The fight against climate change calls for a major energy transition, but the undertaking is made even more complex by a growing demand for electricity driven by the proliferation of artificial intelligence and other new technologies. However, the urgency of the problem alone does not make a project to fix it bankable. As we mentioned in our previous article in this series,1 a project is financed on a risk-by-risk basis, based on demonstrable revenue streams and coherently allocated contractual risks. Similarly, environmental criteria must be identified, measured and allocated so that they can be incorporated into feasible projects. This article examines the issue in two parts. First, it outlines the conditions a green project must meet to be bankable. These are the same as for any infrastructure project, but in an environment that now requires a common language, verifiable indicators and guarding against greenwashing. Second, it provides concrete examples of how these stringent standards are put into practice. Making a green project bankable: the same principles, but with greater discipline The fundamentals of bankability do not change simply because a project carries a green label. The principles set out in our previous article—risk allocation, revenue certainty, commercial viability and regulatory stability—apply in exactly the same way. What is added is the need for a framework to assess environmental performance using common, precise and measurable language. This terminology is currently being defined in Canada. The Taxonomy and Transition Council, established by the Business Future Pathways consortium in collaboration with the Canadian Climate Institute, is developing a national sustainable finance taxonomy. In its draft methodology report, open for public consultation until August 13, 2026,2 three categories of activities are proposed: green, transition and abatement. Furthermore, the Council is expected to issue guidelines for six priority sectors by the end of 2027. In Quebec, the White Paper on Sustainable Real Estate, published in April 2026 by Décarbone+ with the support of Hydro-Québec, the CDPQ, the National Bank, Montoni, Lavery and the Pôle IDEOS at HEC Montréal, pursues the same objective in the real estate sector: to provide a collective benchmark based on concrete data and demonstrate that building decarbonization is not only possible, it is profitable.3 In a financing context, a proper taxonomy can facilitate due diligence, broaden the investor base by providing clarity and predictability, and, through the certainty it brings, reduce the rates at which funds are made available. However, a standardized taxonomy is not sufficient on its own, and any environmental claim must be verifiable. According to TD Securities, global sustainable debt issuances stood at just under USD 1.6 trillion in 2025, down 7% from 2024, while sustainability-linked loans fell from 530 to 418 billion.4This decline could be attributed to a tightening of standards, with lenders looking beyond advertised “greenness” to analyze the underlying substance of a project. Since 2017, Québec’s green bond program has yielded nine issuances totalling approximately $5.7 billion,5 and the $1.85 billion issuance for the REM is among the largest in Canada.6According to the Ministère des Finances, “green bonds do not represent an additional source of financing for Quebec. They are simply another means of financing borrowings that would otherwise have been financed through conventional bonds.”7 The innovative aspect of green bonds lies in the allocation, tracking and reporting frameworks built into them, which unlocks access to pools of investors bound by mandates restricting capital to green initiatives alone. If the project company promises a specific level of environmental performance to a public authority, such as a building’s energy consumption, carbon intensity or a proportion of recycled materials, it must be able to secure the same standard from the contractor, operator and suppliers. Definitions, measurement periods, audit rights and remedies must be consistent across all contracts; otherwise, the project company will face a payment reduction with no recourse against the party responsible for the shortfall, exactly as applies to an improperly allocated construction risk. The risk of greenwashing follows the same logic. An unsubstantiated environmental claim is no longer merely a reputational risk. Since June 2024, such a claim can be sanctioned under the Competition Act, with a fine of up to 3% of annual worldwide gross revenues. Furthermore, since June 20, 2025, the Act has also introduced a private right of action, making third parties entitled to bring proceedings before the Competition Tribunal under certain conditions.8In cases of project financing, an unsubstantiated claim represents an unallocated risk trapped within the structure that could jeopardize the project’s bankability. A well-defined scope and verifiable indicators are necessary to effectively analyze and mitigate this risk. From principles to practice Deep Sky: revenue certainty takes precedence over environmental benefits Although direct air capture is becoming increasingly essential to achieving carbon reduction targets, the bankability of these projects remains grounded in revenue certainty, rigorous contracting and the quality of the financial model. The Deep Sky Alpha facility in Innisfail, Alberta, combines several direct air capture technologies with