Office of the Superintendent of Financial Institutions Canada
Letter on Implementation of the Call to Action on Anti-Racism, Equity and Inclusion

Summer 2021 update

Clerk,

Further to the Call to Action on Anti-Racism, Equity and Inclusion in the Federal Public Service it is my pleasure to provide you with the Office of the Superintendent of Financial Institutions’ (OSFI) open letter in response. This letter outlines the actions taken within our organization and the early impacts they are having.

Of the nine categories in the Call to Action, during the past year our attention has focused on commitment, enablement and inclusion. As an organization, we are committed to providing employees with the tools and opportunities to increase their knowledge about racism, reconciliation, accessibility, equity and inclusion. We also want to foster a safe, positive environment where conversations on these topics are encouraged throughout our workplaces. Our objective is to elevate our organizational diversity and inclusion maturity to a level where DEI is integrated within the fabric of our culture so that it is sustainable; we aim to do this by enhancing awareness and education, being clear and accountable, providing leadership and governance, and strengthening recruitment and staffing as well as inclusion and retention. We pursue comprehensive DEI not only to meet the Call to Action but also to ensure OSFI has a diversity in mindsets and skills that is crucial to meeting the complex risk environment our organization faces.

Overview

OSFI is an independent agency of the Government of Canada, which reports to Parliament through the Minister of Finance. We were established in 1987 to contribute to the safety and soundness of the Canadian financial system. We supervise and regulate federally registered banks and insurers, trust and loan companies, cooperative credit associations, fraternal benefit societies and private pension plans subject to federal oversight. As at March 31, 2021, we had 915 employees located in Ottawa, Toronto, Montreal, and Vancouver offices.

Over the past year we have undertaken a number of activities to ensure that Diversity, Equity and Inclusion (DEI) is built into how we operate as an organization and sets us on an exciting path to continue to grow and build DEI at OSFI. We are pleased to share with you today some of our key activities.

Creation of a Diversity, Equity and Inclusion Unit

In 2020-21, OSFI committed to advancing DEI in a more systematic and structured way across the organization. As a result, we created a new DEI unit in May 2021, with a team of employees devoted exclusively to advancing the DEI agenda; this unit builds on the energy of stakeholders and fosters productive relationships across the organization. Supported by external expertise, this unit is responsible for designing, developing and implementing our multi-year DEI Strategy. A key role of this unit is to ensure the integration of DEI into our culture, values and operations, as well as to work with stakeholders and partners in providing direction on organization-wide DEI initiatives and programs. Early impacts suggest increased collaboration with key influencers across OSFI as well as with our external partners.

Active grassroots initiatives and committees support DEI initiatives

In 2018 our employees launched our Inclusion Network (IN), whose work is supported through both funding and active support of senior leaders.

The IN is about bringing together staff who are interested in promoting workplace inclusion and nurturing an environment where we can all bring our whole selves to work. The Network’s specific objectives are to promote awareness, understanding, and encourage behaviours of inclusion. The IN is also responsible for organizing diversity celebrations and bringing attention and awareness to recognized holidays throughout the year. The IN currently is divided into eight streams: Accessibility, Mental Health, Gender, LGBTQI2S, Multiculturalism, Family Responsibilities, Diversity of Thought and Unconscious Bias. In May 2021, the IN launched a “Family Table” series where employees share lived experiences on various DEI issues; these monthly events are regularly attended by over 25% of OSFI employees and support a deeper understanding of the importance of diversity and inclusion in the workplace.

The IN also launched a Diversity Spotlight Series with the goal of celebrating our differences, shared values and unity. This monthly spotlight series features achievements of inspiring Canadian individuals and/or groups with diverse backgrounds. Their profiles and stories are selected to coincide with cultural, religious or historically significant dates throughout the year. The IN is championed by one of our Executive Committee members, and the IN co-chairs have regular access to the People and Culture Committee co-chairs, one of our senior governance committees.

In addition, our Employment Equity and Diversity Advisory Committee (EEDAC) continued its important advisory role towards achieving a barrier-free and a fully representative workforce by promoting employment equity for members of the four designated groups (women, Aboriginal peoples, persons with disabilities and visible minorities).

The People and Culture committee (PCC), created in 2019, is a formal standing committee of OSFI senior leaders, accountable for and with authority to make decisions on certain matters related to our people and culture, in support of our Strategic Plan and goals. Through its thought leadership, the committee supports, shapes, promotes, oversees the development and evolution of our human capital and culture, and in this way contributes to their safeguarding. The Committee draws on internal resource expertise and the diversity of member experience and judgement to approve and oversee the enterprise portfolio of initiatives. The PCC is responsible for overseeing the design and rollout of our multi-year DEI Strategy and has a discretionary budget to approve initiatives that are related to supporting inclusion and supporting a positive OSFI culture. Going forward, we will be offering the Kairos Blanket Exercise for all our interested employees, in response to the Truth & Reconciliation Commission of Canada’s Calls to Action, and with an aim to deepen our awareness of the legacy of residential schools as well as to support the process of reconciliation in Canada.

