Audit report
Assessment of the Implementation of the 2019 Addendum to the 2006 Canadian Human Rights Settlement Agreement
Canada Research Chairs Program

© His Majesty the King in Right of Canada, as represented by the Minister of Innovation, Science and Industry of Canada, 2023

Cat. No. CR22-127/2023E-PDF
ISBN 978-0-660-69002-5

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Audit Report—Canada Research Chairs Program

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On this page

• Executive summary
• 1. Background
• 2. Audit objective and scope
• 3. Audit methodology
• 4. Audit observations
• 5. Overall conclusion
• 6. Audit team
• Appendix I – Detailed Status of the 2019 Addendum and 2021 Canadian Human Rights Settlement Agreement Requirements
• Appendix II – Audit lines of enquiry and criteria
• Appendix III – Management response to 2023 audit recommendations

Executive summary

Background

The Canada Research Chairs Program (the Program) invests approximately $311 million per year in grants to Canadian postsecondary institutions to fund research professorships through 2,285 Canada Research Chairs. This is to attract and retain a diverse cadre of world-class researchers, to reinforce academic research and training excellence in Canadian postsecondary institutions.

In 2006, a Settlement Agreement was signed between the Government of Canada and a group of eight academics, requiring the Program to implement specific measures to increase the representation of individuals from the four designated groups as identified in the Employment Equity Act: women, visible minorities, persons with disabilities and Aboriginal Peoples. The Program currently defines the four designated groups as: women and gender minorities, racialized individuals, persons with disabilities and Indigenous Peoples. These current terms will be used in the rest of the report.

In 2019, an Addendum to the 2006 Settlement Agreement was signed, specifying legally binding requirements for the Program, to align with Equity, Diversity and Inclusion (EDI) best practices. The Addendum identified specific requirements for the Program and for postsecondary institutions to continue to participate in the Program. The Addendum includes requirements for monitoring and enforcement measures for the Program to implement.

In 2021, a Canadian Human Rights Settlement Agreement was reached between the Program and an individual who filed a complaint with the Canadian Human Rights Tribunal in 2017. The 2021 Settlement Agreement includes consequences that the Program must impose on institutions who did not meet their EDI requirements.

Why It Is Important

The measures included in the 2019 Addendum identify specific actions to address systematic barriers that have led to the underrepresentation of individuals from the four designed groups in the selection of chairholders under the Program. If Canada is going to reach its full potential for research excellence, there needs to be diversity of perspectives to tackle issues and respond to challenges effectively. Therefore, it is critical that researchers do not face systemic barriers in accessing and benefiting from the Program.

The 2019 Addendum requires that an internal audit be carried out three years after it is signed to formally assess the progress of its implementation. In addition, the 2021 Settlement Agreement requires the internal audit to assess the implementation of the consequences tied to the EDI requirements for institutions. Ensuring that the Program has made progress in implementing the measures included in the Addendum is important to ensure that the benefits of EDI best practices are realized to achieve the objectives of the Program: a world-class and impactful Canadian research ecosystem.

Authority

The Assessment of the Implementation of the 2019 Addendum to the 2006 Canadian Human Rights Settlement Agreement is an assurance engagement included in the approved 2022-25 NSERC and SSHRC Risk-Based Audit Plan.

Audit Objective and Scope

The objective of this audit engagement was to assess the progress of the Program’s implementation of the requirements of the 2019 Addendum to the 2006 Canadian Human Rights Settlement Agreement.

The scope of this assessment included the measures taken by Program to implement the requirements of the 2019 Addendum and the 2021 Canadian Human Rights Settlement Agreement. The assessment examined the period between June 2019 and December 2022.

Summary of Key Findings

The Program is responsible for implementing and monitoring the requirements in the 2019 Addendum and the 2021 Settlement Agreement. The requirements address equity targets^{Footnote 1}, EDI action plans^{Footnote 2} and EDI public accountability and transparency^{Footnote 3}, and consequences when requirements are not met by institutions which are funding recipients under the Program.

