HUMAN RIGHTS TRIBUNAL OF ONTARIO
B E T W E E N:
Suzanne Canonaco Applicant
-and-
Tony Canonaco Respondent
DECISION
Adjudicator: Josée Bouchard
Indexed as: Canonaco v. Canonaco
APPEARANCES
Suzanne Canonaco, Applicant Self-represented
Tony Canonaco, Respondent Self-represented
INTRODUCTION
1The applicant was employed as a customer care coordinator with Baywood Homes (“Baywood”), a family-run building and real estate development business, from October 2014 until the closure of the business in mid-August 2015. The respondent, who is the applicant’s uncle, operated Baywood with his two brothers, the applicant’s father, Ralph Canonaco (“father”), and the applicant’s uncle, Frank Canonaco (“Frank”). The father, Frank and the respondent were also directors of the company, along with the applicant’s mother, Cora Canonaco (“mother”), and the applicant’s grand-mother Assunta Canonaco. Baywood was a small company with a workforce of approximately 10 employees.
2The applicant alleges that, as a result of a dispute between the respondent and her parents, the respondent subjected her to offensive comments and denied her medical benefits that were offered to other employees. Although sections 5(1) and 5(2) of the Human Rights Code, R.S.O. 1990, c. H.19 as amended (the “Code”) are not identified on the face of the Application, in her narrative the applicant alleges she experienced harassment and discrimination on the basis of her family status with respect to her employment.
3The issues in dispute are as follows:
Did the alleged incidents occur with respect to employment?
Did the respondent bar the applicant from receiving her medical benefits and as such subject her to adverse treatment?
Did the respondent subject the applicant to adverse treatment because of her family relationship with her parents?
Did the respondent harass the applicant because of her family status?
4Before turning to the merits of the case, I address process related matters.
PROCESS
5Following the completion of a one-day hearing, the Tribunal received unsolicited submissions from the respondent. I decline to consider these submissions as the hearing had concluded and it would be prejudicial to the applicant to do so.
6As the parties were self-represented, the Tribunal issued a Case Assessment Direction (“CAD”) on February 12, 2016 to assist them in preparing for the hearing. The CAD provided directions on the hearing process and the key questions that the Tribunal would consider. At the hearing in my opening remarks I informed the parties that the proceedings would not be recorded or transcribed and I encouraged them to take notes for their own records. Each party presented their testimony and closing statements and introduced documentary evidence. The parties also cross-examined each other. The hearing concluded and I reserved my decision.
7The respondent requested copies or transcripts of the hearing proceedings. Rule 3.7 of the Rules of Procedure states:
The Tribunal does not normally record or transcribe its proceedings. Where a hearing is recorded the recording does not form part of the Tribunal’s record of proceedings including any record filed in respect of an application made under the Judicial Review Procedure Act, R.S.O. 1990, c. J.1
8The Practice Direction on Recording Hearings explains that the Tribunal will record a hearing when it is necessary to accommodate the needs of the panel, a party or a representative under the Code. In this case, the parties did not make a request for accommodation and I am satisfied no accommodation was required.
9I turn now to the facts and merits of this case.
THE FACTS
10The applicant was offered the position of customer care coordinator at Baywood in October 2014, when the position became vacant and had to be filled quickly. The applicant was considered qualified for the position and was hired without an interview. In November 2014, the respondent welcomed her to the business. He had a brief conversation with her about her upcoming employment and later reached out to her by email welcoming her to the business and indicating that he “saw a bright light” in her and she had “compassion and empathy for people”. He encouraged her to develop those skills and suggested she might want to meet his family.
11In May 2015, the applicant’s father signed a Power of Attorney (“POA”) appointing her as his attorney to be exercised during any incapacity on his part to manage his property. The respondent maintains that this made the applicant more than an employee, she was a quasi-partner. He argues that she attended and participated in high level meetings for the company, often with her father. The respondent recalled that around May 2015, the applicant’s father was incapacitated for approximately 30 days and the applicant acted for him during that period. It was the respondent’s view that the POA gave the applicant the power, with other managing partners, to approve expenses, including her own. The respondent maintains that on a number of occasions, the applicant approved requests via email for the disbursement of company funds, including requests from her mother. He was of the view that it would not have been a conflict for the applicant to approve her own medical claims and to sign reimbursement cheques made to the applicant herself.
