inquiry focused on the need for the employer to have a thorough understanding of the employment barriers facing racialized employees, as well as the impact of those barriers. To assess this line of inquiry, the Commission examined the degree to which each employer had:
- Identified the occupational groups where barriers existfor racialized people based on a valid workforce analysis
- Conducted an ESR using a valid workforce analysis that focused on the occupational groups in which racialized people were under-represented
- Consulted with racialized people to identify possible barriers with respect to:
- recruitment, training, coaching, evaluation, promotion, discipline and termination practices
- work flow and procedures
- workplace climate and acceptance
- availability of accommodation
Observations
All 18 employers submitted a valid workforce analysis showing the representation gaps of racialized people by occupational group. However, only 22.2% (four employers) employers audited had recently conducted a valid ESR as required by the EEA, while 44.4% (eight employers) consulted with racialized employees to identify possible employment barriers. It should be noted that in the sector-wide survey (section 3.3), 83.7% of employers self-reported consulting with racialized employees during the development of their EE plan. This suggests that consultations may be taking place at a much higher rate in the public service overall than reflected in the 18 audited departments and agencies.
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Chart 20 - Text version
A bar chart showing the number of audited employers who met each sub-line of inquiry (2.1 to 2.3).
| Sub-lines of inquiry | Number of audited employers (Total= 18) |
|---|---|
| 2.1 Identifying the occupational groups where barriers exist for racialized people based on a valid workforce analysis | 18 |
| 2.2 Conducting an ESR using a valid workforce analysis that focuses on the occupational groups in which racialized people are under-represented | 4 |
| 2.3 Consulting with racialized employees to identify possible barriers with respect to EE | 8 |
Barriers to employment for racialized employees
Throughout the course of the horizontal audit, the 18 employers audited identified multiple employment barriers for racialized employees, particularly those seeking management and executive positions. The number of barriers reported by each employer ranged from three to 19, with an average of eight barriers per employer. The top four barriers most frequently identified were: selection processes, career development, hiring decisions, and workplace culture. It should be noted that in the sector-wide survey (section 3.2), the top four barriers most frequently reported by the 46 surveyed employers were: recruitment strategies, selection processes, hiring decisions, and career development. It appears that workplace culture may be a more prevalent barrier in the audited organizations, or employers may be more likely to under-report barriers related to workplace culture.
61.1% (11 employers) identified the selection processes as a barrier for racialized employees. The main challenges identified within the selection processes were the official languages requirement, and the lack of diversity within selection committees. 55.6% (10 employers) identified career development as a barrier, noting that racialized employees do not have the same opportunities for promotion as other employees.
50.0% (nine employers) identified hiring decisions as a barrier for racialized employees. The primary challenge with hiring decisions stemmed from unconscious bias, specifically favoring candidates who share ethnic or other similarities with the hiring manager or another authority figure.
44.4% (eight employers) identified the workplace culture as a barrier for racialized employees. Employers noted instances of micro-aggressions, discrimination, and harassment faced by racialized employees.
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Chart 21 - Text version
A bar chart showing the barriers identified by audited employers and the number of audited employers that identified each barrier.
| Barriers | Number of audited employers (Total= 18) |
|---|---|
| Selection processes | 11 |
| Career development | 10 |
| Hiring decisions | 9 |
| Workplace culture | 8 |
| Recruitment strategy | 7 |
| Lack of monitoring and engagement | 7 |
| Access to training | 7 |
| Lack of racialized role models and/or mentors | 6 |
| Lack of awareness of EE purposes and goals | 4 |
| Lack of consultation with racialized employees | 3 |
| Lack of accommodation | 3 |
| Lack of mentoring | 2 |
| Other | 5 |
4.3 Line of inquiry three: Improving the representation of racialized people in management and executive positions
This line of inquiry examined the employer's commitment to improving the representation of racialized people by creating an evidence-based action plan that contained numerical goals and initiatives to support those goals. The Commission evaluated whether the employer had:
- Created an evidence-based action plan that contained initiatives related to the employment of racialized employees in the organization, more specifically in management and executive positions
- Established strategies to hire racialized people to fill management and executive roles, where there was limited or no availability of internal candidates
- Developed plans for racialized employees identified through the internal succession planning process to ensure their capacity to compete for management positions
- Allocated sufficient resources to implement each element of the EE Plan
- Assigned a responsibility center, and established timelines and associated performance indicators for initiatives contained in the EE Plan
Observations
Only 11.1% (two employers) of those audited had a valid EE plan. It should be noted that 93.5% of employers surveyed self-reported having an EE plan (consult section 3.3 of this report). This indicates that although employers may have EE plans, these plans may not meet the requirements of the EEA. The audit also found that only 38.9% (seven employers) had established strategies to increase the representation of racialized people in management and executive positions in their respective workplaces either through external hiring or through internal succession planning.
