LABOUR AND EMPLOYMENT LAW NEWS - Blg.com

LABOUR AND EMPLOYMENT LAW NEWS

SUMMER 2011

LABOUR AND EMPLOYMENT LAW NEWS EDITORS’ MESSAGE This edition of the Labour and Employment Law News addresses recent decisions of the Ontario and British Columbia Human Rights Tribunals on workplace policies, and sexual harassment, the immigration requirements when hiring a U.S. contractor to perform work in Canada and a legislative update on the Accessibility Standards required by the Accessibility for Ontarians With Disabilities Act. In addition, this issue addresses the timely issue of managing social media in the workplace. Finally, our Hot Off the Press column keeps you informed of breaking legal developments. We trust that you will find that this newsletter provides you with critical information relevant to managing your employees in today’s environment. If you have any issues you would like addressed in s subsequent edition, please contact us directly.

EDITORS Jennifer M. Fantini Naomi E. Calla 416.367.6726 416.367.6129 [email protected] [email protected]

IN THIS ISSUE Hot Off The Press FEATURES 3 Sexual Harassment Laws: Still Striving to Find the Balance – Shelley-Mae Mitchell 4 Can I Just Hire a U.S. Contractor to do Work in Canada? – Brian D. Portas 7 Facebook, My Space, Twitter and Blogs: How to Manage Social Media at Work – Lisa C. Cabel 8 Legislation Update: Accessibility Standards Impose Obligations on Employers in Ontario – Robert W. Weir 10 Can a Workplace Microwave Policy be Discriminatory? – Lisa C. Cabel

LABOUR AND EMPLOYMENT LAW NEWS | SUMMER 2011

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HOT OFF THE PRESS

AN END TO FEDERAL MANDATORY RETIREMENT? The Federal Budget was tabled on Monday, June 6, 2011. Similar to its proposal in the last Federal Budget, the Government has proposed amendments to the Canadian Human Rights Act and the Canada Labour Code to prohibit federally regulated employers from setting a mandatory retirement age unless there is a bona fide occupational requirement. The Government also proposes to review other acts to further this objective. The budget does not indicate what the specific amendments would be. It also does not address whether the current exemptions with respect to pension and benefits plans will remain in force. The actual Budget Bill had not been introduced and the House of Commons is in recess until September 19, 2011. We will keep you apprised of the details of the bill, once introduced.

ALBERTA MINIMUM WAGE INCREASE On September 1, 2011, the minimum wage in Alberta will be increased from $8.80 per hour to $9.40 per hour for most employees. The 60 cent jump is the first increase since April 2009. The minimum hourly wage for employees serving liquor as part of their regular job will be at a lower rate of $9.05 per hour. Other changes that will become effective on September 1, 2011, include the following:

•

The weekly minimum wage for many salespersons, licensed land agents and certain professionals will increase from $352.00 to $376.00 per week

•

The monthly minimum wage for domestic employees who live primarily in the employer’s home will increase from $1,677.00 per month to $1,791.00 per month

As always, certain categories of employees are exempt from the minimum wage requirement in the Alberta Employment Standards Regulation.

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SEXUAL HARASSMENT LAWS: STILL STRIVING TO FIND THE BALANCE1 Determining the validity of a complaint of workplace sexual harassment requires careful consideration of the facts and a balancing of social policy considerations. Sexual harassment as a form of discrimination based on sex is degrading, demeaning, and may have significant and negative effects upon the victim, particularly when there is a power imbalance between the complainant (employee) and the respondent (employer/supervisor).

