I think in all jurisdictions across Canada you're going to see a multiplicity of fora where you can bring concerns of harassment. I'm not necessarily concerned that someone might be able to bring a complaint under both the Canada Labour Code and the Canadian Human Rights Act. There are processes in place. Typically the commission will put something in abeyance pending the resolution or require you to take other first steps.
I think those avenues should remain open for individuals to make choices with a model they want to use to pursue this, but I would be concerned that this legislation provide at a minimum a base level of protection for everyone equally. I know that right now the legislation is structured so that the minister can decide that one of the other processes is adequate and they don't have to investigate: for example, if you have a grievance process or if you access your remedies under the Canadian Human Rights Act.
I would just want to make sure, though, that an investigation under the Treasury Board policy, in which you're not necessarily going to have an independent and impartial investigator, isn't the replacement for your rights under the act and isn't the basis on which they can say that you've had your right to an investigation.