Imposed lateral move not constructive dismissal

Can an employer ever move an employee upwardly or laterally without fear of constructively dismissing an employee?
|Canadian Employment Law Today

Since 1989 Barry Dykes worked as the manager, human resources, for Saan Stores Ltd. His duties involved a general human resources role for over 3,500 employees at 250 stores across Canada. He supervised three employees who reported directly to him. Mr. Dykes always received favourable annual performance reviews.

In 1999 Mr. Dykes was seconded from his usual duties to work on a new project known as human resources information services (HRIS). This project involved preparing human resource projects dealing with planning and development. Initially the secondment was expected to last six months. However, on Mr. Dykes’ initiative, additional matters were included in the project and it lasted approximately one year. The employer was very satisfied with Mr. Dykes’ work on this project.

While Mr. Dykes was working on the HRIS project, the vice-president of Saan received several complaints from the employees that Mr. Dykes supervised. The complaints referred to his high-handed manners and his attitude towards the employees. The employees accused him of not listening to their suggestions. The vice-president regarded these complaints, if true, as serious, particularly since Saan Stores was trying to establish positive policies for employees and their relationships with customers and other employees.