permanent geological storage.9 Its financing was made possible in particular by carbon removal credit purchase agreements concluded with companies such as Lufthansa and ENGIE, with the latter having committed to purchasing up to 15,000 credits.10 These contracts serve the same purpose as power purchase agreements in wind farm projects, for example, by providing the project with the revenue certainty needed to attract financing. However, as with any offtake agreement, the parameters must be clearly defined: price, volume, delivery schedule, removal certification, permanence of storage, replacement of undelivered credits and buyer creditworthiness. Deep Sky also secured an $11-million credit facility from Finalta Capital backed by refundable clean economy tax credits,11 a structure in which the federal tax credit acts as financing leverage. These examples illustrate the principle that a technology is not bankable simply because it is green—it becomes so when its revenues are as predictable as those of a conventional project. Énergir: financing the transition in a shifting regulatory environment Strict standards do not dictate that only assets that are already “perfectly green” can be financed. The Canadian taxonomy recognizes the “transition” and “abatement” categories, reflecting the reality of an economy in which many sectors can only gradually reduce their carbon intensity rather than shifting it overnight. To finance transition and abatement projects, regulatory predictability is absolutely necessary. Énergir’s trajectory is a clear case in point, as are the uncertainties inherent to its environment. Its regulatory obligation to supply gas from renewable sources rose to 5% in 2025–2026 and was set to reach 10% in 2030–2031.12 To achieve this, Énergir launched a dual-energy program combining electricity and natural gas in April 202613 and set up a subsidiary dedicated to residential geothermal energy in December 2025.14However, in July 2026, the Québec government announced its intention to review the regulatory trajectory for gas from renewable sources, requested an opinion from the Régie de l’énergie (slated for fall 2026), and formed an expert committee whose recommendations are expected in early 2027.15 Clearly, if the regulatory targets underpinning a transition project are subject to midstream changes, the project’s financial model is weakened, its revenue assumptions open to challenge and its appeal to lenders diminished. Because the markets and revenue streams of entities such as Énergir are governed by planning approved by the Régie de l’énergie du Québec, projects led by regulated utilities generally benefit from an unusually high degree of predictability. They are largely insulated from occasional shifts in government policy. Furthermore, the same technical system can produce different results depending on the power grid, the climate or the baseline it replaces. The economic viability of different projects using the same system must therefore be assessed jurisdiction by jurisdiction. Measuring Beyond: measuring what is promised Verifying that environmental promises are kept requires a standard of measurement that goes far beyond simply including covenants into contract documentation. The Measuring Beyond Initiative, launched by HEC Montréal in partnership with the University of Oxford’s Saïd Business School, was designed with this objective in mind: to measure ESG performance with sufficient rigour to allow the findings to be built into financial models, not simply relegated to annual reports.16 The initiative is accompanied by the creation of a Chair in Sustainable Finance, a sign that measuring non-financial performance is now a professional discipline in its own right. HEC Montréal’s Sustainable Transition Office, co-led by Dominique Anglade, is also helping train decision-makers to understand and articulate transition challenges. Climate literacy is, in itself, a prerequisite for sound governance. Decision-makers must be able to understand the environmental assumptions they build into a project before they become contractual covenants. For their part, lenders must verify the consistency of the information throughout the project lifecycle, from the tender stage, through construction and operating contracts, to the financing documentation. Ultimately, sound governance is precisely what turns an environmental metric from an aspirational target into verifiable data that financiers can truly rely on. Conclusion To paraphrase Romain Rolland, rising to the challenge of the energy transition requires combining the pessimism of the intellect—which cuts through every illusion—with the optimism of the will. Optimism is needed to devise ambitious projects, while realism (in lieu of pessimism) provides the discipline required to make them bankable. Without such discipline, an environmental label can turn into greenwashing, undermining the very financing it was intended to support. With it, however, the verified sustainability of a project broadens access to capital markets and makes climate-related revenues genuinely bankable. The same logic applies to so-called “smart” infrastructure. Its data and performance indicators must likewise be reliable, verifiable and subject to contractual requirements. This will be the subject of the next article in this series. D. Tournier and J. Menard, 2026. “Our infrastructure contracts: from the ideal project to the bankable project.” Lavery, de