Treasury Board of Canada Secretariat
Letter on Implementation of the Call to Action on Anti-Racism, Equity and Inclusion

Summer 2021 update

Dear Ms. Charette,

Given its role in supporting the Treasury Board as the employer of the core public administration, the Treasury Board of Canada Secretariat (TBS) recognizes the importance of fostering a diverse workforce that is representative of the people of Canada and supported by an inclusive and barrier-free work environment. As such, we have put greater priority on implementing anti-racism, equity, accessibility and inclusion initiatives in recent years. The Clerk’s Call to Action on Anti-Racism, Equity, and Inclusion added momentum to our efforts and commitment to improving diversity and inclusion outcomes for the entire public service and for our own department.

Attached are summaries of TBS’s concrete actions and early impacts to advance anti-racism, equity, accessibility and inclusion within the public service (Annex A) and internal to the department (Annex B). Although progress has been made, we recognize that changing our culture and systems to be more representative and more inclusive is important work that will require sustained attention. We are committed to driving the changes that are needed, now and into the future.

Peter Wallace
Secretary of the Treasury Board

Erin O’Gorman
Associate Secretary of the Treasury Board

Christine Donoghue
Chief Human Resources Officer

Roch Huppé
Comptroller General

Catherine Luelo
Chief Information Officer of Canada

Yazmine Laroche
Deputy Minister, Public Service Accessibility

Annex A: Action on Anti-Racism, Equity and Inclusion across the Public Service

In response to the expressed needs of public servants, TBS, through the Office of the Chief Human Resources Officer, created the Centre on Diversity and Inclusion and focused on an approach that favours enterprise-wide solutions, co-developed with employees from employment equity and equity-seeking groups, in collaboration with partners and stakeholders. This important and urgent work is supporting deputy heads in bringing lasting change in their organizations. It is framed by the five areas of focus for the public service on diversity and inclusion announced in January 2021:

• disaggregating and publishing data for a more accurate picture of representation gaps
• ensuring the right benchmarks
• increasing the diversity of the senior leaders of the public service
• addressing systemic barriers
• engagement, awareness and education

These priorities demonstrate a recognition that we must take concrete and immediate actions on multiple fronts to bring positive and lasting change.

Supporting departments in telling their story

Access to disaggregated data is critical to understanding gaps in representation and to help target actions. Both qualitative and quantitative data help us better understand the diversity of the public service and the experiences that diverse groups of people are having in the public service.

We made important progress in the past year with the release of eight sets of disaggregated enterprise data that provide first-ever views into the composition of 21 employment equity subgroups, including Black, Métis and Inuit employees, as well as employees with a hearing impairment or mobility challenges. This kind of data responds to requests by stakeholders to enable more granular analysis and is a foundation for better evidence-based decision-making. We’ve been sharing this data publicly on Canada.ca, and we’ll continue to do this as more data become available.

Results of the 2020 Public Service Employee Survey released in March 2021 are key to inform progress on inclusion within departments. These results provide crucial information on the perceived experiences of equity-seeking employees with harassment, discrimination and, for the first time, their perceptions about racism. The 2020 Survey also includes, for the first time, data on the lesbian, gay, bisexual, transgender, queer, two-spirited and other identity (LGBTQ2+) communities within the public service.

To help users easily access and visualize the numbers, we launched an online interactive data visualization tool in April 2021. This business intelligence tool allows users to manipulate fields and parameters easily while accessing and visualizing public service human resources demographic and employment equity data.

Representation numbers are based on those who have chosen to self-identify; the effectiveness of the self-identification process is the key to measuring the progress that is being made in representation, hiring, promotion and separation rates. In September 2020, TBS launched the Self-Identification (self-ID) Modernization Project to increase the accuracy, depth and breadth of the data across government. The project explored ways to reduce stigma associated with self-identification. Following extensive research and consultations, a new questionnaire was co-designed with employees from various diversity networks. Preliminary testing has shown that the new form resulted in an increased intent to self-identify compared with the existing form. The new questionnaire will be implemented this fall.

As well, we continue to provide departments with relevant data on Workforce Availability (WFA) and support deputy heads in the use of these metrics to inform departmental plans.

Joining efforts to diversify senior ranks

While working to achieve WFA in the aggregate across the public service is one goal, it’s also important to achieve strong representation across all levels and occupations. That is why TBS is supporting the construction of a solid pipeline of talent at every level of the public service.

