Office of the Superintendent of Financial Institutions. Internal Audit Report. Human Resources Performance Management.

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1 Office f the Superintendent f Financial Institutins Internal Audit Reprt n Human Resurces Perfrmance Nvember 2010

2 Table f Cntents 1. Backgrund Audit Objectives, Scpe, Apprach, and Criteria Audit Cnclusin Respnse Observatins and Recmmendatins...7 Appendix A Perfrmance Cntrl Criteria...13

3 Office f the Superintendent f Financial Institutins Canada A&CS Audit & Cnsulting Services A&CS 1. Backgrund HR Perfrmance Prcess The Audit Cmmittee and the Superintendent apprved an audit f OSFI s Human Resurces Perfrmance fr inclusin in Audit and Cnsulting Services audit plan. The HR divisin, wh is the key guardian f the Perfrmance (PM) prcess, is respnsible t prvide guidance/supprt t OSFI management in managing and verseeing the prcess t ensure its quality, fairness, transparency, and cnsistency. As stated in the PM Guide, the Perfrmance (PM) prcess is a cntinuus cycle that helps managers and emplyees wrk tgether t establish wrk and perfrmance gals as well as mnitr their prgress twards achieving them, recgnizing the need t identify crrective actin, where necessary. It is an pprtunity fr an emplyee t receive and prvide feedback regarding his/her actual perfrmance and cntributins relative t OSFI s perfrmance expectatins as set ut in the emplyee s Gal Cmmitment Dcument (GCD). At the same time, it shuld ffer the emplyee and his/her manager an pprtunity t discuss and plan fr the emplyee s career develpment. There are fur key steps in OSFI s Perfrmance cycle: Setting perfrmance expectatins. Mnitring perfrmance thrughut the year. Reviewing perfrmance (including the mid-year review and the yearend appraisal). Rewarding perfrmance. The PM prcess is a very significant cntributr t OSFI s mandate due t the imprtance, cmplexity, and difficulty t acquire, develp, and maintain the skills, experience, and knwledge required t cnduct OSFI s activities, resulting in peple risk being rated high n an inherent basis in many areas f OSFI. It supprts OSFI s mandate by requiring management and staff t wrk in partnership t deliver slutins related t perfrmance and career develpment. 2. Audit Objectives, Scpe, Apprach, and Criteria Audit Objectives The purpse f this audit was t prvide assurance n the adequacy f design and peratin f the management framewrk, practices and cntrls in place t manage and versee OSFI s Perfrmance prcess t ensure its quality, fairness, transparency, and cnsistency. Cntinued n next page Audit Reprt n HR Perfrmance 3 f 14

4 Office f the Superintendent f Financial Institutins Canada A&CS Audit & Cnsulting Services A&CS Audit Objectives, Scpe, Apprach, and Criteria, Cntinued Audit Objectives (Cnt) Audit Apprach The bjectives were t determine: Whether plicies and prcedures addressing activities f the PM prcess were develped and frmally dcumented. Whether plicies and prcedures were adequate and were prperly cmmunicated t all OSFI managers and emplyees. Whether plicies and prcedures were applied as designed and cnsistently acrss the ffice. Ptential areas fr imprvement, as apprpriate. The scpe f the audit included OSFI s Perfrmance prcess, including perfrmance planning, mnitring, and reviewing as well as management versight cntrls arund the perfrmance prcess. Excluded frm the scpe f this audit: Rewarding Perfrmance In rder t review a cmpleted perfrmance cycle, ur audit wrk fcused primarily n the perfrmance management activities carried ut during the fiscal year Hwever, recgnizing that the prcess is evlving, A&CS fund it necessary t review and understand infrmatin relating t events befre and after the chsen perfrmance cycle, as apprpriate. Audit Criteria The Audit Criteria listed in Appendix A was derived frm the COSO Framewrk. The criteria was used t help us ascertain the extent t which existing management cntrls ensure that Perfrmance key inherent risks in the areas f Gvernance, Prcess, and Peple are prperly mitigated and mnitred. The audit was cnducted in accrdance with The Institute f Internal Auditrs Internatinal Standards fr the Prfessinal Practice f Internal Auditing, cnsistent with the Treasury Bard Plicy n Internal Audit. Audit Reprt n HR Perfrmance 4 f 14

