Compensation and Employment Standards for School District Employees Not Subject to a Collective Agreement
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- Millicent Walker
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1 Plicy Backgrund Cmpensatin and Emplyment Standards fr Schl District Emplyees Nt Subject t a Cllective Agreement Sectin 6 f the Public Sectr Emplyers Act authrizes the emplyers assciatin t crdinate cmpensatin fr emplyees wh are nt subject t cllective agreements. In accrdance with this statutry directin, cmpensatin and emplyment standards (the Standards ) were develped by the British Clumbia Public Schl Emplyers Assciatin (BCPSEA) and apprved by the Public Sectr Emplyers Cuncil (PSEC). BCPSEA intrduced the Standards t the K-12 public educatin sectr in 1995; a revisin t the Standards was apprved by PSEC and distributed t schl districts in In Octber 2002, gvernment enacted amendments t the Public Sectr Emplyers Act thrugh Bill 66, Public Sectr Emplyers Amendment Act. With these amendments, the K-12 public educatin sectr, alng with the public sectr as a whle, mved frm a vluntary cmpliance mdel with respect t administratin f exempt cmpensatin and cntracts t a statutry mdel. On December 6, 2002, the Minister f Finance apprved the BCPSEA Cmpensatin and Emplyment Standards as a cmpensatin plan under sectin 14.3 f the Public Sectr Emplyers Act. In May 2008, further amendments t the Public Sectr Emplyers Act remved the psitin f Superintendent f Schls frm cverage under these Standards. Bards f Educatin are slely respnsible fr the review and determinatin f cmpensatin fr the psitin f Superintendent. Fr all ther executive and exempt psitins, bards f educatin are required t adhere t these Standards as a way f demnstrating fiscal respnsibility and sund management practices t the public and t their emplyee grups. In December 2015, PSEC directed further amendments t these Standards t align with the cmmn cmpensatin philsphy in the brader public sectr in British Clumbia.
2 Objectives An effective set f cmpensatin and emplyment standards must respect the autnmy and accuntability f individual elected bards f educatin while at the same time ensuring cmpliance with statutry requirements under applicable legislatin. In develping these standards, every effrt has been made t: 1. Prvide crdinatin and cmparability fr exempt emplyees in the K-12 sectr. 2. Enable bards f educatin t attract and retain high quality persnnel. This implies that cmpensatin must: be cmpetitive and reasnably cmparable t cmpensatin received fr psitins with similar respnsibilities in the public service in ther public sectrs, and t a lesser extent, private sectr rganizatins fr in-demand jbs when apprpriate. be sufficiently attractive t retain existing persnnel and t attract new individuals f high calibre t exempt psitins have apprpriate relatinships frm ne psitin t thse at ther levels. 3. Prvide full disclsure. 4. Accunt fr ttal cmpensatin. 5. Recgnize the diversity f schl districts. 6. Prvide a framewrk that assists bards f educatin in cmplying with their fiscal bjectives and supprt in fulfilling their respnsibilities. 7. Prvide simplicity, timeliness and ease f administratin. Cmpensatin and Emplyment Standards The Cmpensatin and Emplyment Standards (the Standards ) cnsist f the fllwing: I. Rles, Respnsibilities, and Reprting Requirements t ensure full disclsure t the public at the lcal bard f educatin level, t BCPSEA, and t the Public Sectr Emplyers Cuncil (PSEC). II. III. Cmpensatin Standards t ensure a cnsistent cmpensatin philsphy and cnsistent cmpensatin administratin practices in the K-12 public educatin sectr. The cmpensatin standards must be incrprated int individual cntracts f emplyment, as well as letters f appintment and general terms and cnditins f emplyment. Exempt staff cmpensatin is reviewed against cmprehensive market cmpensatin surveys cnducted in the brader public sectr and, t a lesser extent, the private sectr fr in-demand jbs when apprpriate. Cmpensatin shuld reflect a defensible and technically sund apprach fr determining cmpetitive cmpensatin levels fr exempt psitins in the public educatin sectr and reflect the public s desire fr fiscally respnsible cmpensatin levels in the public sectr generally. Emplyment Standards t ensure cnsistent emplyment administratin practices in the K-12 public educatin sectr. The emplyment standards must be incrprated int individual cntracts f emplyment, as well as letters f appintment and general terms and cnditins f emplyment. 2 Page