TBS is taking a system-wide approach on succession planning at the assistant deputy minister level. Specifically, we are working with deputy ministers to bring forward talented executives from under-represented groups to take on leadership roles in the senior ranks. This includes sharing the profiles of Black executives to be considered for promotions—an initiative from the Black Executives Network in collaboration with TBS.

The existing Executive Leadership Development Program (ELDP) was modified in September 2020. TBS established the requirement that at least 50% of a department’s nominees for the EX‑01 to EX‑03 ELDP come from persons with disabilities, Indigenous peoples or members of visible minority groups. As a result, our fall 2020 cohort was the most diverse cohort since the inception of program in 2016. Of the candidates selected:

• 52% are from at least one of the most under-represented employment equity groups (Indigenous peoples, members of visible minorities, and persons with disabilities)
• 7% are Black executives
• 63% are women

In December 2020, we launched the Mentorship Plus Program. The sponsorship component of this program pairs members of under-represented groups with executives, enhancing traditional mentorship by including sponsorship. As sponsors, senior leaders are responsible for advocating actively on behalf of their protégé and being an active participant in the career development of their protégé. This is especially important for those employees who might lack access to certain networks (both formal and informal), helping them acquire the skills and competencies for progression to the executive cadre. The program was co-developed with employee networks, and a toolkit for guidance and implementation is available for departments wishing to implement the program. Thirty-six departments confirmed that they have started implementing the Mentorship Plus program.

In addition, TBS developed a strategy to transform the appointment process and collect data in order to increase the diversity of members of Pension and Benefits Boards of Management and Committees, including members appointed by a minister or the Governor in Council.

Enabling systemic and cultural change

We have created and leveraged different public service communities, including by:

• creating a new community of practice of Designated Senior Official for Employment Equity, Diversity and Inclusion (DSOEEDI) to support implementation of initiatives and sharing promising practices across the public service. These individuals are mandated by their deputy heads to oversee each department’s employment equity obligations and implement plans to advance diversity and inclusion. To date, 91% of departments have identified a DSOEEDI, with whom we engage on a regular basis
• amplifying the voices of diverse employees through the new Federal Speakers’ Forum for Diversity and Inclusion, launched in March 2021. The forum provides a platform for departments to reach out to a roster of speakers and tap into their rich repertoire of lived experience and poignant stories. It has recruited 38 speakers and is growing quickly, with speaking engagements booked across the public service
• beginning to develop diversity and inclusion strategies for the government’s financial management and internal audit communities based on consultations with the communities, as well as examinations of employment equity representation within them
• working with the government’s functional communities for acquired services and assets to develop and deliver professional development that increases awareness related to community-specific roles with respect to diversity and inclusion. For example, TBS recently promoted the Real Property Institute of Canada’s professional development sessions on Indigenous procurement and the Accessibility Strategy for the Public Service of Canada
• creating a cross-government Gender, Diversity and Technology working group to bring together employees of all levels to discuss topics of interest on the intersection of gender and diversity with technology.  As well, an award was also created in the digital community to recognize excellence in diversity and inclusion
• partnering with the Public Service Commission (PSC) to convene a Diversity and Inclusion working group for communications professionals. The group held its first meeting held in April 2021 and regularly has about 80 people in attendance. This group of communicators helps raise awareness about diversity and inclusion within their departments, communicate progress across the public service, and build on each other’s successes.

With respect to staffing, TBS collaborated with the PSC to conduct extensive analysis about staffing process issues under the Public Service Employment Act. Engagement sessions were held with employee networks, key stakeholders and bargaining agents about the experiences of members of employment equity and equity-seeking communities in the staffing process. As a result, the act was amended in July 2021. These changes will enable major foundational work that will help the PSC and TBS, as well as departments and agencies, to take measures in their staffing actions to reduce barriers and encourage more diverse recruitment practices. These changes are also aligned with the goals of the Employment Equity Act Review Task Force.

