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Employment equity in Canada and South Africa: a comparative review

The South African Government has sought to redress the historical legacy of workplace discrimination by introducing the Employment Equity Act (1998), which was largely modeled on the Canadian Employment Equity Act. Although there is very little comparative information between South Africa and Canada, we fill this gap by reviewing the literature in both countries, highlighting common features of the legislation, discussing the effectiveness of legislation in both countries as well as the progress made by the designated groups covered by the legislation. This paper provides a background on the rationale for employment equity and associated human resource management policies in both Canada and South Africa. The analysis is largely based on institutional theories of organizations. Our evaluation provides overall conclusions for policy makers and organizational leaders, taking into consideration socio-historical, political, and demographic differences between the jurisdictions. Issues include top management commitment, organizational culture, Black economic empowerment, and diversity policies and practice.