5 Office f the Superintendent f Financial Institutins Canada A&CS Audit & Cnsulting Services A&CS 3. Audit Cnclusin The internal cntrl framewrk ver the perfrmance management prcess needs t be imprved t ensure its quality, fairness, transparency, and cnsistency acrss the ffice. The main dcument gverning Perfrmance (PM) at OSFI is the Perfrmance Guide ( Guide ). We nted that there is lack f clarity with regard t the frce f this dcument (i.e. is it mandatry r nt) and with regard t its true nature (i.e. is it a plicy r just a guide). The degree f cmplexity in the prcess and ambiguity in this Guide, utdated related dcumentatin, as well as a lack f awareness f the Guide s cntent, all have led t variatin in staff interpretatin and incnsistencies in its applicatin. Cnsequently, emplyee mrale and the staff retentin culd be significantly impacted if PM-specific risks are nt effectively managed. The recent emplyee survey indicated that while perfrmance management scred the secnd lwest n percent favurable (ut f 6 survey categries), the verall survey results were psitive with 92% f respndents agreeing they wuld recmmend OSFI t thers as a gd place t wrk. The PM prcess is a significant cntributr t OSFI s mandate due t the imprtance, cmplexity, and difficulty t acquire, develp, and maintain the skills, experience, and knwledge required t cnduct OSFI s activities. In recgnitin f the need t imprve the HR- Perfrmance prcess and enhance its cntributin t the rganizatin, change initiatives were recently intrduced at HR. These initiatives have psitive aspects, ntably enhancements t the perfrmance management frm, including the additin f learning plans t the frm and the prcess. While these changes are psitive and directinally apprpriate, there are several ther areas that need t be addressed t ensure that HR PM meets its mandate mre effectively. These include the fllwing: Frmally establishing a Plicy t be cmplied with, Revisiting the Guide t ensure prcedures and/r guidance including expectatins, rles and respnsibilities are apprpriate, clear and frmally established, Effectively cmmunicating t all emplyees and line managers hw the prcess wrks, Requiring mandatry training n perfrmance management fr all managers, Ensuring jb descriptins are available fr all psitins, and Incrprating emplyee learning and develpment plans int the perfrmance management prcess. Human Resurces, as guardian f the perfrmance management prcess, shuld regularly assess the effectiveness f the prcess in meeting OSFI s bjectives and managing peple risk, by measuring results against predetermined standards and cmpliance with the Plicy. Results frm these peridic assessments shuld be reprted t Executive and learnings shuld be incrprated int training prgrams t supprt cntinuus imprvement in utcmes. Our bservatins and recmmendatins are detailed in Sectin 5 f this reprt. Audit & Cnsulting Services wuld like t thank all participants fr their cperatin and cntributin in the cnducting f this engagement. Chief Audit Executive, A&CS Date Audit Reprt n HR Perfrmance 5 f 14

6 Office f the Superintendent f Financial Institutins Canada A&CS Audit & Cnsulting Services A&CS 4. Respnse We thank the audit team fr bth their cllabrative apprach and depth f review. While we are in agreement with the findings f the perfrmance management audit, it is imprtant t nte that results f prir emplyee surveys and an increased fcus n training and develpment prmpted us t review the perfrmance management prcess last year, ultimately cncluding with a revisin f the perfrmance management frm and the additin f learning plans t the frm and prcess. We als heard frm emplyee fcus grups that mre infrmatin and training needed t be prvided n the perfrmance management prcess itself, and its link t pay. We will be cnducting this training in the latter part f this fiscal year. We agree with the need fr an imprved internal cntrl framewrk as identified in the audit reprt, such as the need t revise ur perfrmance management guideline and create a frmal plicy. We als recgnize the need fr a quality cntrl and mnitring prcess, althugh we will need t find the right balance between mnitring and reprting, and the peratinal burden assciated with this. We are cmmitted t addressing the recmmendatins utlined in the audit. As nted, a number f initiatives have already been undertaken t address sme f the findings, and thers will be addressed ver the next 6-8 mnths. Audit Reprt n HR Perfrmance 6 f 14