Nonetheless, Human Rights Tribunals across Canada have struggled with balancing the need to enforce sexual harassment laws with the desire to avoid having them develop in a manner that unreasonably inhibits normal social conduct. In order to strike a balance between these competing priorities, Tribunals are sometimes willing to consider whether the behaviour complained of is normal social behaviour or whether the complainant contributed to the creation of an environment where such behaviour would be considered acceptable. Given the significant adverse effects of sexual harassment and the desire to avoid blaming victims, these factors are rarely dominant considerations, and when they do influence a decision, tend to mitigate damages rather than extinguish a complaint altogether. The British Columbia Human Rights Tribunal most recently engaged in this delicate balancing act in Kang v. Hill and another.2 Ms. Kang was hired on June 29, 2009 as Mr. Hill’s administrative assistant. Shortly into her employment, Mr. Hill confessed his feelings for her and gave her a list described by Ms. Kang as

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“incredibly intimate” and entitled “Reasons Why I Think You Love Me Too.” By the beginning of August, Ms. Kang had left her employment and filed a sexual harassment complaint with the BC Human Rights Tribunal. Despite the respondent’s actions, the Tribunal found that Ms. Kang was unable to establish a prima facie case of discrimination. In doing so, the Tribunal focused largely on Ms. Kang’s conduct, in particular the fact that from the outset of her employment she routinely asked Mr. Hill increasingly personal questions about his marriage, sex life and his attraction to her. Her willingness to initiate and engage in such intimate conversations created a workplace environment where the respondent’s actions, although not considered ‘normal social interactions,’ were deemed acceptable.3 In light of Ms. Kang’s conduct, the Tribunal found that she had no real fear of adverse consequences to her employment. It was also held that the imbalance of power between probationary employees and supervisor/ employers was not a factor relevant to the

The author wishes to acknowledge the assistance of Brandon Hills, Articled Student, in drafting this article. (No. 2), 2011 BCHRT 154. 3 Para. 49-54. 2


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determination of this case.4 Indeed, the Tribunal held that Mr. Hill’s confession of his attraction was not an assertion of power, but was an “acknowledgment of his weakness, which to some degree placed him under her power.”5 It will be interesting to see how the downplaying of the power imbalance will be treated by subsequent Tribunals as it is often one of the chief considerations in workplace sexual harassment cases. Kang v Hill is significant in that it suggests that a sexually charged working environment created – or contributed to – by the complainant may, in

some cases, provide a defence against allegations of sexual harassment, even where the respondent is the employee’s supervisor and the owner of the business. Nonetheless, the applicability of this case may be limited by its unique factual makeup. Had Mr. Hill’s conduct not been preceded by Ms. Kang’s behaviour, it is likely that his conduct would have constituted sexual harassment.6

Shelley-Mae Mitchell Vancouver 604.640.4160 [email protected]

4

P ara. 54. Para. 53. 6 Para. 56. 5

CAN I JUST HIRE A U.S. CONTRACTOR TO DO WORK IN CANADA? Before retaining a company or hiring a contractor from the United States to perform work in Canada, businesses must consider the implications from an immigration law perspective. It may come as a surprise that the worker can be prevented from entering Canada if he or she does not first have the appropriate paperwork in place. This article will review some of the basic immigration implications that should be considered before having an employee based in the United States perform work in Canada.

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WORK PERMIT Generally speaking, an individual that is not a Canadian citizen or permanent resident of Canada must obtain a work permit before working in Canada. For the purposes of Canadian immigration law, “work” is defined in section 2 of the Immigration and Refugee Protection Regulations (IRPR) as an activity for which wages are paid or commission is earned, or that is in direct competition with the activities of Canadian citizens or permanent residents in the Canadian labour market. Work includes a technician coming to Canada from the United States to conduct repairs, or perform a contract, even if he or she will not be paid directly by the Canadian company for whom he or she is doing the work.

worker qualifies under an exemption category. One of the more common exemption categories used is the NAFTA (North American Free Trade Agreement) Professional category. This category applies to specific occupations such as accountants, architects and engineers that are doing work in their profession for a company in Canada. They must be citizens of the United States or Mexico, be qualified to work in their profession, have pre-arranged employment or a contract with a Canadian employer, and provide professional level services in the field of qualification. In other words, a foreign worker with an engineering degree and a professional designation may not qualify as a NAFTA Professional engineer if he or she will be providing services in Canada that are completely unrelated to engineering.

