Sharon Nolan-Conway and Joanne Greene v. City of Toronto, 2023 CanLII 50685

Pay Equity Hearings Tribunal

PEHT Case No: 2390-19-PE

Sharon Nolan-Conway, Applicant v City of Toronto, Respondent

PEHT Case No: 2391-19-PE

Joanne Greene, Applicant v City of Toronto, Respondent

BEFORE: M. David Ross, Chair, and Members Patricia Greenside and Carol Phillips

DECISION OF THE TRIBUNAL: May 26, 2023

1. These are applications filed under the Pay Equity Act, R.S.O. 1990, c.P.7, as amended (“the Act”).

2. In these applications, the applicants, Sharon Nolan-Conway and Joanne Greene, have alleged that their job classes were not evaluated in accordance with the Act by the respondent, the City of Toronto (“the City”). In this case, the applicant’s job class was evaluated by a third-party consultant, along with other executive and human resources job classes, as part of the pay equity plan for non-unionized employees at the City of Toronto.

3. The applicants objected to the pay equity plan within the timelines set out in section 15 of the Act. Accordingly, in this case, the pay equity plan has yet not been “deemed approved” as defined by section 15(8) of the Act.

4. The first issue that the Tribunal decided was whether the applicants’ job classifications were evaluated “in isolation” as described by the Tribunal’s jurisprudence. After hearing evidence on this issue over two hearing dates, by decision dated July 19, 2021, the Tribunal found that the Human Resources jobs were evaluated differently than other jobs in the City’s non-union pay equity plan. However, the Tribunal made no finding about whether the applicants’ job classes were rated inaccurately, as it could be that the consultant’s initial ratings did not violate the Act, even if the applicants’ job classes were not evaluated using the same process as other non-union job classes. At paragraphs 14 to 16 of its July 19, 2021 decision, the Tribunal held:

5. No independent review was done by a third-party consultant after this email was sent to Ms. Greene, and the evidence heard does not suggest that Ms. Greene was informed that the respondent would not be retaining a third-party consultant as contemplated by the above communication. As such, on a balance of probabilities, it appears to the Tribunal that these classifications were evaluated differently than “the majority” of the other classifications in the non-union pay equity plan, which includes male comparator classifications.

6. Accordingly, given the facts of this case, the Tribunal will not dismiss these applications using its rationale for why it does not hear the merits of a single job classification dispute as cited above from Centennial College, supra.

7. The Tribunal reiterates that it has made no finding or comments whatsoever about the chances of success for the applicants on the merits, and it may be that the respondent may be found to be accurate in how the applicants’ job classes were placed on the grid and no adjustment is warranted. The respondent correctly highlighted that there was no evidence that the applicants evaluated their classes (and as pay equity experts could have) with access to their job descriptions, questionnaires using the GNCS compliant tool either. This will be something that the applicants will have to address during the hearing on the merits. However, if the face of a complaint that a job classification was not evaluated in accordance with the Act, the obligation to establish that a pay equity plan and that the process that was used to create it was compliant with the Act rests with the employer not the applicants at this stage of the proceeding.

8. Also in that decision, the Tribunal held that there was nothing offside the Act with a third-party consultant evaluating job classifications using the gender-neutral comparison system (“GNCS”). At paragraph 10, it held:

The Tribunal notes that it heard no evidence that the process applied by the City to engage a third-party consultant to evaluate job classifications where conflicts of interest would exist if the City internally evaluated them was offside the Act in any way. In this case, the applicants are employed in the human resources department and were responsible for evaluating other job classifications and establishing the City’s pay equity plans. There is nothing wrong, in and of itself, with having an independent third-party evaluate their job classes to avoid a conflict of interest using the City’s pay equity plan and gender-neutral comparison system to evaluate the job classes. That is, the same people do not necessarily have to evaluate every job class in a pay equity plan for it to be compliant with the Act. This is one of the purposes of a gender-neutral comparison system (“GNCS”), which is meant to be an objective job evaluation tool. In a workplace with thousands upon thousands of job classes, it would be unreasonable for the Tribunal to demand that a single person or small team evaluate every job class if one is to be created and finalized in a timely manner so systemic pay discrimination can be remedied as quickly as possible to fulfill the purposes of the Act. However, the process that is used must be clear to the Tribunal.

