Labour and Employment

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.

Artificial intelligence (AI) is no longer merely a futuristic concept but a present-day reality—a practical business tool that is routinely used in management and production. Organizations are increasingly adopting generative AI and analytics solutions for tasks such as writing, sorting, decision-making, monitoring and evaluating. However, this is often done without any prior structured planning.  Employers now face the dual challenge of achieving productivity gains quickly while ensuring that AI does not pose legal, reputational or operational risks. The range of applications is expanding to include writing assistance, decision-making support, performance analysis, digital monitoring and incident and accident prediction. This raises questions of interest to both executives and the media. For example, who should be held responsible when the tool makes a mistake? What data is being used? How far can employers go in monitoring their employees?  If properly regulated, AI can support innovation and expedite its implementation, while also contributing to workplace well-being, health and safety. In Quebec, these benefits are particularly significant in the context of an aging population, labour shortages and increased pressure to boost productivity. Addressing this situation requires solutions that foster growth and competitiveness.  The use of AI systems in the workplace raises real and multifaceted challenges. These include protecting personal information and maintaining confidentiality, establishing liability and accountability where errors or failures occur, and considering the potential impact on workloads and the work environment.  Aware of the effect that digital transformation and AI are having on the workplace, the Minister of Labour launched a consultative process to assess whether existing legislation adequately addressed these developments. In October 2025, he tasked the Comité consultatif du travail et de la main-d’œuvre (the “CCTM”) with further exploring ideas and developing a shared vision regarding:  Consultation processes that factor in the implications of AI use in the workplace;  Ethical, governance and transparency principles in human resources decision-making;  The prevention of emerging occupational health and safety risks.1  CCTM report: Recommendations  The Avis du CCTM concernant les enjeux entourant l’implantation et l’usage des systèmes d’intelligence artificielle en milieux de travail au Québec [CCTM report on the implications of implementing and using artificial intelligence systems in Quebec workplaces] (“CCTM Report”) was released on April 29, 2026. The recommendations set out in the report regarding the implementation and use of AI systems in Quebec workplaces include, in particular:  Applying the current legal framework governing labour and employment law in Quebec; Preserving the essential role of human judgment—and the responsibility that comes with it—in automated decision-making processes;   Applying laws respecting the protection of personal information2 when developing, implementing and using AI systems, and prioritizing solutions that limit the use of electronic surveillance;  Implementing an algorithmic impact assessment process that would involve employees and take into account the impact of automated decision-making on fundamental rights and privacy;  Ensuring that organizations continue to support employee mobility and ongoing professional development;  Regulating algorithms through sound governance practices that promote transparency and explainability in algorithmic decision-making;  Placing emphasis on the need to pay special attention to discriminatory biases.   In its report, the CCTM also makes recommendations to the Commission d’accès à l’information, such as updating its guide on drafting privacy policies to include disclosure requirements regarding AI and surveillance technologies, and encouraging employers to inform employees of their intention to use partially or fully automated decision-making processes.  Lastly, the CCTM recommends that the Ministère du Travail develop, in collaboration with the CCTM, a guide to support the implementation of responsible, compliant and socially acceptable AI.  Guide released by the Ministère du Travail: 5 principles  Further to the recommendations made in the CCTM report, the Minister of Labour released, on June 12, 2026, a document titled L’intelligence artificielle au travail : Guide d’accompagnement pour une intégration responsable [A guide to using artificial intelligence responsibly in the workplace] (the “Guide”).  The Guide aims to ensure that AI is integrated into workplaces in a responsible, user-centric and collaborative manner. It sets out five (5) key principles designed to inform discussions and help organizations recognize the main issues, namely:  Respect for rights and freedoms in the workplace;  Protection of privacy and data governance;  Governance, participation and social dialogue;  Human oversight and transparency;  Sustainable development and well-being.  For each principle, the Guide provides examples of how AI is used in the workplace. It also highlights the associated benefits and challenges, and suggests practical steps to ensure that AI is adopted and used responsibly.  The Guide serves as a practical, evolving tool that organizations and labour market stakeholders are encouraged to tailor to their specific circumstances.   Accessible and regulated AI  While the adoption of AI in the workplace offers tangible opportunities for improvement, it also raises important issues that require careful oversight. With that in mind, the Guide aims to support the use of AI in a way that protects rights and users, while taking workplace considerations into account. It also aims to provide the various stakeholders involved with the tools they need to facilitate the adoption of AI at work.  A number of interesting challenges are likely to arise over the next few years, and Lavery’s highly qualified professionals are ready to help you deal with them. Contact the team today.  Comité consultatif du travail et de la main-d’œuvre, Avis du CCTM concernant les enjeux entourant l’implantation et l’usage des systèmes d’intelligence artificielle en milieux de travail au Québec, online: lien, April 9, 2026, p. 6. (In French only) Act respecting the protection of personal information in the private sector, CQLR c. P-39.1; Act respecting Access to documents held by public bodies and the Protection of personal information, CQLR c. A-2.1.