While most audited employers have established their EE program (sub-lines of inquiry 1.1 to 1.5) and identified barriers for racialized employees (sub-line of inquiry 2.1), they have not taken the next step to create specific plans for increasing the representation of racialized people in management and executive positions.
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Chart 22 - Text version
A bar chart showing the number of audited employers who met each sub-line of inquiry (3.1 to 3.5).
| Sub-lines of inquiry | Number of audited employers (Total= 18) |
|---|---|
| 3.1 Creating a valid evidence-based action plan | 2 |
| 3.2 Establishing strategies to hire racialized people to fill management and executive roles where there is limited or no availability of internal candidates | 7 |
| 3.3 Developing plans for racialized employees identified through the internal succession planning process to ensure their capacity to compete for management positions | 7 |
| 3.4 Allocating sufficient resources to implement each element of the EE plan | 4 |
| 3.5 Assigning a responsibility centre, establishing timelines and associating performance indicators for initiatives contained in the EE plan | 4 |
Positive practices
The 18 employers audited identified various positive practices which help them move towards equitable representation of racialized people in their workplace and increase the representation of racialized people in management and executive positions. The number of positive practices reported by each employer ranged from five to 21, with an average of 9.4 positive practices per employer. The three most common types of positive practices were 1) recruitment methods, 2) monitoring of the EE program, and 3) training on unconscious bias.
77.8% (14 employers) identified positive recruitment practices which support the representation of racialized people in the applicant pool. These practices included: targeted recruitment of racialized people where there are representation gaps, prioritization of racialized employees in existing pools of candidates that have been found to meet the qualifications of a posting, and holding hiring managers accountable for EE hiring targets, when necessary, to ensure fair representation of racialized people.
66.7% (12 employers) identified positive practices related to monitoring their EE program. These practices included: reviewing the EE plan, embedding consultation with racialized employees in future reviews of policies, and strategies to increase self-identification rates.
55.6% (10 employers) identified training on unconscious bias as a positive practice. Approaches varied between employers; some established mandatory training on unconscious bias for hiring managers and members of selection committees, while others focused on providing tools to mitigate bias.
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Chart 23 - Text version
A bar chart showing the top 10 positive practices identified by audited employers and the number of audited employers that identified each positive practice.
| Positive practices | Number of audited employers (Total= 18) |
|---|---|
| Recruitment methods | 14 |
| Monitoring of EE program | 12 |
| Training on unconscious bias | 10 |
| Mentoring program for racialized employees | 7 |
| Communication of EE program goals and progress | 7 |
| Anti-discrimination and anti-harassment policy | 6 |
| Career development programs for racialized employees | 6 |
| Training on anti-harassment | 5 |
| Diversity training | 5 |
| Exit interviews | 5 |
4.4 Line of inquiry four: Designing an accountability framework
This line of inquiry examined whether the employer had a monitoring and accountability framework that incorporated clear indicators for evaluating the progress of the EE Plan. Employers had to demonstrate that they:
- Evaluated the effectiveness of each measure in the EE plan in terms of racialized people
- Established performance goals for hiring managers to help close gaps in representation for racialized people
- Conducted an annual analysis of reasonable progress in meeting the goals for racialized people by assessing the results against performance indicators in the plan
Observations
The audit found that only 16.7% (three employers) had EE plans that evaluated each measure on the effectiveness in increasing the representation of racialized people. 33.3% (six employers) established performance goals for hiring managers to close representation gaps for racialized people, and 22.2% (four employers) conducted an annual analysis to assess reasonable progress in meeting EE goals for racialized people. Collectively, the results from line of inquiry four show a continuation of what was observed in line of inquiry three. Most federal public service employers have not yet progressed past the initial establishment of an EE program and identification of barriers. Most federal public service employers audited do not know if the measures they set are effective, or if they are meeting their hiring goals with respect to racialized people in management and executive positions. This is due to employers either not having established measures and goals, or not evaluating the effectiveness of those measures and goals. To succeed, employers must regularly monitor and evaluate their EE programs to determine whether they are achieving their intended objectives.
