This article explores the most significant employment law cases in 2022, and their related implications.
BAD FAITH DAMAGES
Awards of bad faith damages (as a subset of the broader category of “moral” damages) in wrongful termination litigation in Ontario have been rare. Such awards only arise in exceptional cases where the conduct of the employer is particularly egregious and the employee can show they have suffered mental distress as a result of such conduct. However, there has recently been an uptick in the awards of such damages, as illustrated by two cases of note in 2022.
Pohl v Hudson’s Bay Company, 2022 ONSC 5230
Mr. Pohl, a 50-year-old sales manager with 28 years of tenure at Hudson’s Bay was offered a demotion to a “sales associate lead” with less hours, no guarantee of hours, less pay and a contract that would allow the company to terminate his employment by providing him with only minimum statutory entitlements, all on the condition that he “voluntarily resign” from his managerial position. Mr. Pohl refused the offer and was subsequently walked off the premises. He successfully sued Hudson’s Bay for wrongful dismissal, and was awarded $45,000 in moral damages and $10,000 in punitive damages.
The Court’s reasoning for awarding moral damages included:
- The employer’s highly insensitive decision to walk Mr. Pohl out the door on termination and needlessly embarrass him;
- The “misleading” way in which the employer attempted to lock Mr. Pohl into a new, less beneficial, contract;
- Failure to pay Mr. Pohl’s outstanding wages in a lump sum post termination, despite repeated demands that they do so; and
- Failure to issue a timely and correct Record of Employment, thereby increasing Mr. Pohl’s “sense of exploitation, humiliation, and depression”.
The Court found that the employer’s conduct was effectively an attempt to take advantage of a loyal, long-term employee during a vulnerable moment, which was a breach of the employer’s duty of good faith and fair dealing which warranted an award of moral damages.
Rutledge v Markhaven Inc., 2022 ONSC 3183
Ms. Rutledge, a 43-year-old Executive Director at a long term health facility with 21 years of service, was awarded wrongful dismissal damages of 22 months’ pay in lieu of reasonable notice, as well as $50,000 for bad faith and moral damages resulting from the egregious manner in which Markhaven conducted an investigation into an alleged workplace relationship between Ms. Rutledge and another employee, and litigation conduct of Markhaven’s defence counsel.
Specifically, in awarding bad faith and moral damages, the Court found that:
- Ms. Rutledge was informed that the investigation would be conducted by an independent third party, but it was actually conducted by a business associated with Markhaven’s defence counsel;
- The investigation was undertaken surreptitiously before Ms. Rutledge was informed that the investigation would be taking place, and the investigator secured information from her without her prior knowledge;
- Part of the interviews connected with the investigation took place at a local Tim Hortons where some of the 150 employees of Markhaven frequented, thereby failing to conduct the investigation in a confidential manner; and
- During ensuing litigation, Ms. Rutledge walked into an examination for discovery where she was confronted with photographs of her home, and comments by Markhaven’s lawyer regarding a pending motion for “security for costs”, which was never brought.
The calculation of common law reasonable notice of termination is often referred to as an “art form” and not a “science”. This is particularly true when there are a myriad of factors that must be taken into consideration in making a determination as to the appropriate period of reasonable notice, and weight being given disproportionately to certain factors in accordance with the circumstances in each case, as illustrated in the following cases.
Chin v Beauty Express Canada Inc., 2022 ONSC 6178
Ms. Chin worked at a beauty counter at The Bay for 14 years while it was owned by Premier Salons Ltd. (“Premier”). Premier went bankrupt and Beauty Express Canada Inc. (“Beauty Express”) took over operations. Ms. Chin continued working for Beauty Express under the same management and at the same location for another six years until her eventual termination at the end of 2019, at the age of 69.
Ms. Chin had signed an employment agreement while with Beauty Express, but the agreement was found to be invalid for want of consideration. As such, Ms. Chin was entitled to common law reasonable notice of termination.
It was agreed by all parties that the bankruptcy constituted a constructive dismissal and that Ms. Chin was technically only employed by Beauty Express for six years. Nonetheless, Ms. Chin was awarded 10 months of pay in lieu of notice on the basis that while the experience with the prior employer was important because it allowed her to bring it to Beauty Express, it was not experience which required extensive and specific training. In other words, if Ms. Chin had brought technical skills and experience into the subsequent role beyond what she was able to demonstrate at trial, she would have been awarded a greater reasonable notice period which would have taken into account her entire 14 years of service.
