Finance Committee on Dec. 6th, 2010

[Paul Davidson]

It puts people at higher risk of kidnapping. I will simply say that. And if you want to speak about the measures charities go to, to insure their staff, the fees they pay to insure their employees overseas--

[Thomas Mulcair, NDP, Outremont, QC]

Mr. Davidson, no one is saying you should reduce protection for your employees. No one is saying there's no risk. Your statement is that, if salaries that some already assumed to be high are made public, we're increasing the risk. You have no proof of that. I don't believe that's a well-supported statement, with all due respect.

Thank you, Mr. Chairman.

[The Chair, Conservative, James Rajotte]

Okay, we are at the end of our panel.

I only need an indication from the committee. We are supposed to move on to the second panel. Is that agreed?

[Some hon. members]

Agreed.

[The Chair, Conservative, James Rajotte]

I do want to thank all of you for being here this afternoon, for your presentations and your responses to our questions.

I would say--and I don't think I'm overstepping myself as the chair--that I think the committee has certainly heard your concerns with respect to the amount, but I think there is a great deal of skepticism. I would frankly share Mr. Mulcair's skepticism with respect to the argument concerning disclosure.

If you want to provide anything further to the committee, please do so, because I think this committee needs some convincing on that second point. If you can do so as soon as possible, we'd appreciate that very much.

Thanks to all of you.

We will suspend for a couple of minutes, colleagues, and resume with the second panel.

[The Chair, Conservative, James Rajotte]

Colleagues and guests, we do have a very tight timeline this afternoon, so I'll ask you to take your seats, please.

We have with us for this hour a panel consisting of the Canadian Bar Association; Charity Navigator; Imagine Canada; the Association of Fundraising Professionals; the Calgary Chamber of Voluntary Organizations; SickKids Foundation; and Kingston and District Labour Council. They will present in that order.

I hope some of you have heard the previous discussion. You're obviously all aware of the seeming intent of the committee to address the amount issue, so I hope you can address the concerns any of you may have with respect to the second issue in terms of disclosure.

We'll start with Mr. Carter, please, for five minutes.

[Terrance Carter, Chair, National Charities and Not-for-Profit Law Section, Canadian Bar Association]

Mr. Chair, members of the committee, thank you for the invitation to appear before the committee to provide comments on Bill C-470.

My name is Terrance Carter, and I am chair of the charity and not-for-profit law section of the Canadian Bar Association.

CBA is a national association of 37,000 jurists from across Canada, including lawyers, notaries, law teachers, and students. This submission was prepared by the national charity and not-for-profit law section of the CBA. Members of the section include lawyers from across Canada who advise or serve on the boards of charitable and not-for-profit organizations.

At the outset, the CBA section is very pleased that amendments to Bill C-470 have been proposed to remove the compensation cap of $250,000. What remains of Bill C-470 is a requirement to make available to the public “the name, job title and annual compensation of the five executives or employees with the highest compensation” in excess of $100,000. In this regard, the CBA section questions the need for a name and salary disclosure requirement proposed in the bill.

As will be explained, the stated objective of the bill, namely the need for transparency, in our opinion can be met by permitting the charities directorate to monitor the activities of registered charities, including compensation through executives and other employees in accordance with subsection 149.1(14) of the Income Tax Act requiring all registered charities to file an annual T3010B, registered charity information return.

The concerns of the CBA section will be addressed by explaining three problematic aspects of the bill as amended. Specifically, they are redundancy in transparency objectives, privacy concerns, and the potential prejudicial impact upon the charitable sector workforce.

First, transparency and accountability in the charitable sector is no doubt a desirable objective. However, transparency is not an absolute value, and it must be balanced with privacy, efficiency, and practical impact of the disclosure to be made.

The requirement by CRA that every registered charity must include in its annual T3010B disclosure the compensation ranges, from under $40,000 to over $350,000—but not the names or job titles of persons receiving them—for the ten highest-paid employees provides a suitable level of transparency for both CRA, as the regulator, and the public, without violating the privacy of the employees of the charity.

If the CRA becomes concerned about the question of compensation, they have the authority under the Income Tax Act to conduct an audit and require the disclosure of all details of compensation, including the name, job title, and actual amount paid as compensation. A registered charity that fails to disclose such information is subject to sanctions, including the ultimate sanction of revocation of charitable status.

With regard to the matter of privacy, the CBA section believes there is an unnecessary and unwarranted intrusion of an individual's privacy in requiring disclosure of the name, job title, and compensation received by an employee or executive of a charity simply because the person works for a registered charity. The charity may receive no direct government funding and it may not even issue tax receipts for tax credits.