7 Office f the Superintendent f Financial Institutins Canada A&CS Audit & Cnsulting Services A&CS 5. Observatins and Recmmendatins 5.1 Frmal Perfrmance (PM) Plicy Framewrk Observatin: The main dcument gverning Perfrmance (PM) at OSFI is the Perfrmance Guide ( Guide ). We nted that there is lack f clarity with regard t the frce f this dcument (i.e. is it mandatry r nt) and with regard t its true nature (i.e. is it a plicy r just a guide). We fund several PM related dcuments available n OSFI net, fr which we nted the majrity is nt dated and sme are bslete, as the cntents d nt prperly reflect current practices. Withut a frmal cmprehensive Perfrmance Plicy framewrk, there may be incnsistencies in the prcess fllwed t evaluate emplyees perfrmance, the handling f pr perfrmers, as well as insufficient dcumentatin t supprt perfrmance rating decisins. As a result, emplyee mrale and staff retentin may becme areas f cncern that need t be addressed. We nted the fllwing; The rles and respnsibilities f the varius stakehlders, as listed in the PM Guide, are nt well knwn, fllwed, r cnsistently interpreted r implemented. There is n defined prcess t ensure HR cnducts reviews, at regular intervals, f the existing guide and prcedures t assess their quality and relevance. We recgnize hwever that HR is in the prcess f cnducting a review f the perfrmance evaluatin frm. There is n frmally defined plicy and/r prcedure t deal with emplyee perfrmance issues frm beginning t end, including clear rles and respnsibilities f stakehlders regarding steps t fllw in a crrective actin, and the drafting, retentin and mnitring f required dcumentatin. There is n clearly defined prcess r prcedure fr receiving and addressing nn-uninized emplyee perfrmance-related cmplaints, nr fr escalating them. The Guide des nt require reviews f emplyees perfrmance files r tracking and mnitring f related PM dcumentatin t mnitr adherence t the Guide requirements and t evaluate the PM prcess effectiveness. Access t emplyees perfrmance infrmatin is bradened t all HR staff, as this infrmatin is stred in a central area. Inapprpriate access t emplyee s persnal infrmatin culd result in nn-cmpliance with privacy rules. Cntinued n next page Audit Reprt n HR Perfrmance 7 f 14