We also:

• partnered with Indigenous employee networks in co-developing and launching the Career Pathways for Indigenous Employees website to provide tools and resources to support Indigenous employees as they navigate their career in the federal public service. The website also features resources for Indigenous recruitment, including an inventory of Indigenous applicants, and students who have experience in the federal public service and are available for rehiring or appointment opportunities, along with an Indigenous Recruitment Toolbox for staffing
• collaborated with members of different communities to develop a new, alternative approach for setting selection criteria in staffing processes and determining a candidate’s level of “qualification” for a position. The new methodology essentially acts as a “value translator” that changes the outcomes of traditional government staffing approaches. Extensive work was undertaken to ensure that those from equity-seeking groups and Indigenous ways of learning and working translated to “valued experience” in the new model, thereby leading to increased employment opportunities for applicants. This methodological approach integrates policy compliance with anti-racism theory to achieve results, and has attracted positive and widespread international attention. It is now being integrated into a number of digital talent hiring processes and a new Indigenous Talent Portal, which is being co-developed with Employment and Social Development Canada.

With respect to accessibility, the Office of Public Service Accessibility at TBS is leading efforts to make progress across the public service in accessibility and disability inclusion. The Accessible Canada Act, which came into force in 2019, aims to make Canada barrier-free by January 1, 2040. To respond to the act, the Government of Canada launched the Accessibility Strategy for the Public Service of Canada, also referred to as “Nothing Without Us,” as a roadmap for the public service to lead by example and become a model of accessibility.

Some of the specific examples of TBS leadership in accessibility are:

• letters were sent by the President of the PSC and the Deputy Minster of Public Service Accessibility to all deputy heads of federal government departments detailing the number of employees with disabilities they would need to hire to close their representation gaps and providing concrete tools and support to meet the commitment to hire 5,000 persons with disabilities by 2025
• a regular spotlight series on accessibility at the Public Service Management Advisory Committee (a deputy minister–level committee) shared lessons learned with deputy ministers to accelerate momentum in the removal of barriers in departments and agencies
• two open meetings of the persons with disabilities champions and chairs committee invited all equity-seeking employee groups and their allies to participate in building allyship across groups in the public service
• a full-day National AccessAbility Week event open to all public servants was held on the themes of allyship and intersectionality in advancing accessibility, diversity and inclusion in the public service attended by 3,000 employees
• the Accessibility Hub launched in 2020, serves as a one-stop shop for accessibility information. It is a resource for federal public servants to find guidance, tools, tips and best practices on accessibility and disability inclusion in the federal public service
• through the Centralized Enabling Workplace Fund, TBS partnered with key departments to develop new tools and guidance, improve existing processes, and experiment with solutions that can be scaled or replicated across the federal public service to deliver accommodations that equip employees to contribute to their full potential (for example, a new Workplace Accessibility Passport that streamlines the process for employees and managers and will follow employees as they change jobs, and a centralized Lending Library for commonly requested adaptive devices and technologies that can be loaned to students or term employees)
• TBS is developing new policy requirements aimed at strengthening the accessibility of government communications products and activities. These new requirements will build on existing guidance that is currently available on the Accessible Communications Portal
• the Digital Careers for Persons with Disabilities Recruitment Campaign was launched. At every step, from the application process to being fully assessed, accommodation measures or adjustments are being made available to applicants based on their needs, including accessible environments, different formats, larger fonts, adaptive technology, extra time and individual testing.

Rising to evolving challenges

As we work towards ensuring our readiness to respond to the expanding scope of diversity and inclusion, there is a continued need for more data that is consistently shared and supports evidence-based actions. The focused work on our self-identification project will significantly improve availability and access to relevant data needed for sound decisions.

We realize that given the backdrop of various departmental contexts resulting in unique needs, the one-size-fits-all solutions do not work. It is important to balance departments’ needs for customized solutions with ensuring consistency across the enterprise. Our efforts towards creating frameworks for public service organizations that allow flexibility to implement innovative and customized solutions will ensure nimbleness in the system. The Mentorship Plus program is an example of this flexibility, as it is highly adaptable to ensure alignment with departments’ different contexts, existing programs and diversity objectives.

Employee engagement at the heart of our approach

The foundation of these programs rests on a co-development approach with employees and networks. For example, in the case of Mentorship Plus, co‑development occurred with members of employment equity and equity‑seeking groups to design the program. More specifically, surveys and focus groups were conducted to understand the needs and hopes of equity‑seeking members and to design the program’s framework.

While these initial results are positive, work must continue to create a cohesive, truly horizontal, government-wide approach to effectively create and maintain a culture of inclusiveness that will combat racism and address systemic barriers.