There is no compelling policy reason from an income tax perspective, either based on transparency or accountability, to require the identification of individual employees in the manner called for in the bill.

In order to justify an intrusion of a person's privacy, there needs to be a cogent policy reason for doing so. Since CRA is already collecting and making public the compensation range of the top ten employees of a charity and it has the ability to audit and review the details of compensation paid to such employees, there's no policy reason to justify the intrusion upon an employee's privacy.

[The Chair, Conservative, James Rajotte]

Okay, one minute.

[Terrance Carter]

This raises the last point of concern, and that is the potential prejudicial impact that Bill C-470 could have on the workforce within the charitable sector.

Employees of registered charities are a diverse group, often changing positions within the sector as well as coming into and out of the charitable sector. This is due in part because their compensation tends to be lower than in the business or public sector. As well, there's often less security in their positions and availability of pensions compared to public sector positions.

The charity sector workforce is driven by a passion for what they do. They are generally prepared to receive less compensation than their counterparts in the private sector or in government. To now require those same individuals who receive compensation in excess of $100,000 to have their name, job title, and compensation made public may have the effect of driving good people from the sector.

In addition, for those employees working and travelling in areas of conflict—

[The Chair, Conservative, James Rajotte]

Okay, thank you. Just wrap up very briefly, please.

[Terrance Carter]

Fine.

In conclusion, the CBA section believes that the proposed Bill C-470, as amended to require the public disclosure of name, job title, and compensation, is unnecessary and misguided. The CBA section therefore strongly recommends that the bill, as amended, not be enacted.

[The Chair, Conservative, James Rajotte]

Thank you.

We'll hear from Charity Navigator, please.

[Ken Berger, President and Chief Executive Officer, Charity Navigator]

My name is Ken Berger. I'm the president and CEO of Charity Navigator, and I make $140,000 a year.

Our organization's mission is to be a guide to intelligent giving. So we're here for the donors.

I have to tell you—on behalf of donors in the United States, at least—that the question of the compensation of the leadership of charities is one of the most critical pieces of information donors want to know. We have over three million people who use our website. We get five million hits a year. It's estimated that we impact between $5 billion and $10 billion of charitable giving each year. The most frequent comment we get from our users is regarding CEO compensation. Every year we do a CEO compensation study, and it's because of the public disclosure of that information that we're able to do this. We provide it freely; you can download it from our website. It is without a doubt the most popular thing we do.

I just want to say that from the scandals that have occurred in the United States among well-known charities, from the Red Cross to the United Way to the Smithsonian, and others, there's been the firm belief that transparency in every area, including salaries, is one of the ways to shine a light on the scoundrels and to avoid scandals in the future.

In the United States, the IRS gathers this information. For the first time in over 30 years, they have modified their reporting form to obtain even more information, far more information and more detail on the salaries, because it has been so relevant. While the auditing of charities is a function of theirs, the fact is their ability to do this is very limited. Their staffing is limited. So we think that public disclosure, that shining of the light, is a restraint on some of the extreme outliers and abuses that are out there. It affords an opportunity for a groups like ours, and the media and others, to do investigations of those outliers and problems.

I read with some amazement an argument that's been made by some here that in the United States, because of the transparency and the fact that we now know the salaries, the salaries have skyrocketed. Well, did you know there's been an increase in the number of buffalo and a skyrocketing in text messaging in the United States?

[Some hon. members]

Oh, oh!

[Ken Berger]

The correlation between transparency and this notion of salaries.... In fact, the reason that salaries have increased is in part that in the United States there's been a dramatic increase in the amount of government contracting for charities to do the kinds of work that government has done before; and as the economy has done well—at least up until 2008—and the percentage of money that people give has grown, so have the size and complexity of these organizations. That is the way salaries get determined. According to all of the experts we speak to, the salaries are based on size, complexity, and cause. Those are the reasons that salaries go up, not because of transparency. My God, it's the opposite! Transparency helps as a brake against abuses.

So, other than that, I would argue, in conclusion, that if a charity is truly mission-driven, then when the dust settles and this information is disclosed, it will become more trusted. The most precious commodity a charity has is the trust of the public, and the public wants to know this information. Those charities that are open in this way and disclose information will garner more trust, and it will lead to a more efficient sector. The information will help all of us in making more rational decisions related to determining CEO compensation in this sector.

