![]() Number 2 – April, 2007 |
Canada Signs New UN Convention on the Rights of Persons with DisabilitiesBy Fay Faraday and Victoria Shen On 30 March 2007, Canada joined 80 countries and the European Union in signing the United Nations’ new Convention on the Rights of Persons with Disabilities. While the United Nations has previously developed various non-binding declarations, a programme of action and standard rules for promoting equality for persons with disability, the Convention is significant because it is the first UN instrument to enshrine a comprehensive set of binding commitments to eradicate discrimination against persons with disabilities. The Convention will be an important new tool for advancing the rights of persons with disabilities in Canada – both through lobbying and through litigation. Apart from setting out binding commitments, the Convention is important because it marks a significant “paradigm shift” in how the rights of persons with disabilities are addressed. It adopts the vision of equality, long advocated by disability rights advocates, that disability is socially constructed. This means that while individuals may have various physical, mental, intellectual or sensory impairments or functional limitations, the “disability” arises to the extent that social relations, institutions and environments are constructed without reference to the needs of persons with disabilities and erect barriers to their full and effective participation in society on an equal basis with others. In conjunction with this analysis, the Convention set outs a detailed
set of pro-active commitments which outline the breadth and depth of changes
that are needed in all spheres of human interaction – economic,
social, political, cultural and recreational – in order to secure
equality. As such it will provide new leverage in advancing legal arguments
before federal and provincial tribunals and courts with respect to the
meaning of equality, minimal impairment of rights and accommodation to
the point of undue hardship. A. Current Status of the Convention The Convention and its companion Optional Protocol were adopted by the UN General Assembly on 13 December 2006. It was open for signatures on 30 March 2007. As of mid-April 2006, 86 countries had signed the Convention itself and 45 had signed the Optional Protocol. The Convention is enforced by requiring States to file comprehensive reports every four years outlining the measures taken and progress made to give effect to the obligations under the Convention. The reports are reviewed by a 12-person expert panel called the UN Committee on the Rights of Persons with Disabilities which in turn makes recommendations and suggestions to the State. The Optional Protocol provides a separate enforcement mechanism which gives individuals the right to file complaints claiming a violation of the Convention to which the State must respond. The Committee will examine the individual complaints and has the power to make suggestions and recommendations to the State. While Canada has signed the Convention, it has not signed the Optional Protocol. The Convention will come into effect 30 days after 20 countries have ratified it. The Optional Protocol will come into effect 30 days after 10 countries ratify it. At this point, only Jamaica has formally ratified the Convention. While Canada has signed the Convention, further work is needed before Canada will ratify it. Because the Convention touches on many areas of provincial jurisdiction, the federal government is embarking on discussions with the provinces to secure agreement to ratification. It will be important for human rights advocates to monitor this process federally and in each province to ensure that ratification proceeds. B. Overview of the Convention The development of this UN Convention – the first of the 21st
century – was unprecedented in that it involved extensive participation
by members of civil society who are and represent persons with disabilities.
This involvement is clearly apparent as the text of the Convention sets
out a strong vision of what equality means from the perspectives of persons
with disabilities. Canadian representatives were particularly involved
in the development of the Convention and this influence is also apparent
as the rights to equality pick up the language of equality from s. 15
of the Charter and the concept of reasonable accommodation that has developed
under Canadian human rights statutes.
