I'll begin, and then I'll turn to my colleague to add to it.
Essentially, the intention of the legislation is to include a number of steps that need to be undertaken before a complaint could potentially come forward to the labour program. In other words, when employers become aware of an issue, they have a duty to try to resolve it informally. If at that stage the parties to the complaint are not satisfied, then the employer has a duty to undertake an investigation led by a competent person.
That's where you get impartiality and bias. The department of labour isn't involved at that point, other than.... There will be some reporting, but that's it. An investigation gets undertaken, recommendations are made through that report, and then it's up to the employers to implement those recommendations. Again, the department is not involved. The only time the department would get involved would be if there were a complaint that the process hadn't been followed.