One more step in this regard is the planned launch of a new Management Development Program in the fall of 2021. This new program, co-designed with networks, is intended to address key issues of under-representation in EX positions, which is one of the hardest barriers to overcome for under-represented groups, as identified in many reports.

Leaders have significant influence on organizational culture. Accelerating the career progression of a diverse executive cadre, who can foster meaningful culture change, will help shift our public service culture to foster inclusiveness, where all public servants have a deep sense of belonging, and where we all embrace difference as a source of strength.

This work is as important as it is urgent. It is time to close the gaps and eliminate the barriers that remain, ensuring the public service is truly representative of the people it serves. 

Annex B: Action on Anti-Racism, Equity and Inclusion within TBS

Beyond the responsibility of TBS to provide leadership on enterprise-wide initiatives, TBS must also lead by example in terms of its own internal actions. This attachment provides an overview of TBS’s departmental initiatives and highlights our progress in fostering diversity and inclusion, in line with the Clerk’s Call to Action.¹ Each of these initiatives is aligned with our departmental Employment Equity, Diversity and Inclusion Action Plan, which focuses on the following:

• building and sustaining a fully representative workforce
• fostering a diverse and inclusive workforce
• increasing accessibility

The following sections describe how we have established a strong foundation by:

• creating employee networks that have direct access to senior management and that meaningfully contribute to decision-making
• investing in better and easily available workforce data

Coupled with the department’s staffing strategy of increasing diversity, this foundation has led to improvement in certain employment equity numbers over the last year. Specifically, in TBS’s workforce:

• the number of women has increased by 5.4%
• the number of Indigenous employees has increased by 9.8%
• the number of members of visible minorities has increased by 9.8%
• the number of persons with disabilities has increased by 10.3%

While increases in these broader categories are positive, we cannot overlook that employees within these groups have nuanced identities and experiences. They may belong to more than one group or have different experiences based on multiple identity factors. Our efforts to address this are outlined below.

TBS is also leading the way with mentorship and sponsorship initiatives to help position individuals for career development opportunities. Although progress has been made, we recognize that work must continue to sustain this progress and to address outstanding gaps.

Actions and employee engagement

a) Representation in TBS decision-making

TBS is committed to engaging employees from employment equity and equity-seeking groups to address racism, equity and inclusion. Our approach over the last year focused on:

• engaging employees directly
• raising awareness
• improving departmental data and making data more available to hiring managers

One of the first things TBS did was create an Accessibility Network, as well as departmental networks for Black, Indigenous and LGBTQ2+ employees. The network chairs are members of the departmental employment equity advisory committee led by an assistant deputy minister–level Diversity, Equity and Inclusion Champion who provides senior management with advice and strategies on achieving diversity and inclusion goals. The chairs also frequently meet with TBS’s Human Resources Division to:

• provide advice and guidance on departmental initiatives and communications
• ensure that TBS is applying an intersectional lens to all our anti-racism efforts

b) Identifying pain points via “journey-mapping”

Understanding the lived experiences, both good and bad, of employees from equity and equity-seeking groups is key to achieving real results. To foster this kind of understanding, the department partnered with our Black Employees Network to journey-map their experiences at TBS, a process that identified some of the barriers and pain points for Black employees at TBS. The authenticity of these findings and the subsequent discussions provided senior management with valuable insights and information to enable effective action against racism and to create a more inclusive environment.

As a result of the successful journey-mapping experience with the Black Employees Network, we are committed to journey-map the lived experiences of members of other employee networks to better understand and address their barriers, obstacles and pain points. We recently started journey-mapping with the Accessibility Network, the results of which will be used to shape and inform the department’s Accessibility Plan.

c) Efforts to improve awareness have increased

Awareness and learning play a key role in addressing anti-racism and inclusion at TBS. Over the past year, the department has:

• provided ongoing communications on anti-racism, diversity and inclusion
• worked with the employee networks to organize anti-racism sessions for TBS employees

These sessions and panels involved a varied group of speakers, including:

• senior public service leaders, who spoke about their personal experiences and perspectives
• external experts on topics related to anti-racism
• TBS employees who agreed to share their own lived experiences

The chair and co-chair of our Black Employees Network have also provided several very well-received awareness sessions across the department.