In conclusion, I hope we can have more disclosure in areas like this, so that the mission can be better fulfilled, rather than seeing the abuses where people's pockets get lined, rather than the world being made a better place.

Thank you.

[The Chair, Conservative, James Rajotte]

Thank you very much for your presentation.

We'll now hear from Imagine Canada, please.

[Don McCreesh, Chair of the Board, Imagine Canada]

Thank you, and good afternoon.

My name is Don McCreesh. I am the chair of the board of Imagine Canada, the national umbrella group for Canada's charities and not-for-profits. I've been a volunteer director for over 40 years and often served as chair of the board or head of the HR committee. Compensation issues have formed a large part of my professional life as an HR corporate officer and now director of boards of publicly traded corporations and charities.

I take my responsibilities very seriously, as do the hundreds of thousands of charitable board members who give of their time and expertise.

At a time when charities are striving to respond to growing demands, even as governments and philanthropists are increasingly constrained in their ability to maintain their support, I sincerely hope that the mischaracterizations of charities' compensation levels, of their commitment to transparency and accountability, as you've heard today, and of the use they make of the valuable resources that are entrusted to them have not, even unwittingly, done a great disservice to charities' donors and the people they all strive to support.

Imagine Canada and the charities are committed to increasing public understanding of the true costs of doing good and promoting transparency and accountability regarding all moneys entrusted to the sector, contrary to what has been stated. Canadians need access to a broad range of information in order to make informed decisions, and we're constantly striving to enhance the availability and accuracy of this information.

On the issue of compensation levels in the sector, the facts speak for themselves. Employment in the sector is often characterized by non-competitive salaries, few or poor benefits, and little or no pensions. Of the approximately two million Canadians who work in this sector, over 99% make less than $250,000, but even large organizations with great financial means often find themselves at a disadvantage attracting or retaining highly skilled people, who could just as easily choose employment in the private or public sector.

Over the past several months we have shared our concerns with parliamentarians regarding the unintended consequences of this bill, and we are pleased to see the significant amendments that have been proposed. We strongly encourage members of the committee to look favourably upon those proposed amendments. Imagine Canada is firmly opposed to the compensation cap, both as a matter of principle and for practical reasons.

Charities are governed by independent boards of directors with fiduciary obligations to make decisions in the best interests of the organization, including those concerning compensation. The compensation cap would have undermined the authority and role of these volunteer boards, and would also have been highly discriminatory. No other sector would have been singled out for this treatment, regardless of the public expenditure from which many of them benefit.

As I understand from the amended bill, only one clause would remain in the proposed legislation, the one that would require the disclosure of names, titles, and compensation details for the five most highly compensated employees of a charity, if it exceeds $100,000 a year.

We respectfully submit that this additional layer of transparency, if it's deemed necessary, is best achieved through administrative reforms rather than through legislation. CRA officials have outlined the compensation information that charities are required to provide. That is already publicly available and has been enhanced this past year.

We strongly support this level of transparency and would be prepared to see more reporting ranges added to increase transparency regarding compensation above $350,000. We do question the added public benefit of revealing individual names. Where such practice has been introduced, the end result has been to drive executive compensation upwards.

If members still believe salary disclosure would achieve benefits that outweigh privacy concerns and unintended consequences, this can be achieved through administrative means. This would also allow greater flexibility in adjusting the parameters of these requirements over time and should unintended consequences arise.

If, despite the possibility of directing CRA to implement these changes, members of the committee deem that legislation is required, we once again strongly recommend that the amendments be accepted, but we would add two caveats.

First, where laws have been required on the disclosure of compensation details, one of the main drawbacks has been the lack of an inflationary escalator for the trigger amount. In Ontario, for example, the $100,000 was established almost 15 years ago and has not changed. The disclosure list now includes people it was never intended to capture. We hope the members take this into account and build in an escalator.

Secondly, there are instances when there are potential personal security ramifications to full disclosure. We have heard about international development workers, but I also point out that employees of domestic abuse shelters have the same issue. They often require anonymity, and they have spoken to us about that. We believe the minister should retain the flexibility to choose, where circumstances merit, the publication of this information, and not to publish exact details where that could be an issue.

I commend you for the responsiveness that you've shown to date on this issue and welcome your questions.

[The Chair, Conservative, James Rajotte]

Thank you very much for your presentation.

We'll now hear from Mr. Blumberg, Association of Fundraising Professionals.

[Mark Blumberg, Partner, Blumberg Segal LLP, Association of Fundraising Professionals]

Thank you, Mr. Chairman.