The fundamental right to equality is set out in language taken directly from s. 15 of the Canadian Charter of Rights and Freedoms. To this effect, Article 5 states as follows:
The guiding principles of the Convention are set out in an extensive preamble which enshrines the social development model of disability rights and in Article 3 which outlines the key principles as:
The Convention in Article 4 sets out general obligations on State Parties to ensure and promote “the full realization of all human rights and fundamental freedoms for all persons with disabilities without discrimination of any kind on the basis of disability”. To this end, State Parties are required to undertake a broad range of positive actions “to the maximum of its available resources ... with a view to achieving progressively the full realization of the rights” in the Convention. These pro-active commitments include the obligation to adopt all appropriate legislative, administrative and other measures to implement the rights recognized in the Convention; to modify or abolish existing laws, regulations, customs and practices that constitute discrimination against persons with disabilities; to ensure public authorities and institutions conform with the Convention; to take all appropriate measures to eliminate discrimination on the basis of disability by any person, organization or private enterprise; and to promote research and development with respect to universal design, accessible communications technologies, and mobility aids and training of those working with persons with disabilities to provide the assistance and services guaranteed by the Convention. The Convention makes repeated references to States’ obligation to “closely consult with and actively involve persons with disabilities” in the “development of legislation and policies to implement the Convention and in other decision making-processes concerning issues relating to persons with disabilities” (Article 4). The Convention also makes repeated reference to the obligation to recognize that women and girls with disabilities are subject to particular discrimination and to ensure that all appropriate measures are taken to ensure the full development, advancement and empowerment of women with disabilities (see: Preamble, Article 6). The Convention then sets out extensive pro-active obligations which itemize what steps are needed to ensure equality for persons with disabilities in all contexts. The Convention reaffirms that persons with disabilities have the inherent
right to life (Article 10), the right to legal capacity and the support
that they may need to exercise their legal capacity (Article 12) and the
right to equal access to justice, including the appropriate accommodations
and supports to ensure that persons with disabilities can effectively
exercise their legal rights (Article 13). Persons with disabilities have a right to privacy (Article 22). They have the right to marry, found a family, and access to reproductive and family planning education (Article 23). Children with disabilities have an equal right to a family life and will not be separated from their parents unless it is in the best interest of the child. On the issue of accessibility, the Convention requires countries to identify and eliminate obstacles and barriers to facilitate the access of persons with disabilities to the physical environment, transportation, public facilities, services, information and communication technologies (Article 9). It recognizes too that the freedom of expression is closely linked to facilitating the use of Braille, sign language and other accessible formats of communication (Article 21). Persons with disabilities enjoy an equal right to live independently,
to be included in the community, to choose where and with whom they live
(Article 19). Their mobility and independence are to be fostered by facilitating
access to mobility aids, devices, assistive technologies and live assistance
at an affordable cost (Article 20). The Convention recognizes that persons with disabilities are entitled
to an adequate standard of living for themselves and their families and
to adequate social protection (Article 28). They are entitled to the right
to the highest attainable standard of health without discrimination on
the basis of disability (Article 25) and to habilitation and rehabilitation
services and programs to enable maximum independence (Article 26). Through the Convention, States confirm the right to equal participation in cultural life, including access to cultural materials in accessible formats, and to equal participation in recreation, leisure and sports including participation in mainstream sporting events, as well as the development of disability-specific sporting and recreational activities. Persons with disabilities are also entitled to recognition and support for their specific cultural and linguistic identity (Article 30). As set out above, Canada will be held accountable for compliance with the Convention through its period reports to the UN Committee on the Rights of Persons with Disabilities (Articles 33-37). As they have done in respect of Canada’s reports under other UN instruments such as the Convention on the Elimination of All Forms of Discrimination Against Women, human rights advocates can consider providing input into this process by preparing “shadow reports” on Canada’s compliance. C. Significance of the Convention to Domestic LItigation Despite its lengthy recitation of commitments and guarantees, the Convention does not set out new rights as such. The rights to equality without discrimination on the basis of disability have been guaranteed in domestic and international law for decades and most of the substantive rights set out in the Convention are enshrined in general language in other UN instruments. What the Convention contributes to the law, however, that it provides a comprehensive catalogue of what the right to equality means in specific contexts and what actions are needed in order to implement the general guarantees of equality. It provides is a genuine understanding of what equality means from the perspective of persons with disabilities. It is a substantive equality document. For this reason it has the potential to be an important tool in advancing
the right to equality under domestic statutes. But this does not mean that international covenants have no place in
domestic litigation. In fact, international instruments are frequently
used to interpret domestic rights. They have been referred to increasingly
over the past decade, particularly to give meaning to rights under the
Charter and under human rights statutes.
While the Supreme Court has through a series of cases beginning with Eaton and Eldridge, increasingly moved toward a paradigm that recognizes that disability is socially constructed, Canadian courts and tribunals could benefit from further guidance on the details of what it takes to eradicate those socially constructed barriers. They could benefit from detailed guidance on what it means to build a society that is reflective of and grounded in a practice of equality characterized by social inclusion, participation, accessibility, independence, self-determination for persons with disabilities. It is in the very detailed expressions of what the right to equality and accommodation looks like from the perspective of persons with disabilities that the Convention has the potential to be most helpful in litigation. The detailed expressions of the rights will help give substantive content to general equality principles and to develop substantive standards for accommodation. While arguments grounded in this perspective have been made for years by domestic disability rights advocates, having the principles and rights explicitly enshrined as fundamental international law should provide new leverage to the legal arguments. To view a copy of the Convention on Rights for Persons with Disabilities, click here. To view a copy of the Optional Protocol, click here.