The 2019 Addendum and the 2021 Settlement Agreement comprise 85 distinct requirements that were separately assessed. The assessment is based on the evidence of the progress of implementation of each of the 85 requirements up to December 31, 2022. The implementation status of each of the 85 requirements is provided in Appendix I of this report. The following is a summary of the assessment of the progress made in the implementation of the 85 requirements.

Overall, the Program has made significant progress on implementing the requirements. The assessment found that the Program is continuously monitoring the progress in terms of compliance with the requirements and that enforcement measures were taken and implemented when institutions failed to meet the compliance requirements.

The Program would benefit by developing a roadmap outlining the path forward to implement the remaining requirements. Secondly, the Program should develop a methodology for the risk-based monitoring of chair nominations and define which additional measures can be enforced if an institution repeatedly fails to meet the required targets.

Overall Conclusion

The Program made significant progress in the implementation of the 2019 Addendum and the 2021 Settlement Agreement requirements. The Program monitors the progress in terms of compliance with the requirements and enforcement measures were taken and implemented when institutions failed to meet the compliance requirements.

1. Background

The Canada Research Chairs Program (the Program) stands at the centre of a strategy to make Canada one of the world’s top countries in research and development. It invests approximately $311 million per year to attract and retain a diverse cadre of world-class researchers, to reinforce academic research and training excellence in Canadian postsecondary institutions.

In 2000, the Government of Canada created a program to provide funding to establish research professorships—Canada Research Chairs—in eligible degree granting institutions across the country. There are currently 2,285 Canada Research Chairs allocated within the Program to promote research excellence in engineering and the natural sciences, health sciences, humanities and social sciences. These researchers improve our depth of knowledge and quality of life, strengthen Canada’s international competitiveness, and help train the next generation of highly skilled people through student supervision, teaching and the coordination of other researchers’ work.

In 2003, a group of eight academics from across Canada filed human rights complaints alleging the Program discriminated against individuals who are members of protected groups under the Canadian Human Rights Act. In 2006, a settlement agreement was signed requiring the Program to implement specific measures to increase the representation of individuals from the four designated groups: women, racialized individuals, persons with disabilities and Indigenous Peoples. In 2017, the agreement was made a federal court order at the request of the equity-seeking plaintiffs because they considered that not enough progress had been made over the preceding 11 years in improving representation and addressing the systemic barriers within the Program. In 2018, mediation between the Program, the equity-seeking plaintiffs and the Canadian Human Rights Commission was held in lieu of federal court proceedings, and an Addendum to the 2006 Settlement Agreement was subsequently signed in May 2019.

The 2019 Addendum outlines the new terms of the revised agreement. These new terms were developed collaboratively between the parties and update the original settlement agreement to align with EDI best practices. These new terms include requirements for institutions to set and meet equity targets principally based on Canada’s population for the four designated groups and comply with transparency and accountability measures. Overall, they build on the Program’s current EDI measures and ensure that the objective of attracting and retaining a diverse cadre of world-class researchers at Canadian postsecondary institutions to reinforce excellence in research and training is achieved.^{Footnote 4}

In 2021 a Canadian Human Rights Settlement Agreement was reached between the Program and an individual who filed a complaint with the Canadian Human Rights Tribunal in 2017. The 2021 Settlement Agreement stipulates specific consequences for institutions that do not meet the Program’s EDI requirements.

The 2019 Addendum requires that an internal audit be carried out three years after it is signed to formally assess its implementation. Ensuring that the Program has made progress in implementing the measures included in the 2019 Addendum and the 2021 Settlement Agreement is important to ensure that the benefits of EDI best practices and measures will be realized to support the achievement of the objectives of the Program: a world-class and impactful Canadian research ecosystem.

2. Audit objective and scope

The objective of this engagement was to assess the progress of the Program’s implementation of the requirements of the 2019 Addendum to the 2006 Canadian Human Rights Settlement Agreement.