Billy. https://www.lavery.ca/en/publications/our-publications/6468-our-infrastructure-contracts-from-the-ideal-project-to-the-bankable-project.html Business Future Pathways, 2026. Canadian Sustainable Finance Taxonomy: Methodology Report. https://www.businessfuturepathways.ca/public-comment-period-begins-on-canadas-sustainable-finance-taxonomy/ Décarbone+, 2026. “White Paper, Sustainable Real Estate.” https://decarboneplus.org/initiatives/atelier-1-immobilier-durable/ TD Securities, 2026. “Sustainable Finance 2025 in Review and 2026 Outlook.” https://www.tdsecurities.com/ca/en/sustainable-finance-2025-in-review-and-2026-outlook Ministère des Finances du Québec, 2025. Green Bond Newsletter. https://www.finances.gouv.qc.ca/documents/Autres/en/AUTEN_MFQ_OblVertes_Bulletin_Nov2025.pdf CDPQ Infra, 2026. “REM successfully raises $1.85 billion through its first green bond issuance.” https://cdpqinfra.com/en/news/pressreleases/rem-successfully-raises-185-billion-through-its-first-green-bond-issuance Ministère des Finances du Québec, n.d. “Additional information.” https://www.finances.gouv.qc.ca/department/financing/green_bonds/additional_information.asp Competition Bureau Canada, 2025. “Environmental claims and the Competition Act.”https://competition-bureau.canada.ca/en/how-we-foster-competition/education-and-outreach/environmental-claims-and-greenwashing Deep Sky, 2025. “Deep Sky Alpha Begins Operations with North America’s First CO2 Storage via Direct Air Capture.” https://www.deepskyclimate.com/blog/history-made-deep-sky-alpha-begins-operations-with-north-americas-first-co2-storage-via-direct-air-capture-2 Deep Sky, 2026. “Deep Sky and Lufthansa Group Enter Carbon Removal Credit Agreement.” https://www.deepskyclimate.com/blog/deep-sky-and-lufthansa-group-enter-carbon-removal-credit-agreement; Deep Sky, 2026. “Deep Sky Announces Partnership to Advance Direct Air Capture with ENGIE.” https://www.deepskyclimate.com/blog/deep-sky-announces-partnership-to-advance-direct-air-capture-with-engie Deep Sky, 2025. “Deep Sky Secures First-of-its-Kind Financing with Finalta Capital to Advance Carbon Removal in Canada.” https://www.deepskyclimate.com/blog/deep-sky-secures-first-of-its-kind-financing-with-finalta-capital-to-advance-carbon-removal-in-canada Énergir, 2026. “Renewable Natural Gas, Your Energy Transition Ally.” https://energir.com/en/residential/renewable-natural-gas Énergir, 2026. Dual-Energy Electricity and Natural Gas Program. https://energir.com/files/energir_common/import/Fichiers/Subvention_bienergie/Guide-Participation_bienergie_EN.pdf Énergir, 2025. “Énergir Geothermal Solution: A New Subsidiary Dedicated to Deploying Residential Geothermal Systems in Québec.” https://energir.com/en/about/media/news/energir-geothermal-solution-new-subsidiary-dedicated-deploying-residential-geothermal-systems-quebec Government of Québec, 2026. “Québec veut renforcer sa sécurité énergétique et réduire la facture pour les consommateurs de gaz naturel.” Press release dated July 16, 2026. https://www.quebec.ca/nouvelles/actualites/details/quebec-veut-renforcer-sa-securite-energetique-et-reduire-la-facture-pour-les-consommateurs-de-gaz-naturel-71977 [in French only] HEC Montréal, 2023. “Measuring Beyond Initiative.” https://www.hec.ca/en/sustainable-and-responsible-management/measuring-beyond-initiative/index.html

On October 28, 2025, the government passed An Act to improve certain labour laws,1 also referred to as Bill 101. The reform has the stated objective of improving efficiency in grievance arbitration, in particular by reducing processing times, implementing a more structured case management system, and ensuring more thorough case preparation. The explanatory notes expressly state the intention to “determin[e] the rules relating to the communication of evidence before the hearing of the grievance.”2 In this context, the Labour Code3 was amended to introduce, among other things, section 100.3.1, which now requires parties to disclose in advance the evidence they intend to present, as well as the list of witnesses:  100.3.1. The party that intends to produce an exhibit or other evidence at the hearing must provide a copy of it to the other parties and the arbitrator within the time agreed upon at the pre-hearing conference or at least 30 days before the beginning of the hearing, except in an urgent situation or unless otherwise decided to ensure the proper administration of justice.  The party must, in the same manner, provide a list of the witnesses it intends to call and a list of those whose testimony it intends to present in the form of affidavits, unless there is valid cause not to disclose their identities.  The party must also file with the arbitrator proof that the copy has been provided to the other parties.  This change has significant practical implications. For decades, the issue of advance disclosure of evidence in grievance arbitration has given rise to conflicting jurisprudence. A majority view held that the arbitrator could not require a full exchange of evidence outside the hearing, while a minority view recognized a broader scope for intervention in the interest of fairness and the proper administration of justice.4 Several authors have criticized the role of surprise in arbitration. They found that a lack of advance disclosure leads to unnecessary debates, causes delays and adjournments, and contributes to making the process more cumbersome. Author and arbitrator Marc Mancini aptly summarizes the issue. He points out that the fact that rules governing the advance disclosure of evidence in grievance arbitration are virtually nonexistent can, in certain cases, encourage games of hide-and-seek between the parties.5  Section 100.3.1 is therefore triggering a cultural shift. Advance disclosure is no longer merely a cooperative practice that takes place only when the parties consent to it. It is a legislative obligation, subject to only two exemptions: an urgent situation or when a decision is otherwise rendered to ensure the proper administration of justice.  