My name is Mark Blumberg. I'm a charity lawyer in private practice and a volunteer with the Association of Fundraising Professionals' Canadian government relations committee. I've written quite extensively on Bill C-470, and I'm grateful for the opportunity to address you today.

The Association of Fundraising Professionals, also known as the AFP, is a global professional association for individuals responsible for generating philanthropic support for a variety of non-profit charitable organizations. The AFP advances philanthropy in society by enabling people in organizations to practise effective and ethical fundraising. The core activities through which AFT fulfills this mission include education, training, mentoring, research, and credentialling. AFP is the largest association of fundraisers in the world, representing more than 30,000 practitioners, including 3,100 members in 16 chapters across Canada.

AFP appreciates the spirit of Bill C-470, strongly supports transparency and good stewardship, and is pleased to learn of recent amendments proposed relative to the bill. However, we remain concerned about the bill for a number of reasons.

First, there are already rules on charity compensation. CRA notes that compensation should be fair and reasonable. Otherwise, if compensation were disproportionate to the services rendered, it would contravene the Income Tax Act. The CRA's fundraising guidance, which is available on the charities directorate website, also discusses good staffing processes and notes that the salary should “never exceed the fair market value for the services provided”.

Second, a regulatory framework for transparency already exists. On the revised T3010B , the Canada Revenue Agency already requires that charities must provide compensation information for their ten most highly paid employees in one of nine ranges to the CRA, which then publishes them. Creating another secondary disclosure is unnecessary.

Third, non-profit board members and administrators are already subject to CRA scrutiny and have a fiduciary duty to make sure that all decisions, including those concerning employee and executive compensation, are made in the best interests of the registered charity.

Fourth, CRA already has the power to ask charities, first, to provide additional compensation detail as it deems appropriate, and second, to publish that information. This appears to make the bill as revised unnecessary.

Fifth, providing simply the name, job title, and annual compensation without context could be misleading. One researcher might be paid $150,000 and another $250,000. Which charity is providing appropriate compensation? Or might both be appropriate subject to differing circumstances? To know the answer, an individual would require information including, but not limited to, information on experience, professional qualifications, amount of responsibility, and comparable market compensation.

AFP has strongly supported past tough measures to enhance transparency and accountability, including the June 2009 guidance on fundraising, which owing in large part to open, comprehensive, and cross-sector consultation was well designed and welcomed by the sector. Indeed, the recent Attorney General’s report, while noting capacity challenges, specifically highlighted CRA's improved performance in charity regulation and enforcement.

AFP proposes that this bill not go forward at this time. Instead, we propose that the charities directorate of the Canadian Revenue Agency be instructed to immediately and urgently undertake consultation with the sector and other interested parties about increasing transparency and accountability. CRA Canada, without changes to the Income Tax Act, has already significantly increased disclosures in the T3010B on a number of different issues, including expanding salary ranges from $120,000 to $350,000 and up. That did not require any legislative changes, and I don't believe Mrs. Guarnieri was even aware of that change.

AFP strongly believes that it would be beneficial to this sector, its stakeholders, and the CRA to have greater transparency and more relevant information available. CRA has a proven record of delivering on such matters.

In conclusion, AFP would like to thank the Standing Committee on Finance for this opportunity to appear, and we are available to provide any additional information you require in your deliberations on this important issue.

Thank you.

[The Chair, Conservative, James Rajotte]

Thank you.

We'll now hear from the Calgary Chamber of Voluntary Organizations.

[Katherine van Kooy, President and Chief Executive Officer, Calgary Chamber of Voluntary Organizations]

Thank you very much, Mr. Chairman.

I appreciate the opportunity to be able to comment in person today. My name is Katherine van Kooy and I'm the president and CEO of the Calgary Chamber of Voluntary Organizations. Our 440 members reflect the diversity of this sector in terms of the size of the organizations and the range of areas in which they operate. My comments today are really based on our concern about the implications of this legislation for the broad charitable sector.

We appreciate the response to the concerns that have been raised previously about the impact of this legislation, particularly the amendment that was introduced on November 29 to remove the salary cap. Had there been a legislated compensation cap, it would have put employees of charities into a separate class through government intervention in determining compensation that should be market-driven. In doing so, government would also be sending a very strong message that the work of the charitable sector is less valuable than that of the for-profit sector.

Our organization is committed to the promotion of high ethical standards and accountability for charities. We believe that donors, charities, and communities all benefit when donors feel comfortable that their money is being spent wisely.