3 I. Rles, Respnsibilities and Reprting Requirements 1.1 In meeting the bjectives f these Standards, BCPSEA: Prvides technical assistance t bards f educatin fr determining the applicatin f these Standards and legislative requirements t exempt psitins in the schl district. This includes determining levels f cmpensatin and classificatin f psitins within the benchmark cmpensatin categries. Determines any requests fr variance f this plicy. Crdinates the reprting f ttal cmpensatin and emplyment cntract matters fr executive cmpensatin disclsure as defined in the Public Sectr Emplyers Act, as well as ther exempt emplyees in the K-12 public educatin sectr. 1.2 In meeting the bjectives f these Standards, bards f educatin are required t: Develp and maintain written plicies and emplyment cntract prvisins with respect t prcedures gverning emplyment, cmpensatin, benefits, and expenses that cmply with these Standards and relevant legislatin. Cmpensatin fr all exempt psitins will take int accunt: Ttal cmpensatin relatinships inside and utside the rganizatin Special circumstances such as market cnditins, gegraphy, cst-fliving, and jb respnsibilities Need fr public accuntability and transparency. Maintain high ethical standards and avid cnflict f interest with regard t expense and cmpensatin prcedures. In particular, n emplyee shuld apprve a benefit payment r expense reimbursement t him/herself. Prvide n request t BCPSEA, cmpensatin and emplyment-related plicies, emplyment cntracts, and cmpensatin infrmatin fr all exempt staff. This includes cmplying with the reprting requirements under the Public Sectr Emplyers Act with respect t executive cmpensatin disclsure and reprting f emplyment terminatins under the Emplyment Terminatin Standards Regulatin. Prvide n request t the public, current infrmatin n cmpensatin and emplyment-related plicies, and ttal cmpensatin levels fr all exempt staff. This includes cmplying with the reprting requirements under the Public Sectr Emplyers Act with respect t executive cmpensatin disclsure. Submit any request fr variance f this plicy t BCPSEA fr determinatin. 3 Page
4 II. Cmpensatin Standards 2.1 Cmpensatin data In rder t ensure defensible and cmpetitive cmpensatin levels in the K-12 public educatin sectr, BCPSEA regularly cnducts surveys f ttal cmpensatin paid t exempt benchmark psitins. Benchmark psitins are present in a majrity f schl districts; they represent the spectrum f the exempt staff wrkfrce and have well knwn and relatively stable jb cntent. In determining the relevant labur markets fr btaining cmpensatin data fr executive and exempt emplyees, BCPSEA cnsidered the fllwing questins: what is the supply sectr fr these emplyees (frm where d bards f educatin recruit emplyees) what is the destinatin sectr fr these emplyees (t where d bards f educatin lse emplyees). The scpe f the relevant labur market fr tp level psitins in the K-12 public educatin sectr may include public bards f educatin in British Clumbia, Alberta, Saskatchewan, and Ontari. Other rganizatins in the British Clumbia public sectr, including the BC Public Service Agency, are als surveyed. Private sectr rganizatins are surveyed fr certain high-demand jbs when apprpriate. In additin t the regular survey cycle, BCPSEA cnducts ttal cash surveys n an nging basis t ensure cnsistent cmpensatin practices with the relevant labur markets. 2.2 Elements f ttal cmpensatin Annual base salary Declared persnal prtin (fr Revenue Canada purpses) f vehicle allwance r benefit received by the prvisin f an emplyer-leased vehicle Unvuchered expense allwance, with the exceptin f reasnable meal r travel per diems that are directly related t a specific activity n behalf f the emplyer Rent-free r subsidized husing (in accrdance with Revenue Canada reprting requirements) Nrthern r islatin allwance Vacatin travel allwance Emplyer cntributin twards emplyee benefits, including: medical, health and dental insurance plans life insurance and lng-term disability plans emplyee and family assistance plans pensin plans any ther benefits. Any ther frms f cmpensatin. 4 Page