6. The Tribunal then directed submissions about how the parties will present evidence about whether the applicants’ job classes have been evaluated in accordance with the Act. At paragraph 17, the Tribunal held:

On this point, the Tribunal foresees a challenge in how the evidence will be presented by the applicants given that there are no job descriptions or questionnaires in the parties’ possession. The applicants shall have until August 3, 2021 to file their submissions about how they propose to proceed with calling evidence in this case. The respondent shall have until August 19, 2021 to file any submissions they wish the Tribunal to consider with respect to the process going forward. The Board will consider the submissions received and direct a process in due course.

7. The parties filed their submissions as directed. The Tribunal considered the submissions and directed that the parties shall each prepare a job description that they assert is reflective of the applicant’s job duties, share them with one another, and to identify the disputed language of the job descriptions between the two drafts for the Tribunal. The procedural direction is set out in City of Toronto, 2021 CanLII 86296 (ON PEHT).

8. The parties complied with the Tribunal’s directions, but disputes about the content of the job descriptions remained. To determine whether the disputes about the job descriptions were material to the job evaluation, the Tribunal then directed the parties to evaluate the job descriptions based on both the applicants’ and the respondent’s job description to highlight where the disputes were, and whether those disputes affected the overall rating. The Tribunal also directed the parties to file witness statements to set out the evidence they intend to call in support of their respective positions regarding the disputes in the job description and job evaluation. This procedural direction is set out in City of Toronto, 2021 CanLII 122929 (ON PEHT).

9. The parties’ job descriptions and the document that set out their disputes were filed with the Tribunal on October 29, 2021.

10. The Tribunal heard the evidence about these disputes on November 7, 2022. At the conclusion of the November 7, 2022 hearing date, the parties agreed to present their closing submissions in writing because medical issues prevented counsel from making submissions orally at the next hearing date.

11. The Tribunal has considered the evidence and submissions in this case. This includes the viva voce evidence, the signed witness statements filed with the Tribunal and the documents that were entered into evidence.

Summary of the Parties’ Submissions

12. The applicants assert that their job classes were incorrectly rated one level below where they should have been. Ms. Green submits that her job class, Manager of Compensation should have been placed at level 9, and Ms. Nolan-Conway submits that her job class, Senior Human Resource Consultant, Compensation, should be placed at level 8. The applicants submit that the job description submitted by the City did not accurately capture their job duties.

13. The applicants provided their rationales and provided documents in support of their belief that the ratings are too low for each of the five factors, including providing job descriptions from other job classifications that were rated at the level they state are the correct ones.

14. The respondent submitted that its job descriptions/profiles accurately capture the applicants’ job duties and that its ratings are reasonable for both positions. The respondent submitted that the Act places the obligation to evaluate positions on the employer in situations like this one, and the Tribunal should provide deference to its ratings unless the applicant can demonstrate that its conclusions are unreasonable, as set out in the Tribunal’s jurisprudence, and demonstrate that important job information was not captured or evaluated, that the ratings were influenced by gender bias, or the job class was not evaluated using the statutory criteria of skill, effort, working conditions, and responsibility.

15. The respondent also submitted that there are many principles of job evaluation that must be considered, such as the principle of relativity, and that the Act does not require female job classes to be rated and compared to a specific male comparator, or subfactors be rated against specific male comparators subfactors. The respondent submitted that the applicants are seeking the Tribunal to find that it incorrectly rated their job classifications, but that is not the test. The City submitted that the test is whether the job evaluations were reasonable, and the evidence demonstrates that its ratings are reasonable, and always have been.

16. In reply, the applicants submitted that the Tribunal has found that the human resources job classes were not rated relatively to one another, which is a precise requirement of the Act, and therefore there is no “range of reasonable outcomes” with respect to an employer’s failure to meet that precise requirement of the Act, and as such, deference should not be afforded to the City’s evaluations.

What is Not in Dispute Between the Parties

17. There are several elements of the pay equity process that are not in dispute between the parties.

18. The GNCS that was used to evaluate the job classes is not in dispute. Consequently, there are no issues raised about the statutory criteria not being considered as part of the job evaluation process.

19. The identification of the job classes and their gender dominance are not in dispute, nor is there any dispute that any of the pay bands/levels does not contain a male comparator. Therefore, the Tribunal has confidence that each of the pay bands/levels in the non-union pay equity plan contains at least one male comparator that can used for the purpose of comparability. This is not a case where after evaluating all of the job classes, the job-to-job method of comparison cannot be done in each pay band/level.