Before the foreign worker can apply for a work permit, the Canadian company must first obtain a positive Labour Market Opinion (LMO) from Service Canada unless the employee can meet a specific exemption category from the LMO process. The processing times for an LMO application vary in each province and fluctuate from time to time depending on the number of applications received and the resources allocated to that particular office. If an LMO is required, it could significantly delay the worker’s entry into Canada. For example, it could take 8-10 weeks to process an LMO application in Alberta. In addition, the Canadian company would have to demonstrate it made efforts to recruit a Canadian citizen or permanent resident before submitting the LMO application by complying with Service Canada’s minimum advertising requirements. This usually includes advertising the position for a minimum of 14 calendar days. Provided that a positive LMO is issued by Service Canada, the foreign worker then needs to be provided a copy of it in order to apply to Citizenship and Immigration Canada for a work permit.

Some workers may qualify for entry to Canada as a business visitor without the need for a work permit. A business visitor is a foreign national who seeks to engage in international business activities in Canada without directly entering the Canadian labour market, the primary source of remuneration is outside Canada and the principal place of business remains outside Canada. Included in this category are persons providing after-sales service. After-sales services include those provided by persons repairing and servicing, supervising installers, and setting up and testing commercial or industrial equipment (including computer software). “Setting up” does not include hands-on installation generally performed by construction or building trades (electricians, pipe fitters, etc.). This category also applies to persons seeking entry to repair or service specialized equipment, purchased or leased outside Canada, provided the service is being performed as part of the original or extended sales agreement, lease agreement, warranty, or service contract. Where the work is not covered under such an agreement, a work permit and an LMO may be required.

LMO EXEMPTIONS AND BUSINESS VISITORS

Even if the foreign worker has been provided a copy of the positive LMO for his position or it can be demonstrated that an LMO is not required, the foreign worker may still not qualify for a work

A foreign worker may be able to apply directly for a work permit without the need for an LMO if the


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permit or be prevented from entering Canada. The foreign worker must demonstrate to the Canada Border Services Agency (CBSA) or immigration officer at the port of entry (i.e. airport or border crossing) that they have the qualifications required for the position and must not pose a criminal, security or health risk to Canadians. For example, a citizen of the United States with an impaired driving conviction could be considered “criminally inadmissible” and be denied entry.

TEMPORARY RESIDENT VISAS AND MEDICAL EXAMS Applicants from visa-exempt countries who have a positive LMO, or who qualify under an LMO exemption category, may be able to apply directly at the port of entry (i.e. airport or border crossing). Port of entry applications can significantly speed up the application process if the Canadian company needs the foreign worker in a hurry. However, not all applicants can apply for a work permit directly at the port of entry, such as those workers from a country that require a visa to transit to Canada. There is often confusion caused by the terminology used in Canadian immigration matters. Canadian work permits are often referred to, incorrectly, as visas. A visa in Canada is normally a reference to Temporary Resident Visas, or “TRVs”. Citizens of some countries are required to obtain a TRV in order to enter Canada, including Mexico as of July 14, 2009. This is in addition to any work permit requirements. The person must apply for the TRV at a visa office outside of Canada prior to appearing at a port of entry. Citizens of the United States do not require a TRV. However, the foreign worker located in the United States that is hired by the Canadian company, or the worker being sent by the contracting company in the United States, may not necessarily be a citizen of the United States. As a result, it is important for the parties to know if the person requires a TRV

before trying to enter Canada. If the foreign worker requires a TRV, this requirement could further delay the person’s entry into Canada. The length of this delay will vary depending on that particular visa office’s current processing times. For example, it could take approximately 4-6 weeks for the person’s TRV and work permit to be processed at a visa office. Some applicants may also be required to undergo a medical exam before entering Canada. If a medical exam is required by the local visa office, the processing times would be even longer.