8 Office f the Superintendent f Financial Institutins Canada A&CS Audit & Cnsulting Services A&CS Observatins and Recmmendatins, Cntinued 5.1 Frmal Perfrmance (PM) Plicy Framewrk (Cnt) 5.2 Applicatin f the Perfrmance (PM) Plicy Framewrk Recmmendatin: The PM prcess shuld be gverned by a Plicy and supprting prcedural dcuments that clearly indicate the mandatry requirements. The PM Plicy needs t be develped with emphasis n the key activities f the PM prcess, as well as t prmte fairness, transparency and cnsistency acrss the ffice. Attentin shuld be paid t wrding, s that any flexibility is explicitly identified in the Plicy. The new PM Plicy shuld: Ensure rles and respnsibilities f the varius stakehlders in the PM prcess, including the PM Champin, are clear and frmally established. Outline required measures fr quality assurance f the PM prcess, t ensure plicy is regularly reviewed fr quality and relevance as well as t assess whether its requirements are clearly understd and implemented. Cntain a distinct sectin utlining the steps t fllw fr dealing with pr perfrmers and fr imprving perfrmance. Cntain a distinct sectin utlining the prcedures t fllw fr addressing and fr escalating emplyee cmplaints regarding their appraisals. Define the mechanisms t evaluate cmpliance with the PM prcess. Define the expectatins fr the bjectives, scpe and frequency f HR reviews t evaluate the effectiveness f the PM prcess. Restrict access t emplyee PM files and infrmatin t authrized individuals nly. Observatin: The lack f clarity f the wrding and the level f ambiguity in the Guide and related dcumentatin has led t variatin in staff interpretatin and incnsistencies in its applicatin. We nted the fllwing; There are n criteria fr managers t fllw t determine hw much Key Respnsibilities (KRs) shuld weigh vs. gals. Based n ur file review, the weighting attributed t KRs and gals tends t be cmpletely randm and varies frm ne manager t the next. The Guide s intent is that Key Respnsibilities are taken frm the jb descriptin and shuld nt change frm year t year. Hwever, staff and HR members cnfirmed that written, current jb descriptins d nt exist fr all psitins. As a result, Gal Cmmitment Dcuments ften take the place f nn-existent jb descriptins. Each year, fur behaviural cmpetencies are selected frm the cmpetency mdel t include in the PM prcess. Hwever, the Guide des nt prvide sufficient clarity/detail t explain the ptin f selecting between Behaviural and Technical cmpetencies, s that bth types are cnsidered. Based n ur file review we nted incnsistencies in the selectin f cmpetencies. Cntinued n next page Audit Reprt n HR Perfrmance 8 f 14

9 Office f the Superintendent f Financial Institutins Canada A&CS Audit & Cnsulting Services A&CS 5. Observatins and Recmmendatins, Cntinued 5.2 Applicatin f the Perfrmance (PM) Plicy Framewrk (Cnt) There are three rating scales, with different sets f definitins fr each, and different weightings t attribute fr key respnsibilities, gals and cmpetencies in the Gal Cmmitment Dcument. Because f the cmplexity f, and fcus n, rating calculatins at the year-end review, the applicatin f numerics has becme ineffective and is nt achieving HR management s intended utcme. Perfrmance assessment and perfrmance pay are nt clearly linked in the files reviewed. Based n discussin, HR s rle is limited in situatins where an emplyee files a cmplaint abut his/her appraisal. HR usually advises emplyees t dcument their argument supprting why they d nt agree with sme r parts f their appraisal frm. This dcument is then filed in the emplyee s file. Hwever, we fund n evidence f the eventual reslutin n file. Althugh there were perfrmance imprvement plans in the relevant files reviewed, there was n evidence n file f prgressive discussins and/r indicatin f any fllw-up taking place befre the year-end perfrmance review. We nted that n specific training is prvided t managers fr dealing with pr perfrmance. Althugh HR staff is available t assist managers upn request, these cases seem t be handled n an infrmal basis. There was n evidence that mid-year reviews were dne n a cnsistent and timely manner. Based n discussins with HR and staff, the purpse f the mid-year review was nt always clear with regard t its frce (mandatry r nt), bjectives (t slely identify perfrmance issues and/r t nte changes in the emplyee s wrk plan due t circumstances r resurces); and scpe (t prvide feedback t all OSFI s emplyees r nly thse wh have perfrmance issues). Cntinued n next page Audit Reprt n HR Perfrmance 9 f 14