5 2.3 Cmpensatin administratin Exempt cmpensatin in the K-12 public educatin sectr is administered within the fllwing framewrk Cmpensatin philsphy The cmpensatin philsphy is based upn a set f principles that guide the develpment and maintenance f salary structures and ttal cmpensatin packages and prgrams. At its cre is an integrated view f cmpensatin and rewards nt nly traditinal, quantifiable elements such as salary and benefits (cmpensatin), but als mre intangible elements such as career pprtunities, learning and career develpment, wrk challenge, and supprtive culture (rewards). The ttal rewards cmpensatin prgram further integrates with plans that establish a bard f educatin s verall educatin, business, and human resurces strategies and bjectives t facilitate the attractin and retentin f qualified, experienced, mtivated and high-ptential emplyees wh are cmmitted t bards verarching gal f delivering a high quality public educatin experience t BC students. Cmpensatin structures shuld be cnsistent with the prvince s Taxpayer Accuntability Principles (TAP) f cst cnsciusness, accuntability, apprpriateness, service, respect, and integrity. These principles were established in 2014 and reflect the requirement that all public entities act in the best interests f taxpayers. Inherent in the cmpensatin philsphy are the fllwing cre principles: Perfrmance: The cmpensatin structure and administratin f the structure supprts and prmtes meaningful career grwth and develpment pprtunities, and a perfrmance-based (merit) rganizatinal culture. Differentiatin: Differentiatin f cmpensatin is supprted where there are differences in the scpe f the psitin within an rganizatin, and/r due t superir individual/team cntributins. Accuntability: Cmpensatin decisins are bjective and based upn a clear and well dcumented ratinale that demnstrates the apprpriate expenditure f public funds. Transparency: The cmpensatin prgram is designed, managed, administered, and cmmunicated in a manner that ensures the prgram is clearly understd by emplyees and the public while prtecting individual persnal infrmatin. 5 Page
6 2.3.2 Cmpensatin structure Bards f educatin are respnsible t establish and maintain a defensible, credible cmpensatin structure fr executive and exempt emplyees, taking int accunt all the elements f ttal cmpensatin. The annual base salary cmpnent f ttal cmpensatin shuld reflect an independent analysis f labur market cnditins (e.g., BCPSEA ttal cmpensatin surveys and data) and prvide fr sufficient differential abve psitins supervised t attract and retain individuals f a high calibre Cmpensatin adjustments Adjustments t exempt cmpensatin levels must be reasnable and defensible, and reflect the public s desire fr financially respnsible public sectr cmpensatin practices. Adjustments t exempt cmpensatin levels must be administered within existing peratinal budgets. Service levels cannt be reduced t fund exempt cmpensatin levels. Decisins related t emplyee prgressin thrugh established pay bands must cnsider whether perfrmance expectatins fr the particular jb have been met t the bard s satisfactin. Cmpensatin mandates adpted by the Public Sectr Emplyers Cuncil frm time t time are the fficial plicy f BCPSEA and any adjustments t exempt cmpensatin levels will be cnsidered within the cntext f the applicable cmpensatin mandate. Any increases in ttal cmpensatin must be apprved by BCPSEA prir t implementatin by the bard f educatin Vehicle allwance/lease The prtin f cash cmpensatin attributable t an emplyerprvided vehicle allwance must be treated as a separate cmpnent f ttal cmpensatin and must nt be rlled int the annual base salary prtin. The bard f educatin is respnsible t ensure that: vehicle leases, when utilized, are a cst effective transprtatin slutin fr the schl district. Revenue Canada and Canada Tax Cde rules are cmplied with. vehicle leases cmply with the leased vehicle plicy included as Appendix 1 t these Standards Expense prcedures Bards are expected t have plicies gverning expense guidelines, prcedures and reimbursement frm that are cnsistent with TAP and cnfrm with gd gvernance practice in the public sectr. 6 Page
7 2.3.6 Inapprpriate cmpensatin plicies The fllwing cmpensatin plicies are deemed t be inapprpriate fr a public sectr emplyer and must nt be cntained in any emplyment cntract, letter f appintment, r general terms and cnditins f emplyment. Scial and recreatinal club memberships fr the benefit f an individual. Hwever, an emplyer may prvide club memberships fr a business r human resurce purpse. Bard paid spusal r cmpanin travel. Payment f all r a prtin f retirement allwances and/r service recgnitin allwances while the emplyee is in the active emply f the bard f educatin. Bard paid gasline, maintenance, r insurance fr the persnal use f bard-wned vehicles. III. Emplyment Standards 3.1 Bards f educatin are expected