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Chart 24 - Text version
A bar chart showing the number of audited employers that met each sub-line of inquiry (4.1 to 4.3).
| Sub-lines of inquiry | Number of audited employers (Total= 18) |
|---|---|
| 4.1 Evaluating the effectiveness of each measure in the EE plan in terms of racialized people | 3 |
| 4.2 Establishing performance goals for hiring managers to help close gaps in representation for racialized people | 6 |
| 4.3 Conducting an annual analysis of reasonable progress in meeting the goals for racialized people by assessing the results against performance indicators in the plan | 4 |
5. Benefits and challenges of the horizontal audit
The horizontal audit in the public service offered numerous insights into the sector and various benefits. The main benefits of the horizontal audit were:
- The increased compliance with the requirements of the EEA. The horizontal audit contributed positively to the representation of racialized people in management and executive positions in the public service by holding audited departments and agencies accountable for their EE programs. The audit also ensured that departments and agencies: provide evidence of conducting meaningful consultations with racialized employees and with employees' representatives, put concreate measures in their EE plans to address representation gaps in executive positions and in positions which would be considered to be managerial, and address employment barriers identified in their ESRs.
- The measures taken to remedy non-compliance. Through MAPs issued to the departments and agencies that did not meet the requirements of the horizontal audit, the Commission ensured that they remedy the areas of non-compliance and include the necessary measures in their EE plans and programs to meet their legislative obligations.
- The collaborative approach used while conducting audits. While the Commission's role under the EEA is to enforce the obligations imposed on employers to comply with the requirements of the EEA, EE audits should not be perceived as a "paper exercise" nor a "quota system". In conducting audits, the Commission believes that to fully address the systemic issues in the workplace, it is important to have a collaborative approach to understand each employer's situation and challenges, while still setting appropriate and reasonable expectations for the audit.
- The Commission's perspective. The horizontal audit also helped provide concrete and meaningful recommendations to the Task Force to address discrepancies in the enforcement measures of the EEA and to modernize it for today's context and new challenges.
While the benefits and impacts of the horizontal audit were numerous, some challenges also arose during the audit process. The main challenges encountered were:
- The current EEA does not mandate the collection of disaggregated data on racialized groups. The Commission recognizes that its ability to advance EE is limited to the current legislative obligations outlined in the EEA. Although the Commission encourages organizations to aim for diverse representation within racialized sub-groups, it must also respect the fact that it currently does not have the mandate to enforce this approach. As a result, disaggregated data on racialized groups was not collected during the horizontal audit. Collecting this data would shed light on the diverse systemic issues faced among the racialized sub-groups. The Commission addressed this gap in data collection in its submission to the Task Force by highlighting the need for enhancing and modernizing data collection methods and tools to better reflect diversity and intersectionality within designated groups.
- The federal public service has no specific occupational group for managers. This created difficulties in obtaining data on the representation of racialized employees in management positions. As a substitute for the managerial group, the Commission used the representation of employees in EX minus-one positions during the horizontal audit. While still an approximation, it captured many managers in the federal public service. A proposed recommendation to remedy this situation would be to review the format used in the private sector, which includes specific occupational groups for "Senior Managers" and "Middle and Other Managers" and consider adding these groups to the format used in the public service.