10 Office f the Superintendent f Financial Institutins Canada A&CS Audit & Cnsulting Services A&CS 5. Observatins and Recmmendatins, Cntinued 5.2 Applicatin f the Perfrmance (PM) Plicy Framewrk (Cnt) Recmmendatin: In rder t effectively implement the PM framewrk, we recmmend: Perfrmance requires a curse f its wn, which will allw fr deeper learning, including specific training fr the varius steps in the prcess (i.e. setting expectatins fr KR, gals and cmpetencies; midyear and year-end reviews) and fr managing pr perfrmers. This training shuld be mandatry fr newly-appinted and existing managers. All jbs shuld have jb descriptins since they serve as a key fundatin fr many different HR prcesses, including cmpensatin system design, jb classificatin grup/level, recruitment, and perfrmance management. The purpse f the mid-year review with regard t its frce, bjectives and scpe shuld be clarified. HR shuld mnitr that mid-year reviews are held when they shuld be, and that the results (i.e. psitive r negative feedback and/r crrective actin t be taken and/r training needs) f the mid-year reviews are dcumented in the apprpriate frmat and signed-ff by manager and emplyee. Develp frmal criteria t supprt management in the evaluatin f emplyee perfrmance achievements that clearly link t perfrmance pay. 5.3 Oversight Observatin: versight cntrls related t infrmatin, cmmunicatin, and mnitring are nt adequately built int the perfrmance management prcess. We nted the fllwing; Setting individual perfrmance expectatins begins with the establishment f OSFI s business plans and related pririties fr the rganizatin. These are translated int sectr and divisinal gals that will cntribute t the business plan and the achievement f OSFI s bjectives. After the divisinal gals have been cmmunicated, emplyees and managers meet t identify and agree n individual gals fr the year. The management call letter requires GCDs t be cmpleted by the first mnth f the fiscal year, hwever staff experience delays in receiving the frmal cmmunicatin f crprate gals and pririties, which have significantly impacted the timely issuance f the Gal Cmmitment Dcuments (GCD). As a result, emplyees may be wrking withut having clarity n bjectives and pririties. Cntinued n next page Audit Reprt n HR Perfrmance 10 f 14

11 Office f the Superintendent f Financial Institutins Canada A&CS Audit & Cnsulting Services A&CS 5. Observatins and Recmmendatins, Cntinued 5.3 Oversight (Cnt) At the end f each PM cycle, the Sectr teams review all preliminary emplyee perfrmance ratings fr cnsistency reasns. Hwever, pen cmmunicatin abut this prcess, which is critical t instill cnfidence in the perfrmance prcess, is lacking. HR des nt cnduct reviews f the PM prcess t evaluate its quality and effectiveness. The last review n recrd was dne in 2003/04 perfrmance cycle. Based n discussin with HR representatives and review f dcumentatin, the transfer f knwledge and accuntability fr the past review f the PM prcess, r any previus r subsequent ne, were lacking. HR s tracking and mnitring f the submissin f PM related dcumentatin and timelines by managers as required by HR in the Call Letter is minimal. As a result, HR wuld nt be able t identify and fllw-up n utstanding PM related dcumentatin fr any given PM cycle. Althugh risk assessment in Crprate Services Sectr is cnducted at a high level, we are unclear as t whether there is a frmal risk management prcess in place t identify, assess, mnitr, and reprt PM specific risks. Recmmendatin: In rder t ensure that the PM plicy framewrk is effectively implemented, management versight cntrls need t be strengthened, including: The prcess fr cascading dwn the crprate gals and pririties shuld be revisited t ensure managers are prvided with the necessary infrmatin t cmply with the call letter timelines. Line managers shuld be held accuntable fr their peple-management respnsibilities. These respnsibilities shuld be utlined in their wn perfrmance appraisals, s that managers can be evaluated n their peple management skills in their related respnsibilities, gals, and cmpetencies. Cmmunicatin frm Senir t all OSFI managers and emplyees abut hw the PM prcess wrks needs t be clear and pen in rder t prmte fairness, cnsistency, transparency and instill cnfidence in the PM prcess. The HR Divisin, as the key guardian f the PM system, shuld cnduct peridic reviews t evaluate its effectiveness by measuring utputs and results against pre-determined standards and in mnitring perfrmance trends. These reviews will enable HR t identify specific PM areas that are cause fr cncern and need t be addressed r where managers, newly-appinted and/r existing, require training. Cntinued n next page Audit Reprt n HR Perfrmance 11 f 14