CONCLUSIONS A worker coming from the United States may encounter a number of issues that could result in a denial of his or her entry into Canada. The person’s entry may require a TRV application, a medical exam, recruitment activities for a minimum period of time and an LMO application before a work permit application is even submitted. Canadian companies should also not assume that the requirements of hiring for one position will be exactly the same for another person in a similar position. For example, a United States citizen who qualifies as a NAFTA Professional engineer may be able to apply directly at the port of entry for a work permit and be able to enter Canada relatively quickly to perform the work. On the other hand, it could take months to obtain a work permit for a citizen of another country that requires a TRV and does not qualify under an LMO exemption category to perform the same engineering services. Care must be taken to resolve these issues before the worker’s services are required, so as not to be caught off guard by the delay in processing immigration documentation that can occur.

Brian D. Portas Calgary 403.232.9705 [email protected]

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FACEBOOK, MYSPACE, TWITTER AND BLOGS: HOW TO MANAGE SOCIAL MEDIA AT WORK A recent article in the Globe and Mail described how Canadians spend on average approximately 43.5 hours a month on the Web, which is, according to data released by a Web research firm comScore, almost twice the worldwide average of 23.1 hours.1 With numbers this high, employers have to wonder: how much of that time surfing the Web is done during working hours and involves posting comments relating to the workplace?

In addition to lost time and productivity that employees may be spending mindlessly checking their Facebook page (or ‘creeping’ their friends’ pictures) during working hours, the dramatic increase in social computing has mounted a number of challenges for employers. As more and more employees choose to create or participate in blogs, wikis, online social networks and other forms of online publishing or discussion boards, employers are confronted with unique disciplinary challenges for online conduct both in and outside the workplace. In general, what employees do on their own time is their affair and employers must respect the legal rights of their employees to create or participate in a blog, wiki or online social network. However, activities in and outside of work that affect job performance, the performance of others and/or the rights and privacy of others are the proper focus of employment policies and can be potential grounds for discipline, up to and including termination of employment.

1

There are a few, recent Canadian cases that provide some guidance. For example, Nathalie Blanchard, an employee who was on a leave of absence from her position at IBM for major depression was terminated and had her benefits cut off after the employer’s insurer viewed pictures of her on Facebook enjoying a birthday party, a sun holiday and a Chippendales bar show. In addition, the British Columbia Labour Relations Board recently upheld the summary dismissal of two employees for “offensive and egregious” comments posted on Facebook about their supervisors.2 From a legal perspective, the important question to consider when deciding if online conduct warrants discipline is whether what an employee writes or posts on the internet is sufficiently connected to work that the employer’s legitimate business interests may be at risk.3 It is not necessary for an employer to show that its activities or reputation are actually detrimentally affected, only that there is an objectively reasonable risk that such

Globe & Mail, Omar El Akkad, Canadians’ Internet usage nearly double the worldwide average, March 8, 2011.

2

Lougheed Imports Ltd. (West Coast Mazda) v United Food and Commercial Workers International Union, Local 1518, 2010 CanLII 62482 (BC LRB). 3

See e.g. EV Logistics and Retail Wholesale Union, Loc. 580 (Discharge Grievance), [2008] B.C.C.A.A.A. No. 22 (Laing) [EV Logistics] (off-duty conduct properly the subject of workplace discipline “if it adversely impacts on the legitimate business interests of the employer” at 58).


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damage could occur as a result of the employee’s statements or postings. The absence of actual damage is not indicative of the seriousness of the misconduct.4 Employers are therefore not required to show actual damages but they must still remember that discipline is not simply warranted based on mere dislike of, or disagreement with the content of an employee’s communication. Beyond dislike or disagreement, there must be an identifiable risk to the employer; for example, a risk to working relationships, reputation, or safety. Once again, a desire to avoid discomfort and unpleasantness is not, on its own, sufficient.

technology use policy should reflect the tension between an individual’s right to freedom of expression with their duties and responsibilities as employees. Generally, a code of conduct will describe behaviour that the employer believes to be in contravention of the policy, for example: •