The scope of this assessment included the measures taken by the Program and institutions to implement the 2019 Addendum from June 2019 to December 31, 2022.

3. Audit methodology

The audit was conducted internally by the Corporate Internal Audit Division. The audit team used the following methodology in the conduct of audit work.

• Reviewing key documents such as:
  • The 2006 Settlement Agreement;
  • The 2019 Addendum to the 2006 Canadian Human Rights Settlement Agreement;
  • The 2021 Settlement Agreement;
  • Governance committee documents and internal briefings;
  • Program publications;
  • Postsecondary institutions publications;
  • Documents provided by the Program to satisfy the Addendum requirements;
• Interviews with management;
• Interviews with institutions and equity seeking plaintiffs; and
• Review of random samples^{Footnote 5} of Program and institutional artifacts, documents and websites for compliance with requirements.

This audit conforms with the Institute of Internal Auditors’ International Professional Practices Framework, in accordance with the Government of Canada’s Policy on Internal Audit, as supported by the results of the quality assurance and improvement program. These standards require that sufficient and appropriate audit procedures be conducted, and that evidence be gathered to provide a high level of assurance on the findings contained in this report. The audit conclusions are based on the audit findings against the requirements in Appendix I and the audit criteria in Appendix II.

Katherine Ludwig, Chief Audit Executive
Corporate Internal Audit Division, NSERC and SSHRC

4. Audit observations

4.1 Overall Results

The 2019 Addendum and the 2021 Settlement Agreement comprise 85 distinct requirements that were separately assessed. The assessment is based on the evidence of the progress of implementation of each of the 85 requirements up to December 31, 2022. The implementation status of each of the 85 requirements is provided in Appendix I of this report. The following is a summary of the assessment of the implementation of the 2019 Addendum requirements and the 2021 Settlement Agreement.

The Program has made significant progress in the implementation of the 2019 Addendum and the 2021 Settlement Agreement requirements. As of December 31, 2022, the Program has completed 67 of 85 (79%) of the requirements. Out of the remaining 18 that are not complete, 7 (8%) are in progress and 11 (13%) are not started. Of the eleven (11) requirements that are not started, two (2) of them can only be completed at a future date as stipulated by the addendum.

Given that the 2019 Addendum and the 2021 Settlement Agreement are legally binding agreements and that EDI measures are critical to the success of the Program, the Program should continue its progress in implementing the requirements. Therefore, the Program should prioritize the remaining requirements based on complexity and develop a roadmap to ensure they are all completed.

Recommendation:

The associate vice-president, TIPS, should develop a plan to complete the 2019 Addendum and the 2021 Settlement Agreement requirements, which includes action items, roles and responsibilities, and timelines.

4.2 Equity Targets

4.2.1 Program has set equity targets aligned with the 2019 Addendum

The Addendum requires the Program to set equity targets for the four designated groups: women, visible minorities, persons with disabilities and Indigenous Peoples. However, the terminology used by the Program to define the four designated groups has changed over time. The Program currently defines the four designated groups as: women and gender minorities, racialized individuals, persons with disabilities and Indigenous Peoples. These definitions are refined over time to reflect the spirit of the Addendum and the preferred language of underrepresented communities.

With the exception of persons with disabilities, the Addendum specifies the equity targets are to be based upon the 2016 Census and reflect representation in the Canadian population. The assessment validated that the equity targets were consistent with 2016 Census data. In March 2021, the Program revised its equity target-setting methodology to be based upon population statistics in the 2016 Census.

The Program developed and updated its methodology on equity target-setting and required institutions to set incrementally higher equity targets at interval deadlines (of December 2022, December 2025, December 2027 and the final equity targets for December 2029). The assessment found that management undertook consultations with institutions and performed a thorough analysis of representation data in doing its due diligence to establish the Program guidance and target ranges.

Institutions submitted their equity target plans to the Program in June 2021. The Program developed an equity tool to assist institutions in setting their incremental equity targets based on their respective Chair allocations.