Under this new framework, an initial interlocutory judgment—eagerly awaited by legal practitioners—has clarified the scope of the obligation and, above all, how strictly the exemption for the proper administration of justice is enforced. It was rendered by arbitrator Isabelle Leblanc on June 22, 2026, in Syndicat des professeures et professeurs du Cégep Marie-Victorin and Cégep Marie-Victorin.7  Background on the ruling  The dispute arose in the context of workplace disciplinary measures that included a dismissal. The employer requested an exemption from the requirement to disclose certain documents in advance—primarily messages exchanged on social media and via text—which it preferred to disclose either during or after the complainant’s testimony. The union opposed the exemption, citing the very rationale behind the reform.  In her ruling, the arbitrator first notes that advance disclosure is now the rule and that parties can no longer treat it as a matter of procedural discretion. Advance disclosure, she states, is a strict procedural duty that may be waived only in urgent situations or for the proper administration of justice.  She frames the duty within Bill 101, stating that the reform aims to reduce processing times, enable the parties to better prepare their cases, and promote the resolution of disputes based on evidence known to both sides.  A ruling that’s open to interpretation, yet still sends a clear message  This ruling should be interpreted carefully. The arbitrator herself highlights the unique aspects of the case, in particular that the complainant was either the sender or the recipient of the messages the employer sought to use. The complainant was therefore already aware of the messages, even though he claimed to have deleted them and no longer to have them in his physical possession prior to his testimony.  From a practical standpoint, the arbitrator highlights the risks that inefficiency can entail. She notes that failure to provide advance disclosure may hinder the search for the truth, not because the facts are actually disputed, but because the normal limitations of memory may affect responses. She also notes that failure to provide advance disclosure impacts the efficiency of the hearing due to the time required to review the messages in the hearing room, especially given their volume.  From a legal standpoint, the arbitrator rejects the employer’s argument, one based on having a full and complete defence. She deems the concept inapplicable in arbitration and shifts the focus to the concept of the right to be heard. In her view, withholding evidence in the name of the right to be heard would amount to encouraging a practice that undermines the other party’s right to properly prepare and defend itself.  She specifies that the employer would have to demonstrate a real, concrete, and disproportionate infringement of his rights, constituting a heavy burden of proof that was not met in this case. She suggests that exemptions should not be viewed as merely a way out when advance disclosure is uncomfortable or strategically disadvantageous.  It is important to remember that each case is unique. Section 100.3.1 grants the arbitrator discretion based on the principle of the proper administration of justice, and it is possible that other arbitrators may reach different conclusions depending on the facts.  Rethinking disciplinary investigations and how we gather versions of the facts  A practical lesson emerges clearly from this ruling and is of direct interest to human resources and labour relations managers. The arbitrator points out that the employer already has a forum to assess the employee’s credibility: the investigation conducted prior to imposing the disciplinary measure. She highlights that, while evidence is not generally disclosed during investigations, this is often a deliberate choice rather than a necessity. She adds that the employer is not precluded from challenging the employee’s credibility and that it may do so during the investigation.7  Bill 101 and this ruling therefore call for a more rigorous structure for disciplinary investigations, not only to establish the facts but also to verify the consistency and reliability of the explanations before a decision is made. In many cases, this means the better planning of meetings aimed at gathering the versions of the facts. It is essential to ensure that the relevant questions are asked during the investigation, that the answers are accurately recorded, and that the person in question can clearly explain the allegations against them, especially when the employer intends to rely on this evidence. This way, there is less risk that a late review of evidence will slow down proceedings with delays and interruptions.  