12 Office f the Superintendent f Financial Institutins Canada A&CS Audit & Cnsulting Services A&CS 5. Observatins and Recmmendatins, Cntinued 5.3 Oversight (Cnt) Similarly, HR representatives shuld be held accuntable fr the quality f their mnitring, review and reprting n the PM prcess, including knwledge transfer practices. Their perfrmance n these respnsibilities shuld be evaluated in their wn perfrmance appraisal. HR - Perfrmance specific risks shuld be peridically reviewed and that mechanisms be put in place t help management peridically assess whether cntrls apprpriately mitigate risks identified. 5.4 Skills Develpment and Career Planning Observatin: The identificatin f develpment and learning requirements is nt a frmalized prcess and is nt part f the perfrmance management prcess as recmmended by the Guide. We nted the fllwing; While the main utput f the PM prcess is a perfrmance appraisal review between a manager and his/her direct reprt, the prcess des nt appear t identify emplyee skill, cmpetency, and behaviur gaps, if any, between what is expected and what the emplyee brings t his/her jb. Withut this picture in hand, emplyees will nt be able t imprve their perfrmance in their current rle, r build career develpment plans that better prepare them fr a future rle f interest, r bth. HR des nt cnduct peridic fllw-up reviews f cmpleted appraisal frms s that trends in emplyees perfrmance can be analyzed and learnings, if any, can be incrprated int training prgrams. Cnsequently, HR may nt be able t identify specific areas where OSFI emplyees may need training r supprt. Recmmendatin: Emplyee training and develpment shuld be integral parts f the perfrmance management prcess t ensure a systematic and disciplined apprach is cnsistently applied thrughut the rganizatin. There shuld be a plan fr develping emplyees s that they can naturally grw thrugh the rganizatin and that jbs can cntinue whenever smene leaves. The rganizatin s successin plan may prvide input fr emplyee develpment plans. As a result, management needs t ensure the fllwing: Identificatin f learning requirements fr the current rle, as well as future career develpment planning needs shuld be cmpleted during the perfrmance management prcess. It shuld identify current skills gaps and persnal career gals ver the shrt and lng term s that required educatinal qualificatins, skills, and cmpetencies can be attained and the apprpriate persnal career pprtunities can be identified. Audit Reprt n HR Perfrmance 12 f 14

13 Office f the Superintendent f Financial Institutins Canada A&CS Audit & Cnsulting Services A&CS Appendix A Perfrmance Cntrl Criteria Elements Gvernance: PM Plicy Framewrk Gvernance: Oversight Cmpnents PM related plicies and prcedures exist and are apprpriate, are regularly reviewed, assessed fr quality, and are updated. Rle, respnsibility, and accuntability f the varius stakehlders in the verall PM prcess are clearly dcumented in the framewrk and are cnsistently fllwed. PM related plicies clearly utline required measures fr quality assurance f the PM prcess. Criteria used t evaluate perfrmance achievements and merit are clearly established and cmmunicated t OSFI s managers and emplyees. Links between perfrmance assessment and perfrmance pay and merit are frmally established, transparent and clearly cmmunicated t OSFI staff. Framewrk includes a written plicy / prcedure fr prgressive discipline / crrective actin t deal with emplyee perfrmance issues. Framewrk includes a clearly defined prcess and prcedures fr receiving and addressing emplyee perfrmance cmplaints t ensure disputes are prmptly and prperly reslved, incl. mechanism t escalate perfrmance issues. Framewrk includes a clearly PM defined calendar, deliverables and cntrl pints. Mechanisms are in place t identify, enfrce and mnitr adherence t the framewrk and cllective agreements, where applicable, n a regular basis and take timely and apprpriate actin, as required. versight activities are built int the prcess and perfrmed in the rdinary curse f running the business, such as frmally setting the verall business strategy and the annual crprate gals and ensuring that the latter cascades dwn t the wrk units and subsequently t managers and emplyees in a clear and timely manner. There is a clear prcess f annual review at the crprate, wrk unit, and individual level t evaluate achievements in relatin t the pririties/ gals set, identify areas fr imprvement, and develp plans. There is an updated rganizatinal chart fr each part f the rganizatin. There is a master list f each jb in the rganizatin indicating its status. There are jb descriptins available fr each psitin in the rganizatin. Managers are held accuntable fr cmpleting all required steps f the PM prcess fr their direct reprts. Further, HR tracks and mnitrs PM prcess deliverables due dates and ntifies managers, as required. HR peridically reviews perfrmance ratings and supprting dcumentatin fr incnsistencies, as well as trends in perfrmance acrss the ffice, and frmally reprts results t Senir. The PM prcess (particularly the Sectr Peer Review) is pen and transparent, and the flw f infrmatin is cmplete, adequate, reliable and timely. Emplyee surveys are peridically cnducted (at an apprpriate frequency) t help management identify and address areas that may require imprvement. Audit Reprt n HR Perfrmance 13 f 14