Currie v. Nylene Canada Inc., 2022 ONCA 209
Ms. Currie was terminated from Nylene after 40 years of service, and at 58 years old, and subsequently sued for wrongful dismissal. The Court of Appeal upheld an earlier decision which awarded an unusually high reasonable notice period of 26 months (whereas 24 months tends to be the commonly accepted ceiling on such awards). The Court noted the following factors as significant to its decision:
- Ms. Currie’s advanced age;
- Ms. Currie worked at Nylene for almost her entire working career, starting from high school;
- Ms. Currie started at Nylene at age 18 as a “twisting operator”, and ultimately rose to become the “Chief Operator”;
- Ms. Currie had a very specialized skill set in the manufacturing environment, making it very difficult for her to find alternative suitable employment with skills which were not easily transferrable; and
- Ms. Currie had very limited computer skills which she tried to upgrade in an effort to mitigate her damages, but the trial judge was not convinced that she would succeed.
Ultimately, Ms. Currie’s termination of employment from Nylene was regarded as the equivalent of “a forced retirement”, thereby warranting a higher-than-normal award of reasonable notice with which the Court of Appeal agreed.
UNENFORCEABLE TERMINATION PROVISIONS
By now, the general principles in Waksdale v. Seagon North America Inc., 2020 ONCA 391 are well known. Specifically, if any portion of a termination provision in an employment contract denies (or is ambiguous regarding) the employee benefits that they would be entitled to under the Ontario Employment Standards Act, 2000 (the “ESA”), then the entire termination provision is rendered void and the employee’s rights on termination default to those afforded by the common law.
In 2022, two cases expanded the Waksdale principles to non-termination provisions which also had the potential effect of unlawfully contracting out of the ESA, rendering the termination portions of the contract invalid.
In the Rahman decision below, the Waksdale principles were also tested against the argument that when employees are sophisticated, or receive legal advice prior to signing an employment agreement, then termination provisions that may technically contract out of the ESA should not be struck down, given the employee’s knowledge and understanding of the provisions.
Gracias v. Dr. David Walt Dentistry, 2022 ONSC 2967
For six months, Ms. Gracias worked as a dental hygienist for Dr. Walt under a written employment agreement. Upon termination, Dr. Walt provided Ms. Gracias with one week of pay in lieu of notice pursuant to the ESA. Ms. Gracias sued Dr. Walt for wrongful termination, seeking seven months’ pay in lieu of notice. Dr. Walt disagreed based on Ms. Gracias’ short tenure and the fact that she received approximately $16,000 worth of Canada Emergency Response Benefit (“CERB”) funding following her termination. Dr. Walt also argued that Ms. Gracias falsified mitigation documentation during litigation.
The Court held that Ms. Gracias’ employment agreement contained provisions which, when read in context and together with the termination provisions, contravened or attempted to contract out of the ESA. The specific sections which were at issue were the “conflict of interest” and “confidential information” clauses, both of which contained language effectively stating that any breach of those provisions would result in termination “with cause” and no corresponding payments. In his decision, Justice Perell found that these provisions were not compliant with the ESA as they attempted to deny the employee her ESA entitlements for reasons that may not, at law, amount to “wilful misconduct”, which is the higher standard required to be met under the ESA to justify termination without any amounts owing.
Ms. Gracias was ultimately awarded three months of reasonable notice, without deduction for CERB. Even though Dr. Walt led considerable evidence that Ms. Gracias falsified mitigation documentation, these claims of fraud were found not to have been substantiated.
Henderson v. Slavkin et al., 2022 ONSC 2964
Ms. Henderson worked as a dental receptionist for Drs. Slavkin and Kellner for 20 years pursuant to a written employment agreement. Her employment was terminated in March 2020. Following termination, Ms. Henderson did not start looking for other employment for 12 months, finally securing alternate employment approximately 18 months after her termination. Ms. Henderson received considerable CERB benefits following termination.