Supreme Court of Canada Grapples with the Social Construction of Disability: Council of Canadians with Disabilities v. Via RailIn its recent decision in Council of Canadians with Disabilities v. Via Rail, the Supreme Court of Canada continued to take tentative steps toward embracing a vision of equality for persons with disabilities that acknowledges the social construction of disability. The majority decision in Via Rail puts forward a vision of equality based on full inclusion, accessibility and independence rather than one in which people with disabilities are forced to accept lesser access to inferior rail service. However, the 5-4 split on the Court and the very different analysis adopted by the four dissenting judges shows just how tenuous the acceptance of this vision of equality remains. The Via Rail decision also highlights how important it will be for disability rights advocates to develop legal arguments aimed at solidifying this participatory vision of equality in Canadian law. A. Facts In 2000, Via Rail purchased a fleet of 139 “Renaissance” railway cars at discount prices. The cars were inaccessible to persons with disabilities in several respects: the cars did not have accessible washrooms, the wheelchair tie-down only accommodated a child’s wheelchair, the doorways were too narrow for most personal wheelchairs, and there was insufficient space for a service animal. Most strikingly, the so-called “accessible suite” service cars, separate train cars on which passengers in wheelchairs were to be accommodated, were in fact inaccessible as doors were too narrow and there was insufficient space in them to manoeuvre a wheelchair. The Council of Canadians with Disabilities filed a complaint with the Canadian Transportation Agency (“CTA”) arguing that the cars posed an “undue obstacle to the mobility of persons with disabilities” that required corrective measures under the Transportation Act. The CTA issued a preliminary decision in which it identified a number of obstacles to the mobility of persons with disabilities and gave Via a chance to show why the obstacles were not undue and/or why it would not be reasonable to require Via to modify the cars. Via responded with only limited information and resisted the CTA’s repeated requests for costing information with respect to the recommended accommodations. Following an exchange of correspondence, the CTA issued a final decision requiring Via to modify 13 economy coach cars and 17 service cars out of the 139 cars purchased. Via successfully appealed the CTA’s decision to the Federal Court of Appeal. The Council of Canadians with Disabilities appealed. B. Supreme Court of Canada Judgments The Supreme Court of Canada allowed the appeal and restored the CTA’s decision. However, the split 5-4 decision reflects a division on the Court in regards to the proper analysis of equality rights for people with disabilities in Canada. As described below, the majority and dissent put forward two very different conceptual frameworks for addressing the equality rights of persons with disabilities. Not only do these frameworks speak to different visions of equality, but they also adopt two fundamentally different conceptions of disability and the contributing causes to disability in Canadian society. The majority’s judgment at least partially accepts the paradigm of disability as being socially constructed rather than simply the result of personal impairments. That is, there is an acceptance within the majority judgment that socially constructed barriers cause, or at least contribute to, the disadvantages faced by persons with disabilities. The majority appeared to accept that social barriers, such as the barriers to accessing equal rail service in Via Rail, significantly hinder the full and equal participation of persons with disabilities in Canadian society. Presuming that there is a right to inclusion within the Transportation Act, the majority undertook a more pro-active analysis of accommodation. The outcome of the majority’s judgment is that persons with disabilities have a right to at least one accessible car per train that meets standards generally accepted by Via itself in the voluntary Rail Code adopted almost a decade ago in 1998. In support of its conclusion that Via had discriminated against people with disabilities by failing to provide reasonable accommodations, the majority made the following findings:
The dissent put forward a quite different analysis of the equality rights issues in the case. One that uses the status quo, rather than a right to inclusion, as the baseline for analysis. Although the dissent did accept that the human rights accommodation framework set out in the Supreme Court’s Meiorin decision should be applied, the dissent emphasized that “perfection is not the standard” and that not every obstacle must be removed. The dissent adopted a very narrow focus on the costs of accommodation and accorded substantial deference to Via’s narrowly defined economic purposes for purchasing the Renaissance cars at a discount price. The outcome of the dissenting judgment for persons with disabilities would have been one accessible car per train on its existing fleet (which is in the process of being phased out) and a lower standard of accessibility on its new Renaissance fleet due to all of the obstacles identified in the CTA and majority’s judgments. Applying the Meiorin analysis of the duty to accommodate, the four dissenting judges would have struck the CTA’s decision and remitted the matter back to it for redetermination primarily for the following reasons:
Overall, the dissent emphasized costs on a balance sheet rather than full participation and inclusion. According to the dissent, the CTA “must be attuned to the feasibility of the orders it issues to the parties and the intrusiveness of its process into the management of the carrier.” C. Significance of the Supreme Courts Judgments Although the end result of the Supreme Court’s decision is positive, the very different visions of equality for persons with disabilities deployed in the two judgments suggests that courts will continue to grapple with what full equality, inclusion, and participation for persons with disabilities would look like. As least some judges on the Supreme Court, and other courts, recognize that it is social barriers that create the “disability” experienced by people who live with various physical, mental, intellectual or sensory impairments. However, as a reading of the dissenting judgment makes clear, this paradigm is far from having gained universal acceptance amongst judges. Continued legal advocacy will be required for a full and inclusive vision of equality to become more entrenched in Canadian law, advocacy that draws on the positive developments within cases such as Via Rail as well as developing international standards such as those found in the new UN Convention on the Rights of Persons with Disabilities (see article above). Securing the Health and Safety of Women Workers and Workers with DisabilitiesBy Mary Cornish and Michelle Dagnino The protection of employees against sickness, disease and injury is one of the fundamental objectives of trade unions and professional organizations around the world. In securing that protection, it is essential that occupational health and safety measures address the specific needs and interests of employees who experience systemic discrimination by reasons of their sex, race, disability, ethnic origin or other similar factors. Occupational health and safety laws, policy and collective bargaining provisions must take into account that such employees face multiple and intersecting layers of disadvantage which contribute to their occupational health and safety risks. These include social, physical, psychological and emotional factors and include lack of time, the frequent precariousness of their work and their systemically lower wages. As a result, such vulnerable groups have complex needs and risk factors which must be addressed through:
For example, research shows that
A. Women Focused Health and Safety Requirements An excellent example of the difference resulting from a focused attention to women and gender equality are the Calvert Women’s Principles. In June, 2004, Calvert, in partnership with the United Nations Global Fund for Women (UNIFEM), launched these Principles which were the first global code of corporate conduct focused exclusively on empowering, advancing, and investing in women worldwide. These Principles which also cover areas such employment and income, and education, training and professional development have the following specific “Health Safety and Violence” clause which could be included in a collective agreement (separate provisions could also be adapted for employees with disabilities). “Corporations will promote and strive to attain gender equality by adopting and implementing policies to secure the health and safety and well being of women workers. In this regard, companies agree to take all reasonable steps to:
For the full text of these principles see: http://www.calvert.com/womensPrinciples.html The Latest Development in Almost Two Decades of Litigation: McKinnon v. Ontario (Ministry of Correctional Services)By Janina Fogels and Kate Hughes The Ontario Human Rights Tribunal has issued yet another scathing condemnation of resistant employers who do not address racism and poisoned work environments in McKinnon v. Ontario (Ministry of Correctional Services) 1. Previously, the Divisional Court and the Court of Appeal, in upholding earlier decisions of the Tribunal, described this as "a unique situation in which outrageous discrimination continued unabated.” 2 In this latest decision the Tribunal has issued a further 34 remedies. The new decision by adjudicator H. Albert Hubbard mandates compliance by the Ministry of Corrections with systemic remedial orders aimed at cleansing racism from correctional workplaces and re-issues individual remedies for the complainant. 3 While employed at the Toronto East Detention Centre, Mr. Michael McKinnon, a correctional officer of Aboriginal ancestry, complained to the Ontario Human Rights Commission that while at work, he was subjected to constant racial taunts and slurs. Co-workers and supervisors had targeted Mr. McKinnon and his wife, also a correctional officer, over a number of years. The original 1998 Tribunal ruling found that the Ministry had engaged in systemic racism with respect to the McKinnons. 4 Despite the finding, Mr. McKinnon had to return to the Tribunal as the Ministry failed to make changes ordered and resisted reform. Meanwhile, his tormentors kept their jobs, or enjoyed promotions and other perks. Substantial litigation took place to enforce the original orders and to deal with retaliatory harassment Mr. McKinnon faced for having challenged the behaviour in the first place. 5 Unprecedented Findings This 2007 decision is important for its wide-ranging findings against the Ministry and its far-reaching remedies. The Tribunal found that the Ministry’s obligation of good faith and fair dealing in the context of compliance with the Tribunal’s orders was “at least as high as in the context of dismissing an employee” – i.e., the obligation as set out by the Supreme Court of Canada in Wallace v. United Grain Growers Ltd. (c.o.b. Public Press). 6 The Ministry acted in bad faith with respect to making misleading statements concerning the degree to which it was complying with the order to implement systemic change in the workplace. The deadline imposed by the previous orders was clearly not met. The finding of bad faith was also grounded in the fact that the Ministry suppressed and failed to disclose documents that were germane to the litigation, causing prejudice to Mr. McKinnon's conduct of the case. This bad faith conduct supported a finding of retaliation/reprisal for the original and ongoing human rights complaints. The Ministry was also found to have failed in its obligations on many other counts: it failed to provide Mr. McKinnon with information relevant to his reinstatement and safe return to work, to comply with previous Tribunal orders that allegations of racial harassment and discrimination be handled by external investigators, to make compliance with the Tribunal's orders a part of managers' evaluations, and, to take action against managers mishandling the situation. Further, the Ministry was found to have rewarded wrongdoers by providing these managers and employees with better treatment (lavish monetary