12Although the applicant did not report directly to the respondent, she saw him regularly in the office. The parties agree that their professional relationship at the beginning of the applicant’s employment was generally good.
13There is also agreement that there was tension between the respondent, the applicant’s parents and Frank and that this tension escalated until the closing of the business in mid-August.
14The respondent assigns blame for the demise of the business to the applicant’s parents, suggesting that they were responsible for the highly dysfunctional relationship between the partners, that they “destroyed the company” and that “they went rogue and exercised what they believed was their god given autocratic rule over the rest of the families”. He testified that the applicant’s mother had self-appointed herself as office manager/director and was solely responsible for closing down the office in mid-August, an observation that the applicant did not contradict.
15The following is an example of the deteriorating relationship between the applicant and the respondent. On April 23, 2015, the respondent emailed the applicant and Baywood’s construction manager, copying the applicant’s father, Frank, and other employees. The email requested information about a court proceeding against Baywood. The applicant replied as follows:
Tony, if you would like to see the reports and documents involved in this ongoing case I can provide them to you. There’s a box that [a former employee] dropped off yesterday. Kind regards.
16The following exchange ensued:
Respondent: “Fuck off”.
Applicant: “Excuse me?”
Respondent: “You heard me. Fuck off. Don’t send me emails. I don’t want to hear from you.”
Respondent: “I don’t give a shit who you email. You both (the applicant and the construction manager) can go fuck yourselves”.
17The applicant was shocked. The respondent admitted that his language was inappropriate but he was having a bad day. He explained that he had not been made aware of the costs related to the construction discrepancies referred to in the emails, he wanted an explanation from the construction manager and he was surprised that the applicant interrupted them. The respondent showed remorse for having written the “bad words” to the applicant.
18The applicant admitted that she knew there were issues between the respondent, Frank and her parents but this was the first time she was “caught in the crossfire”. She maintains that the inappropriate emails from the respondent were uncalled for and she felt they were directed at her because she was not as valued as other employees due to her family relationship with her parents. Following this incident, the applicant was afraid to approach the respondent.
19In July 2015 the applicant had sent an email to accounts payable asking when she could expect to be reimbursed for her July medical expenses. In response, she was informed that Frank and the respondent were refusing to approve the reimbursement.
20The applicant emailed Frank, copying her parents and the respondent, asking for the reason for the rejection of her claim and indicating that she was aware that funds were available. The applicant did not produce Frank’s response but testified that Frank told her, and confirmed by email (email not produced), that she would be reimbursed. The parties provided no explanation for Frank’s failure to testify.
21The respondent replied as follows:
I have dependents as well. If they could work they could, so they can collect health benefits too. The last time I asked to have them covered, your mother said no. Since then I have been paying out of pocket. Maybe your mother and father can pay for you too. And your father said no too […]
Also, you really should do yourself a favor, stop wasting your time and my money, I never recruited you or agreed with your employment there, while the company went down the tubes. Your Dad made sure to “tank the turkeys”. He accomplished it. Go find yourself a real job, somewhere you have a future. Have a look around you, there is no one left. Only law suits, debt and a destroyed family business. A university educated person like you should be able to prosper in another company. You’re wasting your time there.
22The respondent sent a further email to Frank, the applicant’s father and the applicant in which he tells the applicant’s father:
You can pay her out of your pocket. The shareholder accounts show you have taken out money that was not yours. She is not my dependent, nor did I give consent to hire her.
23Despite this a cheque for the amount of the claim was made out to the applicant on July 6, 2015. The respondent demanded its cancellation stating:
Under no circumstances are cheques to be signed without my approval. Without full partnership approval, anything less will be considered theft.
24The applicant emailed the respondent, copying her parents, Frank and other employees, indicating that “as an employee, her medical coverage should not be caught in the crossfire of the partnership dispute.” The respondent replied:
For the record, it’s not a partnership dispute. Speak to your father and mother who will provide for you. It wasn’t my decision that they went rogue and exercised what they believe was their god given autocratic rule over the rest of the families. Not going to happen. […] Company can’t afford it. Take it up with the labour board.
25The respondent does not dispute the content of the emails or demanding the cancellation of the cheque. The respondent argues that payment was never approved and that the cheque was cancelled for insufficient funds although he did not dispute the applicant’s evidence of post July 6 payments. The applicant provided evidence that Baywood issued two cheques after July 6, 2015 to confirm Baywood had sufficient funds to honour the payment to her.