In light of these lessons, it appears that the following practices deserve consideration when conducting disciplinary investigations:  Clarifying from the outset what the allegations are and what needs to be verified, and then adjusting the investigation as findings emerge;  Preparing an agenda to gather the parties’ versions of the facts and identify the documents to be discussed;  Documenting responses accurately and completely, including nuances, corrections, and explanations;  Submitting written materials during the investigation, when applicable, to obtain comprehensive and contemporaneous explanations;  Addressing any contradictions or grey areas during the investigation, rather than letting them become more pronounced during the hearing; and  Ensuring that the disciplinary decision reflects the facts known at the time it is made and that the investigation file provides a clear explanation of the decision.  We will closely monitor future rulings under section 100.3.1, as the jurisprudence will clarify, over time, the practical scope of the exemption for the proper administration of justice, as well as its limits in disciplinary matters. In this ever-changing environment, we remain available to assist employers from the investigation stage through to arbitration in order to minimize the risk of contestation and strengthen their case.  SQ 2025, c. 28. Idem., Explanatory Notes. CQLR, c. C-27. Marc Mancini, Frédéric Poirier and Stéphanie Lalande, La preuve et la procédure en arbitrage de griefs, 3rd ed., Wilson & Lafleur, Montréal, 2026, pp. 117–127. Marc Mancini, “Et si la Règle de Browne c. Dunn s’appliquait en arbitrage de griefs au Québec : analyse réflexive sur les enjeux de divulgation de la preuve”, in Sébastien Beauregard et al., 50e anniversaire de la conférence des arbitres du Québec - Un demi-siècle de réflexion et d’évolution, Wilson & Lafleur, Montréal, 2024, pp. 74–83, 93. Syndicat des professeures et professeurs du Cégep Marie-Victorin and Cégep Marie-Victorin, 2026 QCTA 284 (Ms. Isabelle Leblanc). Idem., para. 58.

On May 6, 2026, the Minister of Finance and National Revenue tabled Bill C-31, entitled A second Act to implement certain provisions of the budget tabled in Parliament on November 4, 2025.1 Bill C-31 proposes significant amendments to the Canada Labour Code2 (the “Code”) to prohibit non-compete clauses, by an approach comparable to that adopted in Ontario. However, the federal legislator is going further than its Ontario counterpart by granting itself the authority to potentially prohibit other types of restrictive covenants—such as non-solicitation clauses—through regulations.  Among the key measures enacted by the federal legislator is a prohibition against imposing non-compete clauses on federally regulated employees, subject to two categories of exceptions. The stated objective is to promote employee mobility, reduce certain forms of abuse associated with post-employment restrictions and stimulate competition in the labour market.3 This legislative approach aligns with current trends across the globe restricting non-compete clauses in the world of employment law.   Definitions  A “non-compete clause” means a term or condition of employment, or a clause in an agreement, that prohibits an employee from engaging in any business, work, occupation or trade, profession, project or other activity that is in competition with the employer’s federal work, undertaking or business after the employee ceases to be employed’4 This definition is broad and potentially encompasses non-compete clauses included in documents that are not employment contracts, such as a long-term incentive plan. The Bill also defines an “other employment-related restriction” as “a term or condition of employment, or a clause in an agreement, that is not a non-compete clause and is part of a class specified in the regulations.”5   Scope and proposed changes  Division XI.1, slated to be incorporated into Part III of the Code through the Bill, prohibits an employer from entering into a non-compete clause with an employee or a union.6 It also prohibits imposing such a clause on an employee, in particular by inducing them to agree to one. The Bill also provides for the nullity of clauses subject to this prohibition.7  For now, the prohibitions imposed by the Bill only apply to non-compete clauses. The federal government may, however, through regulation, define “other employment-related restrictions” to make the prohibitions apply to them, further limiting the ability of employers to safeguard their legitimate interests, such as their goodwill.  Exceptions  The law provides for two main categories of exceptions.   First, the prohibition would not apply to a person who, after leasing or transferring all or part of their work, undertaking or business to an employer, including by sale or merger, becomes an employee of that employer and agrees to a non-compete clause or employment-related restriction in that context, when the business is or becomes a federal enterprise as a result of the transaction.8   Second, it would not target the chief executive officer9 nor certain senior management employees reporting directly to the chief executive officer and holding the position or performing the functions of president, chief operating officer, chief financial officer, chief human resources officer, chief information officer, chief technology officer or chief legal officer. The exception for senior management employees is subject to two conditions: 1) The person reporting directly to the chief executive officer must be the only one to hold or perform the functions of the aforementioned positions, and 2) they must be a “manager” within the meaning of section 167(3) of the Code.10 The legislator also reserves the right to add excluded positions by regulation.  