The Program periodically uses the self-identification data it collects from chairholders to calculate the actual representation of individuals from the four designated groups for each participating institution and for the Program as a whole. The report of actual representation, which is aggregated to protect the privacy of chairholders, provides institutions with insight into their progress in achieving their equity targets.

Table II includes the representation as of September 2022 for the Program compared to the December 2029 equity targets.

The following footnotes are included in the Target Setting Methodology^{Footnote 7}:

*Individuals who self-identify as women, transgender, gender-fluid, nonbinary and Two-Spirit contribute to the Program’s equity targets and are reported in the Program statistics in the category in which they self-identify.

**The target of 7.5% (versus 14% in the 2016 Census) for persons with disabilities acknowledges that low self-identification rates could impact the ability to achieve a higher target, due to the reluctance of individuals with disabilities to self-identify in an employment setting. This percentage will be reviewed in 2024.

The following observations were made regarding equity targets:

1. Women and gender minorities

   The assessment found that the 2019 Addendum does not specifically include equity targets for gender minorities such as individuals who are Two-Spirit, non-binary and transgender. The Program has proactively chosen to expand its equity targets for gender to be inclusive of gender minorities in order to mitigate potential systemic barriers for these individuals in the Program’s equity efforts.

2. Persons with Disabilities:

   The target for persons with disabilities was set at 7.5% as specified in the 2019 Addendum and is not based on the 2016 Census (14%). The Addendum requires the Program to review its equity targets for persons with disabilities five years after its signature (2024). The lower percentage target of 7.5% was set due to the very low representation of persons with disabilities in the Program at the time the Addendum was signed (1.6%). Secondly, the percentage target was set at 7.5% in recognition of the challenges in self-identification within the Program due to social stigma more generally within academia and research. However, the percentage target of 7.5% being used in the Program is higher than the labour market representation (LMR) of persons with disabilities since the LMR percentage would be higher if systemic barriers in employment for these individuals did not exist.

   The assessment found that the Program has not commenced work on reviewing the target as this work is not due until 2024; progress and completion of the review of the target for persons with disabilities will be subject to a future audit.

3. Sexual orientation

   While there is a requirement for the Program to collect data regarding sexual orientation, there is no requirement to set equity targets. The assessment found that the Program developed and implemented a self-identification form that includes a question on sexual orientation in June 2020. The Program has not been able to identify a reliable Canadian source of data on sexual orientation upon which to better understand the current representation in the Program.

4. Indigenous Peoples

   The 2019 Addendum set the equity target for representation of Indigenous Peoples in the Program at 4.9%, per the 2016 Census, and requires the Program to engage with Indigenous communities to reassess and revise the target-setting approach as required.

   The assessment found that the target for Indigenous Peoples was set at 4.9% and that the target has not been subsequently increased or otherwise adjusted. Formal engagement by the Program with Indigenous communities to reassess and revise the target-setting approach has not commenced; reassessment and revision of the target-setting approach will be subject to a future audit.

4.2.2 Institutions have set equity targets for the four designated groups in alignment with the methodology prepared by the Program.

The 2019 Addendum requires institutions to set equity targets for representation of chairs for each of the four designated groups. These targets must be increased incrementally over a 10-year period to ensure the population level targets included in the 2019 Addendum are met by December 2029.

In April 2020, the Program implemented an EDI stipend of up to $50,000 for institutions that participate in the Program. These funds are expected to help successfully implement the 2019 Addendum during the 10-year window to meet increased equity targets.

The assessment confirmed for a sample of institutions that they had set incrementally higher equity targets and that large category institutions set targets by tier, according to the methodology required by the Program and in accordance with the 2019 Addendum requirements.

The assessment found that:

• There are 73 institutions required to set equity targets. Out of a sample of 11 institutions, all institutions (100%) had set incrementally higher targets consistent with the methodology established by the Program, including interval dates and within the range provided by the Program.
• There are 16 large category institutions that must set equity targets at the Tier 1 and Tier 2 levels. All 16 institutions (100%) set equity targets at the Tier 1 and Tier 2 level according to requirements of the 2019 Addendum.