t implement the fllwing cmpensatinrelated plicies in emplyment cntracts r terms and cnditins f emplyment with staff nt subject t a cllective agreement: Cntract term, cntract renewal, cntract terminatin Bards f educatin are respnsible fr ensuring that they are able t eliminate an exempt psitin upn rerganizatin f the district. Terms and cnditins f emplyment must be pen fr review and negtiatin n a regular basis at least nce every five years r at the request f either party. Renewal f term emplyment cntracts must require specific actin n the part f the bard f educatin; prvisins fr autmatic rllver f term cntracts in the absence f specific actin by the bard f educatin are nt permissible Terminatin f emplyment Exempt emplyees are subject t the prvisins f the Public Sectr Emplyers Act including the Emplyment Terminatin Standards Regulatin. The Act and Regulatin are attached as Appendix 2 t these Standards. Where an emplyee gives cause fr terminatin, the emplyer may terminate the emplyee in its abslute discretin, withut any ntice f terminatin r pay in lieu theref. Severance payments shall nt be made in the case f vluntary resignatin. 7 Page
8 Revisins and Updates Retirement benefits An emplyer may prvide a paid pre-retirement leave r allwance r paid retirement leave r allwance that is generally available t exempt emplyees but an emplyer shall nt include a paid preretirement leave r allwance t an individual that is nt generally available t all exempt emplyees. An emplyer may expend funds fr a retirement r departure gift upn retirement r resignatin f a bard member r exempt emplyee. The amunt f funds spent shuld recgnize that the gift is a tken f appreciatin and is nt significant enugh t be included as an element f ttal cmpensatin. Any revisins t these Cmpensatin and Emplyment Standards will be subject t the apprval f the Public Sectr Emplyers Cuncil and the Minister f Finance. These Cmpensatin and Emplyment Standards, apprved by the BCPSEA Bard f Directrs, the Public Sectr Emplyers Cuncil, and the Minister f Finance, replace all previus cmpensatin and emplyment standards. Chrnlgy: Apprved by BCPSEA Bard Nvember 17, 1995; Apprved by PSEC December 11, 1995 Amendments apprved Octber 25, 1999 Amendments apprved July 2004 Amendments apprved September 6, 2007 Amendments apprved May 2008 Amendments apprved Nvember 2012 Amendments apprved January Page
9 Appendix 1 Leased Vehicle Plicy K-12 Public Educatin Sectr Backgrund The Public Sectr Emplyers Cuncil has prpsed that the use f leased vehicles by management staff be gverned by a publicly defensible plicy. The British Clumbia Public Schl Emplyers Assciatin believes that the challenges fr district staff f managing a multisite wrkplace require a plicy tailred specifically t the K-12 sectr. A wrking grup was struck t cme up with a leased vehicle plicy which meets the fllwing bjectives: Ensure that vehicle leases, when utilized, are a cst effective transprtatin slutin fr the schl district. Ensure that Revenue Canada and Canada Tax Cde rules are cmplied with. Ensure that the use f leased vehicles is prper and respnsible accrding t perceptins held by the majrity f taxpayers f British Clumbia. Plicy Guidelines 1. The plicy guidelines apply t leased vehicles where the cst f the vehicle lease exceeds the cst f paying mileage t that emplyee. In these cases, the lease is defined as frming part f the emplyee s ttal cmpensatin (even thugh there are times when the vehicle is used fr schl district purpses). 2. Leased vehicles may nly be prvided as part f ttal cmpensatin t superintendents, secretary-treasurers, assistant superintendents r equivalent psitins. 3. The type f vehicle leased must nt exceed that necessary t perfrm the required duties f the psitin. 4. The lease must be structured t be the mst cst effective fr the schl district and ensure that any residual benefit accrues t the schl district and nt t the emplyee. 5. Tender specificatins must be publicly defensible. 9 Page