•

• Employers should also keep in mind that determining the appropriate degree of discipline warranted for an employee’s inappropriate online conduct, requires an assessment of the seriousness of the threat which the misconduct poses to the employer. This is determined by considering the nature of the allegations (e.g. whether they are defamatory), the danger of the message (i.e. potential damage), the employee’s state of mind (i.e. whether it was deliberate and premeditated or a ‘momentary and emotional aberration’); the employee’s employment record (e.g. whether the employee has a long and discipline-free record of service), the appropriateness or history of using corrective discipline, and other relevant circumstances.5 Similarly, employees should always consider whether, if discovered by a fellow employee or a manager, any element of their participation in an online social medium could potentially affect their employment relationship, or be interpreted as a potential risk to the work environment. Finally, in order to set clear boundaries, it is the responsibility of the employer to ensure that the rules governing the responsible use of technology and its code of conduct are clear and widely understood. The content of a responsible

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•

•

u sing the technology to create, distribute or access illegal, offensive, pornographic and/or inappropriate materials; conducting business activities which are unrelated to the employee’s duties and responsibilities at work; advertising or soliciting, including advertising of personal services; downloading, storing or sharing media files, including music or video files, on the employer’s computer system that are illegal, offensive, obscene, inappropriate or that are not intended for employment purposes; and/or sending defamatory, abusive, obscene, profane, threatening or racially offensive messages.

The objective is to achieve responsible involvement and participation with respect to networking and social-based applications. The challenge for employers involves balancing an employee’s right to freedom of expression and personal privacy with the need to ensure a respectful and positive work environment. Clear and specific appropriate use of technology policies which reflect lessons learned from past cases as well as professional codes of conduct will go a long way to ensuring employers have a positive experience with online social media.

Lisa C. Cabel Toronto 416.367.6217 [email protected]

Camosun College and C.U.P.E., Loc. 2018 (Metcalfe Grievance), [1999] B.C.C.A.A.A. No. 490 (Germaine) at 101 [Camosun College].

5

See e.g. Camosun College, ibid. at 102-121

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LEGISLATION UPDATE: ACCESSIBILITY STANDARDS IMPOSE OBLIGATIONS ON EMPLOYERS IN ONTARIO On July 1, 2011, the Integrated Accessibility Standards came into force through Ontario Regulation 191/11. The Accessibility Standards were developed by the Ministry of Citizenship and Immigration pursuant to the powers established by the Accessibility for Ontarians With Disabilities Act, 2005 (the AODA). The purpose of the AODA is to develop, implement and enforce accessibility standards for Ontarians with disabilities with respect to goods, services, facilities, accommodation, building, structures, premises and, importantly, employment. The Accessibility Standards have broad application, effectively applying to any organization that provides goods, services or facilities to the public or other third parties and that has at least one employee in Ontario. Such organizations are referred to in the regulation as an “obligated organization”. Although the application is broad, the Accessibility Standards leave organizations with plenty of time to achieve compliance. For example, every obligated organization shall develop, implement and maintain policies governing how the organization achieves or will achieve compliance with the Accessibility Standards. The dates for achieving compliance with this obligation are staggered depending on the nature and size of the organization in the following manner: •

F or the Government of Ontario and the Legislative Assembly, January 1, 2012; • For all designated public sector organizations with 50 or more employees, January 1, 2013; • For all designated public sector organizations with fewer than 50 employees, January 1, 2014; • For all other obligated organizations with 50 or more employees (Large Organizations), January 1, 2014; and • For all other obligated organizations with at least one but fewer than 50 employees (Small Organizations), January 1, 2015.