The assessment concluded that institutions set equity targets following the Program target-setting methodology, reported these targets to the Program and published their equity targets on their respective program reporting and accountability websites.

The first formal reporting exercise of institutional representation compared with equity targets is expected in spring 2023, based on the equity targets set for December 2022. If equity targets are not met, the Program will impose consequences on the institutions. As this exercise was not completed at the end of the examination phase, the results of this exercise will be included as part of a future audit.

To conclude, the assessment found that the Program implemented specific requirements for institutions to set incrementally higher targets over the 10-year period to ensure the 2029 population level targets for each of the four designated groups are achieved. Institutions set targets consistent with the policies of the Program and the requirements of the 2019 Addendum.

4.2.3 Self-identification data is collected based on best practices and analyzed to monitor the level of representation within the Program.

The 2019 Addendum requires the Program to collect self-identification representation data for the four designated groups and the LGBTQ+ community on a disaggregated basis and monitor the level of representation for individuals from these groups in the Program.

The assessment considered the extent to which the Program implemented processes to collect and monitor the self-identification data provided on a confidential basis by chairholders. The assessment included interviews with program management and examined program artifacts including program literature, communications with institutions, system functionality and source data.

The Program used a process that allowed chairholders and nominees to confidentially self-identify through the online Convergence platform (used by individuals participating in the Canada Research Chairs Program). The Program’s process allows chairholders and nominees to provide self-identification information and to update their self-identification information at any time. The Program conducted a survey in the fall of 2019, encouraging chairholders to update their self-identification data. Chairholders also have the opportunity to periodically update their self-identification data in the Convergence Platform during their term.

The Program collects representation data on a disaggregated basis through options provided in the self-identification form. For instance, in addition to self-identifying as an Indigenous person, a chairholder can be more specific about their identity as First Nations, Métis or Inuit.

The assessment found that the Program reports representation data at the program-level for the four designated groups on an intersectional^{Footnote 8} basis. For instance, a chairholder may self-identify as belonging to more than one designated group and individuals are reported in all groups in which they self-identify.

The assessment found that the Program has addressed the requirement to update Program materials and uses best practices to reflect individuals that belong to more than one of the four designated groups on an intersectional basis, subject to the Privacy Act. The Program monitored the representation of the four designated groups and periodically reported the aggregate anonymized information back to institutions. It was also evident that the data was collected based on best practices (on an intersectional basis, promoting and providing options for chairholders and nominees to report, etc.) and analyzed to monitor the level of representation.

The assessment found that the Program’s public-facing web page includes ‘best practices’ around collecting data, disaggregated data, key principles, recruitment, hiring and retention and ensuring EDI language is up-to-date (EDI language is always evolving).

Program literature clarified the importance of ensuring confidentiality for chairholders and nominees, and that the representation choices available under each designated group reflect current terminology and range of choices in order to ensure the accuracy of representation.

The Program provides summary reporting on representation to institutions but does not share individual personal-level data of chairholders and nominees with institutions. Self-identification statistics are reported by the Program in aggregate. To protect the privacy of individuals, if the number of individuals who self-identified within one of the four designated groups is less than five, the statistics related to that group are not publicly reported.

In addition to collecting representation data of the four designated groups within the Program, the assessment considered the extent to which the Program had processes to collect and monitor the self-identification data related to representation of the LGBTQ+ community within the Program.

The assessment found that the Program’s collection of disaggregated data related to the LGBTQ+ community is a work-in-progress. There are challenges with the current dataset on the representation of the LGBTQ+ community in Canada, as the Program has not identified sufficient LGBTQ+ representation data from Statistics Canada or other credible and objective source. The Program added a question on sexual orientation to the self-identification form in June 2020 to improve monitoring of the representation of persons from the LGBTQ+ community. To date, the Program still does not have a full data set for the LGBTQ+ community as not all chairholders have self-identified using the June 2020 form. Additional work is required to better understand the full representation of individuals from the LGBTQ+ community in the Program.