10 Appendix 2 Public Sectr Emplyers Act and Emplyment Terminatin Standards Regulatin Cpyright (c) Queen's Printer, Victria, British Clumbia, Canada License Disclaimer B.C. Reg. 379/97 O.C. 1266/97 Depsited Nvember 18, 1997 effective May 1, 1997 Public Sectr Emplyers Act EMPLOYMENT TERMINATION STANDARDS Nte: Check the Cumulative Regulatin Bulletin 2015 and 2016 fr any nn-cnslidated amendments t this regulatin that may be in effect. 1 Definitins [includes amendments up t thse made by Sch.] 2 Limitatin n ntice perid and severance 2.1 Limitatin n retiring allwance 3 Duties f emplyee during ntice perid 4 Severance payment instead f ntice 5 Amunt f ntice and severance 5.1 Executive ntice and severance 6 Re-emplyment in the public sectr 7 Term f emplyment cntracts The Emplyment Terminatin Standards established by the Public Sectr Emplyers Cuncil are adpted as emplyment terminatin standards fr the purpses f sectin 14.4 f the Public Sectr Emplyers Act. Definitins 1 In these standards: "Act" means the Public Sectr Emplyers Act; "emplyee" has the same meaning as in sectin 14.1 f the Act; 10 Page
11 "ntice f terminatin" means ntificatin by a public sectr emplyer t an emplyee that his r her cntract f emplyment will be terminated; "ntice perid" means the length f time frm the date n which ntice f terminatin is given t an emplyee until the date n which emplyment will terminate; "retiring allwance" means a payment that, by a cntract f emplyment, an emplyee may receive n r after retirement f the emplyee frm his r her emplyment in recgnitin f the emplyee's service, but des nt include the fllwing: (a) superannuatin r a pensin benefit; (b) an amunt received as a cnsequence f the death f the emplyee; (c) a benefit designated by the minister; "severance" means the severance payment made in lieu f the ntice perid; "successr emplyer" means a purchaser, lessee r transferee referred t in sectin 35 f the Labur Relatins Cde. [am Sch, s. 1.] Limitatin n ntice perid and severance 2 (1) An emplyee must nt be given a ntice perid r severance in the case f (a) terminatin fr cause, (b) expiry f a cntract f emplyment with a definite term, r (c) vluntary resignatin r retirement. (2) Subsectin (1) des nt prevent an emplyer frm prviding severance under a labur adjustment plicy r prgram apprved by the minister. 11 Page
12 (3) A labur adjustment plicy r prgram apprved by the cuncil befre this subsectin cmes int frce is deemed t be a labur adjustment plicy r prgram apprved by the minister fr the purpses f subsectin (2). [am Sch, s. 2.] Limitatin n retiring allwance 2.1 (1) An emplyee wh receives a ntice perid r severance must nt be given a retiring allwance. (2) Subsectin (1) des nt prevent an emplyer frm prviding a retiring allwance under a labur adjustment plicy r prgram apprved by the minister. (3) A labur adjustment plicy r prgram apprved by the cuncil befre this subsectin cmes int frce is deemed t be a labur adjustment plicy r prgram apprved by the minister fr the purpses f subsectin (2). [en Sch, s. 3.] Duties f emplyee during ntice perid 3 (1) During the ntice perid, a public sectr emplyer, in its sle discretin, may (a) require the emplyee t cntinue with his r her duties, assignment, tasks r prjects, (b) assign the emplyee t ther duties, assignments, tasks r prjects with the same r a successr emplyer, ntwithstanding that the assignment may amunt t a cnstructive dismissal, if (i) the assignment is reasnably cnsistent with the emplyee's ability and respnsibility at the time f the assignment, and (ii) the emplyee is nt required t relcate unreasnably, 12 Page
13 (c) assign the emplyee t a nn-successr emplyer with the agreement f the emplyee, r (d) excuse the emplyee frm perfrming his r her duties. (2) If an emplyee refuses t perfrm duties assigned by the emplyer in accrdance with this sectin, the emplyee is deemed t have vluntarily resigned and is nt entitled t a cntinuatin f the ntice perid r any payment in lieu f the ntice perid. Severance payment instead f ntice 4 (1) If an emplyer terminates emplyment withut cause and excuses the emplyee frm perfrming his r her duties under sectin 3 (1) (d), the emplyer, in its sle discretin, may prvide the emplyee with severance. (2) Severance must be in the frm f peridic payments unless the emplyer, in its sle discretin, cnsiders a lump sum payment t be mre apprpriate. Amunt f ntice and severance 5 (1) A ntice perid r severance must nt exceed the fllwing: (a) an amunt calculated accrding t an emplyment terminatin plan fr the emplyee that has been apprved by the minister; (b) if n emplyment terminatin plan has been apprved by the cuncil, the lesser f (i) an amunt equal t the remaining term f the cntract, r (ii) an amunt prvided under cmmn law calculated as thugh the emplyee were subject t an indefinite term agreement with n prvisin regarding severance. 13 Page (1.1) An emplyment terminatin plan apprved by the cuncil befre this subsectin cmes int frce is deemed t be an emplyment terminatin plan apprved by the minister fr the purpses f subsectin (1).