Through CCVO's work, we know that one of the major issues raised by organizations in Alberta and across the country is the growing overburden of multiple reporting requirements. These requirements increase administrative costs without contributing in a meaningful way to improved accountability and services to the community. Therefore, we urge that the priority of this committee be given to streamlining reporting requirements and improving the existing mechanisms first.

As already outlined by others, there is an existing mandatory reporting system in place for all registered Canadian charities through the annual T3010 reports that are filed with the Canada Revenue Agency. The system already requires substantial reporting of information about revenues and expenditures, fundraising costs, compensation levels, details about directors, and more. When organizations are not fulfilling their reporting requirements, or when the information provided raises concerns, we fully encourage the CRA to take action. They already have the power to do so. In fact, as you know, the CRA has the power to investigate not only executive salaries that Bill C-470 is now focused on, but other areas as well.

Some concerns have been raised about the information available on the CRA website. I would point out that the timeliness of reporting requirements is far more stringent in Canada than it is in the United States. In terms of the issues raised about accessibility of the information, that's a matter that can be resolved without the need for legislation.

The focus of Bill C-470 is now entirely on disclosure of compensation levels, including compensation for fundraisers, as though this is the only basis on which donors should choose to invest in charities. This information conveys nothing about the impact of the organization in pursuing its mission, or the value of its work in the community it serves. As a donor, that's the information I need in order to be comfortable that my donation is a wise one. Meaningful information about the potential impact of my donation is hard to find. At least it's hard to find in one central location.

I suggest it would be more effective for us to extend and improve the type and quality of information that's collected and available on the CRA website. These changes could be made simply through administrative reforms. If the committee feels it is necessary, the annual T3010 return could be adjusted, as others have suggested, to provide more information about top salaries. It makes sense to use the framework that is already in place. CCVO, and I'm sure many other organizations, would be more than happy to work with the CRA to continue to improve the quality, usefulness, and accessibility of information about Canadian charities.

We do not support the need for this legislation. However, if the committee decides that legislation is required, we urge, as others have, that two amendments be included to further enhance the positive addition of a minimum threshold for reporting the top five salaries in an organization.

First, include an escalator clause that will adjust the threshold level automatically for inflation. This would preserve the intent of reporting on executive-level compensation and not drift down over time into reporting on non-executive staff.

Second, we also feel it's essential that the minister be able to exercise discretion to deal with situations where public disclosure of the names and salaries of employees could compromise their safety.

Finally, we recommend that there be opportunity for further consultation on any new changes that may be proposed to this legislation. This is to ensure that the changes do not in turn have unexpected consequences.

Bill C-470 is intended to increase transparency and improve information for donors. I encourage the committee to consider whether those goals are best achieved through new legislation and new provisions regarding the same type of monetary-only information, or if what is required is more meaningful information and increased follow-through on the provisions already in place for the CRA as the regulator of Canadian charities.

Thank you.

[The Chair, Conservative, James Rajotte]

Thank you very much.

We'll now hear from SickKids Foundation, please.

[Patsy Anderson, Chair, Board of Directors, SickKids Foundation]

Thank you very much.

My name is Patsy Anderson and I've been sitting as chairman of the board of SickKids Foundation since 2006. I've served on the board since 2001, and I'm also a trustee on the board of the hospital.

I thought as an opener I would just talk to you briefly about what SickKids Foundation is. We are the partner of the Hospital for Sick Children, which has for generations affectionately been known as SickKids in central Toronto. They have patients from across Ontario, across Canada, and around the world. Their health care workers are a huge brain gain to Canada, with medical and scientific leaders from all over the world.

SickKids has over 7,000 employees. We have over 300,000 donors and raise between $80 million and $100 million a year. Our endowment is currently worth $680 million.

It's a great honour for me to hold this role. It follows many years as a SickKids parent. I'm also a donor and take very seriously how donor dollars are spent at SickKids.

SickKids Foundation supports the goal of increased transparency and accountability for the charitable sector. Our commitment to transparency and accountability is fulfilled through public disclosure of our regulatory filings with the Canada Revenue Agency and the Internal Revenue Service in the United States. These annual filings include detailed information on the costs of fundraising and administration of our foundation, and in the case of the IRS filing, the actual compensation paid to named senior employees. Indeed, SickKids has been publicly disclosing salaries paid to senior employees for more than ten years, and we are prepared to do so with the Canada Revenue Agency if asked. The foundation’s annual report and audited financial statements are also publicly available on our website.