Early impacts of this governance structure have allowed for a greater number of employees to have their voices heard at various levels across the organization.

Examination and Revamping of Hiring and Promotion Processes, Tools and Practices

An external human resources consultant was engaged to review and analyze our hiring policies and practices, related strategic initiatives, and past selection processes, to identify issues and areas for improvement. The consultant also interviewed hiring managers, senior executives, candidates, human resources advisors, and members of relevant governance committees, to better understand our practices. The review confirmed that we continue to be compliant with our legislative requirements, but highlighted that we could better align our actions to our goals by enhancing the staffing process, educating hiring managers, increasing transparency, and improving access and representation.

In response to the review findings, we realigned our strategic direction with regards to hiring and promotion practices and employment equity representation. Specific responsibilities for hiring managers were identified and initiatives to attract a more diverse work force were created. This work involved educating managers, updating the Hiring Manager’s Guide, simplifying and standardizing job posters, placing greater emphasis on people skills in the hiring process and through leadership development, and, whenever possible, using standardized online assessment tools to assess competencies.

We also piloted initiatives such as the use of external representation on selection panels, assessing for leadership potential, and creating working groups to identify more diverse talent pools. It is too early to confirm early impacts of the new measures to increase objectivity, fairness and transparency, but baseline comparisons will be available in 2022. 

Inclusion of Workforce Planning Pillar within Human Capital Strategy

As an organization, we have and continue to undergo a number of organizational changes. In May 2017, we launched our Human Capital Strategy (HCS), which sets the direction for human resources policies, programs and practices. In March 2021, a new HCS priority was included, which reflected our commitment to the Hiring and Promotion review and highlights that we will develop an enterprise-wide Diversity, Equity, and Inclusion strategy. It also underlines our commitment to fostering an environment that supports a diverse, inclusive, and engaged workforce, including taking proactive steps to remove real or potential biases, or systemic barriers in our people management, recruitment, and promotion processes. This is an important step in creating an organization that fully represents the communities in which we live and work.

DEI Corporate Commitments Included for All Employees

New corporate commitments have been included in the 2021-22 performance management agreements of all employees. One of the new corporate-wide commitments pertains specifically to Diversity, Equity and Inclusion: Enhance own understanding of diversity, equity and inclusion (DE&I) in the workplace by spending time annually on DE&I activities and/or training. The addition of this commitment was a collaborative effort; it was proposed by our Inclusion Network, supported by the Human Resources Division and endorsed by the People and Culture Committee. As a result, all employees, including executives, have included this DEI OSFI-wide commitment in our 2021-22 performance agreements in order to continue to strengthen our collective understanding and unify our efforts in our journey to build a better, stronger, healthier, more diverse and more inclusive OSFI. Early impacts of this corporate commitment suggest more DEI-focused discussions are taking place across the organization as well as increased participation in various diversity initiatives.

Diversity and Inclusion Diagnostic to inform OSFI’s DEI Strategy

Since early 2021, work is underway, with the expertise and support of an external partner, to conduct a Diversity and Inclusion Diagnostic, which will be concluded in Fall 2021. The diagnostic explores DEI factors around inclusion and belonging at OSFI. The diagnostic includes individual interviews, focus groups as well as an OSFI-wide online assessment to ensure that all our employees have an opportunity to have their voices heard. This diagnostic will support the development of a multi-year DEI Strategy that takes into consideration our current state, work that we have done on DEI preceding this diagnostic, and a vision of where we would like to be.

We are committed to strengthening the workplace in terms of DEI and respect for people. The strategy will be the cornerstone of how we will embed diversity and inclusion in all our processes, structures and practices, and will include an outcomes driven suite of performance measures.

In 2021, we developed our DEI Accountability Framework, which includes a detailed evergreen RACI Matrix (Responsible, Accountable, Consulted, and Informed) that contains the most up-to-date information on tasks, roles, obligations, and milestones in the evolution of the DEI Strategy and broader portfolio. Already this framework is proving valuable in clearly identifying the different stakeholders and their respective roles, responsibilities and accountabilities for DEI work.

The OSFI DEI Strategy will be co-created in the coming months by the newly established DEI unit and key stakeholders. This will provide a structured approach to fostering inclusion across OSFI by promoting inclusive leadership which focuses both on the structural (equitable and transparent structures) and behavioural (inclusive mindsets, skillsets and relationships) elements of creating a diverse, equitable and inclusive workforce.

Closing

Our intent is to combat racism, discrimination and other barriers to inclusion in the workplace by taking action on what we have learned, empowering employees to speak up about bias and access, and better equipping managers to address systemic issues.

I am proud of the work that we have undertaken in the past year in the area of DEI. I am committed to go beyond legislative frameworks in order to embed diversity, equity, and inclusion into the very fabric of our culture. In so doing, OSFI will have the diverse mindsets and skills that will be necessary to meet a risk environment that grows more complex by the day.

Sincerely,

Peter Routledge
Superintendent
Office of the Superintendent of Financial Institutions