14 (2) Despite subsectin (1), the maximum ntice perid that an emplyee may be given is 18 mnths. (3) Despite subsectin (1), the maximum severance that an emplyee may be given is the value f salary and benefits the emplyee wuld therwise be entitled t fr the ntice perid. [am Sch, s. 4.] Executive ntice and severance 5.1 (1) In additin t the limits impsed under sectin 5, this sectin applies in relatin t emplyees f a public sectr emplyer, ther than an emplyer referred t in paragraph (g) f the definitin f "public sectr emplyer" in sectin 1 f the Act, wh are appinted t r emplyed in the fllwing psitins: (a) deputy minister; (b) chief executive fficer r president f a public sectr emplyer; (c) superintendent f a schl. (2) The ntice perid r severance that may be given t an emplyee in a psitin referred t in subsectin (1) must nt exceed (a) an amunt calculated accrding t an emplyment terminatin plan fr the emplyee that has been apprved by the Treasury Bard, r (b) if n emplyment terminatin plan has been apprved by the Treasury Bard, the fllwing limits: (i) up t a 6 mnth ntice perid r severance, if the emplyee has served r been emplyed in that psitin fr fewer than 12 mnths; (ii) up t a 9 mnth ntice perid r severance, if the emplyee has served r been emplyed in that psitin fr 12 t 17 mnths; 14 Page (iii) up t a 12 mnth ntice perid r severance, if the emplyee has served r been emplyed in that psitin fr 18 t 35 mnths;
15 (iv) up t a 14 mnth ntice perid r severance, if the emplyee has served r been emplyed in that psitin fr 36 t 47 mnths; (v) up t a 16 mnth ntice perid r severance, if the emplyee has served r been emplyed in that psitin fr 48 t 59 mnths; (vi) up t an 18 mnth ntice perid r severance, if the emplyee has served r been emplyed in that psitin fr 60 r mre mnths. (3) Treasury Bard may nt apprve an emplyment terminatin plan under subsectin (2) (a) that wuld prvide an emplyee mre than a 12 mnth ntice perid r severance fr fewer than 18 mnths f service r emplyment. (4) An emplyment terminatin plan apprved by the cuncil befre this subsectin cmes int frce is deemed t be an emplyment terminatin plan apprved by the Treasury Bard fr the purpses f subsectin (2). [en Sch, s. 5.] Re-emplyment in the public sectr 6 (1) In this sectin, "re-emplyment" includes entering int a cntract fr services with a public sectr emplyer either individually r thrugh a sle prprietrship, partnership r crpratin. (2) An emplyee must ntify the emplyer f any re-emplyment with a public sectr emplyer during the ntice perid r perid f ntice in lieu f which severance is prvided. (3) If an emplyee cmmences emplyment with a public sectr emplyer during the ntice perid r perid f ntice in lieu f which severance is prvided, (a) n severance cvering this perid f re-emplyment is payable, and 15 Page
16 (b) the emplyee must pay the gvernment any amunt that is attributable t the perid during which the emplyee is re-emplyed. (4) During the ntice perid r perid in lieu f which severance is prvided, if an emplyee is re-emplyed at a lwer level f cmpensatin, nthing in this sectin prevents an emplyer frm prviding t the emplyee an amunt equivalent t the difference between their frmer cmpensatin level and their cmpensatin level upn re-emplyment. Term f emplyment cntracts 7 If an emplyee is emplyed under a cntract f emplyment fr a definite term the cntract must (a) subject t paragraph (b), be fr a term f nt mre than 5 years, and (b) if emplyment under the cntract may be extended fr mre than 5 years, make the extensin cnditinal n a renegtiatin f the cntract during the term f the cntract. [en Sch, s. 6.] Prvisins f the Public Sectr Emplyers Act, R.S.B.C. 1996, c. 384, relevant t the enactment f this regulatin: sectin 14.4] Cpyright (c) Queen's Printer, Victria, British Clumbia, Canada 16 Page
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