Following a series of urgent proceedings in late December and early January, the Quebec Superior Court issued an interesting decision1 on January 8, 2026, providing important clarifications on the scope of policies relating to intellectual property, confidential information and conflicts of interest, as well as on the duties of loyalty and confidentiality set out in employees’ employment contracts. The facts Concordia University (“Concordia”) sought a provisional injunction from the Court against a former employee and student, Mr. Oleg Khalimonov, as well as against Polaris Aerospace Inc. (“Polaris”), a company of which he was a director and shareholder. Mr. Khalimonov was employed by Concordia from September 2023 to December 2025. He had also been a student at the University since 2016 and, since 2023, he had served as Program Leader for Space Concordia, one of the University’s student associations. The group received significant public visibility with the launch of Starsailor in August 2025, described as the first rocket launch from Canadian soil in twenty-five years. These research and development activities are said to have generated significant intellectual property and attracted interest from commercial partners looking to invest in Concordia’s projects. In December 2025, Concordia was informed that Polaris was claiming in the market it had acquired Space Concordia’s intellectual property and as the entity behind the Starsailor project. On December 16, 2025, Concordia formally notified Mr. Khalimonov that his dual role with Polaris and Space Concordia raised serious concerns about potential breaches of his employment contract, the University’s Intellectual Property Policy, and its Conflict of Interest Policy. This process led to Mr. Khalimonov’s resignation as Program Leader for Space Concordia on December 18, 2025. On December 29, 2025, Polaris submitted a bid under the Launch the North initiative, a program of the Government of Canada’s Department of National Defense providing for a total of 105 million dollars in investments and grants over three years. Concordia asked the Court to order Polaris and Mr. Khalimonov to: Cease any use of proprietary or confidential information belonging to the University. Withdraw Polaris’s bid; and Remit any documentation in their possession relating to Space Concordia and/or the Starsailor project. Analysis of the criteria applicable to the provisional injunction The Court concluded that issuing the requested provisional injunction was appropriate and that Concordia had met its burden of proof. The evidence clearly showed that Mr. Khalimonov had played a central role in the University’s rocketry initiatives and that he had never formally disclosed to Concordia his simultaneous involvement with Polaris. He had undertaken to comply with strict obligations to Concordia regarding intellectual property and proprietary information, including keeping such information strictly confidential during and after his employment and acknowledging that any intellectual property developed in the course of his employment would remain Concordia’s exclusive property, with no vested rights accruing to him. Mr. Khalimonov also had to comply with university policies, including the Conflict of Interest Policy and the Intellectual Property Policy. The latter provided that the “Inventors” of “Qualifying Inventions” were deemed to have automatically assigned to Concordia the related intellectual property. The Court found that Starsailor constituted a “Qualifying Invention”, and that Mr. Khalimonov met the definition of an “Inventor” within the meaning of that policy. It also found that Polaris’s proposal used intellectual property and confidential information belonging to Concordia. In that context, the Court considers, on a prima facie basis, that Mr. Khalimonov had breached his obligations arising from his employment contract, the Intellectual Property Policy, and the Conflict of Interest Policy. The Court also concluded that refusing to grant the provisional injunction would result in the submission of competing proposals under the Launch the North initiative, creating significant uncertainty as to the ownership of the intellectual property upon which those proposals were based, and thereby causing irreparable harm to Concordia. It found that the balance of inconvenience favored Concordia and supported granting the requested provisional injunction, since the absence of a provisional injunction would likely lead to the disqualification of both Polaris’s and Concordia’s proposals due to unresolved competing claims regarding the intellectual property. Conclusions The Court granted Concordia University’s application for a provisional injunction and ordered, among other things, that Mr. Khalimonov and Polaris cease disseminating false statements suggesting that Polaris held any rights whatsoever in Concordia’s intellectual property, including in relation to Space Concordia’s rocketry projects. It also ordered Mr. Khalimonov and Polaris to cease using Concordia’s intellectual property (including for Space Concordia’s rocketry projects), as well as any confidential or proprietary information belonging to Concordia. Finally, it ordered the immediate withdrawal of Polaris’s submission filed under the Launch the North project. General Principles — Ownership of Inventions In Canada, except for inventions developed by federal public servants, ownership of inventions is derived from inventorship. Thus, the starting point for ownership of an invention lies with the inventor(s), who may subsequently transfer their rights. For Canadian federal public servants, inventions produced by a federal employee in the course of their employment are “vested in Her Majesty in right of Canada” and therefore belong to the federal government, pursuant to the provisions of the Public Servants Inventions Act. However, the Patent Act contains no comparable express provisions regarding ownership of an invention developed by an employee in the course of