Ms. Henderson’s contract of employment included a “termination without cause” section, as well as “conflict of interest” and “confidential information” clauses, both of which stated that a breach of said clauses would result in Ms. Henderson’s termination for just cause. Justice Brown found that while the termination without cause section was valid, the “conflict of interest” and “confidential information” clauses were so “broad, unspecific and ambiguous” that Ms. Henderson would not be able to conclude that the conduct prohibited by the clauses indeed rose to the standard of “wilful misconduct” or “wilful neglect of duty” as required under the ESA. Therefore, the termination provision too became invalid, and Ms. Henderson was entitled to common law reasonable notice stemming from her termination.
Justice Brown awarded Ms. Henderson 15 months’ pay in lieu of reasonable notice, with three months deducted for Ms. Henderson’s failure to seek re-employment for 12 months after termination. Following the decision in Gracias, Justice Brown refused to deduct CERB payments from Ms. Henderson’s damages.
Rahman v. Cannon Design Architecture Inc., 2022 ONCA 451
Ms. Rahman was employed as a senior architect at Cannon for over four years. When terminated without cause, she was provided with four weeks of base salary. Ms. Rahman sued Cannon for wrongful dismissal on the basis that the termination provisions in her contact of employment were contrary to the ESA.
In a rare “win” for employers, the motion judge found that the termination provisions in Ms. Rahman’s contract were valid and enforceable because she was a sophisticated employee who had had access to independent legal advice at the time of signing the contract. Furthermore, the motion judge took into consideration the parties’ subjective intentions to be bound by the ESA, despite the plain wording of the provisions being contrary to the ESA.
Disagreeing with the motion judge, the Court of Appeal overturned the decision, finding that, “By allowing subjective considerations to distort and override the wording of those provisions, the motion judge committed an extricable error of law…”. As such, Ms. Rahman’s agreement was held to be unenforceable, and the matter was remitted back to the Superior Court for quantification of Ms. Rahman’s damages.
INFECTIOUS DISEASE EMERGENCY LEAVE
During the COVID-19 pandemic, temporary measures were introduced by O. Reg. 228/20: Infectious Disease Emergency Leave (“IDEL”) under the ESA which stated that a non-unionized employee whose employer has temporarily reduced or eliminated their hours of work for reasons related to COVID-19, were deemed to be on a job-protected infectious emergency leave and not laid off or “constructively dismissed” under the ESA.
Several subsequent cases wrestled with whether the IDEL regulation precluded an employee who was temporarily laid off in the absence of a contractual term allowing such lay off to allege constructive dismissal under the common law.
In 2021, several cases, such as Coutinho v. Ocular Health Centre Ltd., 2021 ONSC 3076, held that an employer could not take advantage of the IDEL provisions to temporarily lay off an employee if the employee has not agreed to a contractual term permitting the layoff, as the ESA and its regulations could not override the common law principle of constructive dismissal. However, in Taylor v. Hanley Hospitality Inc., 2021 ONSC 3135, Justice Ferguson refused to follow Coutinho, finding the COVID-19 circumstances unusual enough to permit the IDEL regulation in precluding a common law claim of constructive dismissal.
Ms. Taylor appealed, and, being the last outstanding decision on point, the employment bar waited with bated breath for the outcome. Ultimately, the Court of Appeal (2022 ONCA 376) held that Justice Ferguson had made an error of law. However, the error was not the finding itself, but Her Honour’s treatment of the decision which had been made under rule 21.01(1)(a) for a determination of a question of law. Consequently, the Court dismissed the motion and remitted the action for determination before another judge of the Superior Court.
As the IDEL provisions in questions ceased to be in effect in mid-2022, and given the remaining case law was aligned in its treatment of IDEL and its relationship to common law constructive dismissal, it is unlikely that the Taylor decision will be re-decided. This is also true given that during the pandemic, most employees were better off accepting available government support and waiting for their job to become available rather than alleging constructive dismissal, quitting, and searching for work in an extremely challenging market. As such, despite the importance of the legal issue raised in the decisions, the quantum of such decisions was far less than initially expected.
BANKRUPTCY AND NOTICE PERIODS
Under the ESA, employees are usually owed outstanding compensation and termination pay (as well as possible severance pay) in the event of termination by their employer. However, when an employer is in financial distress and is seeking protection under either the Bankruptcy Act or the Companies’ Creditors Arrangement Act (“CCAA”), the employee becomes an unsecured creditor, making it difficult to obtain their full ESA entitlements. Further, companies on the verge of bankruptcy are often purchased at a discount, and the control of the company is transitioned to a new owner along with the company’s assets, including its employees. This bankruptcy-related change of control often triggers considerations into whether the employee’s prior service flows through to the new owner. The case below from the Ontario Court of Appeal provides some clarity on how the Court will consider an employee’s length of service and their termination entitlements in the event a company undergoes bankruptcy under the CCAA.