Designated public sector organizations include school boards, hospitals, colleges and universities. The Accessibility Standards further require all designated public sector organizations and Large Organizations to establish, implement, maintain and document a multi-year accessibility plan. The plan will outline the organization’s strategy to prevent and remove barriers to accessibility. The plan will be available to the public and must be updated every five years. Large designated public sector organizations must have a plan by January 1, 2013 while small designated public sector organizations and Large Organizations must comply by January 1, 2014. Small Organizations are exempt from the requirement to develop an accessibility plan. The Accessibility Standards require employers of an obligated organization to train their employees and volunteers on the requirements of the Accessibility Standards and on the Human Rights Code as it pertains to persons with disabilities. Training must take place as soon as practicable but, again, compliance with this obligation is staggered depending on the nature and size of the organization from January 1, 2014 for large public sector employers to January 1, 2016 for Small Organizations.


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The Accessibility Standards also create Employment Standards that apply to all obligated organizations. The Employment Standards will require these employers to: •

• • • •

•

•

•

otify its employees, all job applicants and the N public about the availability of accommodation for applicants with disabilities in its recruitment process; Provide for suitable accommodation at the request of a job applicant; Notify successful applicants of its policies for accommodating employees with disabilities; Inform its employees of its policies to support employees with disabilities; Where an employee with a disability requests it, consult with the employee to provide accessible formats and communication supports for information that is needed to perform the employee’s job and information that is generally available to employees in the workplace; Provide individualized workplace emergency response information to employees who have a disability; Except for Small Organizations, develop and have in place a written process for the development of documented individual accommodation plans, which plans shall include detailed information respecting the development and review of the accommodation plan; and Except for Small Organizations, employers must develop and have in place a return to work process for employees who have been absent from work due to a disability and require disability-related accommodation in order to return to work.

Compliance with the Employment Standards is in accordance with the following time lines:

•

F or the Government of Ontario and the Legislative Assembly, January 1, 2013; • For all designated public sector organizations with 50 or more employees, January 1, 2014; • For all designated public sector organizations with fewer than 50 employees, January 1, 2015; • For Large Organizations, January 1, 2016; and • For Small Organizations, January 1, 2017. Employers are also required to take into account the accessibility needs of employees with disabilities in any performance management, career development and advancement or re-deployment process in their workplaces. Some six years in the making, the Accessibility Standards set out comprehensive guidelines for breaking down barriers faced by disabled persons. In addition to employment, the standards address the accessibility of public transportation, the sale of goods, the provision of services and encompass a myriad of commercial and other activities. Employers will need to start thinking about developing policies and implementing the requirements now notwithstanding the fact that the government has provided lengthy time periods for compliance. In many cases, compliance will simply be a matter of reviewing and modifying existing policies and practices. In others, compliance will require the completion of new policies and training. In all cases, employers should use the Accessibility Standards themselves as the template and guide for preparing those policies and modifying practices.

Robert W. Weir Toronto 416.367.6248 [email protected]

CAN A WORKPLACE MICROWAVE POLICY BE DISCRIMINATORY? Seema Saadi was terminated by her employer, a government-funded provider of settlement services for immigrants, just 6 weeks after she had been hired. The employee filed a human rights complaint with the Human Rights Tribunal of

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Ontario (Tribunal), alleging discrimination on the basis of her race, colour, ancestry, place of origin, disability (subsequently abandoned), ethnic origin, creed and sex. Most of these claims were dismissed by the adjudicator, but he did find that the employer’s policies on workplace dress (which required ‘business attire’) and its ban on heating smelly food in the microwave in the lunch room were discriminatory. As a result, her termination was also deemed discriminatory.