20. There is also no allegation or dispute that the job evaluation system was influenced by gender bias. While the applicants allege that the human resources job classes were not appropriately evaluated because they went through a different process, the evidence is that the applicants agreed with most of the placement of the human resources jobs that were evaluated by the third-party consultant. Out of a possible 1225 job classes, the evidence is that the applicants suggested that only a select 7 of those job classes required a pay equity band/level increase, the applicants’ job classes being two of those. Furthermore. Only two job classes of the 47 human resources job classes have been challenged to the Pay Equity Office and then the Tribunal. Therefore, while the applicants complain that their job classes were not evaluated in accordance with the Act, the evidence is clear that the applicants agreed (as pay equity specialists) with the placement of approximately 99.4% of the job classes in the non-union plan and have not challenged the placement of any other 45 job classes in human resources. This is by no means conclusive of this application, but it exemplifies that the process that was used by the City appears to be agreed to yield accurate results for the vast number of classifications, however they were evaluated.

The Standard

21. The keystone issue in this case is whether the Tribunal should review the City’s evaluations of the applicants’ job classes on a correctness or a reasonableness standard. The City submits that the Act places the obligation on the employer to make the pay equity comparisons and the standard remains a reasonableness standard. The applicants assert that because the Tribunal found that the human resources jobs were evaluated using a different process, that it cannot be a “range of outcomes” and therefore the Tribunal should apply a correctness standard.

22. On this point, it is apparent that the applicants overstate the Tribunal’s findings in its July 19, 2021 decision. In that decision, the Tribunal dismissed the City’s argument that the Tribunal should not look further into the application because it was a job classification grievance pursuant to the reasoning as set out in Centennial College, 2002 CanLII 49436 (ON PEHT). In the July 19, 2021 decision, the Tribunal found that because the evidence disclosed that the jobs were rated using a “different” process, that the City did not have an argument available to it that it would have had the pay equity plan been a deemed approved plan. As such, the applicants were entitled to present evidence that their job classifications should be placed at a higher level than what they were evaluated at by the City. As set out above, the Tribunal was explicit that it made no comment about the merits of the complaint and said that it could be that the City’s evaluation of the applicants’ job classes was entirely accurate even if the process used differed.

23. Furthermore, in its decision, the Tribunal noted that the fundamental issue with the City’s argument at that time was that the material used to evaluate the applicants’ job classes was no longer available, and the person who performed the evaluation did not present evidence. Instead, as a result of the July 19, 2021 decision, the Tribunal directed the parties to reevaluate the job classifications based on job descriptions/profile that the Tribunal directed them to create, and to re-evaluate the job classes using both descriptions. The parties complied with these directions.

24. In the Tribunal’s view, the process that it directed in its September 2, 2021 and November 18, 2021 decisions cured the procedural deficiencies that may have occurred with how the applicants’ job classes were described and evaluated prior to the July 19, 2021 decision. In effect, the Tribunal ordered the City to reevaluate the applicants’ job classes, which is what the City said should have happened in her email to Ms. Greene almost a decade ago. The applicants’ job classes have now been evaluated by the City, in consideration of the job descriptions prepared by both the applicants and the City, and compared against the other non-human resources job classes in the non-union pay equity plan. The applicants have had the opportunity to present their evidence and views about how their job classes should be evaluated, and that evidence has been considered by the Tribunal.

25. It is well established in the Tribunal’s jurisprudence that the evaluation of a job class is an exercise of discretion that could yield a range of reasonable outcomes. The standard has been described by the Tribunal repeatedly in the oft-cited decision of Ottawa Board of Education, 1996 CanLII 7947 (ON PEHT):

It is our view that the standard applicable to determining whether the contravention has been established is necessarily different, depending upon whether the provision in question sets an exact minimum standard or implies a range. Thus, where the Act is precise, compliance is clearly necessary. Where the Act grants an element of choice to those designing the plan, some deference to their decision is appropriate. When the provision of the Act alleged to be contravened sets an exact requirement, we will inquire whether the impugned aspect of the plan is correct. When the provision is not capable of exact application, but implies a range or an exercise of discretion, we will inquire whether the impugned aspect of the plan is reasonable. The decision about whether a plan complies with the minimum standards of Part I is thus as objective an exercise as is possible.