Antchipalovskaia v. Guestlogix Inc., 2022 ONCA 454
Ms. Antchipalovskaia commenced her employment with Guestlogix in 2011 under the terms of a written employment agreement. In 2016, Guestlogix sought and obtained protection under the Companies’ Creditors Arrangement Act. Guestlogix was subsequently purchased by a third party, and, as a result, Ms. Antchipalovskaia was terminated and immediately rehired under the same conditions of employment. Ms. Antchipalovskaia submitted a “Proof of Claim” to the Superior Court in order to receive her termination and severance pay from the proceeds of the sale as an unsecured creditor, and was successful, receiving roughly 72% of her total claim amount. She continued to work for Guestlogix until she was terminated without cause in 2019. Ms. Antchipalovskaia sued Guestlogix for wrongful dismissal and sought damages for reasonable notice at common law based on her entire service with Guestlogix from 2011 to 2019.
Ms. Antchipalovskaia brought a motion for summary judgement, and the motion judge agreed that her full service with Guestlogix ought to be considered continuous despite the sale. Accordingly, she was awarded 12 months’ pay in lieu of notice, less the amounts paid in 2016.
Guestlogix appealed the decision of the motion judge. The Court of Appeal clearly distinguished between the ESA and common law approaches to continuous service following the sale of business. The Court held that at common law, following the sale of a business, a contract for personal service cannot be assigned to a new employer without the consent of the parties. As such, employees under the common law are deemed to have been constructively dismissed as soon as the business is sold, thus creating a break in the employee’s service with the employer.
However, the Court determined that while service may not be seen as continuous under the common law, years of service with the same employer could still be a relevant Bardal factor in determining common law reasonable notice for the employee since the employer benefited from the service of an employee who could perform their job at a high level for a number of years. Ultimately, based on the employee’s years of service, age and position, the Court found a seven month notice period to be appropriate.
CANADA LABOUR CODE AND UNJUST DISMISSAL DAMAGES
For a federally regulated employee to be terminated with just cause under the Canada Labour Code, the employer must demonstrate a good faith attempt to progressively discipline the employee, similar to the level of protection typically bargained for by unionized employees. Where an arbitrator finds the employee to have been unjustly dismissed, they may consider whether reinstatement of an employee is an appropriate option, scrutinizing whether the employee has learned from their mistakes and will be able to return to the workplace successfully. Where reinstatement is not appropriate, entitlement to compensation is the only remaining remedy. In the case below, the Federal Court of Appeal weighed in on the proper approach to calculating an employee’s entitlements to compensation where reinstatement is not deemed appropriate.
Hussey v. Bell Mobility Inc., 2022 FCA 95
Ms. Hussey was terminated from her employment and subsequently made an unjust dismissal complaint against her former employer under the Canada Labour Code. The matter was heard before an arbitrator, who agreed that Ms. Hussey had been unjustly dismissed, but refused to reinstate her as he did not believe that she was remorseful or would change the behaviour that led to her dismissal if reinstated. Instead, the arbitrator awarded eight months’ pay in lieu of reinstatement based on calculations derived from the principles of common law reasonable notice, with an additional amount in recognition of Ms. Hussey’s loss of just cause protection under the Canada Labour Code.
Ms. Hussey sought judicial review of the decision, alleging a breach of procedural fairness and arguing that the compensation decision was incorrect in its importing the principle of common law reasonable notice. She argued that instead, the “fixed term” approach should have been adopted, which considers expected earnings until the employee’s retirement and then discounts the amount based on contingencies. The application for judicial review was denied, and Ms. Hussey appealed to the Federal Court of Appeal.
On appeal, the Court agreed with the findings of the arbitrator that utilizing common law reasonable notice as a foundation for calculating pay in lieu of reinstatement was a reasonable approach, and that there has been no consensus among arbitrators or adjudicators to the contrary or to deem the “fixed term” approach as the standard. As a result, the Court upheld the award of eight months’ notice. The Court also disagreed that Ms. Hussey had been denied procedural fairness.