payments, covering legal expenses, to which they had "no legal or moral entitlement") than it did to Mr. McKinnon or any employees or managers testifying on his behalf. Finally, the Deputy Minister was found to have failed to be accountable for the Tribunal orders, taking a damage-control approach rather than a true reform approach to the orders issued in 2002 Unprecedented Remedies As a result of these findings, the Tribunal issued both systemic and individual remedies. Organizational change was identified as paramount. The Ministry must now establish a province-wide tracking system for human rights complaints, workplace discrimination and harassment grievances and policy matters. Third-party, anti-racism consultants have been given wide latitude to effect organizational change and to eradicate racism from the ranks of the Ministry. The Deputy Minister must now establish a transparent system of delegation to competent personnel in assisting in implementation responsibilities. Managers have been made responsible for taking timely and appropriate action in response to violations of the Ministry’s workplace discrimination and harassment policy and the Tribunal’s orders. Finally, the third-party consultants were ordered to consider the need for an Aboriginal Issues Coordinator for both staff and inmate issues. With respect to individual relief, the Tribunal made directions to facilitate the successful re-integration of Mr. McKinnon and his wife, including job-shadowing and assignments to acting positions. Interestingly, the McKinnons have been offered the option to secure positions with the “Workplace Effectiveness Branch”, a new unit within the Ministry charged with managing conflicts within the institution. It also ordered $10,000 as damages for mental anguish caused by the reprisal and general damages and compensation for various losses to be assessed for both Mr. and Ms. McKinnon, as well as an independent assessment of the value of lost opportunities suffered by both since 2002. It remains to be seen how much the McKinnons are able to recoup in terms of their careers, and how the Tribunal will evaluate the opportunities they lost over the last five years. For this, another submission to the Tribunal in the near future is required. Conclusion Under Bill 107, An Act to Amend the Human Rights Code, the Human Rights Tribunal has enhanced powers to award damages. In particular, the cap of $10,000 on damages for mental anguish that existed at the time this decision was made has been eliminated. In addition, a new Anti-Racism Secretariat now has the power to initial research and make recommendations to eliminate race-related discrimination. Workplaces rife with racist behaviour and managers who tolerate it will, it is hoped, no longer be able to evade institutional reform. To read the Tribunal’s January 30, 2007 decision, please click
here:
Update on Human Rights Reform – Ontario Human Rights Commission Introduces Pilot Project for Processing ComplaintsBy Fay Faraday
Most of the substantive changes introduced by Bill 107 will not come into effect until a date to be named by proclamation. In the meantime, however, the Ontario Human Rights Commission has announced other changes that will affect the current enforcement of human rights. Until Bill 107 is proclaimed in effect, human rights complaints continue to be filed with the Ontario Human Rights Commission. In March 2007, the Ontario Human Rights Commission announced a pilot project that is underway to speed up the processing of complaints that are filed with the Commission. This is being done by setting strict time lines for mediation and fact-finding and requiring parties’ participation failing which a complaint may be referred for decision without further notice to the party. Under the pilot project, when a complaint is served, the parties will be given set dates for a mediation and a fact-finding meeting. Parties are expected to attend at the set dates, although requests for extensions will be considered in cases of extreme personal hardship or for reasons that require accommodation under the Code. If a party does not attend for mediation, the complaint may be dealt with under s.34 if a request has been made to dismiss it under s. 34, or the complaint could be referred for investigation. The parties are required to collect and produce all documents and other information requested by the investigator in advance of the fact-finding meeting. The fact-finding meeting is part of the investigation process and involves both investigation and conciliation. It will usually be scheduled within six to eight weeks after the scheduled mediation meeting. If the respondent has not provided a response to the complaint, the investigator will give a deadline of 10 calendar days. If the respondent has not filed a response within that period, the complaint may be referred for decision by the Commission without further notice to the respondent. If either party fails to attend at the fact-finding meeting, fails to cooperate in the fact-finding meeting, fails to produce the documents requested by the investigator, or cannot be located to complete the processing of the case, the complaint may be dismissed or referred to the Human Rights Tribunal without further notice to that party. Further information about the Commission’s pilot project is posted on the Commission website. In other developments directly connected with Bill 107, Ontario Human Rights Tribunal Chair Michael Gottheil is continuing to develop the Tribunal’s new processes and approaches to adjudication and has been holding “targeted advice sessions” with stakeholders on key elements of the Tribunal procedures. Before the Human Rights Code reforms are proclaimed in effect, the Tribunal will make its Draft Rules available for public review and comment. Further information can be obtained on the Human Rights Tribunal website. Finally, Helena Birt has been appointed as the Transition Director of the Human Rights Legal Support Centre. Ms Birt was formerly the Manager of Family and Civil Duty Counsel Services for Legal Aid Ontario. As Transition Director, she will collaborate with the Human Rights Tribunal and Human Rights Commission to design and develop the new Human Rights Legal Support Centre.