SickKids Foundation does not support a compensation cap on charity salaries, and we applaud member of Parliament Albina Guarnieri for removing this element from her proposed bill.

Professional fundraising employees and dedicated volunteers help to generate $112 billion in revenues in Canada’s charitable sector. Very large charities like SickKids Foundation are complex organizations, and our senior staff are required to provide leadership in fundraising priority setting with the Hospital for Sick Children and dozens of fundraising programs.

The investment management task is very complex, with the endowment I referenced earlier. Our governance is very complicated, and we pride ourselves on best practices. Grant-making is also very complicated. I think you would be interested to know that SickKids Foundation has granted over $75 million outside of the Hospital for Sick Children to pediatric researchers from coast to coast to coast in Canada. We also have complex brand management tasks, stakeholder relations, and human resource management. This is a very complex job.

This requires that we attract and retain leaders who have a broad range of skills, proven track records of success, and professional credentials. It also requires us to compensate them according to the scope of their responsibility, in comparison to what they would earn in other leading not-for-profit positions.

The compensation objectives, philosophy, and annual salary increases at SickKids Foundation are approved by the compensation committee and the board of directors annually. It's a very thorough review with best practices, and we're very proud of it. Based on these findings, the board approves any changes to salaries to keep them competitive. We are concerned that a compensation cap will deter the recruitment of new young talent into the charitable sector, which I believe is critical for the health of the sector going forward.

In summary, we support all efforts to make charities transparent and accountable for their operations. We welcome opportunities to work with the government to find ways to increase transparency and accountability, without interfering with the ability to raise money for good purposes that benefit society.

Thank you very much.

[The Chair, Conservative, James Rajotte]

Thank you very much, Ms. Anderson.

We'll now hear from the Kingston and District Labour Council.

[Joan Jardin, Treasurer, Kingston and District Labour Council]

Hello, and thank you to the Standing Committee on Finance for allowing me a few minutes to address your honourable members.

I'm here today on behalf of all the affiliates and community members of the Kingston and District Labour Council. I'm sensing it's quite a different position or background from that of a lot of my esteemed colleagues here.

We have been chartered with the Canadian Labour Congress since 1956. I'm Joan Jardin, and I'm the treasurer of the labour council. We represent over 40 member unions and 156 union locals in the Kingston region. Our membership totals almost 10,000 workers, in addition to many community coalitions and groups. We are active in labour concerns and in employment, municipal, provincial, federal, and social issues.

As you're aware, there's a strong partnership between organized labour in Kingston and the United Way serving Kingston, Frontenac, Lennox, and Addington. I have personally been in the campaign cabinet as labour liaison for over seven years, and I've also worked on the citizens review panel, where we do the real accountability, not the paper accountability that can be published in a quick snippet. We actually go to the agencies. We look at their income. We look at the programs. We take a look at their actual outcomes, and we also visit the organization. So we do the real accountability. We can actually take a look at the organizations. Just taking one piece out of the other really is information in a vacuum and really does pit people against each other.

It's due to this very important relationship that we feel it's necessary to inform you of our thoughts surrounding Bill C-470. I hope you've received a copy of the letter that we have sent. If passed, this legislation would have a far-reaching impact, not only on the charitable sector, but on many institutions, such as schools, hospitals, universities, and more. To the extent that this bill seeks to further strengthen transparency and disclosure, we are in principle supportive. There are, however, some serious issues that the Kingston and District Labour Council sees with the bill. The Kingston Labour Council has identified five areas of concern, which will have a direct and negative effect on our community. On behalf of those I represent, I sincerely ask that this bill not be passed as written and that this committee consider all ramifications of the language in this piece of legislation.

Also, I wear another hat--and I haven't actually seen all the amendments proposed, because I actually have a full-time job in addition to working for agencies--in that I'm a teacher, and when I look at this, it seems as though there's been a problem, and you're trying to hurt the class, and I don't think any of you would like that. If there are some particular issues, we address those issues, and we find ways to deal with those. Also, I believe in accountability, but I don't believe in pretend accountability, so I think we really have to make sure we're not just making extra work for people, but that we actually are looking deep into the very important issues of charities. I wish we didn't need charities, but unfortunately we do.

First, of course, is disclosure. The disclosure requirements could be quite problematic for the vast majority of charities that are very small and have very few employees. The small charities will be forced to publicly disclose names and salaries of their staff. Of course, given the amendment changing it to $100,000, that disclosure will be a bit limited, but especially if it's a small charity, it will certainly be possible to pinpoint who they are, and that's a bit of an issue.