JUST CAUSE TERMINATIONS
The concept of “just cause” in employment agreements has faced significant scrutiny following the Waksdale decision, cited above. The Ontario Court of Appeal has recently weighed in on the different thresholds for just cause terminations under the ESA and the common law, and how they relate to an employee’s entitlements upon termination for such reasons. Of note is also a recent arbitration decision relating to just cause termination in the face of a breach of COVID-19 policies.
Render v. ThyssenKrupp Elevator (Canada) Limited, 2022 ONCA 310
Mr. Render was terminated for cause after he slapped the buttocks of a female co-worker in front of a number of colleagues and later made jokes about the situation. Mr. Render sued for wrongful dismissal, but was unsuccessful at trial where it was found that he was not truly apologetic for his actions, nor appreciated the seriousness of his misconduct. Further, the trial judge held that while ThyssenKrupp had a workplace culture that seemingly condoned horseplay and inappropriate comments, Mr. Render’s misconduct was of such an egregious nature that termination for cause was justified.
Mr. Render appealed the trial judge’s decision, arguing that the workplace culture of ThyssenKrupp should have been considered a mitigating factor that reduced the penalty for his misconduct to something less than termination. The Court of Appeal dismissed Mr. Render’s argument that an inappropriate workplace culture was a justifiable mitigating circumstance, and took a hard stance against condoning such toxic “locker-room” type workplace cultures.
However, the Court did agree that Mr. Render’s actions were not pre-meditated, but rather in the heat of the moment, and therefore held that Mr. Render’s conduct did not rise to the ESA standard of “wilful misconduct.” As such, the Court held that Mr. Render was entitled to receive his statutory termination entitlements. In contrast, the Court confirmed that Mr. Render’s conduct did meet the threshold for just cause under the common law, and denied his entitlements to common law reasonable notice accordingly.
Given the recent amendments to the ESA regarding the prohibition of non-competition clauses under the Working for Workers Act, 2021 (subject to only a few concrete exceptions), employers and employees alike have been curious to see how this development will be interpreted and applied by the courts. The cases below address some of the common questions raised by the passing of the legislation, including as to whether the amendment has retroactive applicability.
M & P Drug Mart Inc. v. Norton, 2022 ONCA 398
Mr. Norton commenced his employment as a pharmacist with M & P Drug Mart Inc. (M&P) in 2014 under the terms of a written employment agreement that was negotiated with the assistance of independent legal counsel. The employment agreement contained a non-competition clause which precluded Mr. Norton from being “engaged in, concerned with, or interested in, directly or indirectly” any business that was the same as M&P within a fifteen (15) kilometer radius for one year following the termination of his employment.
In 2020, Mr. Norton resigned from M&P and immediately began working as a pharmacist for a pharmacy located only three kilometers from M&P. M&P brought an application attempting to enforce the non-competition clause in Mr. Norton’s employment agreement, but the application judge found the clause to be overbroad and ambiguous, which rendered it unenforceable under the applicable common law principles regarding enforceability of non-competition clauses.
M&P appealed the decision, arguing that the language of the non-compete was clear, and that Mr. Norton had the benefit of legal counsel when he signed his employment agreement and should therefore be bound by its terms. The Court of Appeal agreed with the application judge that the non-competition clause was ambiguous, as it did not expressly prohibit Mr. Norton from working as a pharmacist in another pharmacy.
Importantly, the Court of Appeal also clarified that the recent amendments to the enforceability of non-competition clauses through the Working for Workers Act, 2021 were not applicable as the employment agreement in question was entered into before the enactment of the legislation.
Parekh et al v. Schecter et al, 2022 ONSC 302
The plaintiffs entered into an agreement for the purchase of a dental practice. The purchase agreement included an express condition that one of the existing dental associates, Dr. Schecter, would sign a non-competition and non-solicitation agreement. The non-compete prohibited Dr. Schecter from practicing dentistry within five kilometers of the plaintiffs’ dental practice for two years after he left or was terminated from the practice. Shortly after the purchase of the dental practice was finalized, Dr. Schecter resigned and began practicing dentistry at another dental office within five kilometers from the plaintiffs’ practice.