26. Accordingly, the Tribunal has held that some deference must be provided to the parties which are statutorily obligated to create a pay equity plan (whether that be the employer and union where the employees are represented by a bargaining agent, or the employer where no bargaining agent exists) where elements of choice are afforded to them by the Act.

27. In this case, the party obligated to create the pay equity plan is the City. The statutory obligation is found at section 7(1) of the Act:

Every employer shall establish and maintain compensation practices that provide for pay equity in every establishment of the employer.

28. Section 12 of the Act confirms that the obligation to conduct the comparison between female and male job classes rests with the employer:

Before the mandatory posting date, every employer to whom this Part applies shall, using a gender-neutral comparison system, compare the female job classes in each establishment of the employer with the male job classes in the same establishment to determine whether pay equity exists for each female job class

29. To contrast this obligation, the Act specifically provides bargaining agents the right to negotiate the GNCS and pay equity plans but does not provide those equivalent rights to employees who are not represented by a trade union, as in this case. Section 14(2) of the Act states:

(2) The employer and the bargaining agent for a bargaining unit shall negotiate in good faith and endeavour to agree, before the mandatory posting date, on,

(a) the gender-neutral comparison system used for the purposes of section 12; and

(b) a pay equity plan for the bargaining unit.

30. Therefore, the City is the party obligated to ensure that the applicants’ job classes are paid at a rate comparable to a male job class of equal or comparable value. As such, the Tribunal disagrees with the applicants’ submission that there is no range of reasonable outcomes in this case.

31. The fact that the applicable plan in this case has not been deemed approved, and that the Tribunal found that the applicants’ job classes may have been evaluated “in isolation” prior to the July 19, 2021 decision, does not change the standard that applicants must meet to succeed in their argument, especially since the Tribunal ordered the job classes to be reevaluated not in isolation, and in consideration of the applicants’ submissions. To reiterate, the impact of the Tribunal’s findings in its July 19, 2021 decision was to provide the applicants with the opportunity to provide their input and present evidence and demonstrate that the placement of their job classes should have been at a higher level, instead of having the applications dismissed based on its well-established jurisprudence set out in Centennial College, 2002 CanLII 49436 (ON PEHT) that the Tribunal does not inquire into allegations that a job classification was improperly rated “without more” evidence than just the disagreement with the evaluation results. As such, the Tribunal provided both parties with the opportunity to present the “more” which is not the typical way the Tribunal hears these types of disputes.

32. It is noteworthy that in the July 19, 2021 decision, the Tribunal held that the “respondent correctly highlighted that there was no evidence that the applicants evaluated their classes (and as pay equity experts could have) with access to their job descriptions, questionnaires using the GNCS complaint tool either. This will be something that the applicants will have to address during the hearing on the merits”. The applicants did not adequately address this aspect of the decision in their evidence or submissions.

33. In this case, the parties have redrafted and presented evidence about what they assert are the appropriate job descriptions, and how they assert those job classes should be evaluated. The evidence is too voluminous to be reproduced in this decision, nor is it necessary to do so, but the Tribunal has reviewed and considered all of the evidence and submissions with respect to each job description and the evaluation of subfactors for each of the job classes.

34. Accordingly, this decision is in consideration of the evidence and submissions that have been made in this proceeding, where the onus in this case rested with the applicants to persuade the Tribunal that the City’s evaluations of the applicants’ job classes were not reasonable.

Did the Job Descriptions/Profiles Fail to Capture Relevant Job Duties?

35. One of the reasons that the Tribunal could find that the City’s evaluation of a job class was unreasonable is that the job descriptions used in the evaluation failed to capture relevant job duties, and as a result, rendered the evaluation unreasonable.

36. As set out above, the Tribunal directed the parties to prepare their own job descriptions for each of the applicant’s job class, and to identify where they disagreed. This is a result of the fact that job profiles did not exist or otherwise could not be located for the applicants’ job classes. The parties provided a helpful chart that highlighted the differences between them.

37. Upon review of this document, the parties’ disputes about the job descriptions generally fall into two categories that we will refer to as: characterization disputes and contextual disputes.

38. The characterization disputes appear where it is obvious to the Tribunal that the parties’ disagreement is more about how they wanted to characterize a job duty, as opposed to a disagreement about the duty that was performed by the job class. The existence of this type of dispute is unsurprising to the Tribunal, as it is common for parties to attempt to draft their job duties in a manner where they believe that they will have an advantage on how the job is evaluated. In cross-examination, Ms. Greene admitted that job evaluation considers the actual duty that was performed as opposed to how one party characterized it. Fortunately, the Tribunal has ample evidence before it about the job duties performed to evaluate whether the job descriptions capture the relevant information.