d) Equipping hiring managers with better data

To ensure that managers have the latest and most accurate data, the department developed an interactive workforce dashboard that is shared with all executives on a quarterly basis. The dashboard contains key workforce metrics such as representation, gaps, and turnover and promotion rates for employment equity groups. This information addresses a major barrier to more inclusive hiring by enabling management to consistently make informed decisions on how to build and maintain a representative and diverse workforce. The workforce dashboard shows:

• the historical number of employment equity employees going back to 2017–18
• the breakdown by occupational group
• the gap between current numbers and workforce availability

In line with the efforts to improve data for the entire public service, TBS continues to invest in better departmental data and is working on adding a disaggregated lens to the dashboard, enabling the ability to drill down into classification levels, as well as new metrics on promotion and tenure to better understand and address remaining workforce gaps.

Attachment A references the Self-Identification (self-ID) Modernization Project that aims to provide more reliable data about employees from employment equity groups. TBS, as a department, participated in the pilot for this initiative and looks forward to the implementation of the new tools in the coming months.

e) “Hard-wiring” diversity into staffing

It is essential that our staffing processes are aligned with our broader efforts to encourage culture change and growth. Hiring managers are expected to use the detailed data noted above and apply a diversity lens in their daily staffing decisions. This is reinforced through the requirement for each staffing action to include an explanation on how diversity and inclusion were considered. To more effectively support this effort, staffing advisors at TBS have been provided with training so that they can help managers attract and select more diverse talent.

We recognize that success means harnessing the influence of those in leadership positions. To ensure that these priorities remain top of mind for every executive, commitments have been added to their performance agreements to:

• increase the social and cultural diversity of the workforce
• combat racism
• address systemic barriers
• increase accessibility

At the end of the performance period, executives must report on the actions they have taken in relation to these commitments.

Specific actions have also been taken to improve representation in the executive ranks of TBS. In the last fiscal year, TBS launched three EX processes (EX‑04, EX‑03 and EX‑01) where members of visible minorities, Indigenous peoples, and persons with disabilities were either the first or only candidates to be considered. Including those processes, TBS appointed eight individuals to EX positions who had self-identified as members of visible minorities.

f) TBS is a leader in mentorship and sponsorship

Attachment A references Mentorship Plus, which was recently launched as a new and enhanced approach to mentorship. Beyond the work to launch Mentorship Plus at the enterprise level, TBS is also one of the early adopter departments of the Mentorship Plus learning lab and has focused its first cohort on diverse employees who are ready to become executives to potentially increase the diversity of our executive cadre and accelerate culture change in the department.

To reinforce the importance of this initiative at TBS, 12 assistant deputy ministers and three executive directors are participating in the program as sponsors. TBS has demonstrated leadership in both the speed of implementing the sponsorship component and in the number of protégés, that is, sponsor relationships established, relative to the size of the organization.

Based on the success to date, TBS is currently planning for the second cohort.

g) Making progress on accessibility

TBS also recognizes the importance of advancing accessibility. Beyond efforts to increase the representation of persons with disabilities, TBS is an early adopter department of the GC Workplace Accessibility Passport that was developed by the Office of Public Service Accessibility and is being tested in over 20 organizations across the public service. The passport follows an employee wherever they go over the course of their career to reduce the burden often placed on employees with disabilities to repeat the same requests over and over.

A campaign to raise awareness and TBS’s capacity to create accessible documents was launched in 2020. The combined effort of the departmental Accessibility Champion, the Human Resources Division and the Office of Public Service Accessibility saw a series of articles in the department’s internal newsletter TBS In-Brief where all employees were offered tips and templates to create accessible documents and forms from the start to enable a more inclusive workplace.

Measurement and results

TBS tracks representation and other key metrics on a quarterly basis via the department’s workforce dashboard. Through combined efforts between management and TBS’s Human Resources Division, the representation of women and members of visible minorities at TBS now exceeds their workforce availability.

TBS also reviews the annual Public Service Employee Survey results with a gender-based analysis plus (GBA Plus) and intersectional lens to identify potential issues and barriers facing employees based on first official language, gender and sexual orientation, in addition to traditional employment equity lenses. These findings will be integrated into TBS’s Taking Action Plan, which the department produces in response to the annual survey results.