4.3. Accountability, Compliance and Enforcement

4.3.1. Program literature is reviewed and updated according to the requirements of the 2019 Addendum.

The Program is required to review and update the program literature regularly, including review of the Program’s evaluation criteria, program literature, peer review literature and nomination packages.

A specific requirement in the 2019 Addendum is for the Program to develop and provide institutions with an evergreen best practice guide for EDI, including guidance for promoting EDI in the policies and procedures for recruiting, hiring and supporting institutions. The best practices guide is updated periodically (last update was March 2021). The Program also reviews the entire chairs website periodically and the equity pages annually.

The Program has developed, maintained and implemented a communication strategy to highlight the research excellence of chairholders from the underrepresented groups and to promote the links between EDI and research excellence.

When 250 chairs were added to the Program as part of Budget 2018, revisions were made to formally incorporate EDI into the highest-level objective of the Program “to attract and retain a diverse cadre of world-class researchers.”

4.3.2. Institutions comply with EDI action plan requirements

All institutions with five or more chair allocations must develop and implement an institutional EDI action plan as an eligibility requirement of the Program. This plan must guide institutional efforts to identify and address systemic barriers to sustain the participation of and/or address the underrepresentation of individuals from the four designated groups among their chair allocations.^{Footnote 9}

Institutions were required to submit EDI action plans prior to the signing of the 2019 Addendum as part of the Program’s EDI action plan, launched in 2017. Institutions were required to submit EDI action plans in December 2018 for review by an external panel in three phases. At the conclusion of the Phase Two review in the spring of 2020, there were still 15 institutions that did not satisfy the requirements of the EDI action plans. The Program has continued to review institutional responses to the recommendations from the Phase 3 review in spring 2021 and all but one institution had addressed all recommendations. For non-compliant institutions, the peer review decisions for all their nominations (and, where applicable, associated funding for chair awards) will be withheld until the EDI action plan is resubmitted and found to be compliant.^{Footnote 10}

The assessment found that:

• There are 54 institutions required to develop EDI action plans and make these EDI action plans publicly available on their respective public accountability and transparency web page. Out of a sample of 11 institutions, all institutions (100%) had developed EDI action plans and made the plans and the annual progress reporting available on their website.

Overall, institutions meet the compliance and accountability requirements of EDI action plans and the Program is managing any exception. The Program continues monitoring the implementation of these plans through annual reporting.

The Addendum will require institutions with fewer than five chair allocations to develop and implement a simplified EDI action plan. These simplified requirements have yet to be established.

4.3.3. Institutions comply with EDI public accountability and transparency requirements

Public accountability and transparency requirements outline the specific information related to administering the Program that institutions must clearly publish on their websites to be eligible for the Program. These requirements cover information that is generated by institutions, such as incremental equity targets and their EDI action plan and related progress reports. They are also required to provide or link to program-level information such as the 2019 Addendum and the program-level representation statistics.

The assessment found that:

• There are 78 institutions required to disclose their public accountability and transparency information on their respective web page. Out of a sample of 11 institutions, all institutions (100%) published their public accountability and transparency information on their respective web page.
• There are 78 institutions required to provide a link to the 2019 Addendum and to the Program statistics data on their respective web page. Out of a sample of 11 institutions, all institutions (100%) had either provided the 2019 Addendum or a link to the Addendum on the Program website and published a link to the Program statistics data on their respective web page.

The Program disclosed on its website that all institutions were complying with EDI public accountability and transparency, reporting one exception.^{Footnote 11} For this specific case, all nominations for this institution (and, where applicable, associated funding for chair awards) will be withheld until the public accountability requirements are met.

Overall, institutions meet the compliance and accountability requirements for EDI public accountability and transparency included in the 2019 Addendum and the Program is managing any exception.