- The lack of compliance with the requirements of the horizontal audit. Even though all the departments and agencies selected for the audit were previously audited by the Commission or selected for an EE review, 16 out of the 18 did not meet the requirements of the horizontal audit, which only looked at the employment experience of one of the four designated groups. The Commission issued remedial actions through MAPs for each of these departments and agencies and closed the audit files when it was satisfied that they met all the requirements of the audit. Although all the audited departments and agencies understood their obligations to comply with the EEA and the importance of the audit, an improved annual reporting requirement for employers regarding their progress would encourage them to be more proactive in keeping their EE programs up to date.
- The delays in publishing the sector-wide report. Many departments and agencies experienced human resources and organizational challenges which caused delays in obtaining information about their EE programs. For example, at the beginning of the 2024-25 fiscal year, two departments still had not completed all the requirements of their MAPs. The last remedial item was only completed in October 2024. These delays impacted the publication of the sector-wide report since the Commission had to provide extensions to most departments and agencies audited to ensure a fulsome participation and gather the appropriate findings for the report. With modernized audit compliance functions, the Commission would have better tools to evaluate employers' situations while ensuring that they meet their legislative obligations in a reasonable timeframe.
6. Conclusion
This report outlined the findings of the horizontal audit on the employment of racialized people in management and executive positions in the public service. Extensive data was collected from the 46 departments and agencies surveyed. The audits conducted on 18 departments and agencies also provided insights into the EE systems and practices implemented across the public service. The horizontal audit identified several barriers to employment for racialized employees present in recruitment strategies, selection processes, hiring decisions, career development, and workplace culture. Additionally, the audit highlighted several positive practices that can enhance an employer's EE program. These practices include implementing diverse and clearly defined recruitment methods, providing training on anti-harassment and unconscious bias, monitoring the EE program, and implementing fair selection processes for promotions.
The Commission would like to emphasize the significant role the federal public service plays in advancing EE in the Canadian labour market, specifically in this current context. With a workforce of over 300,000 employees, the public service is often viewed as a leader in EE and sets a positive example for others to follow. While significant progress has been made, some work still remains to achieve EE throughout the entire federal public service. The modernization of the EEA would provide the Commission with better tools to evaluate employers' EE programs while ensuring that they meet their legislative obligations.
Moving forward
As a next step, the Commission will conduct an EE Blitz audit in three years to monitor the representation of racialized people in the public service and assess progress. This streamlined approach assesses compliance with two or more requirements of the EEA and provides a resource-efficient method of ensuring compliance.
Annex A – List of participating departments and agencies
- Agriculture and Agri-Food Canada
- Atlantic Canada Opportunities Agency
- Canada Border Services Agency
- Canada Food Inspection Agency
- Canada Revenue Agency
- Canada School of Public Service
- Canadian Heritage
- Canadian Institutes of Health Research
- Canadian Nuclear Safety Commission
- Canadian Security Intelligence Service
- Canadian Space Agency
- Communications Security Establishment
- Correctional Service Canada
- Courts Administration Service
- Crown-Indigenous Relations and Northern Affairs Canada
- Department of National Defence
- Elections Canada
- Employment and Social Development Canada
- Environment and Climate Change Canada
- Finance Canada
- Fisheries and Oceans Canada
- Global Affairs Canada
- Health Canada
- Immigration and Refugee Board of Canada
- Immigration, Refugees and Citizenship Canada
- Indigenous Services Canada
- Innovation, Science and Economic Development Canada
- Justice Canada
- Library and Archives Canada
- National Research Council of Canada
- Natural Resources Canada
- Office of the Auditor General of Canada
- Office of the Superintendent of Financial Institutions of Canada
- Parks Canada Agency
- Public Health Agency of Canada
- Public Prosecution Service of Canada
- Public Safety Canada
- Public Service Commission
- Public Services and Procurement Canada
- Royal Canadian Mounted Police
- Shared Services Canada
- Statistical Survey Operations
- Statistics Canada
- Transport Canada
- Treasury Board of Canada Secretariat
- Veterans Affairs Canada
HR4-132/2025E-PDF
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Employment Equity