employment. The case law has established the general principle mentioned above: in the absence of a valid agreement relating to such rights in the context of employment ownership of an invention  vests in the employee who created it, unless the employee was “hired to invent.” The leading case in this respect is the Federal Court’s decision in Comstock2. In that case, the Court noted that the nature and context of the employer–employee relationship could be analyzed using various factors in order to determine whether an employee had indeed been “hired to invent.” Such a determination can be complex and remains uncertain, since each case depends on its particular facts. It is therefore always prudent to put in place an agreement governing ownership of inventions developed in the course of employment. Key Takeaway   Concordia University’s success in its application for a provisional injunction underscores the importance for employers of including robust intellectual property and confidentiality clauses in employment contracts. This decision is a reminder that it is not enough to rely on general principles: employers are well advised to draft comprehensive, clear, and operational provisions governing (i) the ownership and assignment of intellectual property rights, (ii) the definition and handling of confidential information, and (iii) the rules applicable during employment and after its termination. It is just as crucial that these policies and undertakings (intellectual property, confidentiality, conflicts of interest) be brought to the employee’s attention at the time of hiring, properly incorporated into or referenced in the employment contract, and easily accessible at all times. These contractual mechanisms complement the duties of loyalty and confidentiality set out in article 2088 of the Civil Code of Québec, which continue to apply after the end of the employment contract—but whose scope often remains insufficient in specialized sectors where intellectual property issues are decisive. In short, this case shows that, without well-structured contractual clauses, Concordia would have had much greater difficulty asserting its rights and obtaining the withdrawal of Polaris’s competing submission under Launch the North. Concordia University v. Polaris Aerospace Inc., 2026 QCCS 30. Comstock Canada et al. v. Electec Ltd. and Hyde, (1991) 45 F.T.R. 241 (TD).

With Christmas festivities just around the corner, employers must strike a balance between festive atmosphere, team spirit and legal obligations, particulary in terms of risk prevention. Although employers have always had responsibilities in relation to Christmas parties,1 the obligations regarding psychosocial risk prevention, introduced in October 2025, imposes new requirements.2 These obligations require that employers pay special attention to the psychological health of employees and specific measures to prevent psychosocial risks during company events, such as Christmas parties. But responsibilities do not fall on employers alone, employees also have a role to play during Christmas parties. To ensure that festive gatherings between colleagues are a success, everyone must do their part. 1. Employer’s obligations 1.1 Work accidents Although a Christmas party may take place outside what is considered regular working hours, an accident occurring during such an event may still be deemed to have occurred “in the course of work”, within the meaning of the Act respecting workplace accidents and occupational diseases.3 Because this concept is not defined in the law, case law establishes certain criteria to determine whether an activity in which a worker engaged at the time of the accident is closely related to their work. These criteria include: Where the incident occurred; the time of the incident; the remuneration for the activity in which the worker was engaged at the time of the incident the existence and degree of authority or subordination of the employer if the incident does not occur on the premises or during working hours; the purpose of the activity performed at the time of the incident, whether incidental, ancillary or optional to the employee’s working conditions; the nature of the connection or relative usefulness of the employee’s activity relative to the performance of their duties.4 None of these criteria is decisive on its own. They must be considered as a whole, taking the specific facts of each case into account. As an example of how broad the scope of this principle is, the Administrative Labour Tribunal (“ALT”) recently found that a worker who had injured herself while dancing during an activity organized by the employer’s social committee had suffered an accident “in the course of work”.5 The fact that the employer had allocated a budget for the event and granted time off to encourage employee participation made it possible to establish a link of usefulness and relevance to work.6 Conversely, in another decision, a worker who was running a stand serving hot drinks at an event held for city residents participated in a game called “The Christmas Tree Toss” with volunteers and employees after closing her stand.7 While performing her throw, she suffered an injury to ther right knee. After reviewing the aforementioned criteria, the ALT found that the accident had occurred as part of the worker's private life and not “in the course of work.” The gathering and participation in the event were not part of professional duties, and the event was intended for city residents. All attendees had left the premises, with only employees and volunteers left.8 1.2 Harassment and the importance of following procedures The Act respecting labour standards requires employers to take reasonable measures to prevent psychological and sexual harassment.9 In particular, all employers must develop a harassment prevention and management policy and make it available to their employees. Since September 2024, such policies must include recommendations on appropriate behaviour during work-related social activities, such