A. Keays v. Honda On 29 March 2007, the Supreme Court of Canada granted leave to appeal in the case of Keays v. Honda Canada which deals with a disabled employee who was terminated without just cause. In particular, the employee was awarded significant punitive damages because of the employer's bad faith and discriminatory conduct. An analysis of Keays v. Honda can be found in our November 2006 issue of Human Rights Update by clicking here.
Employment Equity also remains a priority for Ontario workers. The Ontario Federation of Labour is holding an Employment Equity Roundtable on May 31, 2007. See: http://ofl.ca/index.php/about/index_in_in/employment_equity_roundtable/ In the absence of specialized employment equity legislation in Ontario,
efforts are being made to develop new workplace strategies to address
the need to create workplaces and conditions of work that reflect the
diversity of Ontario’s working population. For racialized persons,
persons with disabilities, aboriginal peoples, women and other vulnerable
workers, there is a need to negotiate employment equity provisions in
collective agreements. Alternatively, or in addition, existing anti-discrimination
provisions in collective agreements must be used to require employers
to take proactive steps to remove barriers and take positive measures
to improve the representation of disadvantaged workers at all levels of
the job hierarchy in workplaces. See: Strategies
for Achieving Employment Equity C. Pay Equity Pay Equity continues to be an important agenda item for the labour and human rights movement. On May 2-3, 2007, the Pay Equity Network composed of trade unions and women’s groups will be meeting in Ottawa to discuss the way forward at the Federal level. With globalization leading to women making up the dominant proportion of ever more precarious forms of employment – including home-based work, dependent and independent contracting – efforts need to be made to expand the scope of pay equity in order to end the discrimination in the diverse forms of women’s work. Click here to link to “Closing the Global Gender Pay Gap: Securing Justice for Women’s Work”, Mary Cornish’s article in the most recent volume of the Journal of Comparative Labour Law and Policy. D. Human Rights Mary Cornish has recently completed a Chapter “Securing Sustainable
Human Rights Justice for Workers” for the forthcoming ILO Book on
Labour Law in the 21st Century edited by Arturo Bronstein. The Chapter
focuses the areas of gender and racial equality, equality for persons
with disabilities and the protection of religious freedom and the right
to privacy in developed and developing countries to provide guidance to
the equality-seeking community for translating the human rights of workers
into sustainable and just outcomes. A copy of the Chapter is available
by clicking here. Human Rights Update Archives | Cavalluzzo website | Update for Professionals We welcome your comments. If you have comments about the newsletter, we would value receiving them, or to unsubscribe to this newsletter, please send a reply e-mail with UNSUBSCRIBE in the subject or send an e-mail to the Editor, Jo-Anne Pickel, at humanrightsupdate@cavalluzzo.com. To add yourself to the newsletter mailing list, please send an email to majordomo-2@cavalluzzo.com with the word SUBSCRIBE in the subject line. To find out more information about the firm and its lawyers and the scope of our practice generally, visit our web site at www.cavalluzzo.com. Providing this information does not constitute individualized legal advice, and does not establish any form of lawyer-client relationship with our firm or with any of our lawyers. Readers should not rely on or take any action based on this information; professional advice should be obtained. While we strive for accuracy, mistakes are possible and there may be errors and omissions. We disclaim any liability for such errors and omissions. Copyright 2007 © Cavalluzzo
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