26On August 6, 2015 the respondent emailed Frank and the applicant’s parents, copying the applicant. The email is directed at the applicant’s parents:
It was better to give back or cooperate with family than Alex during the mutually agreed recovery path that you both willfully and recklessly sabotaged with an exploiting lawyer. Also don’t think I’m not going to vigorously defend myself with [the applicant] taking me to the Human Rights Tribunal with complete disregard for her Uncle. I am not her employer and she is not a typical employee. It’s a disgrace how she was raised to disrespect her Uncle who cared for her as his first niece. Going against family that cared is the worst decision you guys ever made. The company was not built alone by one person. But it certainly was destroyed by both of you […] You ruined your lives, and everyone else’s.
27A further email from the respondent to the applicant’s mother, copied to Frank, the applicant’s father and the applicant, states about the applicant:
She is a spoiled brat who has no respect. Nothing ever comes good from a spoiled brat. I’ll ask my lawyer to move up the tribunal date. Can’t wait to tell my side of the story.
ANALYSIS AND DECISION
Credibility
28Much of the evidence regarding this case is not in dispute. However, where I have needed to resolve any conflicts in the evidence, I have assessed credibility in accordance with the principles set out in Faryna v. Chorny, 1951 CanLII 252 (BC CA), [1952] 2 DLR 354 (BCCA) at pp. 356-357. In particular, when making credibility findings I sought to determine which account of the facts in relation to each issue is “in harmony with the preponderance of the probabilities which a practical and informed person would readily recognize as reasonable” in the circumstances.
29I was also guided by factors considered by the Tribunal in Cugliari v. Clubine and Brunet, 2006 HRTO 7, at para. 26: the motives of the witnesses, the relationship of the witnesses to the parties, the internal consistency of their evidence, inconsistencies and contradictions in relation to the other witnesses’ evidence, and observations as to the manner in which the witnesses gave their evidence.
With Respect to Employment
30The first issue before me is whether the alleged incidents occurred “with respect to employment”.
31The applicant maintains that she was an employee of Baywood from January to August 2015. To show this, the applicant produced an employment letter dated October 8, 2014 confirming that she was employed by Baywood with an annual salary paid bi-weekly. The applicant also produced an earnings statement and her bank account activities indicating that she was still receiving a salary in July and the beginning of August 2015.
32The applicant testified that she was not sure whether the POA had been acted upon. She confirmed attending some high level meetings of the company as an observer, which she considered a privilege. She never perceived herself as a partner or director of Baywood and she maintains that she never signed cheques for the company. The applicant admitted that she would often be copied on emails to the managing partners requiring approval for disbursements of funds. She explained that the emails were usually for the approval of operational disbursements and she would “ok” the requests. She did not consider this an approval of the requests as the managing partners had to provide their approval.
33During the hearing process, the Tribunal was made aware of a Ministry of Labour decision (“MOL Decision”) made pursuant to the Employment Standards Act, 2000 (“ESA”) involving the applicant as claimant against Baywood. The applicant filed a copy of the decision to allow the Tribunal to consider whether, under section 45.1 of the Code, the Application should be dismissed because another proceeding had appropriately dealt with the substance of the Application.
34The purpose of s. 45.1 of the Code is to avoid the duplication of proceedings and the re-litigation of issues that have been appropriately dealt with elsewhere. That section is generally considered in two parts: (1) was there another “proceeding” and (2) if so, did it “appropriately deal with” the substance of the application.
35The Tribunal has held on a number of occasions that an ESA complaint process meets the requirements of a “proceeding” for the purposes of section 45.1 of the Code. See, for example, Henderson v. Nutech Fire Protection, 2010 HRTO 2153.
36On the question of whether or not the ESA process appropriately dealt with the substance of the Application, the MOL Decision only addressed the issue of unpaid wages and termination pay owed to the applicant upon the closure of Baywood and was not determinative of the Code related matters. However, the MOL decision is useful to the analysis of the employment relationship between the applicant and Baywood.