39. An example of a characterization dispute is where Ms. Greene described herself as a “city expert” and the City described her skill as having “expertise”. These kinds of disputes are prevalent throughout their disagreements, but for the most part, the Tribunal sees that these distinctions do not affect the actual rating of the subfactors when reviewing the evaluation criteria. It is obvious to the Tribunal that the City recognized Ms. Greene as a job evaluation expert who managed a team of human resources personnel under her area of expertise, and it considered this expertise when it evaluated the position.

40. The Tribunal has reviewed each of these “characterization” disputes and arrives at the same conclusion. It is not evident to the Tribunal that the parties disagree much on what the applicants did in their jobs. Instead, where the parties disagree is the value that should be attributed to the work performed. These disputes are more appropriately considered where the Tribunal determines whether the City’s evaluations of the job duties were unreasonable, rather than whether the job description omitted relevant information.

41. The one dispute where there is a relevant disagreement is the level of leadership required by Ms. Nolan-Conway’s job class as a Senior Compensation Consultant. In consideration of the evidence, the Tribunal finds that the Senior Compensation Consultant job class did not require the level of leadership that the applicants purport, and it is not reasonable for the Tribunal to find that her Senior Compensation Consultant position required a higher level of leadership than the other Senior Compensation Consultants that worked in the human resources department. Accordingly, the Tribunal prefers the City’s job profile where the disputes involve the leadership and advice subfactor for Ms. Nolan-Conway’s classification.

42. The second category of disputes between the parties’ job descriptions are “contextual” disputes where one party has attempted to bolster its position in this proceeding by describing what happened during the applicants’ employment, as opposed to describing an actual job duty. Again, the Tribunal is benefitted from ample evidence about the applicant’s job duties and what was entailed during the performance of their jobs to be able to afford the appropriate weight to these factors in this case.

43. One example of a “contextual” disagreement between the parties where Ms. Greene listed the following as a job duty:

The amalgamation was the result of new legislation passed by the province and was the product of the fusion of seven former municipalities that reflected a massive restructuring of municipal institutions. It was a massive undertaking for which there were no precedents or predetermined outcomes. Provided leadership and advice on all compensation and policy issues.

44. The relevant job duty in the example above is “provided leadership and advice on all compensation and policy issues”. The fact that the City of Toronto was formed as an amalgamation of different municipalities and was a “massive undertaking” is interesting and provides information as to what Ms. Greene did in the 17 years she held the position, but it is not a job duty. Ms. Greene submitted that this wording is important to understand the scope, depth, breadth and complexity of the projects and job functions. While the Tribunal agrees that context is helpful to understand the nature of the job duties performed, inserting context in a job description is not typical and it is not unreasonable to exclude “context” from a job description or job profile. On review of the other job descriptions/profiles that were relied on by the parties, those job descriptions/profiles did not contain the same kind of this contextual information.

45. Likewise, there are several examples where the City attempted to qualify a job duty by referring to that duty being under the supervision or direction of Ms. Greene’s director. Again, these disputes appear to be a contextual dispute that is more appropriately considered when the Tribunal determines whether the evaluations were unreasonable, as opposed to whether the job description accurately reflects the job duties.

46. Accordingly, the Tribunal has reviewed the job descriptions provided by the parties and the disputes between them. The Tribunal has considered the totality of the evidence and the parties’ submissions. The Tribunal finds that the City’s job descriptions/profiles reasonably capture the relevant job duties of the applicants’ job classes.

Were the City’s Evaluations of the Applicants’ Job Classes Unreasonable?

47. The onus is on the applicant to demonstrate that the evaluation of the applicant’s job class was unreasonable. As set out above, the City’s evaluation does not need to be “correct” or the same evaluation that the Tribunal would have afforded to a position so long as the result falls within the range of reasonable outcomes.

48. On this point, the applicants’ submissions focus on what they believe to be the “correct” result in each of the disputed factors. The applicant identified a number of male comparators for each subfactors she asserts should have been rated higher. The City relied on its own select comparisons in support of why its evaluations are reasonable.