as Christmas parties.10 More broadly, according to the Act respecting occupational health and safety, in Quebec, employers must take measures to prevent situations of physical or psychological violence, including spousal, family or sexual violence.11 Employers must strictly adhere to their internal procedures if this type of incident occurs. A grievance arbitrator made this point in a case where a plaintiff was dismissed from his employment after having refused to cooperate in an investigation regarding allegations of participation in events of a sexual nature and drug use after a Christmas party having been held by the plaintiff’s employer.12 Although the alleged acts took place in a hotel outside working hours and in a private setting, they had a negative impact on the work environment. The employer had been informed of persistent rumours that were detrimental to the proper functioning of the business. In this case, to warrant the holding of an internal investigation, the employer had been able to establish a sufficient link between the activities, which first appeared to have taken place in the employee’s private life, and its business. However, the fact that the employer had failed to obtain the plaintiff's version of events before taking disciplinary action, as required by its own procedure, affected the outcome. As a result, the contestation of the dismissal was allowed.13 To avoid this type of situation, employers must make it a point to follow their own internal complaint handling procedure. 1.3 Disciplinary offences Since office Christmas parties are connected to the workplace, employees are generally required to fulfill their obligations. Misconduct on their part could warrant disciplinary measures. For example, if an employee engages in harassment or insubordination, in particular while under the influence of alcohol, which can be a catalyst for problematic behaviour, their employer will be entitled to impose disciplinary measures. However, an employer cannot impose two penalties on an employee who committed a disciplinary offence. A grievance arbitrator has ruled that suspending an employee for three days for a sexually suggestive gesture made jokingly at a Christmas party, in addition to prohibiting the employee from attending subsequent Christmas parties for three years, constituted double punishment. The financial penalty linked to the suspension was deemed sufficient as a disciplinary measure for the alleged offence.14 2. Best practices for employers In order to minimize the risks associated with the Christmas holidays, employers could implement the following practices. To prepare for parties : Ensure that your harassment and alcohol and drug use policies are up to date, in accordance with applicable law. Prepare an incident-related risk analysis mechanism (and include psychosocial risks). Send employees a reminder before the event, pointing out that employer policies continue to apply and reminding them of expected behaviours and ways to get help or report problematic situations. Implement preventative measures regarding alcohol consumption. For example, employers should limit alcoholic consumption by providing coupons, offer a choice of non-alcoholic drinks, along with food, or close the bar at a specific time. Offer employees options at the event where alcohol will be consumed, such as taxi vouchers, ride-sharing services or accommodation. During the party : Employees comply with internal policies and respond immediately. Managers are present and able to respond quickly to inappropriate behaviour and document any incidents that occur. Preventive measures, such as closing the bar or distributing taxi vouchers, among others, are applied. After the party : Follow up with the organizing team to determine what went well and what did not, including any incidents that occurred, to apply corrective actions. Objectively assess all reports and initiate an impartial and confidential investigation if necessary, meeting with the parties involved to obtain each person’s version of the facts, in compliance with policies or rules arising form laws, collective agreements or contracts. Keep records of incidents that have occurred, as needed. Update policies and procedures in light of lessons learned. 3.Conclusion With Christmas parties just around the corner, it is worth remembering that for a party to be deemed successful by employers and employees alike, it is not only the festive atmosphere that counts, but also the effectiveness of the implemented preventive measures. Before holding your event, put the necessary risk prevention measures in place so that everyone can fully and safely take part in it. We invite you to read the following articles on these subjects: Lavery, “The Success of Employer-Organized Christmas Parties: It Is Everyone’s Business?” November 29, 2023, URL: The Success of Employer-Organized Christmas Parties: It Is Everyone’s Business?. Lavery, “The return of Christmas parties: What employers need to know,” December 9, 2022, URL: The return of Christmas parties: what employers need to know. We invite you to read the following article on this subject : "Occupational health and safety: Understanding employers’ new obligations", December 10, 2025, URL: Occupational health and safety: Understanding employers’ new obligations Act respecting industrial accidents and occupational diseases, CQLR, c. A-3.001, s. 2. Cannara Biothech (Valleyfield) inc. et Boulanger, 2025 QCTAT 1771, para. 9. Ibid, para. 1. Ibid, paras. 23–29. Murphy et Ville de Léry, 2022 QCTAT 5309, para. 1 Ibid, paras. 40–46. Act respecting labour standards , CQLR c. N-1.1, s. 81.19. Ibid., s. 81.19, para. 1, subpara. 3. Act respecting occupational health and safety, CQLR, c. S-2.1, section 51 (16). Syndicat des salariés(es) de l'agroalimentaire de Ste-Claire (CSD) et Kerry Canada inc. (Richard Guay) , 2022 QCTA 224, para. 1.  Ibid, paras. 109–111. Teamsters Québec, section locale 1999 et Univar Canada ltée (Jean-Martin Gobeil), 2020 QCTA 344 paras. 77–80.