On judicial review to the Divisional Court1, Molloy J found many deficiencies in the reasons of the Tribunal, all of them stemming from the lack of factual evidence to support the findings of discrimination. A new hearing at the Tribunal was ordered, before a different adjudicator. As a preliminary matter, the Divisional Court was prepared to admit fresh evidence – or rather evidence that the adjudicator had refused to consider at the hearing. The first of these pieces of evidence was a letter from a key witness for the employer, in which he explained why he could not attend the Tribunal hearing. Because the employer was self-represented, it was incumbent on the adjudicator to explain that it would be possible to seek an adjournment in order to permit the witness to testify, especially in light of the importance of the witness’s testimony about matters in issue. The adjudicator had drawn an adverse inference from the witness’s failure to testify. All of this was a breach of procedural fairness. The second piece of fresh evidence submitted by the employer was a photograph of someone wearing the kind of clothing which Saadi had worn to work which was simply a visual aid and there was no reason in principle to exclude it. As for the microwave policy, the Divisional Court just didn’t buy the contention that it discriminated against any person or group of persons on one of the enumerated grounds. Speaking of the policy’s enforcement by the employer, the court stated: ‘I do not see how the ethnicity and ancestral rights of a Bengali-Canadian Muslim [Saadi] are adversely affected by being prevented from reheating somebody else’s Tunisian food’. The adjudicator’s findings on this simply had

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Audmax Inc. v Ontario Human Rights Commission, 2011 ONSC 315.

no rational basis. The same result was reached in relation to the dress code. There was no evidence to support the allegation that the dress code was applied so as to discriminate against Saadi, and nothing in the dress code that prevented her from wearing clothing appropriate to her religious beliefs. Wearing an old sweatshirt and baggy trackpants might satisfy Saadi’s religious requirement to wear ‘modest’ dress, but could validly be objected to by the employer as unprofessional in the workplace. By refusing to hear the testimony of the key witness or to accept what he did hear about suspicious behaviour on Saadi’s part, the adjudicator unreasonably concluded that discrimination was the real cause for her termination. The employer was awarded its costs, payable by Saadi – something the Tribunal could not have ordered even if it originally made the correct decision. This is the first case since the amendments to the Human Rights Code in which the Divisional Court has struck down a decision of the Tribunal and ordered a new hearing, reconvened by a differently constituted panel. Accordingly, it demonstrates a willingness by the Divisional Court to question the Tribunal’s decision-making with respect to evidentiary standards, procedure and outcome. This is especially significant considering the high degree of deference usually afforded to the Tribunal.

Lisa C. Cabel Toronto 416.367.6217 [email protected]

LABOUR AND EMPLOYMENT LAW GROUP Calgary Sharon E. Borgland Duncan Marsden Brian D. Portas Laurie M. Robson

Toronto 403.232.9452 403.232.9722 403.232.9705 403.232.9482

Montréal Thomas M. Davis François Longpré Katherine Poirier Jean-René Ranger André Royer Patrick Trent Philippe C. Vachon

514.954.3133 514.954.2543 514.954.3175 514.954.2548 514.954.3124 514.954.3154 514.954.3134

Ottawa Jim Anstey Noëlle Caloren Nadia Effendi Jacquie El-Chammas Morton G. Mitchnick

613.369.4754 613.787.3536 613.787.3562 613.369.4785 613.787.3568

S. Margot Blight Lisa Cabel Naomi Calla Matthew L.O. Certosimo Jennifer M. Fantini Melany V. Franklin Michelle S. Henry Robert W. Kitchen Jeffrey P. Mitchell Morton G. Mitchnick Brian D. Mulroney Genny Na Eric M. Roher Susan E. Sorensen Sarah Stiner Melanie A. Warner Robert W. Weir

416.367.6114 416.367.6217 416.367.6129 416.367.6068 416.367.6726 416.367.6091 416.367.6626 416.367.6023 416.367.6226 416.367.6413 416.367.6009 416.367.6032 416.367.6004 416.367.6017 416.367.6571 416.367.6679 416.367.6248

Vancouver Peter Eastwood Alka Kundi Shelley-Mae Mitchell Gabriel M. Somjen Steve M. Winder

604.640.4046 604.632.3465 604.640.4160 604.640.4013 604.640.4118

IMMIGRATION GROUP Calgary Brian D. Portas

Toronto 403.232.9705

Victoria Cowling Brian Dingle

514.954.3105 514.954.3175

Vancouver

416.367.6136 416.367.6189

Montréal Darren McGuire Katherine Poirier

Jeffrey Thomas

604.640.4203

Ottawa Mandy Moore

613.787.3500

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