37In McCormick v. Fasken Martineau DuMoulin LLP, 2014 SCC 39, the Supreme Court of Canada determined “employment relationships” for purposes of the British Columbia Human Rights Code, RSBC 1996, c. 210. It concluded, at paras. 23 and 31:
Deciding who is in an employment relationship for purposes of the Code means, in essence, examining how two synergetic aspects function in an employment relationship: control exercised by an employer over working conditions and remuneration, and corresponding dependency on the part of a worker. In other words, the test is who is responsible for determining working conditions and financial benefits and to what extent does a worker have an influential say in those determinations? The more the work life of individuals is controlled, the greater their dependency and, consequently, their economic, social and psychological vulnerability in the workplace […]
Among the distinctive features of a partnership is that partners generally have a right to participate meaningfully in the decision-making process that determines their workplace conditions and remuneration […] This is reflected in, for example, the duty to render accounts to other partners in order to permit them to have the information they need to participate in workplace decisions and ensure that their interests are adequately considered.
38Although the principles arose out of a case decided in British Columbia, the differences in the two statutes with respect to discrimination in employment are not material and the Supreme Court of Canada’s reasoning is equally applicable in Ontario: Wing v. Niagara Falls Holding Corp., 2014 HRTO 1482; Swain v. MBM Intellectual Property Law LLP, 2015 HRTO 1011, and Di Muccio v. Corporation of the Town of Newmarket, 2016 HRTO 406.
39Applying these principles to the facts of the case, I find that the claim arises with respect to an employment relationship under the Code. Other than the one month in May 2015 when the applicant may have acted for her father under the POA, I find that she did not exercise control over the workplace conditions and remuneration at Baywood. The respondent and applicant agreed that the applicant’s father, Frank, and the respondent were the managing partners of the business. There were also five shareholders. The respondent testified that all three brothers had to approve the payroll for employees. The applicant provided evidence that she was on the payroll of the company and the MOL Decision confirms this.
40I find that the applicant received direction from and was affected by the decisions of the managing partners. For example, even though the respondent argued that the applicant was a “quasi-partner”, the applicant’s medical claim remained unpaid and beyond her control. I also find that the applicant did not believe or act in a way that showed that she had the ability to influence decisions that critically affected her working life. The applicant testified that she attended, as an observer, meetings with external parties and the partners but did not participate in decision-making. The applicant was not in control of the business but was rather subjected to the decisions of the three partners or five directors.
Bar from Medical Benefits
41I turn now to the issue of whether the respondent barred the applicant from receiving medical benefits by first considering whether the applicant was entitled to medical benefits.
42The applicant produced a Baywood spreadsheet indicating that Baywood reimburses its employees a maximum of $200 for prescription glasses, 80% for dental benefits and 90% for prescription medication. The spreadsheet included a list of claims made by various employees between September 2014 and July 2015, the name of each claimant, the description of the claim, the amount of the claim, remarks regarding the entitlement, the allowance for each claim and the status of each claim. Employees had made more than 60 medical and dental claims during that period which were all paid except for three.
43The applicant maintains that medical and dental benefits were included as part of her employment arrangement and were generally approved as a matter of course. It was her understanding that any two managing partners could approve payment.
44The respondent does not dispute that Baywood provided medical and dental benefits to its employees but, contrary to the applicant’s belief, maintains all three managing partners had to approve payment. The respondent was a director and managing partner of Baywood and, as such, I rely on his description of the approval process. The practice of the company was to receive medical claims directly from employees for approval by the three managing partners.
45The respondent testified that all three managing partners refused the applicant’s July medical claim. He explained that, by July 2015, Baywood was in great financial difficulty and the managing partners were forced to make difficult decisions about what should be paid. However, I do not accept this explanation, as the July claim was modest and Baywood continued to issue cheques after July 6, 2015.
46I find that it was the practice of Baywood to approve eligible medical and dental benefits as a matter of course. The parties did not dispute the eligibility of the applicant’s July claim and I find that she was eligible for reimbursement.
47I turn now to the issue of whether the respondent barred the applicant from reimbursement. The respondent admits he refused the claim and ordered the cancellation of the cheque. As all three managing partners had to approve the disbursement of funds, I find that the respondent’s refusal to approve the applicant’s claim effectively prevented her reimbursement.
48I believe the applicant’s testimony that Frank told her that her medical claim would be approved. There is no evidence to suggest that Frank had reason to reject the claim and payment was an established company practice. I also find, for the same reason, that the applicant’s father would have approved the claim.