Other provisions included in the Bill  The Bill introduces a prohibition on retaliation, preventing an employer from reprimanding or penalizing an employee for refusing to agree to a non-compete clause.11  It also provides for a reversal of the burden of proof. The employer will have the burden of demonstrating that a condition of employment or stipulation does not constitute a non-compete clause or, if it does, that it is not null.12  The path to enactment13  Bill C-31 was tabled on May 6, 2026. On June 3, 2026, the second reading was passed in the House of Commons and the Bill was referred to the Standing Committee on Finance. It still needs to pass the third reading and the process in the Senate before royal assent.  Coming into force is scheduled for a day to be fixed by order of the Governor in Council.   Once the law comes into force, federally regulated employers will no longer be permitted to require employees to enter into non-compete clauses, subject to the exceptions provided in the Bill. Non-compete clauses existing at the time the law comes into force will remain valid for one year and will only become null after the grace period expires. Employers would be well advised to immediately begin developing alternative strategies to mitigate the upcoming prohibition of non-compete clauses for employees who are currently bound by such clauses.   Practical recommendations   Here are some practical recommendations to help federally regulated organizations both comply with this new legal framework and protect their legitimate interests:  Review existing restrictive covenants within in your organization  A comprehensive review of employment contracts and other relevant contractual documents is crucial to identify non-compete and other restrictive covenants currently in force within your organization.  The review should not be limited to employment contracts alone—it should also extend to any other program, policy or document containing restrictive covenants, including short-term or long-term incentive plans, such as stock option plans. Any atypical non-compete clause, such as one providing for the cancellation of stock options or units if the participant joins a competing business, should also be listed, as it may fall within the scope of the law. Because we do not yet know how the new restrictions will be interpreted, a broader review is more prudent at this stage.  Assess your organizational structure   Given the well-defined exceptions provided for by the law, organizations would do well to review their organizational structure to identify the individuals who may be bound by a non-compete clause and ensure that the corresponding legislative requirements are met.    Exercise increased caution in commercial transactions     Greater caution is required in the context of commercial transactions to ensure that contractual documents are compatible with the exception established by the law.   Identify alternative contractual strategies  What many employers have done in Ontario is use non-solicitation clauses and confidentiality agreements. This could be a good option to proportionately protect the legitimate interests of a federally regulated organization while preserving employee mobility. However, the federal government may limit this contractual strategy by prohibiting other types of restrictive covenants through regulation.  In certain circumstances, garden leave clauses, which we do not believe to be restrictive covenants under Quebec civil law,14 are certainly options to consider for some employees of federally regulated organizations.   Monitor ongoing legislative updates  We recommend implementing an internal or external monitoring strategy, through your legal counsel, to track the progress of the Bill and any regulations that the federal government may adopt under it.   Our Labour and Employment Law group will closely follow all developments related to Bill C-31. We remain at your disposal to answer any questions you may have regarding these changes and provide innovative strategic advice to protect your legitimate interests under this new legal framework.   A second Act to implement certain provisions of the budget tabled in Parliament on November 4, 2025., Bill C-31 (first reading – May 6, 2026), 1st Session, 45th Legislature. Can., section 9. R.S.C. 1985, c. L.-2. Department of Finance Canada, Minister Champagne introduces second piece of legislation to implement Budget 2025: Canada Strong, online: Minister Champagne introduces second piece of legislation to implement Budget 2025: Canada Strong - Canada.ca. A second Act to implement certain provisions of the budget tabled in Parliament on November 4, 2025, Supra, note 1, s. 237.1. Id. Id., s. 237.2(1). Id., s. 237.2(2). Id., s. 237.2(3)(a). Id., s. 237.2(3)(b). Id., s. 237.2(3)(c). Id., s. 237.3. Id., s. 237.4. Parliament of Canada, A second Act to implement certain provisions of the budget tabled in Parliament on November 4, 2025, online: C-31 (45-1) - LEGISinfo - Parliament of Canada. Maude Grenier and Frédéric Desmarais, “Quand la clause de jardinage tombe dans le terrier du lapin civiliste : Alice est-elle au pays des merveilles ? Histoire d’une clause possiblement restrictive,” in Service de la qualité de la profession du Barreau du Québec, Développements récents en droit du travail (2020), Cowansville, Yvon Blais, 2020, p. 185.