While measuring progress is important, TBS is not focused exclusively on numerical targets. Workforce representation does not indicate whether employment equity and equity-seeking groups are experiencing inclusion in their daily work or whether sub-demographics within those groups are facing unique barriers. As such, we are partnering with our employee networks to journey-map their lived experiences and co‑creating solutions as a practical way of adding an intersectional perspective and directly improving employees’ workplace experience.

Challenges and barriers

TBS’s approach of journey-mapping with departmental employee networks to identify barriers and pain points is proving to be an excellent way to identify and address the needs of our communities.

To date, journey-mapping with our Black Employees Network has revealed that we need to:

• improve fairness and transparency in staffing, performance and talent management processes
• provide consistent and equitable access to onboarding, mentoring and sponsorship
• foster an anti-racist work culture that is free from micro-aggressions and welcoming to employees expressing their authentic selves
• enable authentic and empathetic leadership that values diversity and inclusion at all levels

Preliminary results from journey-mapping with our Accessibility Network indicate that we need to:

• rethink how we accommodate employees
• provide better training for supervisors
• provide more developmental and career opportunities for persons with disabilities

We must keep in mind that when our employees share their experiences through journey-mapping, it can be painful and also add to their existing workload. We must therefore make every effort to do this with care and empathy.

We also note that TBS has a gap in the number of Indigenous executives and a large overall gap in the number of persons with disabilities. Both of these gaps will require deliberate and targeted action from management to build a workforce that represents the population we serve.

Although fewer TBS Black employees (21%), members of visible minorities (15%), persons with disabilities (20%), women (11%), and gay or lesbian employees (7%) reported being a victim of harassment in the 2020 Public Service Employee Survey, they all reported higher rates of harassment when compared with TBS employees who are not members of these groups. As well, Indigenous employees reported an increased rate of harassment (14%) compared with the previous year’s survey.

Broadly, changing our culture and systems to be more representative and more inclusive is important work that will continue for the foreseeable future. 

Maintaining momentum

TBS has an ongoing commitment to diversity and inclusion that predates the Clerk’s Call to Action. Management is committed to continuing to empower and collaborate with the department’s employee networks to co-create timely and practical solutions to:

• address systemic barriers
• improve the department’s anti-racism, equity and inclusion efforts

We recognize the importance of maintaining the momentum that the recent increased focus on diversity, inclusion and accessibility has created.

Principles such as empowering employees, co-creating solutions, reviewing processes with a user-centred lens, and leveraging data to improve decision-making will make TBS a more diverse and inclusive workplace, and will also improve the overall effectiveness of the department and contribute to thinking around the future of work.

Data on employment equity at TBS

The employment equity data in this appendix is based on employee self-identification. The totals provided include all self-identification choices made by employees. As such, some employees may be counted in more than one category. In addition, employment equity totals may add up to more than the total number of employees.

In the executive ranks of the department, we do not have any gaps for members of visible minorities, persons with disabilities, and women as of April 1, 2021. There is a gap of six Indigenous EXs.

Table 1 shows the breakdown of TBS employees by employment equity group, April 1, 2020, to April 1, 2021.

Table 1: breakdown of TBS employees by employment equity group, April 1, 2020, to April 1, 2021

In terms of employment equity groups, the numbers of TBS employees in each group have been trending in a positive direction for all groups over 2020–21. However, there are still gaps for Indigenous employees and, particularly, persons with disabilities according to the targets based on workforce availability. The number of employees who are members of visible minorities is barely over the target and will still require vigilance over the short term.

Table 2 shows the breakdown of TBS employees who are members of visible minorities, April 1, 2020, to April 1, 2021.

Table 2: breakdown of TBS employees who are members of visible minorities, by visible minority subgroup, April 1, 2020, to April 1, 2021

The data on visible minority subgroups shows that the number of TBS employees in these groups increased in most cases, which reflects the progress made over the last year. The use of this disaggregated data will expand in future years to guide diversity and inclusion staffing strategies.

Table 3 provides the number of TBS employees who are Indigenous peoples and members of visible minorities and who were appointed to EX positions at TBS in 2020–21.

Table 3: number of TBS employees who are Indigenous peoples and members of visible minorities who were appointed to EX positions at TBS in 2020–21

Due to privacy concerns, we are unable to provide disaggregated data for the category of members of visible minorities for Table 3 as there were fewer than six Black employees and fewer than six other racialized employees appointed to EX positions.