4.3.4.Institutions comply with recruitment and nomination requirements

The Addendum also requires the institutions to comply and the Program to monitor compliance with requirements applicable to recruitment and nomination activities to fill chair positions. The Program website clearly states all the steps and requirements in the recruitment and nomination process for chairholders.

The Program has identified certain points in the process where the institution must provide information for review including each job posting, the mid-point attestation and the final attestation. The requirement for attestations by a senior institutional official clearly puts the onus on the institution to monitor their own processes and compliance with the EDI requirements of the Addendum. The final attestation has been integrated as the final step for online submission by institutions of nominations.

The assessment found that:

• There were 362 nominations since the mid-point attestation process was implemented in January 2022. Institutions were required to provide certification of the mid-point attestation in advance of the evaluation of each nomination. Out of a sample of 13 nominations, certification was provided for all 13 (100%) nominations.

In order to monitor the compliance of institutions the Program implemented a process to review the job postings and mid-point attestations for compliance before the nomination can proceed. The current process used by the Program considers specific documents for each nomination. This process is not efficient and does not address the 2019 Addendum requirements to undertake a randomized review of nominations from all institutions.

The Addendum also requires the Program to identify institutions which repeatedly fail to meet the recruitment and nomination requirements and to carry out monitoring activities of such institutions. To date, the Program has not developed a monitoring plan for institutions that repeatedly fail the recruitment and nomination requirements. A monitoring plan, which includes a definition of “repeatedly fail”, would be useful to guide future work of the Program to implement the requirements of the 2019 Addendum.

Recommendation

The associate vice-president, TIPS, should develop a methodology for the risk-based monitoring of chair nominations that includes:

• a process for the randomized review of nominations, as required in the Addendum;
• a definition of institutions that “repeatedly fail” to meet the recruitment and nomination requirements of the Program; and
• a plan for targeted monitoring of institutions that repeatedly fail to meet the recruitment and nomination requirements.

4.3.5. The Program can implement enforcement measures when requirements are not met

The 2019 Addendum and the 2021 Settlement Agreement include consequences for institutions that do not meet the Program requirements for EDI. The Program has set specific deadlines for institutions to meet in terms of equity targets, EDI action plans and public accountability and transparency requirements. The Program also reviews the institutional documents for compliance.

In the case of an institution not meeting these deadlines or Program requirements, the institution’s ability to fill chair positions will be impacted. Institutions may not be permitted to submit new nominations to the Program (other than in cases where a nomination contributes to meeting their equity targets) or peer review decisions for all nominations (and, where applicable, associated funding for chair awards) may be withheld until the respective institution is in compliance with Program requirements.

Overall, as noted under 4.2.2, enforcement measures are implemented when institutions fail to meet Program requirements.

Other enforcement measures may also be implemented at the discretion of the Program’s governance committees; however, a clear definition of the level of non-compliance that would trigger additional consequences has not been established. Information on the nature of the failure and the consequence is provided on the Program website but consolidating the requirements that are subject to enforcement, the nature of the related consequences and the roles and responsibilities for imposing and for removing consequences into a comprehensive framework would provide clarity.

Recommendation

The associate vice-president, TIPS, should develop a comprehensive framework that defines the criteria of non-compliance and the associated consequences in terms of nominations, peer review, funding for chairs and re-allocation of chairs, including roles and responsibilities for imposing and removing consequences.

5. Overall conclusion

The Program made significant progress in the implementation of the 2019 Addendum and the 2021 Settlement Agreement in the period between June 2019 and December 31, 2022, and is continuing monitoring their progress. Significant efforts have been made to improve EDI in the Program and institutions are generally meeting their compliance and accountability requirements.

Appendix I summarizes the progress of each requirement included in the 2019 Addendum and the 2021 Settlement Agreement.

The Corporate Internal Audit Division would like to acknowledge and thank management and staff for their support throughout the conduct of this audit.

6. Audit team

Appendix I – Detailed Status of the 2019 Addendum and 2021 Canadian Human Rights Settlement Agreement Requirements

The following table provides the definition of the status for each requirement of 2019 Addendum to the 2006 Canadian Human Rights Settlement Agreement and the 2021 Canadian Human Rights Settlement Agreement.