Adverse Treatment Because of the Applicant’s Relationship with her Parents
49I turn now to the respondent’s reason for refusing the claim. The relevant provisions of the Code are:
5(1) Every person has a right to equal treatment with respect to employment without discrimination because of race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, gender identity, gender expression age, record of offences, marital status, family status or disability.
10(1) “family status” means the status of being in a parent and child relationship.
50In B. v. Ontario (Human Rights Commission), 2002 SCC 66 at para. 58, the Supreme Court of Canada concluded that family status within the meaning of the Code encompasses claims arising from the particular identity of the applicant’s child or parents. In that case, A’s employment with the family business was terminated when A’s daughter alleged that she had been sexually assaulted by a family member. The Court found that the proper inquiry was whether A was arbitrarily disadvantaged on the basis of his marital or family status. Even if A’s dismissal was based on personal animosity, the animosity did not result from any action or behaviour by A, but because of his familial affiliations. The attribution of the daughter’s behaviour to A reflected stereotypical assumptions about him that had nothing to do with his individual merit or capabilities.
51Applying B. v. Ontario, above, I find the respondent’s conduct toward the applicant was affected by her relationship with her parents with whom the respondent was in a dispute. I provide the following reasons.
52The respondent claims the decision to refuse payment was made for an entirely non-discriminatory reason: insufficient funds. I accept that Baywood stopped conducting business in mid-August. However, the respondent did not produce evidence that Baywood did not have sufficient funds in July to reimburse the applicant’s modest claim to support this non-discriminatory explanation.
53Rather, beginning in April 2015 the evidence confirms the respondent’s escalating animosity toward the applicant’s parents and by extension toward the applicant. In his explanations to the applicant refusing to pay her claim the respondent expressly connected the parents’ conduct to his decision. For these reasons I find the respondent subjected the applicant to adverse treatment and denied her a benefit she would otherwise have received because of her relationship to her parents. This constitutes discrimination on the basis of family status.
Harassment Because of Family Status
54Section 5(2) of the Code states:
Every person who is an employee has a right to freedom from harassment in the workplace by the employer or agent of the employer or by another employee because of race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sexual orientation, gender identity, gender expression, age, record of offences, marital status, family status or disability.
55In order to constitute harassment, the evidentiary burden on the applicant is to demonstrate that the impugned behaviour was (i) a course of vexatious conduct or comments, (ii) by an employer or employer’s agent, (iii) unwelcome or ought to be known to be unwelcome and (iv) related to a ground under the Code. See Szabo v. Niagara (Regional Municipality), 2010 HRTO 1083 and Canada (Human Rights Commission) v. Canada (Armed Forces), 1999 CanLII 18902 (FC).
56I find that the respondent’s behaviour was a course of vexatious conduct or comments made by him as the employer of the applicant. Between April and August 2015, the respondent made a series of vexatious comments to the applicant about her and her parents. The respondent admitted that the April 2015 comments were inappropriate and as such unwelcome. I find that the respondent also ought to have known that the further July and August comments described above were unwelcome as they were egregious and made to the applicant for colleagues to read. As discussed above, I find that the comments were made because of the applicant’s family relationship.
REMEDIES
57Section 45.2 of the Code permits the Tribunal to make the following remedial orders:
(1) An order directing the party who infringed the right to pay monetary compensation to the party whose right was infringed for loss arising out of the infringement, including compensation for injury to dignity, feelings and self-respect.
(2) An order directing the party who infringed the right to make restitution to the party whose right was infringed, other than through monetary compensation, for loss arising out of the infringement, including restitution for injury to dignity, feelings and self-respect.
(3) An order directing any party to the application to do anything that, in the opinion of the Tribunal, the party ought to do to promote compliance.
58The applicant seeks $411.72 in monetary compensation for her unpaid medical claim. Neither the applicant nor respondent disputed the amount of the applicant’s medical claim. I award $411.72 to the applicant in compensation.
59In Arunachalam v. Best Buy Canada, 2010 HRTO 1880, the Tribunal discussed awards for injury to dignity, feelings and self-respect, at paras. 52 – 54:
The Tribunal’s jurisprudence over the two years since the new damages provision took effect has primarily applied two criteria in making the global evaluation of the appropriate damage for injury to dignity, feelings and self-respect: the objective seriousness of the conduct and the effect on the particular applicant who experienced discrimination: see, in particular, Seguin v. Great Blue Heron Charity Casino, 2009 HRTO 940 at para. 16.