49. This exercise reaffirms exactly why the Tribunal has repeatedly held that it does not review job classification disputes in isolation, and why it directed a process for the parties to evaluate the job classes not in isolation prior to hearing evidence on these issues. There are hundreds of job descriptions, and several could be used to support either the applicants’ or City’s position in each subfactor. In this case, it is apparent that both parties “cherry-picked” a small subset of comparators in support of their positions. By no means did either party provide an exhaustive list of all the comparisons that could be made relative to one another, and this was not expected of the parties. This is exemplified by the applicants’ analysis references, and charted, dozens if not hundreds of additional positions that could have been used for comparison. In the Tribunal’s view, this information clearly demonstrates that there are reasonable comparisons that could be made in support of both the applicants’ and respondent’s positions on each subfactor, and there is indeed a range of reasonable outcomes.

50. In each subfactor, the applicants compare their job classes to male comparators that have the higher subfactor score. The City submits that the gender dominance of job classes is not relevant or used to specifically compare subfactors. The City is correct on this point.

51. There is no statutory requirement or principle of job evaluation that each female job class is compared to a male job class in each subfactor. What the Act requires is that job classes are evaluated using a GNCS, and a value is attributed to that position based on the ratings and weightings of each subfactor. Once those ratings have been finalized, the job classes get placed in wage bands/levels. What is required to achieve pay equity using the job-to-job method is that at least one male comparator is placed in each job band in accordance with its overall evaluation, and then the wage comparisons are made. Where the male wage rate is equal to or less than the female job class in the same band, no pay equity adjustments are required. If the male comparator is paid more than the female job class, then the wage rate of the female job class is raised to achieve equity. Where multiple male comparators exist, the Act dictates that pay equity is achieved where the female job classes are paid comparably to the lowest paid male comparator in the band/level. Therefore, while it is reasonable and understandable for a party to point to another job class that they assert shares similar characteristics to support their position for a specific rating, it is not a requirement to equivalate a male comparator to each of those ratings.

52. The City’s pay equity plan is interesting in that the descriptions for the subfactor ratings is described at each even numbered level and there are no additional criteria set out for the odd numbered levels. Instead, the odd numbered levels act almost as half levels, where if the job class possesses enough elements of the next even level, but not all, they can be rated between the two levels. This demonstrates that there should be an even higher level of discretion afforded to when a job class possesses enough of the characteristics of the higher band to move up to the odd numbered level (as compared to a more typical plan which sets out criteria for each level).

53. The Tribunal has reviewed and considered the evidence and the parties’ submissions on each of the subfactors in dispute. The Tribunal concludes that it is evident that the City’s evaluations are reasonable, and the placement of the Manager of Compensation at level 8, and Senior Compensation Consultant at level 7 are reasonable. While it may be that this panel may have evaluated some of the subfactors at the level sought by the applicants, it is not the role of the Tribunal to substitute its view of what it may have done unless the evaluation was unreasonable, and the Tribunal found no evidence that the City’s ratings were unreasonable.

54. With respect to the principle of relativity and hierarchy, the Tribunal did not review the parties’ ratings and evaluations relative to other human resources positions (except the two applicant’s positions as compared to one another). This was intentional to avoid the potential that the human resources job classes were systemically undervalued as the Tribunal found that human resources jobs were evaluated “differently” in the July 19, 2021 decision. The evidence disclosed that non-human resources job classes possessed similar differential ratings between directors and managers as there are many occurrences where managers are placed at level 8 and a director is placed at band 10 or 11 in the same department. While, in the Tribunal’s view, it could also have been reasonable to have evaluated Ms. Greene’s job class at level 9, it was not unreasonable to have evaluated it at level 8 given the evaluation criteria and when considering the principles of relativity between job classes across the non-union pay equity plan. The Tribunal found no evidence that it would be reasonable to have the Senior Compensation Consultant role be placed at the same level as the manager they report to, and as set out above, found that Ms. Nolan-Conway’s job description over emphasized the level of her leadership and advice responsibilities.

Disposition

55. The Tribunal finds that the applicants’ job classes have been evaluated in accordance with the principles of the Act. In consideration of the evidence and the parties’ submissions, the Tribunal confirms that the ratings of level 8 for the Manager of Compensation and level 7 for the Senior Compensation Consultant are reasonable.

"M. David Ross" Chair

“I concur” "Patricia Greenside" Member

“I concur” "Carol Phillips" Member