The following is a summary of the status of the implementation of the 2019 Addendum and 2021 Settlement Agreement requirements:

Status of the Implementation of the 2019 Addendum Requirements

Of the eleven (11) requirements that are not started, requirement #10 below (2019 Addendum requirement 8) must be completed after the 2029 deadline and requirement #6 below (2019 Addendum requirement 5) must only be completed in 2024.

The following tables IV and V provide the audit assessment of the requirements of the 2019 Addendum to the 2006 Canadian Human Rights Settlement Agreement (requirement 1 to 42) and the 2021 Canadian Human Rights Settlement Agreement (requirement 1 to 8), which comprise a total of 85 distinct requirements. The tables include a unique assessment number (a control number from 1 to 85, assigned by the audit), the requirement number and corresponding text from the 2019 Addendum and 2021 Settlement Agreement, the audit criterion number related to each requirement, the status of the requirement assessed by the audit (based on Table III) and a description of the assessed status.

Appendix II – Audit lines of enquiry and criteria

The following areas of examination and the associated criteria were derived during the audit planning phase.

• 1. Data Management
  • 1.1. Equity targets are set using the data sources required by the 2019 Addendum.
  • 1.2. Self-identification data is collected based on best practices and analyzed to monitor the level of representation within the Program. 
• 2. Accountability, Compliance and Enforcement
  • 2.1. The Program meets the compliance and accountability requirements included in the 2019 Addendum.
  • 2.2. Program literature is reviewed and updated according to the requirements of the 2019 Addendum.
  • 2.3. Enforcement measures are implemented when equity targets, EDI action plan, public accountability and transparency requirements are not met.

Appendix III – Management response to 2023 audit recommendations

Covering Memo

The Canada Research Chairs Steering Committee is pleased the audit has found that strong progress has been made in implementing the 85 commitments of the 2019 Addendum (‘the Addendum’) to the 2006 Canadian Human Rights Settlement Agreement in the three and a half years since its signing in May 2019. This finding is directly aligned with program management’s steadfast commitment toward addressing the persistent inequities and barriers that have led to the long-standing underrepresentation of researchers who are women, gender minorities, racialized, Indigenous, disabled and who are part of the 2SLGBTQIA+ communities, in both the Canada Research Chairs Program (CRCP) and the research ecosystem more broadly.

To successfully implement the Program’s EDI action plan launched in 2017 and the 2019 Addendum, the Program has relied on participating institutions to do their part to identify and redress the systemic barriers in their policies and processes by developing and implementing their institutional EDI action plans for the CRCP, meeting their equity targets and meeting the Program’s other public accountability and transparency requirements. That such strong progress has been made in implementing the Addendum in the context of a years-long, world-wide global pandemic demonstrates the collective willingness to work together toward greater equity. This collaboration has led to strong progress being made in increasing the longstanding underrepresentation in the Program over a short period of time. These historically high levels of participation of individuals from underrepresented groups in the Program demonstrate the full breadth of excellent research talent available in the ecosystem that was previously not being tapped into and valued. These results also demonstrate how actively identifying and addressing systemic barriers is critical to the excellence of Canada’s research ecosystem. Despite the progress made in addressing the underrepresentation in the program, the the three federal research funding agencies understand that the numbers tell only one part of the story. Further efforts are needed across the research ecosystem to continue to address the barriers that negatively impact the lived experiences of researchers who are women, gender minorities, racialized, Indigenous, disabled and who are part of the 2SLGBTQIA+ communities.

In alignment with the audit’s findings, program management recognizes the importance of engagement and of clarifying roles, responsibilities and timelines more fully in the coming years.

The following table is the Canada Research Chairs Management Response Action Plan to the audit recommendations, and includes columns for the recommendation number, the Recommendation text, the Management Response, the management lead for the action and a target date for the completion of each action.

Date modified:

2023-12-08