The first criterion recognizes that injury to dignity, feelings, and self-respect is generally more serious depending, objectively, upon what occurred. For example, dismissal from employment for discriminatory reasons usually affects dignity more than a comment made on one occasion. Losing long-term employment because of discrimination is typically more harmful than losing a new job. The more prolonged, hurtful, and serious harassing comments are, the greater the injury to dignity, feelings and self-respect.
The second criterion recognizes the applicant’s particular experience in response to the discrimination. Damages will be generally at the high end of the relevant range when the applicant has experienced particular emotional difficulties as a result of the event, and when his or her particular circumstances make the effects particularly serious.
60In Sanford v. Koop, 2005 HRTO 53, the Tribunal listed a number of factors to consider when awarding monetary compensation including whether the applicant experienced humiliation, hurt feelings, loss of self-respect, loss of dignity, loss of self-esteem, loss of confidence, victimization, the applicant’s vulnerability and the seriousness, frequency and duration of the offensive treatment.
61The Tribunal has considered the appropriate remedy for a single comment or a few comments in a short period of time or number of occasions and has generally awarded relatively modest damages. See Adorgloh v. Seasons Foodmart and Feng Lin, 2013 HRTO 1201 ($2,000.00); Romano v. 1577118 Ontario Inc., ($1,000.00); Baisa v. Skills for Change, 2010 HRTO 2161 ($1,500.00); Brooks v. Total Credit Recovery Limited, 2012 HRTO 1232 ($2,500.00); Abdallah v. Thames Valley District School Board, 2008 HRTO 230 ($1,500.00); Szyluk v. United Food and Commercial Workers Canada, 2009 HRTO 902 ($2,000.00); and Kannaiti v. Allen, 2015 HRTO 502 ($7,500.00).
62Although this Application is about reimbursement of a modest sum of less than $500, I find that the discriminatory conduct surrounding the refusal of the claim significantly impacted the applicant. The refusal arose out of a family dispute between the respondent and the applicant’s parents. The respondent was a managing partner of the company and as such one of the applicant’s superiors. The respondent not only used vulgar language directed at the applicant, his niece, but he repeated the language and used the language in written exchanges of emails copied to other employees and family members. The respondent made extremely disrespectful and unprofessional comments to the applicant and her parents, about her and her parents, and again made those comments in written email exchanges copied to other employees and family members. Such inappropriate emails were not isolated incidents but occurred first in April 2015, then in July 2015 and again in August 2015, and showed a pattern of adverse treatment of the applicant because of her family status.
63The applicant testified that she felt embarrassed, anxious, fatigued, had difficulty concentrating and was afraid of what could happen at the office. She found it very difficult to work and concentrate. At the same time, I note that there is no medical evidence before me of medical, health or psychological issues arising from this incident, which is a factor considered by this Tribunal when making an award of compensation at the higher end of the scale.
64In all of these circumstances, it is my view that an award of $3,500 is appropriate compensation for injury to the applicant’s dignity, feelings and self-respect, consistent with this Tribunal’s jurisprudence.
65I find that the respondent did not appreciate how inappropriate his statements and actions were. Accordingly, I find it appropriate to order the respondent to take the eLearning module “Human Rights 101” that is found on the Ontario Human Rights Commission’s website at www.ohrc.on.ca and confirm completion of same in writing to the applicant within 90 days of the date of this Decision.
66The Tribunal orders as follows:
(1) Within 45 days of the date of this Decision, the respondent shall pay to the applicant $411.72 as compensation for loss of medical expense benefits;
(2) Within 45 days of the date of this Decision, the respondent shall pay to the applicant $3,500.00 as compensation for injury to dignity, feelings and self-respect;
(3) In the event that the respondent fails to make the payment described above within 45 days of the date of this Decision, the respondent shall pay post-judgment interest in accordance with section 129 of the Courts of Justice Act, R.S.O 1990, c. C.43; and,
(4) The respondent shall take the eLearning module “Human Rights 101” that is found on the Ontario Human Rights Commission’s website at www.ohrc.on.ca and confirm completion of same in writing to the applicant within 90 days of the date of this decision.
Dated at Toronto, this 3rd day of May, 2016.
“signed by”
Josée Bouchard
Vice-chair