The plaintiffs attempted to enforce the terms of the non-compete through an interlocutory injunction. Dr. Schecter argued that he was not bound by the terms of the non-compete given the amendments made under the Working for Workers Act, 2021. The Superior Court agreed with the plaintiffs, and held that it was the intention of parliament for the amendments to the enforceability of non-competition clauses to apply to all agreements entered into after October 25, 2021. According to the Court, the amendment has no retroactive power to affect agreements that were entered into before the implementation date. Applying the three-prong test for injunctions, the Court held that Dr. Schecter was bound by the non-competition clause, and therefore prohibited from practicing dentistry within a five kilometer radius of the plaintiffs’ practice until October 27, 2023.
REASONABLE EXPECTATION OF PRIVACY
In recent years, Ontario courts have recognized new torts of “intrusion upon seclusion” and “public disclosure of private facts”. While these developments signalled a move towards a greater preservation of privacy rights in Ontario, it was yet to be seen how these rights may apply to employees in the workplace. In the case below, the Court of Appeal has provided a helpful analysis of an employee’s reasonable expectations of privacy in the public sector. It is yet to be seen whether the principles of this case will have an impact on private sector employers, but, given the recent trends in privacy law in favour of protecting employee privacy rights, they are likely to be persuasive.
Elementary Teachers Federation of Ontario v. York Region District School Board, 2022 ONCA 476
Two elementary school teachers were concerned that another teacher was receiving preferential treatment from their principal, and contacted their union for support. The union suggested that the teachers keep a log of each instance of preferential treatment they witnessed in the event of a future grievance. The teachers created and shared a log between one another, and stored it on their personal Google Drive accounts. The log was then accessed throughout the day on their school board (“Board”) provided laptops. The principal of the school learned of the existence of the log, and sought to find it. When one of the teachers was away from her laptop, the principal accessed the computer and discovered the log. He proceeded to take pictures of every entry, and shared it with the Board. The contents of the log were then used to discipline both participating teachers, which resulted in reprimands on file for three years that the teachers had failed to conduct themselves in accordance with the Ontario College of Teachers’ Standards of Practice. The teachers grieved the discipline, and alleged a breach of their privacy rights.
The Arbitrator and the Divisional Court both decided that the Board’s right to manage the workplace outweighed the teachers' individual privacy rights, and upheld the discipline.
The Court of Appeal confirmed that the Canadian Charter of Rights and Freedoms (the “Charter”) applied to public institutions such as school boards, and therefore was tasked with deciding whether the Board’s actions amounted to an unreasonable search and seizure in breach of section 8 of the Charter.
The Court began by determining whether and to what degree the teachers may have had a reasonable expectation of privacy in the workplace. It is important to note that from the outset of the Court’s analysis, it held that the fact the teachers were using a Board-issued laptop did not impact the Court’s decision on whether there was an expectation of privacy. Instead, the Court focused on the “totality of the circumstances” which included considering the personal nature of the material seized, the teachers’ personal interest in keeping the information private, whether the teachers had a subjective expectation of privacy, and whether it was objectively reasonable to expect that the log would be kept private.
The Court ultimately held that the teachers had a sincerely held belief that the information stored in the log was deserving of protection, and took steps they deemed appropriate to protect the information such as storing information on a “cloud” which is password protected. The Court also recognized that the teachers were directed to collect the information at the direction of their union representative, and that the use of the information by the Principal clearly lead to their discipline. The appeal was therefore allowed, the order of the Arbitrator was quashed, and the Divisional Court’s decision overturned. Given the timing of the appeal, the reprimands had already been removed from the teachers’ files, but, the outcome confirming a breach of section 8 of the Charter was highly significant.
About the authors
Daria (Dasha) Peregoudova is a partner at Aird & Berlis LLP, and a member of the firm’s Workplace Law and Litigation & Dispute Resolution and Groups. She works with a variety of companies and organizations on various employment-related, ethical and governance matters, including within unionized environments. Dasha has appeared as counsel before various tribunals and all levels of court, including the Supreme Court of Canada.
Ljubica Durlovska practices employment law at HRC Law Professional Corporation. She is a passionate employment lawyer with 10 years of experience in the field and a track record of successfully assisting corporate clients in a wide range of employment matters. In addition to her legal practice, Ljubica is also a speaker and writer on employment law topics.
Zachary Sippel is a member of the Workplace Law Group at Aird & Berlis LLP. His practice includes a wide range of employment and labour-related matters, including advising on occupational health and safety requirements and labour arbitrations.
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