14 Office f the Superintendent f Financial Institutins Canada A&CS Audit & Cnsulting Services A&CS Elements Gvernance: Skills Develpment & Training Cntrl Prcesses: Applicatin f the Plicy Framewrk Risk Cmpnents The rganizatin prvides emplyees with the necessary tls, training, resurces and infrmatin t supprt the discharge f their respnsibilities. Adequacy f the knwledge, skills and experience f management and HR staff needed t perfrm assigned tasks related t their HR respnsibilities and accuntabilities. Key PM-related rles and respnsibilities within HR have been identified, knwledge transfer practices are adequate, and sufficient back up exists amngst HR representatives t ensure a smth, cntinuus management f HR s PM related respnsibilities. Key cre management / leadership cmpetencies fr rganizatinal success have been identified and described, and adequate training is available fr managers (new and existing) t develp their peple management skills. Perfrmance reviews emphasize actin plans fr psitive imprvement fr bth, thse wh meet r exceed their gals and/r cmpetencies and thse wh d nt. Cnsequently, a persnal learning plan that links jb skills t training pprtunities is part f the annual perfrmance review f each emplyee. Results f HR s peridic reviews f cmpleted perfrmance management dcumentatin, and the results f trend analyses in perfrmance management acrss the ffice, feed int training prgrams as apprpriate. PM related plicies and related tls and templates t assist managers in their HR respnsibilities are accessible, are applied as intended and cnsistently. Emplyees are prvided with nging perfrmance feedback and caching. HR prcedure in place t deal with emplyee perfrmance-related cmplaints ensures that: emplyee disputes are prmptly and prperly reslved and expert resurces t investigate and reslve these cmplaints are accessible t all OSFI emplyees. There is a regular senir management review f the nature and reslutin f cmplaints t ensure that PM-related plicies are fllwed cnsistently. HR prcedure in place t deal with emplyee perfrmance issues ensures that: sample templates fr prgressive discipline/ crrective actin are cmpliant with applicable emplyment legislatin; managers timely and prperly dcument steps taken t imprve emplyee s perfrmance and emplyee acknwledgment is prperly dcumented; emplyees are infrmed f their rights and respnsibilities when subject t disciplinary / crrective actin; emplyees are regularly cached n hw t imprve perfrmance and prgress discussins are prperly dcumented; and HR, wrking alngside line managers, tracks all emplyees n frmal perfrmance imprvement plans and mnitrs deadlines. HR cnducts peridic reviews f cmpleted PM dcuments t assess the quality f cntent (i.e. key respnsibilities are relevant t the jb, gals are realistic and measurable, cmpetencies are related t business bjectives, etc) and dcumentatin f perfrmance in rder t ensure prcess is transparent, fair and cnsistently applied acrss OSFI. Access t emplyee PM files and infrmatin is limited t authrized individuals and prvided n a need-t-knw basis t ensure cnfidentiality f persnal infrmatin is maintained. identifies HR-PM specific risks and peridically assesses whether current cntrls apprpriately mitigate thse risks. Audit Reprt n HR Perfrmance 14 f 14

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